Bolling v. Sharpe
Bolling v. Sharpe was a landmark Supreme Court decision concerning school segregation in Washington, D.C., announced concurrently with the more widely known Brown v. Board of Education case in 1954. This case was significant as it addressed the issue of racial segregation in public schools within the context of the federal government, specifically noting that the equal protection clause of the Fourteenth Amendment did not apply to congressional actions. Chief Justice Earl Warren articulated that segregation in education imposed an undue burden on African American children, which constituted an arbitrary deprivation of liberty under the Fifth Amendment's substantive due process interpretation.
Warren's ruling emphasized that the principles of equal protection should extend to both federal and state actions, establishing a standard that held the federal government accountable in similar ways to the states regarding civil rights. The decision also drew parallels to previous Japanese American relocation cases, reinforcing the idea that the Court acknowledged an equal protection component inherent within due process rights. Bolling v. Sharpe thus played a vital role in the broader movement towards desegregation and civil rights, highlighting the complexities of legal interpretations of equality and liberty in the context of American education.
Bolling v. Sharpe
Date: May 17, 1954
Citation: 347 U.S. 479
Issues: Segregation; substantive due process
Significance: The Supreme Court unanimously held that de jure segregation by the federal government violated the due process clause of the Fifth Amendment.
The Bolling v. Sharpe decision dealt with school segregation in Washington, D.C., and was announced the same day as Brown v. Board of Education (1954). The equal protection clause of the Fourteenth Amendment did not apply to acts of Congress, so the two cases had to be considered separately. Speaking for the Supreme Court, Chief Justice Earl Warren implicitly used a substantive due process interpretation of the Fifth Amendment. He stated that because segregation in education was not reasonably related to a proper governmental function, it imposed a burden on African American children that constituted “an arbitrary deprivation of their liberty.” Ironically, Warren referred to the Japanese American relocation cases, in which the Court’s opinions had recognized an “equal protection component” in the concept of due process. Bolling established that the federal government and the states are usually accountable to the same standards in equal protection cases.
