University of Maryland v. Murray
182 A. 590, 169 Md. 478 (1936)
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Rule of Law:
Under the Equal Protection Clause of the Fourteenth Amendment, if a state provides legal education, it must offer substantially equal facilities to all races. Providing out-of-state scholarships for Black students does not constitute a substantially equal alternative to an in-state law school available to white students.
Facts:
- Donald Gaines Murray, a Black resident of Baltimore City and a graduate of Amherst College, applied for admission to the University of Maryland Law School.
- The law school was the only state-supported institution for legal education in Maryland and was located in Baltimore.
- Murray met all academic and other qualifications for admission.
- The University of Maryland denied Murray admission for the sole reason that he was Black.
- At the time, Maryland's policy was to maintain segregated schools.
- As an alternative for Black students seeking professional education, Maryland provided a limited number of scholarships for them to attend institutions outside the state.
Procedural Posture:
- Donald Gaines Murray petitioned the Baltimore City Court, a state trial court, for a writ of mandamus to compel the University of Maryland to admit him to its law school.
- The trial court granted the petition and ordered the University to admit Murray.
- The officers and governing board of the University of Maryland, as appellants, appealed the trial court's order to the Court of Appeals of Maryland, the state's highest court.
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Issue:
Does a state university's refusal to admit a qualified Black applicant to its law school, solely on the basis of race, violate the Equal Protection Clause of the Fourteenth Amendment when the state offers scholarships for the applicant to attend law school out-of-state?
Opinions:
Majority - Bond, C. J.
Yes. The state's refusal to admit Murray to its only public law school because of his race, while offering an out-of-state scholarship as an alternative, violates the Equal Protection Clause. The University of Maryland is a state agency and is therefore bound by the Fourteenth Amendment's requirement of equal treatment. While states may segregate races in education, they must provide substantially equal facilities. The out-of-state scholarship program is not substantially equal because it imposes significant financial and practical disadvantages, such as increased travel and living expenses, and denies the student the opportunity to study Maryland law in Maryland courts. The constitutional mandate for equal treatment is a present obligation, and since the only state law school available is the one at the University of Maryland, the school must admit the qualified applicant.
Analysis:
This case represents a significant early victory in the NAACP's legal strategy to dismantle segregation in public education. By focusing on the tangible inequalities in graduate and professional schools, the decision successfully challenged the 'separate but equal' doctrine established in Plessy v. Ferguson. The court's reasoning, which highlighted the practical and professional disadvantages of out-of-state education, established a precedent that 'separate' was often inherently unequal. This ruling laid the groundwork for subsequent Supreme Court cases like Missouri ex rel. Gaines v. Canada and Sweatt v. Painter, which further eroded the 'separate but equal' doctrine and culminated in Brown v. Board of Education.
