McLaurin v. Oklahoma State Regents for Higher Education
94 L. Ed. 2d 1149, 339 U.S. 637, 1950 U.S. LEXIS 1810 (1950)
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Rule of Law:
Once a state admits a student to a state-supported graduate school, the Equal Protection Clause of the Fourteenth Amendment requires that the student receive the same treatment from the state as students of other races, and prohibits the state from imposing restrictions that segregate the student.
Facts:
- G.W. McLaurin, a Black citizen of Oklahoma holding a Master's Degree, applied to pursue a Doctorate in Education at the University of Oklahoma.
- His application was initially denied solely because of his race, in accordance with state statutes that mandated segregation in schools.
- After a court ruling, the University of Oklahoma Graduate School admitted McLaurin.
- Upon admission, the university subjected McLaurin to segregated conditions to comply with a newly amended state law.
- Initially, he was required to sit at a designated desk in an anteroom adjoining the classroom, at a special desk on the library's mezzanine floor, and eat at a separate table at a different time in the cafeteria.
- These conditions were later modified: McLaurin was assigned a seat in a classroom row specified for Black students, a designated table on the main library floor, and a separate table in the cafeteria, though he could eat at the same time as other students.
Procedural Posture:
- McLaurin filed a complaint in a statutory three-judge U.S. District Court, seeking an injunction against the University of Oklahoma for denying him admission based on race.
- The District Court held that the state had a duty to provide him the education and that the statutes denying him admission were unconstitutional, but it declined to issue an injunction.
- After the university admitted McLaurin under new state-mandated segregated conditions, McLaurin filed a motion with the same District Court to modify its prior judgment and remove the conditions.
- The District Court denied the motion, holding that the segregated treatment did not violate the Fourteenth Amendment.
- McLaurin (appellant) appealed the District Court's denial of his motion directly to the U.S. Supreme Court.
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Issue:
Does a state's imposition of segregated conditions on a student within a state university's classrooms, library, and cafeteria, after he has been admitted, violate the Equal Protection Clause of the Fourteenth Amendment?
Opinions:
Majority - Mr. Chief Justice Vinson
Yes, a state's imposition of segregated conditions on an admitted student violates the Equal Protection Clause. Such state-imposed restrictions on a student's academic life are unconstitutional because they impair and inhibit his ability to study, engage in discussions, and exchange views with other students, which are indispensable parts of effective graduate instruction. The Court reasoned that these restrictions handicapped McLaurin in his pursuit of an advanced degree in education, thereby creating an inequality that the Fourteenth Amendment cannot sustain. The Court distinguished between state-imposed barriers to intellectual commingling and the private choices of individuals, holding that the state may not be the instrument of such segregation. By setting McLaurin apart, the state deprived him of his personal and present right to the equal protection of the laws.
Analysis:
This case significantly eroded the 'separate but equal' doctrine established in Plessy v. Ferguson. Moving beyond the tangible equality of facilities addressed in cases like Sweatt v. Painter, the Court focused on the intangible harms of segregation itself. By recognizing that state-imposed separation within an institution impairs the quality of education and the ability to learn, the decision invalidated 'separate but equal' in the context of graduate education. This ruling was a crucial step toward the Supreme Court's landmark decision in Brown v. Board of Education, which would declare segregation in public schools unconstitutional four years later.
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