This Case Commentary is written by Nidhi Verma, a Second-Year Law Student of Shri Ramswaroop Memorial

CASE DETAILS:-

COURT – SUPREME COURT OF INDIA

EQUIVALENT CITATION - 347 U.S.483 ( 1954)

BENCH – 9 JUDGES BENCH

DECIDED ON - 17 MAY 1954

CASE TYPE. - CIVIL RIGHTS CASE

PARTIES:-

PLAINTIFF – OLIVER BROWN

DEFENDANT – BOARD OF EDUCATION OF TOPEKA

ABSTRACT :

Brown v. Board of Education of Topeka was a landmark 1954 Supreme Court case in which the justices ruled unanimously that racial segregation of children in public schools was unconstitutional. Brown v. Board of Education was one of the cornerstones of the civil rights movement and helped establish the precedent that “separate-but-equal” education and other services were not, in fact, equal at all.

INTRODUCTION :

Brown v. Board of Education, a case in which, on May 17, 1954, the U.S. Supreme Court ruled unanimously that racial segregation in public schools violated the Fourteenth Amendment to the Constitution, which prohibits the states from denying equal protection of the laws to any person within their jurisdictions. The decision declared that separate educational facilities for white and African American students were inherently unequal. It thus rejected as inapplicable to public education the “separate but equal” doctrine, advanced by the Supreme Court in Plessy v.

Ferguson (1896), according that which laws mandating separate public facilities for whites and African Americans do not violate the equal protection clause if the facilities are approximately equal. Although the 1954 decision strictly applied only to public schools, it implied that segregation was not permissible in other public facilities.

BACKGROUND AND FACTS OF CASES -

In the late 1940s, the National Association for the Advancement of Colored People (NAACP) began a concentrated effort to challenge the segregated school systems in various states, including Kansas. There, in Topeka, the NAACP encouraged several African American parents to try to enroll their children in all-white schools. All the parents’ requests were refused, including that of Oliver Brown. He was told that his daughter could not attend the nearby white school and instead would have to enroll in an African American school far from her home. The NAACP subsequently filed a class-action lawsuit. While it claimed that the education (including facilities, teachers, etc.) offered to African Americans was inferior to that offered to whites, the NAACP’s main argument was that segregation by its nature was a violation of the

Fourteenth Amendment’s equal protection clause. A U.S. district court heard Brown v. Board of Education in 1951, and it ruled against the plaintiffs. While sympathetic to some of the plaintiffs’ claims, it determined that the schools were similar, and it cited the precedent set by Plessy and Gong Lum v. Rice (1927), which upheld the segregation of Asian Americans in grade schools.

The NAACP then appealed to the U.S. Supreme Court.

In October 1952 the Court consolidated Brown with three other class-action school-segregation lawsuits filed by the NAACP: Briggs v. Elliott (1951) in South Carolina, Davis v. County.

School Board of Prince Edward County (1952) in Virginia, and Gebhart v. Belton (1952) in Delaware; there was also a fifth case that was filed independently in the District of Columbia,

Bolling v. Sharpe (1951). As with Brown, U.S. district courts had decided against the plaintiffs in Briggs and Davis, ruling based on Plessy that they had not been deprived of equal protection because the schools they attended were comparable to the all-white schools or would become so upon the completion of improvements ordered by the district court. In Gebhart, however, the Delaware Supreme Court affirmed a lower court’s ruling that the original plaintiffs’ right to equal protection had been violated because the African American schools were inferior to the white schools in almost all relevant respects. In Bolling v. Sharpe (1951), a U.S. district court held that school segregation did not violate the due process clause of the Fifth Amendment (the equal protection clause was not relevant since the Fourteenth Amendment only applies to states).

The plaintiffs in Brown, Biggs, and Davis appealed directly to the Supreme Court, while those in Gebhart and Bolling were each granted certiorari (a writ for the reexamination of an action of a lower court).

Brown v. Board of Education was argued on December 9, 1952. The attorney for the plaintiffs was Thurgood Marshall, who later became the first African American to serve on the Supreme Court (1967–91). The case was reargued on December 8, 1953, to address the question of whether the framers of the Fourteenth Amendment would have understood it to be inconsistent with racial segregation in public education. The 1954 decision found that the historical evidence bearing on the issue was inconclusive.

QUESTION

Does the segregation of public education based solely on race violate the Equal Protection Clause of the Fourteenth Amendment?

ISSUE UNDER CASE

1. The issue in Brown v. Board of Education (1954) centered on the legality of racial segregation in public schools. The case challenged the “separate but equal” doctrine established by Plessy v Ferguson (1896) arguing that segregated schools were inherently unequal and violated the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court unanimously ruled that racial segregation in public education was unconstitutional, significantly advancing civil rights and laying the groundwork for future desegregation efforts.

2. The Brown v. Board of Education of Topeka (1954) is a landmark case in which the U.S. Supreme Court addressed the issue of racial segregation in public schools. The Court’s decision overturned the “separate but equal” doctrine established by the earlier case Plessy v. Ferguson (1896), which allowed racial segregation so long as the separate facilities were considered equal.

ARGUMENT OF BOTH THE PARTIES

The plaintiffs argued that:

Segregation Violates Equal Protection Clause: The plaintiffs, including Oliver Brown, claimed that racial segregation in public schools violated the Equal Protection Clause of the 14th Amendment. They contended that separating students based on race inherently made African-

American children feel inferior, even if the physical facilities and other tangible factors were “equal.”

