Missouri ex rel. Gaines v. Canada

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Missouri ex rel. Gaines v. Canada

Argued November 9, 1938
Decided December 12, 1938


Full case name:	State of Missouri ex rel. Gaines v. Canada, Registrar of the University of Missouri, et al.

Citations:	305 U.S. 337; 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

Holding

States that provide only one educational institution must allow blacks and whites to attend if there is no separate school for blacks.

Court membership

Chief Justice: Charles Evans Hughes
Associate Justices: James Clark McReynolds, Louis Brandeis, Pierce Butler, Harlan Fiske Stone, Owen Josephus Roberts, Benjamin N. Cardozo, Hugo Black, Stanley Forman Reed

Case opinions

Majority by: Hughes
Joined by: Brandeis, Stone, Roberts, Black, Reed
Dissent by: McReynolds
Joined by: Butler

Laws applied

U.S. Const. amend. XIV

Missouri ex rel. Gaines v. Canada, 305 U.S. 337 (1938)^[1], was a United States Supreme Court decision holding that states that provide a school to white students must provide in-state education to blacks as well. States can satisfy this requirement by allowing blacks and whites to attend the same school or creating a second school for blacks.

1 Facts
2 Issue
3 Result
4 Analysis
5 See also
6 External links

[edit] Facts

Petitioner Lloyd Gaines was refused admission at University of Missouri School of Law because he is black; he was otherwise qualified. State statute suggests the eventual construction of a separate law school for blacks and provides scholarships to send them to neighboring states, but bars their admission at Mizzou. Gaines' lawyer, famed civil rights attorney Charles Hamilton Houston, argued that the discrimination was in violation of the Fourteenth Amendment’s Equal Protection Clause and requested a writ of mandamus to compel admission.

[edit] Issue

Does providing for the legal education of Missouri blacks in other states satisfy equal protection?

[edit] Result

No. Writing for the majority, Chief Justice 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. McReynold’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—Mizzou could still deny Gaines admission.

[edit] 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.