McLaurin v. Oklahoma State Regents for Higher Education - Law and Higher Education
McLaurin v. Oklahoma State Regents for Higher Education (1950) was one of the key cases that invalidated intra-and interinstitution racial segregation in colleges and universities that helped to pave the way for Brown v. Board of Education, Topeka (1954). In McLaurin and its companion case, Sweatt v. Painter (1950), the U.S. Supreme Court held that African American students must receive the same treatment as all other students in the realm of higher education.
Facts of the Case
The litigation in McLaurin began to take shape when an African American student with a master’s degree applied for admission to the University of Oklahoma in pursuit of a doctorate in education but was denied entry solely due to his race. At the time, an Oklahoma law made it a misdemeanor to operate, teach at, or attend an educational institution that admitted both White and African American students. The student filed a complaint for injunctive relief, claiming that the statute was unconstitutional, because it deprived him of equal protection of the laws.
A three-judge federal trial court determined that officials in Oklahoma had a constitutional duty to provide the plaintiff with the education he wanted as soon as they offered the same to students of any other race. Although the court declared that the statute allowing officials to deny the student admission to the program was null and void, it refused to grant his request for an injunction based on the assumption that officials would follow the constitutional mandate in its order. Even so, the court retained jurisdiction of the case in order to provide the student with equal protection of the laws with regard to his education.
In response, legislators in Oklahoma amended the statute, permitting African Americans to be admitted to institutions provided that the education was “upon a segregated basis.” The student was then admitted to the Graduate School of the University of Oklahoma, a state-funded institution, where he was permitted to use the same cafeteria, library, and classrooms as White students. However, he was not allowed to eat at the same time as all other students.
As a result of the amended Oklahoma law, though, the plaintiff was assigned to a row of seats in the classroom reserved for African American students, had to sit at an assigned table in the library, and while he was allowed to eat in the cafeteria, he had a designated table and was assigned to eat at a different time from other students. After the plaintiff unsuccessfully filed a motion to amend the earlier order and judgment of the trial court, he appealed to the Supreme Court.
During the time between the student’s having filed his appeal and the Supreme Court’s having conducted oral arguments, university officials modified their treatment of the plaintiff. The sign that hung around the student’s sites in the classroom stating “Reserved For Colored” was removed, and he was assigned to a table on the main floor of the library; his previous table was on the mezzanine level.
The Supreme Court’s Ruling
On appeal, the Supreme Court focused on the question of whether officials could treat a student at a state university differently from other students based solely on his race. In a unanimous decision authored by Chief Justice Vinson, the Court reversed in favor of the student. The Court reasoned that under the Fourteenth Amendment’s Equal Protection Clause, state officials had the legal duty to treat the plaintiff in the same manner as students of other races.
Using sweeping language, the Supreme Court acknowledged that because American society was changing, discrimination based on race had no place in education. In addition, the Court ruled that insofar as the restrictions that officials imposed on the student impaired and inhibited his ability to study and to engage in discussions and debates with other students as well as faculty, this treatment had a detrimental impact on his overall educational experience.
In its defense, attorneys for the State of Oklahoma argued that the restrictions that officials imposed on African American students were nominal, because the facilities were made available to all students and the rooms that he was assigned had no disadvantages when compared to those used by all other students. The Court summarily dismissed this argument, noting that the treatment set the plaintiff apart from other students even if he had been allowed to use the same facilities, because he was still restricted as to where he could sit. In fact, the Court responded that the restrictions were designed to comply with the state statute that ordered officials in institutions of higher education to treat students differently based on their races. As a result, the Court pointed out that the plaintiff was held back in pursuit of his education, because he was unable to debate and discuss his ideas with other students and faculty with the result that his ability to learn his chosen profession, teaching, was hampered.
As part of its analysis, the Supreme Court recognized that because society was becoming more diverse and complex, the country needed a greater number of well-educated teachers. To this end, the Court observed that by pursuing his doctorate in education, the plaintiff endeavored to become a teacher and leader whose students would reflect the education that he received. In this regard, the Court was convinced that the plaintiff deserved an education that was equal to that of his peers in order to provide future generations of students with proper education and development. As a result, the Court asserted that any state-imposed restriction that produced inequalities could not be continued.
At the same time, the Supreme Court addressed the State’s argument that the restrictions might have benefited the plaintiff by enabling him to avoid discriminatory acts by his fellow students. The Court rejected this argument as holding no weight, indicating there is a vast difference between the state-imposed discrimination that resulted from the admissions policy based on race and the discrimination of private individuals. While the Court conceded that the removal of the restrictions would not necessarily have eliminated the prejudices of some students, it was still inappropriate for the state, through institutional officials and the weight that their actions carried, to have deprived the plaintiff and other students of opportunities afforded to other students.
Rounding out its opinion, the Supreme Court ruled that officials at the University of Oklahoma violated the student’s right to equal protection of the law by denying him an education that was equal to that of his peers. The Court thus concluded that the Fourteenth Amendment precluded the enforcement of the Oklahoma statute that required African American students to be treated differently and that because the plaintiff had been admitted to a state-supported school, he had to be treated like every other student, regardless of his race.
Megan L. Rehberg
See also equal protection analysis
Brown v. Board of Education, Topeka, 347 U.S. 483 (1954).
McLaurin v. Oklahoma State Regents for Higher Education, 339 U.S. 637 (1950).
Sweatt v. Painter, 339 U.S. 629 (1950).