''Mississippi University for Women v. Hogan'', 458 U.S. 718 (1982), was a
landmark decision of the
Supreme Court of the United States, decided 5–4, which ruled that the
single-sex admissions policy of the
Mississippi University for Women
Mississippi University for Women (MUW or "The W") is a coeducational public university in Columbus, Mississippi. It was formerly named the Industrial Institute and College for the Education of White Girls and later the Mississippi State College ...
violated the
Equal Protection Clause of the
Fourteenth Amendment to the United States Constitution.
Background of the case
The Mississippi University for Women was established in 1884 in
Columbus, Mississippi and originally called the Mississippi Industrial Institute and College for the Education of White Girls, later changed to Mississippi State College for Women. It was the first state-supported
women's college in the United States. In 1971, the School of Nursing was established, initially offering a two-year
associate's degree
An associate degree is an undergraduate degree awarded after a course of Tertiary education, post-secondary study lasting two to three years. It is a level of qualification above a high school diploma, GED, or matriculation, and below a bachelo ...
, and later four-year
baccalaureate degree and
graduate degree
Postgraduate or graduate education refers to academic or professional degrees, certificates, diplomas, or other qualifications pursued by post-secondary students who have earned an undergraduate (bachelor's) degree.
The organization and struc ...
programs.
In 1979, Joe Hogan, a
registered nurse and nursing supervisor in Columbus who did not have a baccalaureate degree in nursing, 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 courses in which he was interested, but he could not enroll for credit because he was male. Hogan could have attended classes and received credit in one of Mississippi's two
public
In public relations and communication science, publics are groups of individual people, and the public (a.k.a. the general public) is the totality of such groupings. This is a different concept to the sociological concept of the ''Öffentlichk ...
,
coeducational programs leading to a
Bachelor of Science in Nursing
The Bachelor of Science in Nursing (BSN, BScN) also known in some countries as a Bachelor of Nursing (BN) or Bachelor of Science (BS) with a Major in Nursing is an academic degree in the science and principles of nursing, granted by an accredited ...
, but these were at the
University of Southern Mississippi
The University of Southern Mississippi (Southern Miss or USM) is a public research university with its main campus located in Hattiesburg, Mississippi. It is accredited by the Southern Association of Colleges and Schools to award bachelor's, ma ...
in
Hattiesburg
Hattiesburg is a city in the U.S. state of Mississippi, located primarily in Forrest County (where it is the county seat and largest city) and extending west into Lamar County. The city population was 45,989 at the 2010 census, with the populat ...
(178 miles from Columbus) and the
University of Mississippi
The University of Mississippi ( byname Ole Miss) is a public research university that is located adjacent to Oxford, Mississippi, and has a medical center in Jackson. It is Mississippi's oldest public university and its largest by enrollment ...
in
Oxford
Oxford () is a city in England. It is the county town and only city of Oxfordshire. In 2020, its population was estimated at 151,584. It is north-west of London, south-east of Birmingham and north-east of Bristol. The city is home to the ...
(114 miles from Columbus). Hogan filed an
action
Action may refer to:
* Action (narrative), a literary mode
* Action fiction, a type of genre fiction
* Action game, a genre of video game
Film
* Action film, a genre of film
* ''Action'' (1921 film), a film by John Ford
* ''Action'' (1980 fil ...
in the
, claiming the single-sex admissions policy of MUW's School of Nursing violated the
Equal Protection Clause of the Fourteenth Amendment, and seeking
injunctive and
declaratory relief
A declaratory judgment, also called a declaration, is the legal determination of a court that resolves legal uncertainty for the litigants. It is a form of legally binding preventive by which a party involved in an actual or possible legal ma ...
as well as
compensatory damages
At common law, damages are a remedy in the form of a monetary award to be paid to a claimant as compensation for loss or injury. To warrant the award, the claimant must show that a breach of duty has caused foreseeable loss. To be recognised at ...
.
Case history
The District Court ruled in favor of the Mississippi University for Women, concluding 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 court held that 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
In law, a summary judgment (also judgment as a matter of law or summary disposition) is a judgment entered by a court for one party and against another party summarily, i.e., without a full trial. Summary judgments may be issued on the merits of ...
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.
The
Court of Appeals for the Fifth Circuit reversed, holding that because the admissions policy discriminated on the basis of sex, a rational relationship test was improper, and the proper test was whether the sex-based admissions policy was
substantially related to an important governmental objective. The court, while recognizing that the State has a significant interest in providing educational opportunities for all its citizens, 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.
Opinion of the Court
The Supreme 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. By the 2020-2021 academic year, one in five students were men.
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. These suits were dismissed as groundless and had no effect on the name.
In 2002, the administration of the university considered changing the name and pursued efforts to do so despite opposition, particularly from alumnae. In her convocation speech on August 11, 2008, President Limbert announced a new proposal to remove "women" from the university's name which was abandoned.
See also
*
Gender equality
Gender equality, also known as sexual equality or equality of the sexes, is the state of equal ease of access to resources and opportunities regardless of gender, including economic participation and decision-making; and the state of valuing d ...
*
List of gender equality lawsuits
*
List of United States Supreme Court cases, volume 458
This is a list of all the United States Supreme Court
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court ca ...
References
External links
*
{{US14thAmendment
United States equal protection case law
United States Supreme Court cases
United States Supreme Court cases of the Burger Court
Mississippi University for Women
Women's universities and colleges in the United States
1982 in United States case law
Gender discrimination lawsuits