Caseflicks

Supreme Court of the United States • 1950

McLaurin v. Oklahoma State Regents for Higher Education

339 U.S. 637 | 70 S. Ct. 851 | 94 L. Ed. 2d 1149 | 1950 U.S. LEXIS 1810 | 94 L. Ed. 1149

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Takeaway

In short, this case holds that a State cannot satisfy equal protection by admitting a Black graduate student while using race-based rules that isolate him and impair his ability to learn.

Background

George W. McLaurin, a Black Oklahoma resident who already held a master’s degree, applied to the University of Oklahoma Graduate School to pursue a doctorate in education. Oklahoma law then barred racially integrated schooling, and the University denied his application solely because of his race.

McLaurin sued for injunctive relief under the Fourteenth Amendment. A three-judge federal district court, relying on Missouri ex rel. Gaines v. Canada and Sipuel v. Board of Regents, held that Oklahoma had to provide McLaurin the graduate education it provided to students of other races. The court declared the exclusionary statutes unconstitutional insofar as they denied him admission, but initially denied an injunction while retaining jurisdiction.

Oklahoma then amended its laws to allow Black students into white institutions when the desired degree program was unavailable at Black schools, but required instruction on a segregated basis. The University admitted McLaurin subject to segregation rules. He was required to sit separately in class, use a designated library desk, and eat separately in the cafeteria. Although the University later relaxed some of these measures, it continued assigning him separate seating or tables. The district court held that this treatment did not violate equal protection, and McLaurin appealed.

Issues

Issue #1

Whether a state that admits a Black student to a state-supported graduate school may nevertheless require him to use its classroom, library, and cafeteria facilities separately from white students solely because of his race.

Holding

No. Once the State admits a student to a state-supported graduate school, the Fourteenth Amendment requires the State to give that student the same treatment it gives students of other races.

Reasoning

The Court limited its decision to the treatment of a student whom Oklahoma had already admitted to its graduate program. The relevant question was not merely whether McLaurin had access to the University’s buildings and courses, but whether the State afforded him equal treatment within the educational program it provided.

Oklahoma’s restrictions formally placed McLaurin in the same classroom, library, and cafeteria as white students, but required him to sit and eat apart from them. Those distinctions were imposed by the State to preserve segregation and therefore marked him as separate from the other graduate students.

The Court concluded that enforced separation impaired McLaurin’s ability to obtain an effective graduate education. Graduate study depends substantially on studying with peers, participating in discussions, exchanging views, and developing professional relationships. By inhibiting those forms of intellectual interaction, the restrictions made his educational opportunity unequal.

The inequality was especially serious because McLaurin sought an advanced degree in education and was preparing to become a leader and teacher of others. A diminished graduate education would affect not only him, but also the students and communities that would later be influenced by his work.

The possibility that fellow students might voluntarily avoid associating with McLaurin did not justify state-imposed separation. There is a constitutional difference between private choices to associate or not associate and official restrictions that prohibit intellectual commingling. Without the State’s barrier, McLaurin would at least have the opportunity to gain acceptance from his classmates on his own merits.

Because the State’s race-based restrictions produced unequal educational conditions, they denied McLaurin his personal and present right to equal protection. The Fourteenth Amendment therefore precluded the differential treatment Oklahoma imposed after admitting him.