One of the most important Supreme Court decisions of the 20th century, Brown v. Board of Education desegregated schools, reversing the Court’s 1896 decision in Plessy v. Ferguson.
Plessy had established the “separate but equal” principle, which allowed individual states to provide separate public facilities for blacks as long as the facilities were equal to those provided for whites. The court thus decided that Jim Crow laws—state-mandated statutes establishing racial segregation in public accommodations and education—did not violate the Fourteenth Amendment’s Equal Protection Clause. Plessy also declared that using separate facilities carried with it “no badge of inferiority.” Southern states used the ruling to further entrench Jim Crow.
Brown marked the culmination of a decades-long litigation campaign against racial segregation organized by the National Association eor the Advancement oe Colored People (NAACP) and its legal arm, the NAACP Legal Defense and Education Fund. Filing suits in state and federal courts, which challenged Jim Crow, the NAACP’s strategy was to chip away at the Plessy decision. By the early 1950s, the NAACP had secured several major victories against segregation, including Shelley v. Kraemer (1948) in which the Court declared that restrictive covenants were unconstitutional, and Sweatt v. Painter (1950), which rejected segregation in law schools.
After these successful precedents, the NAACP fought segregation in public elementary and secondary schools, filing suits against school boards across the nation. A Kansas suit involved Oliver Brown, a black minister who wanted to enroll his young daughter Linda in a public elementary school located just blocks from his home. The Topeka school board refused since a state segregation law required black children to attend an all-black school located across town. Brown, backed by the NAACP, sought relief. By 1952, the Supreme Court had agreed to hear Brown’s case combined with four others involving segregated public education in Delaware, South Carolina, Virginia, and Washington, D. C.
Led by THURGOOD Marshall, NAACP lawyers argued in Brown that separate schools could never be equal, regardless of the comparative quality of the facilities, and that segregated schools violated the Fourteenth Amendment. They used social scientific evidence to show that segregation socially and psychologically handicapped black children. In a series of studies conducted by psychologists Kenneth and Mamie Clark, northern and southern black children were shown two dolls—one black, one white—and asked which doll they liked. The Clarks found that a preponderance of the black children preferred the white doll. When asked which doll was most like them, many children became upset when they chose the black doll they had rejected. The Clarks concluded that black children, especially those educated under Jim Crow, had internalized a sense of inferiority. These tests and other social science data served as proof that school segregation in itself was damaging. The NAACP lawyers urged the court to consider these deeper negative effects of segregation.
Prominent constitutional lawyer John W. Davis represented the school boards. He argued that the Fourteenth Amendment did not apply to segregation in public schools. Davis also denied that the court had the power to force desegregation in school systems on the basis of controversial sociological evidence.
The court was leaning toward desegregation by mid 1953, but members remained undecided on the question of relief. During this stalemate, Chief Justice Fred Vinson died. He was replaced by Earl Warren, who ended the stalemate by calling for rearguments and suggesting that a separate opinion be handed down regarding relief.
On May 17, 1954, the Supreme Court unanimously struck down Plessy’s separate but equal doctrine, outlawing segregated public schools. In the Court’s opinion, Warren cited social science evidence and wrote that “separate educational facilities are inherently unequal” and were responsible for a “feeling of inferiority” in black children “as to their status in the community that may affect their hearts and minds in a way unlikely ever to be undone.” Therefore, the Court ruled that segregation in public schools denied blacks equal protection as guaranteed under the Fourteenth Amendment. This decision is referred to as Brown I. In 1955, after rearguments, the Court handed down Brown II, which dealt with implementation. In this second decision, the justices set no firm deadlines or guidelines for desegregation. Instead, Brown II equivocally called for communities to desegregate their schools “with all deliberate speed.”
After Brown, school desegregation proceeded slowly and met with resistance. While some communities quickly complied with Brown, many segregationists used violence or other means to prevent integration. In 1957 in Little Rock, Arkansas, Governor Orval Faubus barred nine black students from Central High School. President Dwight D. Eisenhower reluctantly sent federal troops to protect the black students’ rights. Meanwhile, civil rights activists fought for integration in public facilities. Brown did not end the school desegregation battle; enforcement issues were debated in the nation’s courts into the 1970s.
