Caseflicks

Supreme Court of the United States • 1950

Sweatt v. Painter

339 U.S. 629 | 70 S. Ct. 848 | 94 L. Ed. 2d 1114 | 1950 U.S. LEXIS 1809 | 94 L. Ed. 1114

Full access

Unlock the video and quiz

The written brief is free to read below. Subscribe to watch the video explainer and take the quiz.

Create an account Log in

Takeaway

In short, Sweatt held that separate professional schools violate equal protection when they deny Black students not only comparable resources but also the intangible educational and professional advantages of an established white institution.

Background

Heman Marion Sweatt applied to the University of Texas Law School for the February 1946 term. The school rejected him solely because he was Black, as Texas law restricted the University to white students. At that time, Texas operated no law school for Black students.

Sweatt sought a writ of mandamus compelling his admission. The state trial court held that Texas had denied him equal protection by providing legal education to white students but not to Black students. Instead of ordering his admission, however, the court delayed the case for six months so the State could create substantially equal facilities for Black students.

Texas then established a separate law school for Black students. On remand, the trial court concluded that the new school was substantially equivalent to the University of Texas Law School and denied mandamus. The Texas Court of Civil Appeals affirmed, and the Texas Supreme Court denied review. The U.S. Supreme Court granted certiorari.

Issues

Issue #1

Whether Texas's separate law school for Black students provided Sweatt educational opportunities substantially equal to those available at the University of Texas Law School under the Equal Protection Clause of the Fourteenth Amendment.

Holding

No. The separate law school did not provide Sweatt a legal education substantially equal to that available at the University of Texas Law School.

Reasoning

The Court first compared the schools' measurable features. The University of Texas Law School had sixteen full-time and three part-time professors, about 850 students, more than 65,000 library volumes, a law review, moot-court opportunities, scholarships, and Order of the Coif affiliation. The Black law school had a much smaller faculty, student body, and library and lacked comparable courses, specialized opportunities, and institutional resources.

The constitutional comparison could not stop with physical facilities and numerical measures. The University of Texas possessed important but less tangible advantages: the faculty's reputation, the administration's experience, the influence and position of its alumni, its community standing, its traditions, and its prestige. Those features materially contributed to the quality and value of a legal education and could not be duplicated merely by creating a new separate school.

Legal education is also intensely practical and cannot be evaluated in isolation. The separate school excluded students from racial groups comprising 85 percent of Texas's population, including many of the lawyers, judges, jurors, witnesses, and officials with whom Sweatt would later work. Exclusion from this professional and intellectual exchange meant that Sweatt's education was not substantially equal to the education he would receive at the University of Texas.

Issue #2

Whether prior separate-but-equal doctrine, including Plessy v. Ferguson, required the Court to uphold Texas's exclusion of Sweatt from the University of Texas Law School.

Holding

No. Even without reconsidering Plessy itself, Texas failed to furnish Sweatt substantially equal legal education, so the Equal Protection Clause required his admission to the University of Texas Law School.

Reasoning

The Court treated the right at issue as personal and present. Under Missouri ex rel. Gaines v. Canada and Sipuel v. Board of Regents, a State that provides legal education must furnish each qualified applicant educational facilities substantially equal to those it offers students of other races, and it must do so when it provides education to those other students.

Texas could not satisfy that obligation by relying on a future promise of equality or by directing Sweatt to a separate school that was unequal in fact. The lower court's decision to postpone relief while the State created a Black law school did not cure the constitutional deprivation of Sweatt's individual right.

Because the separate school was demonstrably unequal in both tangible resources and indispensable intangible qualities, the Court did not need to decide whether Plessy should be overruled. On the narrower ground presented by Sweatt's individual claim, Texas had to admit him to the University of Texas Law School.