Brown v. Board of Education, 347 U.S. 483 (1954), was a landmark Supreme Court case that overturned the “separate but equal” doctrine of Plessy v. Ferguson, 169 U.S. 537 (1896), ruling that blacks and whites be allowed to attend the same public schools. The decision was a major blow to the system of southern de jure segregation, which required by law that blacks and whites be separated in all areas of public facilities, such as waiting rooms, restaurants, hotels, buses and trains, drinking fountains, and even cemeteries.

Racial segregation in public schools was especially problematic because it was clear that schools for white children and schools for black children were not equal and could not be made equal if they were to retain racial separation. The average amount spent by southern cities for each black pupil was usually less than half that spent on each white pupil. In many parts of the South, black children were forced to travel long distances to attend schools lacking basic facilities and qualified teachers. Some rural schools provided instruction for only 3 months out of the year; others provided no high school for black children. Even in urban areas of the South, schools were overcrowded and lacked the amenities of whites-only schools.

The case of Brown v. Board of Education rested on a class action suit filed in 1951 against the Board of Education of the City of Topeka, Kansas, by the local NAACP (National Association for the Advancement of Colored People) on behalf of 13 plaintiffs. Among those plaintiffs, Oliver Brown—for whom the case is named—served on behalf of his daughter, Linda Brown. Miss Brown lived in a racially mixed neighborhood but had to travel more than an hour to attend school because her neighborhood school was segregated white. Because Kansas was a border state, and Topeka was not racially segregated in all areas of public facilities (e.g., waiting rooms), the NAACP strategically chose the city as its next battleground in the effort to desegregate public life. It was just one of five cases decided within the Brown decision, which included cases from South Carolina (Briggs v. Elliott), Delaware (Gebhart v. Belton), Virginia (Davis v. County School Board of Prince Edward County), and Washington, D.C. (Bolling v. Sharpe). Out of the five cases, Brown v. Board of Education was the only case predicated on black parents’ constitutional right to send their children to local neighborhood schools. This was a major shift in the argument for dismantling a system of racial inequality and segregation: that racial segregation is inherently unequal regardless of the quality of public facilities.

One of the compelling arguments used in the Brown decision against segregated schools was that segregation causes psychological harm to individuals forced into segregation by the dominant group. This argument was based on the social scientific work of psychologists Kenneth B. Clark and Mamie Phipps Clark. Clark and Clark conducted experiments in which they showed black children in segregated schools and non-segregated schools pictures of brown and white dolls. A majority of black children tested in a southern segregated school said that they preferred white dolls over brown dolls, leading the researchers to conclude that segregation caused self-loathing and acceptance of racist stereotypes in these black children.

Clark and Clark also argued that the lack of cross-status contact inherent in segregation causes hostility and suspicion between races. The historical assumption behind racial segregation was that segregated groups are intellectually and socially inferior and thus should be separated from the dominant group. The Clarks and other social scientists questioned this assumption by making the point that segregation produces inequality by creating different and unequal environments resulting in observable differences between races. This was effectively argued in an appendix (signed by 32 prominent psychologists) to the appellants’ briefs in the Brown, Briggs, and Davis cases. A number of other social scientific works were cited in these briefs, including Gunnar Myrdal’s famous work on U.S. racial inequality, An American Dilemma, of 1944.

Brown v. Board of Education was decided in a unanimous 9-0 vote on May 17, 1954, in favor of the plaintiff. Chief Justice Earl Warren delivered the opinion of the court. He argued that public education was an increasingly important right of U.S. citizens and that individuals who are denied equal access to education are denied full citizenship in violation of the 14th Amendment of the U.S. Constitution, which guarantees equal protection under the law. Although the separate facilities for black and white children in Kansas were not measurably different, Warren argued that forced legal segregation makes black children feel inferior, retarding their “educational and mental development,” and concluded that separate but equal facilities in education are inherently unequal.

The Brown ruling was a victory for civil rights, but it was not until 1955 that the Supreme Court ordered states to comply with the ruling “with all deliberate speed” (in an ambiguous, open-ended ruling often referred to as Brown II). Not until the 1970s did many southern schools become desegregated, by which time many white students had fled to private schools. Subsequent critiques of the Brown ruling question the effectiveness of public school desegregation, which some argue did nothing to solve the problem of racial inequality, institutional racism, and segregation in other, nonpublic areas of life.

In 2006, the Supreme Court reassessed Brown’s legal interpretation in two cases, dealing with Seattle, Washington, and Louisville, Kentucky. Both cities had color-conscious policies that specifically sought to create a more balanced and racially integrated school system. Although students in each city had school choice, they could be denied admission based on race if their attendance would disrupt the racial balance in the school. On June 27, 2007, the Supreme Court ruled by a 5-4 vote along ideological grounds that school admission programs in Seattle and Louisville violated the Constitution’s guarantee of equal protection to individuals. Because this decision stipulates race cannot be used to decide where students go to school, educators believe it may lead many districts to drop efforts at racially balancing schools.

Bibliography:

  1. Barnes, Robert. 2007. “Divided Court Limits Use of Race by School Districts.” Washington Post, June 29, p. A01.
  2. Clark, Kenneth B., Isidor Chein, and Stuart W. Cook. 2004. “The Effects of Segregation and the Consequences of Desegregation: A (September 1952) Social Science Statement in the Brown v. Board of Education of Topeka Supreme Court Case.” American Psychologist 59(6):495-501.
  3. Myrdal, Gunnar. 1944. An American Dilemma: The Negro Problem and Modern Democracy. New York: Harper & Brothers.
  4. Patterson, James T. 2001. Brown v. Board of Education: A Civil Rights Milestone and Its Troubled Legacy. New York: Oxford University Press.