Missouri ex rel. Gaines v. Canada
Encyclopedia
Missouri ex rel
. Gaines v. Canada, 305 U.S. 337
(1938), 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.
refused admission to Lloyd Gaines because he was an African-American. At the time there was no Law School specifically for African-Americans within the state. Gaines cited that this refusal violated his Fourteenth Amendment
right. The state of Missouri had offered to pay for Gaines’ tuition at an adjacent state’s law school, which he turned down.
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 decision in 1896. This case was brought to suit 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 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 which could never 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 and is generally presumed to have been murdered. When the University of Missouri soon after moved to dismiss the case, the NAACP did not oppose the motion.
Ex rel
Ex rel is an abbreviation of the Latin phrase "ex relatione" meaning "by the relation of" . The term is a legal phrase most commonly used when a government brings a cause of action upon the request of a private party who has some interest in the matter. The private party is called the relator in...
. Gaines v. Canada, 305 U.S. 337
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1938), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
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.
Facts
The Law School at the University of MissouriUniversity of Missouri
The University of Missouri System is a state university system providing centralized administration for four universities, a health care system, an extension program, five research and technology parks, and a publishing press. More than 64,000 students are currently enrolled at its four campuses...
refused admission to Lloyd Gaines because he was an African-American. At the time there was no Law School specifically for African-Americans within the state. Gaines cited that this refusal violated his Fourteenth Amendment
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
right. The state of Missouri had offered to pay for Gaines’ tuition at an adjacent state’s law school, which he turned down.
Issue
In light of the equal protection clause of the 14th Amendment, does Missouri violate this clause when it affords whites the ability to attend law school in state while not affording the same right to blacks and instead forcing them to attend adjacent states for their law education?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. 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 couldn't still deny Gaines admission.Analysis
This decision does not quite strike down separate but equalSeparate but equal
Separate but equal was a legal doctrine in United States constitutional law that justified systems of segregation. Under this doctrine, services, facilities and public accommodations were allowed to be separated by race, on the condition that the quality of each group's public facilities was to...
education as upheld in Plessy v. Ferguson
Plessy v. Ferguson
Plessy v. Ferguson, 163 U.S. 537 , is a landmark United States Supreme Court decision in the jurisprudence of the United States, upholding the constitutionality of state laws requiring racial segregation in private businesses , under the doctrine of "separate but equal".The decision was handed...
(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
Brown v. Board of Education
Brown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court that declared state laws establishing separate public schools for black and white students unconstitutional. The decision overturned the Plessy v. Ferguson decision of 1896 which...
(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
Separate but equal
Separate but equal was a legal doctrine in United States constitutional law that justified systems of segregation. Under this doctrine, services, facilities and public accommodations were allowed to be separated by race, on the condition that the quality of each group's public facilities was to...
” standard made by the Plessy decision in 1896. This case was brought to suit 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 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 which could never 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 and is generally presumed to have been murdered. 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
- Civil Rights CasesCivil Rights CasesThe Civil Rights Cases, 109 U.S. 3 , were a group of five similar cases consolidated into one issue for the United States Supreme Court to review...
- Sipuel v. Board of Regents of Univ. of Okla.Sipuel v. Board of Regents of Univ. of Okla.Sipuel v. Board of Regents of Univ. of Okla., 332 U.S. 631 is a United States Supreme Court case that dealt with the Fourteenth Amendment to the United States Constitution....
- - Sweatt v. PainterSweatt v. PainterSweatt v. Painter, , was a U.S. Supreme Court case that successfully proved lack of equality, in favor of a black applicant, the "separate but equal" doctrine of racial segregation established by the 1896 case Plessy v. Ferguson. The case was also influential in the landmark case of Brown v...
- - Brown v. Board of EducationBrown v. Board of EducationBrown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court that declared state laws establishing separate public schools for black and white students unconstitutional. The decision overturned the Plessy v. Ferguson decision of 1896 which...
of Topeka - - Timeline of the American Civil Rights MovementTimeline of the American Civil Rights MovementThis is a timeline of African-American Civil Rights Movement.-Pre-17th century:1565*unknown – The colony of St...