End date 1938 | ||
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Full case name State of Missouri ex rel. Gaines v. Canada, Registrar of the University of Missouri, et al. Citations 305 U.S. 337 (more)
59 S. Ct. 232; 83 L. Ed. 208; 1938 U.S. LEXIS 440 Prior history The Circuit Court denied the writ. The Missouri Supreme Court upheld the judgment against Gaines, 113 S. W.2d 783. Subsequent history Remanded to lower courts Majority Hughes, joined by Brandeis, Stone, Roberts, Black, Reed Dissent McReynolds, joined by Butler Ruling court Supreme Court of the United States Similar Sweatt v Painter, McLaurin v Oklahoma State Reg, Sipuel v Board of Regents, Lum v Rice, Murray v Pearson | ||
Missouri ex rel. Gaines v. Canada, 305 U.S. 337 (1938)[1], was a United States Supreme Court decision holding that states that provided a school to white students had to provide in-state education to blacks as well. States could satisfy this requirement by allowing blacks and whites to attend the same school or creating a second school for blacks.
Contents
Facts
The Registrar at the Law School of the University of Missouri, Cy Woodson Canada, refused admission to Lloyd Gaines because he was an African-American. At the time there was no law school specifically for African-Americans within the state. Gaines cited that this refusal violated his Fourteenth Amendment right. The state of Missouri had offered to pay for Gaines’ tuition at an adjacent state’s law school, which he turned down.
Issue
In light of the equal protection clause of the 14th Amendment, does Missouri violate this clause when it affords whites the ability to attend law school in state while not affording the same right to blacks and instead forcing them to attend adjacent states for their law education?
Result
Writing for the majority, Chief Justice Charles Evans Hughes held that when the state provides legal training, it must provide it to every qualified person to satisfy equal protection. It cannot send them to other states, nor can it condition that training for one group of people (such as blacks) on levels of demand from that group. Key to the court’s conclusion was that there was no provision for legal education of blacks in Missouri, which is where Missouri law guaranteeing equal protection applies. To the court, sending Gaines to another state would have been irrelevant. Justice James C. McReynolds's dissent emphasized a body of case law with sweeping statements about state control of education before suggesting the possibility that—despite the majority opinion—Missouri could still deny Gaines admission.
Analysis
This decision does not quite strike down separate but equal education as upheld in Plessy v. Ferguson (1896). Instead, it provides that if there is only a single school, students of all races are eligible for admission, thereby striking down segregation by exclusion where the government provides just one school. Though this case didn’t go as far as Brown v. Board of Education (1954) would, it was a step in that direction.
This decision is very significant because it marks the beginning of the Supreme Court's reconsideration of the “separate but equal” standard made by the Plessy decision in 1896. This case was brought to suit by the NAACP on behalf of Lloyd Gaines, and aimed to test the constitutionality of segregation. In this case the Supreme Court did not overturn Plessy v. Ferguson or violate the "separate but equal" precedents, but began to concede the difficulty, and near impossibility, of a state maintaining segregated black and white institutions which could never be truly equal. Therefore, it can be said that this case helped forge the legal framework for the U.S. Supreme Court's landmark 1954 decision, Brown v. Board of Education, which banned segregation in public schools.
Despite the initial victory claimed by the NAACP, after the Supreme Court had ruled in Gaines' favor and ordered the Missouri Supreme Court to reconsider this case, Gaines was nowhere to be found. When the University of Missouri soon after moved to dismiss the case, the NAACP did not oppose the motion.