Gong Lum v. Rice
275 U.S. 78, 48 S. Ct. 91 (1927)
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Rule of Law:
A state's classification of a U.S. citizen of Chinese descent as 'colored' for the purpose of segregating public schools does not violate the Equal Protection Clause of the Fourteenth Amendment, as this falls within the state's discretion to regulate public education under the 'separate but equal' doctrine.
Facts:
- Gong Lum, a resident of Mississippi and a taxpayer, was the father of Martha Lum, a nine-year-old, native-born U.S. citizen of Chinese descent.
- Martha Lum was an educable child of good moral character who resided in the Rosedale Consolidated High School District.
- At the start of the school term, she attended the Rosedale Consolidated High School, which was a school for white children.
- During the noon recess on the first day, the school superintendent notified her she would not be allowed to return.
- The Board of Trustees excluded her from the school solely on the ground that she was of Chinese descent and therefore not a member of the white race.
- There was no public school established in the district or county specifically for the education of children of Chinese descent.
Procedural Posture:
- Gong Lum filed a petition for a writ of mandamus on behalf of his daughter, Martha Lum, in the Circuit Court of Mississippi for Bolivar County, seeking her admission to a public school for white children.
- The defendants, the Board of Trustees, filed a demurrer to the petition.
- The Mississippi trial court overruled the demurrer and ordered that the writ of mandamus be issued, ruling in favor of Gong Lum.
- The defendants appealed the trial court's decision to the Supreme Court of Mississippi.
- The Supreme Court of Mississippi reversed the trial court's ruling, holding that the state constitution allowed for the segregation and that Martha Lum, being of the 'Mongolian or yellow race,' could be constitutionally excluded from the white school.
- The case was then brought to the Supreme Court of the United States for review.
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Issue:
Does requiring a U.S. citizen child of Chinese descent to attend a public school designated for 'colored' children, rather than one for white children, violate the Equal Protection Clause of the Fourteenth Amendment?
Opinions:
Majority - Chief Justice Taft
No, requiring a U.S. citizen child of Chinese descent to attend a public school for 'colored' children does not violate the Equal Protection Clause of the Fourteenth Amendment. The Court reasoned that the power to regulate public education is fundamentally a state matter. Citing the precedent of Plessy v. Ferguson and numerous state court cases, the Court held that the 'separate but equal' doctrine, which permits the establishment of separate schools for white and colored children, is a valid exercise of state legislative power. The Court concluded that the question of whether to classify a child of the 'yellow race' with children of the 'black' and 'brown' races is a matter within the discretion of the state and does not present a different constitutional issue than the segregation of African American children. As long as the state provides access to some form of public education, even in a segregated school for 'colored' children, it has met its obligation under the Fourteenth Amendment.
Analysis:
This case significantly broadened the application of the 'separate but equal' doctrine established in Plessy v. Ferguson. By ruling that a child of Chinese descent could be classified as 'colored' for segregation purposes, the Supreme Court affirmed that the doctrine was not limited to the Black/white binary. This decision reinforced the immense discretion states had in defining racial categories and managing their public school systems, effectively sanctioning the segregation of Asian Americans and other minority groups under the same legal framework used to segregate African Americans. The ruling stood as a major obstacle to educational equality for all non-white children until it was effectively overturned by Brown v. Board of Education in 1954.
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