Analysis: Mendez et al. v. Westminster School District of Orange County et al.

Date: February 18, 1946

Author: Paul John McCormick

Genre: court case

Summary Overview

Gonzalo Méndez, a Mexican native, became a naturalized citizen of the United States in 1943. Méndez was a successful vegetable farmer and had three children who were fluent in both Spanish and English. When the Méndez family registered their children for school in their primarily Anglo-American school district in California's Orange County, however, they were told that they would need to attend the Hoover School in another district. This school's pupils were all of Mexican descent. Méndez argued for his children to attend the school in their district but made no headway with the school administration, the local school board, or the county school board.

In the course of pursuing his cause, Méndez and his lawyer discovered that other school districts were also segregating their Mexican and Latin American students. In March 1945, Méndez and four other plaintiffs filed suit in a United States district court against four Orange County school districts and their superintendents and school boards. They argued that segregating children of Mexican or Latin American ancestry was a violation of the Fourteenth Amendment promise of equal protection of law. Méndez and his fellow plaintiffs won the case, and on February 18, 1946, the segregation of Mexican American students was declared a violation of the Fourteenth Amendment.

Defining Moment

Mexican Americans were considered second-class citizens in California as early as 1848, when the territory that became the state was won from Mexico by the United States. Racial theories were applied to non-Anglo-American populations, including Mexican Americans and other Latino citizens in the United States. Specific laws excluded African American and Asian American citizens from access to equal education on the basis of race, but Mexican Americans, who were considered White, if culturally inferior, were left out of overt legal discrimination. As farming boomed in the early twentieth century, however, the need for labor led to increased immigration, particularly from Mexico, and the Mexican American population in California exploded. Immigration from Mexico was not restricted until a country-of-origin quota system was implemented in the early 1920s, and hundreds of thousands of Mexicans flooded into California during and after the Mexican Revolution (1910–20). Californian communities responded with growing discrimination against these immigrants and their families, limiting access to employment and education. As Mexican American students were segregated, the quality of the education available to them declined. Teachers in these schools were paid less, the facilities were often in poor repair and overcrowded, and little effort was made to prepare these children for higher education. Aptitude and intelligence tests were administered irregularly or not at all.

Mexican Americans fought with distinction during World War II, and like many other underprivileged groups in the United States, they expected that their service would result in greater opportunities at home. The Méndez family moved into a predominantly Anglo-American school district in Orange County in 1945 and expected to be able to register their three children for public school. When they were denied admission, Gonzalo Méndez appealed to the local and county school boards. When this had no effect, Méndez and four other families filed a class action lawsuit on behalf of the five thousand Mexican Americans living in four Orange County school districts.

The Mendez v. Westminster suit was tricky, however. In Plessy v. Ferguson in 1896, racial discrimination in education had been supported by law. The Mendez v. Westminster case argued that Mexican American students were not racially separate from other students, but were discriminated against based on their national origin. The schools argued that the language barrier necessitated that Spanish-speaking students attend separate schools until they had mastered English. This, of course, would not have applied to the Méndez children, who spoke proficient English, and the lawyers for the plaintiff argued that no reliable language test was given, and the only real basis for segregation was national origin. On February 18, 1946, US district court judge Paul McCormick agreed with Méndez that segregation based on national origin was unconstitutional, as it violated the equal protection of law provision of the Fourteenth Amendment.

Author Biography

Paul John McCormick was born in New York City on April 23, 1879. He attended St. Ignatius College in San Francisco and, after passing the California bar in 1900, went into private practice. He served as deputy district attorney of Los Angeles County beginning in 1905. From 1910 until 1921, he was a judge in the California Superior Court, County of Los Angeles, and then an associate justice of the California Appellate Court until 1924. That year McCormick was appointed to a seat on the United States District Court for the Southern District of California. He became the chief justice of this court in 1948 and held that position until 1951. McCormick died on December 2, 1960.

Document Analysis

This court ruling begins with a summary of the case. The five families involved, “all of Mexican or Latin descent,” filed a suit against four school systems, all in Orange County, California, arguing that the segregation of “persons of Mexican or Latin descent or extraction” in elementary schools denied these children equal protection of the law guaranteed by the Fourteenth Amendment.

