Sweatt v. Painter
339 U.S. 629 (1950)
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Rule of Law:
In the context of professional education, a state cannot satisfy the Equal Protection Clause of the Fourteenth Amendment by providing a separate law school for Black students if that school is not substantially equal in both tangible facilities and intangible qualities, such as faculty reputation, prestige, and alumni influence.
Facts:
- In 1946, Heman Marion Sweatt, a Black man, applied for admission to the University of Texas Law School.
- His application was rejected solely because of his race, in accordance with Texas state law, which mandated segregation in education.
- At the time Sweatt applied, there was no law school in Texas that admitted Black students.
- In response to Sweatt's legal action, the state of Texas established a separate law school for Black students.
- The University of Texas Law School had a large, distinguished faculty, a student body of 850, a library of over 65,000 volumes, and a powerful alumni network.
- The newly established law school for Black students was substantially inferior, with a small faculty, few students, a much smaller library, and no established reputation or alumni network.
- The segregated law school also isolated its students from the majority of the state's population and the overwhelming majority of future lawyers, judges, and officials with whom they would interact professionally.
Procedural Posture:
- Heman Sweatt filed suit for a writ of mandamus against school officials in a Texas state trial court to compel his admission to the University of Texas Law School.
- The trial court found a violation of the Equal Protection Clause but continued the case for six months to allow the state to create a substantially equal law school.
- After six months, the trial court denied the writ, satisfied that the state had made provisions for a new law school for Black students.
- Sweatt appealed to the Texas Court of Civil Appeals, which remanded the case for a new hearing on the equality of the new school's facilities.
- On remand, the trial court found the new school 'substantially equivalent' and again denied the writ of mandamus.
- The Texas Court of Civil Appeals affirmed the trial court's decision.
- The Texas Supreme Court denied Sweatt's application for a writ of error, declining to hear the case.
- The U.S. Supreme Court granted certiorari to review the decision.
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Issue:
Does the Equal Protection Clause of the Fourteenth Amendment permit Texas to deny admission to a Black applicant to the University of Texas Law School by establishing a separate, newly created law school for Black students?
Opinions:
Majority - Chief Justice Vinson
No. The Equal Protection Clause does not permit Texas to exclude a Black applicant from its primary law school by offering admission to a separate law school that is unequal in both tangible and intangible respects. The court found that the University of Texas Law School was superior in terms of faculty, course variety, library size, and other tangible facilities. More importantly, the court emphasized intangible qualities that are critical to a legal education and cannot be objectively measured, such as the reputation of the faculty, experience of the administration, position and influence of the alumni, and the school's standing in the community and prestige. Furthermore, a legal education cannot occur in an academic vacuum; isolating petitioner from the vast majority of the legal community denies him the opportunity for the interplay of ideas and exchange of views essential to the study of law. Because the education offered at the separate school was not substantially equal to that at the University of Texas Law School, Sweatt's personal right to equal protection was violated.
Analysis:
This decision significantly undermined the 'separate but equal' doctrine established in Plessy v. Ferguson, particularly within the realm of higher and professional education. By introducing 'intangible' factors like prestige and professional interaction into the equality analysis, the Court created a standard that was practically impossible for states to meet when creating segregated graduate schools. This ruling paved the way for Brown v. Board of Education four years later, which would declare the 'separate but equal' doctrine unconstitutional in all public education, as it demonstrated that separation itself inherently creates inequality.
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