| Missouri ex rel. Gaines v. Canada | |
|---|---|
 | |
| Argued November 9, 1938 Decided December 12, 1938 | |
| Full case name | State of Missouri ex rel. Gaines v. Canada, Registrar of the University of Missouri, et al. |
| Citations | 305U.S.337 (more) 59 S. Ct. 232; 83L. Ed. 208; 1938U.S. LEXIS 440 |
| Case history | |
| Prior | TheCircuit Court denied the writ. TheMissouri Supreme Court upheld the judgment against Gaines, 113S.W.2d 783 (Mo. 1937);cert. granted,305 U.S. 580 (1938). |
| Subsequent | Rehearing denied,305 U.S. 676 (1939); remanded, 131 S.W.2d 217 (Mo. 1939). |
| Holding | |
| States that provide only one educational institution must allow blacks and whites to attend if there is no separate school for blacks. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Hughes, joined by Brandeis, Stone, Roberts, Black, Reed |
| Dissent | McReynolds, joined by Butler |
| Laws applied | |
| U.S. Const. amend. XIV | |
Missouriex rel. Gaines v. Canada, 305 U.S. 337 (1938), was aUnited States Supreme Court decision holding thatstates which provided aschool to White students had to provide in-state education to Black students as well. States could satisfy this requirement by allowing Black and White students to attend the same school or creating a second school for Black students.[1]
The Registrar at the Law School of theUniversity of Missouri,Silas Woodson Canada, refused admission toLloyd Gaines because he was black.[2] At the time, Black students could attend no law school specifically in the state. Gaines cited that the refusal violated theFourteenth Amendment. The State of Missouri had offered to pay for Gaines'stuition at an adjacent state's law school, which he turned down.
Gaines, assisted by theNAACP, sued the all-white university in 1935. The issue was whether Missouri violated theEqual Protection Clause of the Fourteenth Amendment by affording White people, not Black people, the ability to attend law school within the state.
The initial trial started inColumbia, Missouri in Boone County.[citation needed]
Writing for the majority, Chief JusticeCharles Evans Hughes held that when the state provides legal training, it must provide it to every qualified person to satisfy equal protection. It can neither send them to other states, nor condition that training for one group of people, such as Black people, on levels of demand from that group. Key to the court's conclusion was that there was no provision for legal education of Black people in Missouri so Missouri law guaranteeing equal protection applied. Sending Gaines to another state would have been irrelevant.
JusticeJames C. McReynolds's dissent emphasized a body of case law, with sweeping statements about state control of education before suggesting the possibility that despite the majority opinion, Missouri could still deny Gaines admission.
The decision did not quite strike downseparate but equal facilities, upheld inPlessy v. Ferguson (1896). Instead, it provided that if there was only one school, students of all races could be admitted. The decision struck down segregation by exclusion if the government provided just one school, making the decision in this case a precursor toBrown v. Board of Education (1954).
This marked the beginning of the Supreme Court's reconsideration ofPlessy. The Supreme Court did not overturnPlessy v. Ferguson or violate the "separate but equal" precedents, but began to concede the difficulty and near-impossibility of a state maintaining segregated Black and White institutions that could never be truly equal. This case helped forge the legal framework forBrown v. Board of Education, which banned segregation in public schools.
Despite the initial victory claimed by theNAACP, after the Supreme Court had ruled in Gaines' favor and ordered the Missouri Supreme Court to reconsider the case, Gaines wasnowhere to be found. When the University of Missouri soon after moved to dismiss the case, the NAACP did not oppose the motion.
Works related toMissouri ex rel. Gaines v. Canada at Wikisource
