''Missouri
ex rel. Gaines v. Canada'', 305 U.S. 337 (1938), was a
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 cases, and over state court cases that involve a point o ...
decision holding that
states which provided a
school
A school is an educational institution designed to provide learning spaces and learning environments for the teaching of students under the direction of teachers. Most countries have systems of formal education, which is sometimes co ...
to white students had to provide in-state education to blacks as well. States could satisfy this requirement by allowing blacks and whites to attend the same school or creating a second school for blacks.
[.]
Background
The Registrar at the Law School of the
University of Missouri
The University of Missouri (Mizzou, MU, or Missouri) is a public land-grant research university in Columbia, Missouri. It is Missouri's largest university and the flagship of the four-campus University of Missouri System. MU was founded in ...
, Silas Woodson Canada, refused admission to
Lloyd Gaines
Lloyd Lionel Gaines (born 1911 – disappeared March 19, 1939) was the plaintiff in '' Gaines v. Canada'' (1938), one of the most important early court cases in the 20th-century U.S. civil rights movement. After being denied admission to the ...
because he was black.
At the time, blacks could attend no law school specifically in the state. Gaines cited that the refusal violated the
Fourteenth Amendment. The State of Missouri had offered to pay for Gaines's
tuition
Tuition payments, usually known as tuition in American English and as tuition fees in Commonwealth English, are fees charged by education institutions for instruction or other services. Besides public spending (by governments and other public bo ...
at an adjacent state's law school, which he turned down.
Gaines, assisted by the
NAACP
The National Association for the Advancement of Colored People (NAACP) is a civil rights organization in the United States, formed in 1909 as an interracial endeavor to advance justice for African Americans by a group including W. E.&n ...
, sued the all-white university in 1935. The issue was whether Missouri violated the
Equal Protection Clause
The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "''nor shall any State ... deny to any person within its jurisdiction the equal ...
of the Fourteenth Amendment by affording whites, not blacks, the ability to attend law school within the state.
Trial
The initial trial started in
Columbia, Missouri
Columbia is a city in the U.S. state of Missouri. It is the county seat of Boone County and home to the University of Missouri. Founded in 1821, it is the principal city of the five-county Columbia metropolitan area. It is Missouri's fourt ...
in Boone County.
Decision
Writing for the majority, Chief Justice
Charles Evans Hughes
Charles Evans Hughes Sr. (April 11, 1862 – August 27, 1948) was an American statesman, politician and jurist who served as the 11th Chief Justice of the United States from 1930 to 1941. A member of the Republican Party, he previously was the ...
held that when the state provides legal training, it must provide it to every qualified person to satisfy equal protection. It can neither send them to other states, nor 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 so Missouri law guaranteeing equal protection applied. Sending Gaines to another state would have been irrelevant.
Justice
James C. McReynolds'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, Missouri could still deny Gaines admission.
The decision did not quite strike down
separate but equal
Separate but equal was a legal doctrine in United States constitutional law, according to which racial segregation did not necessarily violate the Fourteenth Amendment to the United States Constitution, which nominally guaranteed "equal protec ...
facilities, upheld in ''
Plessy v. Ferguson'' (1896). Instead, it provided that if there was only one school, students of all races could be admitted. The decision struck down segregation by exclusion if the government provided just one school, making the decision in this case a precursor to ''
Brown v. Board of Education'' (1954).
This marked the beginning of the Supreme Court's reconsideration of ''Plessy''. The Supreme Court 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 that could never be truly equal. Therefore, it can be said that this case helped forge the legal framework for ''Brown v. Board of Education'', which banned segregation in public schools.
Despite the initial victory claimed by the
NAACP
The National Association for the Advancement of Colored People (NAACP) is a civil rights organization in the United States, formed in 1909 as an interracial endeavor to advance justice for African Americans by a group including W. E.&n ...
, after the Supreme Court had ruled in Gaines' favor and ordered the Missouri Supreme Court to reconsider the case, Gaines was
nowhere to be found
Nowhere To Be Found (often abbreviated as NTBF) are an alternative metal band formed in Ericeira in 2018. The group consists of vocalist Tiago Duarte, bassist Manel Gomes, drummer Miguel Rodrigues and lead guitarist João Quintais. The style of t ...
. When the University of Missouri soon after moved to dismiss the case, the NAACP did not oppose the motion.
See also
*
List of United States Supreme Court Cases
This page serves as an index of lists of United States Supreme Court cases. The United States Supreme Court is the highest federal court of the United States.
By Chief Justice
Court historians and other legal scholars consider each Chief J ...
*
Civil Rights Cases
* ''
Sipuel v. Board of Regents of Univ. of Okla.
''Sipuel v. Board of Regents of the University of Oklahoma'', 332 U.S. 631 (1948), is a ''per curiam'' United States Supreme Court decision involving racial segregation toward African Americans by the University of Oklahoma and the application of ...
'' -
* ''
Sweatt v. Painter'' -
* ''
Brown v. Board of Education of Topeka'' -
*
Timeline of the civil rights movement
This is a timeline of the civil rights movement in the United States, a nonviolent mid-20th century freedom movement to gain legal equality and the enforcement of constitutional rights for people of color. The goals of the movement included sec ...
References
External links
*
*
A profile of Gaines' attorney, Charles Hamilton Houston, and the ''Gaines'' case
{{US14thAmendment
1938 in United States case law
United States Supreme Court cases
United States Supreme Court cases of the Hughes Court
United States equal protection case law
United States racial desegregation case law
United States education case law
1938 in Missouri
20th century in Columbia, Missouri
African-American history in Columbia, Missouri
History of racism in Missouri
Legal history of Missouri
African-American history between emancipation and the civil rights movement
University of Missouri
Civil rights movement case law