3.2 Brown v. Board of Education

Brown v. Board of Education was a landmark Supreme Court case that ended racial segregation in public schools. The 1954 ruling overturned the "separate but equal" doctrine, declaring segregated schools unconstitutional under the 14th Amendment's Equal Protection Clause.

The case combined five lawsuits challenging school segregation in different states. Led by the NAACP, plaintiffs argued that segregation violated equal protection, while school boards defended the practice based on Plessy v. Ferguson. The unanimous decision reshaped American education and civil rights.

Background of Brown v. Board of Education

• Brown v. Board of Education was a landmark Supreme Court case that addressed racial segregation in public schools in the United States
• The case challenged the long-standing doctrine of "separate but equal" established by Plessy v. Ferguson, which had allowed for segregation in public facilities
• The case was a culmination of the NAACP's legal strategy to challenge racial segregation and discrimination through the courts

Plessy v. Ferguson and "separate but equal"

• Plessy v. Ferguson (1896) was a Supreme Court case that upheld the constitutionality of racial segregation under the "separate but equal" doctrine
• The case involved Homer Plessy, who challenged a Louisiana law that required separate railway cars for Black and white passengers
• The Court ruled that segregation was legal as long as facilities were "equal," leading to widespread segregation in public accommodations (schools, transportation, restaurants)

Racial segregation in public schools

• Following Plessy, many states, particularly in the South, maintained segregated public school systems
• Black schools were often underfunded, had inferior facilities, and lacked resources compared to white schools
• Segregation in schools was seen as a means to maintain white supremacy and limit educational opportunities for Black children

NAACP's legal strategy to challenge segregation

• The National Association for the Advancement of Colored People (NAACP) developed a legal strategy to challenge segregation through the courts
• The NAACP focused on cases related to education, believing that segregated schools were inherently unequal and violated the Equal Protection Clause of the 14th Amendment
• The organization filed lawsuits in multiple states, including Kansas, South Carolina, Virginia, and Delaware, challenging the constitutionality of segregated schools

Facts of the case

• Brown v. Board of Education was a combination of five separate cases from different states challenging school segregation
• The named plaintiff, Oliver Brown, was a Black parent in Topeka, Kansas, whose daughter had to travel a significant distance to attend a segregated school
• The Topeka Board of Education maintained separate schools for Black and white students, despite the fact that many Black children had to travel farther to attend segregated schools

Oliver Brown and other plaintiffs

• Oliver Brown was one of several plaintiffs in the Kansas case who challenged the constitutionality of segregated schools
• Other plaintiffs included parents and children from South Carolina, Virginia, and Delaware who faced similar circumstances
• The plaintiffs argued that segregated schools were inherently unequal and violated the Equal Protection Clause of the 14th Amendment

Topeka Board of Education's segregated schools

• The Topeka Board of Education, like many school districts in the United States at the time, maintained separate schools for Black and white students
• The Board argued that the segregated schools were "equal" and therefore constitutional under the Plessy v. Ferguson doctrine
• However, evidence presented in the case demonstrated the inequalities between Black and white schools in terms of facilities, resources, and educational opportunities

Consolidated cases from multiple states

• Brown v. Board of Education consolidated five cases from Kansas, South Carolina, Virginia, and Delaware
• Each case challenged the constitutionality of segregated schools in their respective states
• The consolidation of these cases allowed the Supreme Court to address the issue of school segregation on a national level

Legal arguments

• The Brown v. Board of Education case presented competing legal arguments about the constitutionality of segregated schools
• The NAACP, representing the plaintiffs, argued that segregated schools violated the Equal Protection Clause of the 14th Amendment
• The Topeka Board of Education, defending segregation, relied on the precedent set by Plessy v. Ferguson and the "separate but equal" doctrine

NAACP's argument: segregation violates Equal Protection Clause

• The NAACP argued that segregated schools were inherently unequal and violated the Equal Protection Clause of the 14th Amendment
• They presented evidence showing the disparities between Black and white schools in terms of facilities, resources, and educational opportunities
• The NAACP also argued that segregation had negative psychological effects on Black children, citing the work of psychologist Kenneth Clark and his "doll tests"

Board's argument: Plessy allows "separate but equal"

