Missouri ex rel. Gaines v. Canada

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Missouri ex rel. Gaines v. Canada
Supreme Court of the United States
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.

Contents

[edit] Facts

Petitioner Lloyd Gaines, a citizen of the state of Missouri and a qualified African American graduate with a Bachelor of Arts, was refused admission to the School of Law at the State University of Missouri because it was a facility that exclusively educated white students. 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 the University of Missouri. Gaines' lawyer, famed civil rights attorney Charles Hamilton Houston, argued that the discrimination was in violation of the Fourteenth Amendment’s Equal Protection Clause. At the time, the state of Missouri provided separate public schools and universities for white citizens and colored citizens. However, whereas the State University of Missouri had a Law School, the Lincoln University in Missouri for African Americans did not provide legal training to its students. The University of Missouri claimed that since Gaines had the opportunity to apply to any one of four law schools in adjacent states, which accepted nonresident students, the rejection was in accord with Missouri’s laws and public policies pertaining to the admissions of colored individuals within the state’s public school system. Gaines brought suit and requested that a writ of mandamus be issued to the University of Missouri’s curators in order to compel admission. The Circuit Court denied the writ and the Supreme Court of Missouri upheld the judgment against Gaines at which point he appealed to the Supreme Court.

[edit] Result

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.

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 v. Ferguson decision in 1896. This case was brought to suite by the NAACP on behalf of Lloyd Gaines, and aimed to test the constitutionality of segregation. It must be noted that in this case the Supreme 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 ever 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.

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