In particular, for an unspecified period, children of Mexican and Latin American descent had been barred from attending certain schools in their districts, which had been restricted to “children purportedly known as White or Anglo-Saxon children,” and were forced to attend schools with only Mexican or Latin American students. Though this document does not specifically address this, part of the impetus for this case was the fact that Gonzalo Méndez's nieces, Alice and Virginia Vidaurri, were allowed to register in the school system, as they had a last name that was not identifiable as Mexican, and they were light-skinned. This led to a very subjective, selective enforcement of this segregation, based on skin tone, name, and appearance, rather than an objective language or aptitude test that would have identified the kind of special educational needs of students for whom English was a new language. In fact, since the Méndez children were no more Mexican than their cousins and spoke fluent English, the argument made by the schools that the language barrier necessitated separate schools was patently false. The plaintiffs demanded that segregated schools be ended at once.

The court ruling was subject to the criticism that such educational decisions were at the discretion of the local and county school boards and the state, so the court took great pains to establish its jurisdiction over the case. In answer to the charge that educational segregation was a local issue and, therefore, should be subject to state courts, the court argued that since the state set the standards for education and oversaw local boards, education was a state, rather than local, issue. While the court agreed that education was a state issue, “it is not so absolutely or exclusively.” If the rights of the citizens, guaranteed to all by the “supreme law of the land,” were violated in any state, federal courts has a right to intervene. Certainly, the court argued, an alleged violation of the Constitution qualified. The court ruling first laid out the ways that segregation based on national origin was a violation of California's own constitution, stating, “We perceive in the laws relating to the public educational system in the State of California a clear purpose to avoid and forbid distinctions among pupils.”

The court decision picked apart the argument that a language barrier was a compelling reason to segregate students. Some of the schools named in the suit segregated children through the fifth grade, others as far as eighth grade. If the language barrier was so great, the court argued, why the inconsistency? The segregation of Spanish-speaking students also made the acquisition of English more difficult, further affecting the quality of their education. The court declared that providing equal, or in some cases superior, facilities for students of Mexican and Latin American descent was not a compelling reason to deny these students “social equality.” Schools must be open to all children, regardless of ancestry.

Impact

Méndez v. Westminster was the first successful court challenge to the segregation in schools that was widespread in the United States. Within five years, similar segregation was outlawed in Texas and Arizona. It established an important legal pathway for other cases challenging the “separate but equal” doctrine that supported segregation. In particular, the case paved the way for the Supreme Court's more famous 1954 Brown v. Board of Education of Topeka ruling that overturned legal segregation of schools.

The Méndez case has been remembered through a 2003 documentary, a 2007 commemorative postage stamp, and an educational park in Westminster dedicated in 2022. The El Modena High School library was renamed for one of the plaintiffs, Lorenzo Ramirez, in 2012, and in 2023 Congressman Jimmy Gomez introduced a bill to rename the federal courthouse the Felicitas and Gonzalo Mendez US Courthouse. Sylvia Méndez herself went on to lecture secondary and college students around the US about the case and received the Presidential Medal of Freedom in 2011.

Glossary

Effectuated/effectuating: to make done; effect

evinces: to show clearly; make evident or manifest; prove

gamut: the entire scale or range

inculcation: the act of inculcating or teaching or influencing persistently and repeatedly in order to implant an idea or attitude

peremptorily: leaving no opportunity for denial or refusal; imperious

promulgated: to make known by open declaration; publish

redress: the setting right of what is wrong; relief from wrong or injury

thereof: from or out of that origin or cause; of that

Bibliography and Additional Reading

Aguirre, Fredrick P. “Mendez v. Westminster School District1: How It Affected Brown v. Board of Education.” Journal of Hispanic Higher Education, vol. 4, no. 4, 2005, pp. 321–32.

“Mendez v. Westminster Background.” United States Courts. Administrative Office of the US Courts, Federal Judiciary. Accessed 16 Feb. 2015.

“Setting the Precedent: Mendez, et al. v. Westminster School District of Orange County, et al. and the US Courthouse and Post Office.” National Park Service, 13 Sept. 2023, www.nps.gov/articles/000/setting-the-precedent-mendez-et-al-v-westminster-school-district-of-orange-county-et-al-and-the-us-courthouse-and-post-office.htm. Accessed 26 Feb. 2024.

Strum, Phillipa. Mendez v. Westminster: School Desegregation and Mexican-American Rights. U of Kansas P, 2010.