BRIEF #1

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Dec 6, 2023

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Sidney Scoville March 10, 2019 CASE BRIEF Brown v. Board of Education of Topeka, Kansas, 347 U.S. 483 (1954) Judicial History: This case came before the United States Supreme Court on a Writ of Certiorari from the District Court in Kansas. As an indication of the importance of this case, it came directly to the Supreme Court from the District Court. Facts: The schools in Topeka, Kansas were segregated. Some schools were for Whites only, other schools were for African Americans only. Brown filed suit in the District Court in Kansas and alleged that the segregation policy of the Board of Education of Topeka, Kansas was a violation of the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. Issue: Does the segregation policy of the Board of Education of Topeka, Kansas, that divides children in public schools solely on the basis of race, even though the physical facilities and other “tangible” factors may be equal, deprive the African American children for equal protection rights as guaranteed by the Fourteenth Amendment to the United States Constitution? Rule: The United States Supreme Court cited too many cases in the footnotes to its opinion; however, it relied primarily on the cases of Sweat v. Painter 339 U.S. 629 and McLaurin v. Oklahoma 339 U.S. 637. Analysis: The Brown case actually encompassed a number of other cases that had been brought on similar issues. The Supreme Court convinced all of these cases into the Brown opinion because, ultimate, they all asked the same question, to which the Supreme Court gave one answer. The schools in Topeka, Kansas were dived based upon the race of the children attending. The Court recognized that the Board of Education provided equal facilities and other “tangible” benefits to all the children in the school district regardless of their race and which school they attended. The Court noted that the case that arose in Delaware that was Combined into the Brown case had significantly different facts and outcome. In the Delaware case, the Delaware Supreme Court found that the white and black school were not equal and ordered that African American children be enrolled in the better white schools. The analysis in Brown focuses exclusively on race and not the better or worse facilities of the segregated schools. Although the Delaware case reached the conclusion that African Americans be enrolled in white schools, it did so based upon the difference is physical facilities and other tangible benefits, and left alone any analysis of the inference inequity of dividing children on refacing alone. The Court cited to the cases of the Slaughter-House Cases 16 Wall. 37 (1873) and Struader v. West Virginia 100 U.S. 303, 307-308 (1880) that the very first analysis of the equal protection right of the Fourteen Amendment found that any and all discrimination of an African American bases exclusively on race was forbidden. It was only later Court cases (Plessy v. Ferguson 163 U.S. 537) that greater the concept of “separate but equal.” Under the “separate but equal” doctrine, it was permissible
to discriminate on the basis of race, provided that the opportunities were equal between the white persons and African Americans. The Plessy decision allowed continued segregation and discrimination under certain circumstances. The Brown Court rejected the concept of “separate, but equal,” and as such overruled the Plessy case. The Plaintiff’s in the Brown case argued that segregated school and not “equal” nor can they be made “equal” by providing equal physical opportunities. The Court stated that this is an issue of great importance and this is why it accepted the case and assumed jurisdiction. The Court stated that it had heard the additional argument of the history of the Fourteenth amendment and what the drafters actually meant and how it had been interpreted by subsequent judicial opinions. The Court concluded that the equal protection guarantees of the Fourteenth Amendment could not be overcome by providing equal treatment after an impermissible separation based upon race. The Court cognized that the analysis, in this case, could not be on equal opportunities, so instead, it analyzed the facts under the concept of its effect of unlicensed education itself and not necessarily the individuals would suffer discrimination. The Court discussed what place equal education has in current American life throughout the entire nation. The Court placed the provision of free public education as the most fundamental responsibility of state and local governments. Such an important aspect of life must be provided in equal terms to all children. The division of children based upon race may give rise to the children in the discriminated class feeling inferior to the majority of white children, and this feeling of inferiority may last into adulthood. The segregated child may feel inferior, and this would affect his ability and willingness to learn. The Court ultimately determined that the doctrine of “separate, but equal” had no place in public education. No matter how much the local education authority may try to balance the opportunities provided to white and African American children, it could not do so because of the in inherent effect that serration has upon this who feel lessened because of its impact. Thus, segregation in education based upon race is a violation of equal protection as guaranteed in the Fourteenth Amendment to the United States Constitution and entirely impermissible. Conclusion: The United States Supreme Court held that any serration in public education violated the equal protection clause of the Fourteenth Amendment to the United States Constitution and as such is wholly impermissible.
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