McLaurin v. Oklahoma State Regents for Higher Education

Petitioner
George McLaurin
Respondent
Oklahoma State Regents for Higher Education, et al.
Petitioner's Claim
That an Oklahoma state law mandating racial segregation in postgraduate education violated the Equal Protection Clause of the Fourteenth Amendment.
Chief Lawyers for Petitioner
Robert L. Carter, Amos T. Hall
Chief Lawyer for Respondents
Fred Hansen
Justices for the Court
Hugo Lafayette Black, Harold Burton, Tom C. Clark, William O. Douglas, FelixFrankfurter, Robert H. Jackson, Sherman Minton, Stanley Forman Reed, Fred Moore Vinson (writing for the Court)
Justices Dissenting
None
Place
Washington, D.C.
Date of Decision
5 June 1950
Decision
Upheld the petitioner's claim and reversed a lower court ruling, holding thatthe segregation practiced by the University of Oklahoma's Graduate School ofEducation was in violation of the Equal Protection Clause of the FourteenthAmendment.
Significance
The ruling provided further evidence of the Court's abandonment of the "separate but equal" approach to racial segregation in education as advanced in Plessy v. Ferguson (1896). This doctrine was replaced with complete opposition to segregation in education, which the Court established in Lloyd Gaines v. University of Missouri (1937) and Sipuel v. University of Oklahoma (1948). Eventually, the Court's stand against educational segregation yielded what is arguably its most historic decision in Brown v. Board ofEducation (1954).
Separate but Equal
At the time of its ratification, the Fourteenth Amendment to the Constitutionof the United States was interpreted as prohibiting state discrimination onthe basis of race. Given the deep divisions between the races, particularly in the years prior to the Civil War, it is not surprising that many states codified racial discrimination with segregationist statutes. Racial tensions didnot disappear with the end of the Civil War, and states in both the North and South continued to pass segregationist legislation. In fact, this approachto race relations was sanctioned by the Supreme Court in Plessy v. Ferguson. In this case, the Court ruled that a Boston, Massachusetts statute mandating racial segregation in schools and on public transportation was constitutional. The Court stated that "the object of the [Fourteenth] Amendment wasundoubtedly to enforce the absolute equality of the two races before the law,but in the nature of things it could not have been intended to abolish distinctions based upon color." Thus, Plessy v. Ferguson established the "separate but equal" doctrine, which rendered virtually all segregationist statutes legally binding provided that facilities of equal quality existed for all races. In reality, of course, the facilities available to African Americanswere seldom equal to those available to the majority under segregation.
Abandonment of the "Separate but Equal" Doctrine
The nation endured separate but equal educational facilities for nearly halfa century. As time passed, however, the doctrine succumbed to its own internal contradictions. Moreover, integration in the armed forces during the SecondWorld War removed some opposition to integration of society as a whole. In Lloyd Gaines v. University of Missouri (1937), the Court ruled that theUniversity could not deny Mr. Gaines admission, since no equivalent institution for African Americans existed in the state at the time of his applicationfor admission. The Court continued its movement away from Plessy v. Ferguson in Sipuel v. University of Oklahoma (1948) when it reversed lower court decisions that interpreted Gaines as not requiring states with segregationist laws to admit African American students to white postsecondary educational institutions. Clearly, the days of "separate but equal" werenumbered.
Not Separate but Still Unequal
George W. McLaurin, a young man of African descent pursuing his doctorate, secured admission to the Graduate School of Education of the University of Oklahoma shortly after the Court's decision in Sipuel. National legal andlegislative institutions may have been moving away from segregationism, but many states, including Oklahoma, most certainly were not. The state's university system had grudgingly begun to accept African American students, but segregationism was alive and well on campus.
George McLaurin found his personal situation within the Graduate School of Education unbearable. Although he was allowed to attend the University of Oklahoma and, by his own stipulation, was not placed at a disadvantage in any way,the treatment he received was inhumane. McLaurin was forced to sit at a designated desk in an anteroom attached to the classroom where his fellow students sat, to use only a designated space in the mezzanine of the library, and toeat at a designated table and at a different time than his fellow students in the university's cafeteria.
Legal Action
McLaurin filed a motion with the district court to compel the university to allow him a more normal campus life. This motion was denied on the grounds that his treatment did not violate the Equal Protection Clause of the FourteenthAmendment, since it did not affect his ability to receive the same educationas his classmates. The university did take voluntary action, however, removing a railing surrounding McLaurin's designated eating place and also taking down a sign over his table that read: "Reserved for Colored Only." McLaurin was also allowed to sit in the same classroom as the other students, although made to occupy a specified section, and to eat at the same time as his classmates. He still found his situation unsatisfactory, however, and his case was appealed to the U.S. Supreme Court, which heard arguments on 3 and 4 April 1950.
Equal Protection or Equal Treatment?
Chief Justice Vinson delivered the opinion for a unanimous Court, which ruledthat the University of Oklahoma's treatment of McLaurin, even in its modified form, was unconstitutional and must be stopped. Vinson had a strong personal interest in civil rights cases, and worked tirelessly behind the scenes toinsure unanimity in the decision so as not to dilute the message he believedthe Court should send to society. The Court was careful to point out that itwas only ruling on the narrow question of "whether a state may, after admitting a student to graduate instruction in its state university, afford him different treatment from other students solely because of his race." However, theCourt was also willing to face the wider implications of its decision.

Our society grows increasingly complex, and our need for trained leaders increases correspondingly. Appellant's case represents, perhaps, the epitome of that need, for he is attempting to obtain an advanced degree in education, to become, by definition, a leader and trainer of others.

The Court thus ruled that separate but equal facilities worked against the national interest, and strongly implied that they would no longer be tolerated inthe field of education.
Impact
McLaurin v. Oklahoma State Regents for Higher Education represents a watershed for the Civil Rights Movement in the United States. In conjunction with Sweatt v. Painter (1950), in which, on the same day that it announced its ruling in McLaurin , the Court ruled that the University of Texas Law School had to admit African American students despite the existence of traditionally black law schools within the state, the case marked the beginning of the end of the legal doctrine of separate but equal within higher education in the United States. Despite Chief Justice Vinson's death in 1953, the Court continued its advocacy of racial integration under his successor, Earl Warren. Under Warren, the Court completely disposed of the doctrine of separate but equal and delivered what may be its most famous and influential decision: that states could not bar children of African American descent from attending public primary and secondary schools in Brown v. Board of Education (1954).
Related Cases

• Plessy v. Ferguson, 163 U.S. 537 (1896).
  
• Lloyd Gaines v. University of Missouri, 305 U.S. 337 (1937).
  
• Sipuel v. University of Oklahoma, 332 U.S. 631 (1948).
  
• Sweatt v. Painter, 339 U.S. 629 (1950).
  
• Brown v. Board of Education, 347 U.S. 483 (1954).