Runyon v. McCrary
Runyon v. McCrary is a significant Supreme Court case that addresses issues of racial discrimination in education. Originating from a lawsuit filed by African American parents in Virginia, the case challenged the refusal of private commercial schools to admit their children based on race. The Supreme Court ruled by a 7-2 majority that the 1866 Civil Rights Act prohibited private racial discrimination, affirming that the right to contract includes the right to access educational opportunities without racial barriers. The ruling clarified that while parents have the right to choose schools that align with their beliefs, this does not extend to practices that exclude racial minorities. The decision emphasized the importance of combating segregation and upheld the premise that such exclusion is not a protected form of free association. Although subsequent decisions, like Patterson v. McLean Credit Union, limited the ruling's scope, the Civil Rights Law of 1991 reinstated its broader interpretation, reflecting ongoing efforts to ensure equal access to education regardless of race. This case remains a pivotal moment in the ongoing dialogue about civil rights and educational equality in the United States.
Runyon v. McCrary
Date: June 25, 1976
Citation: 427 U.S. 160
Issue: Race discrimination
Significance: The Supreme Court interpreted the Civil Rights Act of 1866 as prohibiting private nonreligious schools from discriminating on the basis of race.
In Jones v. Alfred H. Mayer Co. (1968), the Supreme Court held that the 1866 Civil Rights Law outlawed private racial discrimination and that the law was valid under the Thirteenth Amendment. A key element of the law was its broad right-to-contract provision in Title XLII. Based on this provision, African American parents in Virginia brought suit against private commercial schools that had refused to admit their children.
By a 7-2 vote, the Court ruled in favor of the plaintiffs and also held that forbidding segregation in the schools did not violate the white parents’ right to free association. Writing for the majority, Justice Potter Stewart conceded that parents have a First Amendment right “to send their children to educational institutions that promote the belief that racial discrimination is desirable” but stated that “it does not follow that the practice of excluding racial minorities from such institutions is also protected by the same principle.” Two justices dissented on the grounds that Jones had been wrongly decided. Although the Court greatly restricted Runyon’s scope in Patterson v. McLean Credit Union (1989), the Civil Rights Law of 1991 reinstated Runyon’s broad interpretation of Title XLII.