Psychological Harm: The plaintiffs relied on social science studies, such as the “Doll Test” conducted by psychologists Kenneth and Mamie Clark. These studies showed that segregation instilled feelings of inferiority among Black children, thus damaging their self-esteem and hindering their educational growth.

Inherently Unequal Facilities: Even though segregated schools were supposed to be “equal,” the plaintiffs argued that, in practice, Black schools received fewer resources, had lower funding, and had inferior facilities.

Arguments of the Respondents (Board of Education):

The Board of Education of Topeka and other respondents made several arguments in defense of segregation:

Separate but Equal Doctrine: The defense argued that segregation was permissible under the Plessy v. Ferguson ruling if facilities for Black and white students were equal. They maintained that segregated schools in Topeka provided comparable educational environments.

States’ Rights: The respondents also invoked the principle of federalism, arguing that decisions about education and segregation should be left to individual states rather than being governed by federal law.

Custom and Precedent: Segregation had been a long-standing practice, and the respondents argued that changing it would disrupt the educational system. They argued that segregation was accepted by society and had not been proven to cause legal harm.

SUPREME COURT DECISION

The Supreme Court, in a unanimous decision written by Chief Justice Earl Warren, ruled in favor of the plaintiffs. The Court held that:

“Separate but Equal” Is Inherently Unequal: The Court concluded that segregation in public schools violated the Equal Protection Clause of the 14th Amendment. Even if facilities were physically equal, separating students based on race created an inherent sense of inferiority that had lasting negative effects on the education and personal growth of African-American children.

Education Is a Fundamental Right: The Court recognized that education is essential to a child’s development and future success. Denying Black children equal access to education by segregating them was a violation of their constitutional rights.

This decision led to the desegregation of public schools and was a significant victory in the broader civil rights movement.

COMMENTS

The Brown v. Board of Education court case was a milestone in American education and politics. The unanimous 1954 U.S. Supreme Court ruling declared that separating children in public schools by race was unconstitutional.

This week marks the 70th anniversary of the ruling. The decision overruled the 1896 Plessy v. Ferguson case, in which the court held that state-mandated segregation laws did not violate the equal protection clause of the Fourteenth Amendment.

Florida State University faculty members are available to speak to reporters about the legacy of the Brown v. Board of Education case.

THE JUDGEMENT IS CORRECT AND CLEARS LAW.

The 1954 landmark Supreme Court case Brown v. Board of Education had profound positive implications for American society, particularly in advancing civil rights and promoting equality.

Some of the key positive outcomes include:

End of Legal School Segregation: The ruling declared that “separate but equal” schools were unconstitutional, effectively ending the legal basis for racial segregation in public education.

This was a major step toward dismantling institutionalized racism in the U.S.

The catalyst for the Civil Rights Movement: The decision provided momentum to the broader Civil Rights Movement. It inspired activists and fueled campaigns that led to further victories, such as the Civil Rights Act of 1964 and the Voting Rights Act of 1965.

Establishing Equality as a Legal Principle: Brown v. Board of Education established the principle that segregation violated the Equal Protection Clause of the 14th Amendment. This paved the way for future rulings that would challenge discriminatory practices in other areas, like housing and employment.

Promotion of Social Integration: The decision fostered greater racial integration in schools, which helped build bridges between different racial communities. It allowed children of all races to learn and grow together, promoting mutual understanding and reducing racial prejudice over time.

Legacy of Educational Equity: The ruling underscored the importance of providing equal educational opportunities for all children, regardless of race. This laid the foundation for ongoing efforts to improve access to quality education and address disparities that persist in American schools.

Global Impact: The case also sent a powerful message internationally, particularly during the Cold War, that the United States was taking steps to address its internal issues of racial injustice, which had implications for its image as a global leader in democracy and human rights.

Overall, the Brown v. Board of Education decision was a watershed moment in the fight for racial equality, marking a significant shift towards a more just and inclusive society.

CONCLUSION

Separate but equal educational facilities for racial minorities are inherently unequal, violating the Equal Protection Clause of the Fourteenth Amendment.

Chief Justice Earl Warren delivered the opinion of the unanimous Court. The Supreme Court held that “separate but equal” facilities are inherently unequal and violate the protections of the Equal Protection Clause of the Fourteenth Amendment. The Court reasoned that the segregation of public education based on race instilled a sense of inferiority that had a hugely detrimental effect on the education and personal growth of African American children. Warren-based much of his opinion on information from social science studies rather than court precedent. The decision also used language that was relatively accessible to non-lawyers because Warren felt all Americans needed to understand its logic.

REFERENCE

https://www.law.cornell.edu/wex/brown_v_board_of_education_(1954)#:~:text=The%20Su preme%20Court’s%20ruling%20in,for%20the%20Civil%20Rights%20Movement.

https://www.archives.gov/milestone-documents/brown-v-board-of-education https://www.britannica.com/event/Brown-v-Board-of-Education-of-Topeka https://www.oyez.org/cases/1940-1955/347us483 https://en.m.wikipedia.org/wiki/Brown_v._Board_of_Education https://www.uscourts.gov/about-federal-courts/educational-resources/supreme-courtlandmarks/brown-v-board-education-podcast https://news.fsu.edu/news/expert-pitches/2024/05/14/fsu-experts-available-to-comment-foranniversary-of-brown-v-board-of-education/