Missouri ex rel. Gaines v. Canada
Missouri ex rel. Gaines v. Canada is a pivotal legal case in the history of civil rights in the United States, particularly concerning educational access for African Americans. In the context of segregation, Missouri had no law schools that admitted Black students, offering only limited scholarships for them to attend law schools in other states. Lloyd Gaines, an African American man, challenged this policy after being denied admission to the University of Missouri's law school due to his race. The Supreme Court's ruling in this case, decided by a 6-2 vote, determined that Missouri's approach did not meet the equal protection requirements of the Fourteenth Amendment. The Court found that the state's policy failed to provide African Americans with equal educational opportunities within Missouri. This landmark decision suggested that segregated educational facilities would only be acceptable if they could ensure near-absolute equality, setting a precedent for future cases related to segregation and education. The case laid the groundwork for further challenges to discriminatory practices, contributing significantly to the broader civil rights movement.
Missouri ex rel. Gaines v. Canada
Date: December 12, 1938
Citation: 305 U.S. 337
Issue: Separate but equal doctrine
Significance: Chipping away at the separate but equal doctrine, the Supreme Court ruled that states must provide equal opportunities for legal education within the borders of the state.
The state of Missouri, like other southern states, had no law schools that admitted African Americans. The state claimed to provide separate but equal opportunity by offering a few scholarships to help pay expenses for African Americans to attend law schools in other states. The state also indicated that it would begin a separate law school for African Americans if there were sufficient demand. Lloyd Gaines, an African American resident of the state, sued the registrar of the University of Missouri, S. W. Canada, after being denied admission to the law school because of his race.
By a 6-2 vote, the Supreme Court held that Missouri’s scholarship policy fell short of the demands of the equal protection clause of the Fourteenth Amendment. Chief Justice Charles Evans Hughes, for the majority, wrote that the policy denied African Americans the equal right to obtain a legal education without leaving the state. Hughes noted that the state, if it wished, might fulfill its constitutional obligations “by furnishing equal facilities in separate schools.” The Gaines decision suggested that the Court would henceforth disapprove of segregated schools unless they met standards of near-absolute equality.
In Sweatt v. Painter (1950), the Court built upon Gaines when it held that an all-black law school in Texas was inadequate because it did not provide “substantial equality” of educational opportunities available to white persons.