Mississippi University for Women v. Hogan
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| Mississippi University for Women v. Hogan | ||||||||||||
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| Argued March 22, 1982 Decided July 1, 1982 |
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| Holding | ||||||||||||
| The exclusion of men from enrollment in Mississippi University for Women's nursing school violated the Fourteenth Amendment to the United States Constitution's Equal Protection Clause. | ||||||||||||
| Court membership | ||||||||||||
| Chief Justice: Warren E. Burger Associate Justices: William J. Brennan, Jr., Byron White, Thurgood Marshall, Harry Blackmun, Lewis F. Powell, Jr., William Rehnquist, John Paul Stevens, Sandra Day O'Connor |
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| Case opinions | ||||||||||||
| Majority by: O'Connor Joined by: Brennan, White, Marshall, Stevens Dissent by: Burger Dissent by: Blackmun Dissent by: Powell Joined by: Rehnquist |
Mississippi University for Women v. Hogan, 458 U.S. 718 (1982), is a five to four ruling of the United States Supreme Court in which the Court ruled that Mississippi University for Women's single sex admissions policy violated the Fourteenth amendment's equal protection clause[1].
[edit] Background
Mississippi University for Women, established in 1884 in Columbus, MS, previously named Industrial Institute and College and Mississippi State College for women, was the first state-supported Women's colleges in the United States.[2] In 1971 the School of Nursing was established, initially offering a 2-year [associate degree] and later the school instituted a 4-year baccalaureate degree program in nursing and also a graduate degree program.[3]
In 1979 Joe Hogan, registered nurse and nursing supervisor in Columbus MS, applied for admission to the MUW School of Nursing's baccalaureate program. Although he was otherwise qualified, he was denied admission to the School of Nursing. School officials provided the option to audit the courses in which he was interested, but could not enroll for credit because of his sex. Hogan could have attended classes and received credit in one of Mississippi's public coeducational nursing programs; two other Mississippi universities offered coeducational programs leading to a Bachelor of Science in Nursing, The University of Southern Mississippi in Hattiesburg, MS, 178 miles from Columbus and the University of Mississippi in Jackson, MS, 147 miles from Columbus.
Hogan filed an action in the United States District Court for the Northern District of Mississippi, claiming the single-sex admissions policy of MUW's School of Nursing violated the Equal Protection Clause of the Fourteenth Amendment. Hogan sought injunctive and declaratory relief, as well as compensatory damages. The court concluded that maintenance of MUW as a single-sex school bears a rational relationship to the State's legitimate interest "in providing the greatest practical range of educational opportunities for its female student population." The admissions policy was not arbitrary, providing single-sex schools is consistent with a respected, though by no means universally accepted, educational theory that single-sex education affords unique benefits to students. Stating that the case presented no issue of fact, the court informed Hogan that it would enter summary judgment dismissing his claim unless he tendered a factual issue. When Hogan offered no further evidence, the District Court entered summary judgment in favor of the State.[4] The Court of Appeals reversed this decision, recognizing that the State has a significant interest in providing educational opportunities for all its citizens, the court then found that the State failed to show that providing a unique educational opportunity for females, but not for males, had any substantial relationship to that interest.
[edit] Implications
The court’s ruling did not require that the entire university become coeducational, however the Board of Trustees of Mississippi State Institutions of Higher Learning ordered the university to change its policies to allow the admission of qualified males into all university programs.[5] Today MUW’s student body is approximately 15% male.[6]
The court’s ruling also did not require the school to change the name of the school, and as a result the school remains “Mississippi University for Women”. Suits have been filed against the university to change the name claiming that its name and mission discourage males from applying for admission; men would like to get the kind of personal, liberal-arts education offered at the W, but would be treated as outsiders if they went there. These suits were dismissed as groundless and had no effect on the name. The current administration of the university considered changing the name[7] however the proposal generated outrage.[8] and the name will not change any time soon.
This ruling has had an effect on the operations of other universities. In United States v. Virginia, the last all-male university in the United States, Virginia Military Institute, was required to admit women after a Supreme Court Ruling citing MUW v. Hogan as one of the factors leading to this ruling.
Joe Hogan did not complete his degree at Mississippi University for Women.