In the wake of declining enrollment, the Monroe Elementary School in Topeka closed in 1975 and was subsequently purchased by the Brown Foundation for Educational Equity, Excellence and Research, which lobbied Congress to preserve the case’s historic role in the struggle for racial equality. In 1992 President George H. W. Bush signed the Brown v. Board of Education National Site Act to create a historic site at the school. Opened on May 17, 2004, the 50th anniversary of the court decision, the school is the only National Park site named after a Supreme Court case and commemorates Brown’s significance as part of the ongoing struggle for equal educational opportunities in the United States.
Further reading: Waldo E. Martin, Jr., ed. Brown v. Board of Education: A Brief History with Documents (New York: Bedford/St. Martin’s, 1998); James T. Patterson, Brown v. Board of Education: A Civil Rights Milestone and Its Troubled Legacy (New York: Oxford University Press, 2001).
—Lori Creed
Bunche, Ralph (1904-1971) diplomat, UN official
Serving his country in a variety of areas, Ralph Bunche was a political scientist, government official, and United Nations official, who won the Nobel Peace Prize in 1950 for mediating the conflict between Israel and Arab countries.
Born in Detroit, Michigan, on August 7, 1904, Bunche was the descendant of both African Americans and Native American Indians. Orphaned at the age of 13, he moved to Los Angeles, California, and into the care of his maternal grandmother. He worked his way through the University of California at Los Angeles and graduated summa cum laude in 1927. During these years, Bunche developed an interest in race relations. He earned a Ph. D. from Harvard in government and international relations in 1934. Following graduation, Bunche became chief assistant from 1938 to 1940 to Gunnar Myrdal, the Swedish sociologist who
Dr. Kwame Nkrumah, prime minister of Ghana (right), chats with United Nations official Ralph Bunche, 1958. (Library of Congress) wrote a study on African Americans titled An American Dilemma.
During World War II, Bunche worked in the Office of Strategic Services as a senior social science analyst and expert on colonial areas and peoples. He then moved to the State Department in 1944, and, in 1946, he joined the Trusteeship Council of the United Nations (UN), an organization he helped establish. As problems developed in the Middle East, Bunche, now a member of the UN Secretariat, flew to Palestine in 1947 and formed the Palestine Implementation Commission to partition Israel and Palestine. As the first Arab-Israeli war broke out following the establishment of the state of Israel, the then acting chief mediator, Count Folke Bernadotte, was assassinated. Bunche took on the position of mediator himself. By negotiating separately with Israel and each Arab country, Bunche exercised extreme patience and diplomatic skills in breaking down resistance to peace and pushing for compromise. Following months of 18- to 20-hour days, an armistice was signed. For his work in mediation, Bunche received the Nobel Peace Prize in 1950, the first black man to do so.
Bunche faced difficulties during the anticommunist crusade of the 1950s. A loyalty investigation, under the authority of Henry Cabot Lodge, the ambassador representing the United States at the United Nations, and executed by the Federal Bureau of Investigation (FBI), began in 1953. Later, the administration of DwiGHT D. Eisenhower created the International Organizations Employees Loyalty Board to continue the investigation. When it came to public attention in May 1954 that Bunche was under investigation, Eisenhower sent Maxwell Rabb, a presidential assistant, to warn Bunche and offer support. Bunche, however, chose to stand alone at the hearing, as two ex-communist witnesses who had worked for the Justice Department accused him of having communist connections. After two days of testimony, Bunche was unanimously cleared of all charges.
Serving as deputy secretary general of the United Nations, Bunche held the highest position by an American in the organization. Much of his work in the 1950s involved settling continuing disputes in the Middle East. In the 1960s, he turned his attention to Aerica, trying to end violence and make peace in the Congo.
Bunche continued to serve both the United Nations and the United States throughout the 1960s. He flew to Yemen in 1963 to try to prevent a possible civil war and to Cyprus in 1964 to direct troops for peacekeeping. He was also a participant in the Civil Rights movement, on the Board of Directors of the National Association eor the Advancement oe Colored People (NAACP), and spoke at the 1963 March on Washington.
Further reading: Jean G. Cornell Ralph Bunche: Champion of Peace (Champaign, Ill.: Garrard Publishing Company, 1976).
—Katherine R. Yarosh
World History