• The Topeka Board of Education, defending segregation, relied on the precedent set by Plessy v. Ferguson (1896)
• They argued that as long as the segregated schools were "equal" in terms of tangible factors like facilities and resources, segregation was constitutional
• The Board maintained that segregation was a matter of state policy and that the federal government should not intervene

Amicus briefs supporting desegregation

• Several organizations filed amicus curiae (friend of the court) briefs in support of the NAACP's position
• The United States Department of Justice, under the Eisenhower administration, filed a brief arguing that segregation violated the Equal Protection Clause
• Other organizations, such as the American Jewish Congress and the American Civil Liberties Union (ACLU), also filed briefs supporting desegregation

Supreme Court's decision

• On May 17, 1954, the Supreme Court issued its unanimous decision in Brown v. Board of Education
• The Court ruled that state-mandated segregation of public schools was unconstitutional and violated the Equal Protection Clause of the 14th Amendment
• The decision overturned the "separate but equal" doctrine established by Plessy v. Ferguson and marked a significant victory for the civil rights movement

Unanimous ruling against segregation

• The Supreme Court's decision in Brown was unanimous, with all nine justices agreeing that segregation in public schools was unconstitutional
• The unanimous nature of the decision was significant, as it sent a strong message about the Court's stance on racial segregation
• Chief Justice Earl Warren worked to achieve a unanimous decision, recognizing the importance of a united front in such a landmark case

Chief Justice Warren's majority opinion

• Chief Justice Earl Warren wrote the majority opinion in Brown v. Board of Education
• In his opinion, Warren stated that "separate educational facilities are inherently unequal" and that segregation violated the Equal Protection Clause
• Warren emphasized the importance of education in a democratic society and the negative effects of segregation on Black children

Overturning Plessy v. Ferguson

• The Brown decision explicitly overturned the "separate but equal" doctrine established by Plessy v. Ferguson
• The Court recognized that segregation, even if facilities were "equal," was inherently unequal and unconstitutional
• By overturning Plessy, the Court paved the way for further challenges to segregation in other areas of society

Holding: segregation violates Equal Protection Clause

• The central holding of Brown v. Board of Education was that state-mandated segregation of public schools violated the Equal Protection Clause of the 14th Amendment
• The Court found that segregation, even if facilities were "equal," was inherently unequal and had negative effects on Black children
• The decision established that separate educational facilities were unconstitutional and that states must desegregate their public schools

Impact and aftermath

• The Brown v. Board of Education decision had far-reaching impacts on American society and the civil rights movement
• While the decision was a significant victory, it also faced resistance and challenges in implementation, particularly in the South
• The case paved the way for further desegregation efforts and civil rights legislation in the following decades

Resistance to desegregation in the South

• Many Southern states and school districts resisted the implementation of the Brown decision
• Some states, such as Virginia, adopted a policy of "massive resistance," which involved closing public schools rather than desegregating them
• Resistance to desegregation often took the form of legal challenges, delays, and even violence

"Massive resistance" and school closures

• "Massive resistance" was a strategy employed by some Southern states to oppose desegregation
• This included closing public schools, redirecting funds to private segregated schools, and enacting laws to maintain segregation
• In some cases, schools remained closed for several years, denying education to both Black and white students

Integration of Little Rock Central High School

• The integration of Little Rock Central High School in Arkansas in 1957 was a significant event in the aftermath of Brown
• Nine Black students, known as the "Little Rock Nine," attempted to enroll in the previously all-white school
• Their enrollment was met with violence and resistance, requiring the intervention of federal troops to ensure their safety

Civil Rights Act of 1964 and further desegregation

• The Civil Rights Act of 1964 was a landmark legislation that further strengthened the desegregation efforts initiated by Brown
• The Act prohibited discrimination based on race, color, religion, sex, or national origin in various areas, including education
• The Act also provided the federal government with the power to enforce desegregation in schools and other public facilities

Legacy of Brown for civil rights and education

• Brown v. Board of Education is considered a landmark case in the civil rights movement
• The decision paved the way for further desegregation efforts and civil rights legislation, such as the Civil Rights Act of 1964 and the Voting Rights Act of 1965
• The case also highlighted the importance of education as a fundamental right and the role of the courts in addressing racial inequality
• Despite progress, the legacy of Brown remains relevant today, as issues of educational equity and racial disparities persist in the United States