McLaurin v. Oklahoma State Regents for Higher Education

McLaurin v. Oklahoma State Regents for Higher Education, legal case in which the U.S. Supreme Court ruled unanimously (9–0), on June 5, 1950, that racial segregation within the facilities and institutions of colleges and universities is inconsistent with the equal protection clause of the Fourteenth Amendment. In this ruling and its companion case, Sweatt v. Painter, decided on the same day, the Supreme Court held that African American students must receive the same treatment as all other students in the realm of higher education.

Facts of the case

The litigation in McLaurin began to take shape when George W. McLaurin, an African American student with a master’s degree, applied for admission to the University of Oklahoma in pursuit of a doctorate in education but was denied entry solely because of his race. At the time, an Oklahoma law made it a misdemeanor to operate, teach at, or attend an educational institution that admitted both white and black students. The student filed a complaint for injunctive relief, claiming that the statute was unconstitutional because it deprived him of equal protection of the laws.

A three-judge federal trial court determined that officials in Oklahoma had a constitutional duty to provide the plaintiff with the education he wanted as soon as they offered the same to students of any other race. Although the court declared that the statute allowing officials to deny the student admission to the program was null and void, it refused to grant his request for an injunction, assuming that officials would follow the constitutional mandate in its order. Even so, the court retained jurisdiction of the case in order to provide the student with equal protection of the laws with regard to his education.

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In response, legislators in Oklahoma amended the statute, permitting African Americans to be admitted to educational institutions provided that the instruction the institutions provided was “upon a segregated basis.” The student was then admitted to the graduate school of the University of Oklahoma, a state-funded institution.

As a result of the amended Oklahoma law, the plaintiff was assigned to sit in a row of classroom seats reserved for African American students, had to sit at an assigned table in the library, and, while he was allowed to eat in the cafeteria, he had a designated table.

During the time between the student’s filing of his appeal and the Supreme Court’s having conducted oral arguments, university officials modified their treatment of the plaintiff. The sign that hung around the student’s sites in the classroom stating “Reserved for Colored” was removed, and he was assigned to a table on the main floor of the library; his previous table was on the mezzanine level.

The Supreme Court’s ruling

On appeal, the Supreme Court focused on the question of whether officials could treat a student at a state university differently from other students based solely on his race. In a unanimous decision authored by Chief Justice Fred M. Vinson, the Supreme Court reversed the lower court’s decision. The Supreme Court reasoned that, under the Fourteenth Amendment’s equal protection clause, state officials had the legal duty to treat the plaintiff in the same manner as students of other races.

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Using sweeping language, the Supreme Court acknowledged that, because American society was changing, discrimination based on race had no place in education. In addition, the court ruled that, insofar as the restrictions that officials imposed on the student impaired and inhibited his ability to study and to engage in discussions and debates with other students as well as faculty, this treatment had a detrimental impact on his overall educational experience.

In its defense, the state of Oklahoma argued that the restrictions that officials had imposed on African American students were nominal, because the facilities had been made available to all students and the rooms assigned to the plaintiff had no disadvantages when compared with those used by other students. The court summarily dismissed this argument, noting that the treatment set the plaintiff apart from other students, because he was still restricted as to where he could sit. In fact, as the court noted, the restrictions were designed to comply with the state statute that had required officials in institutions of higher education to treat students differently based on their races. As a result, the court pointed out, the plaintiff was held back in pursuit of his education, because he was unable to debate and discuss his ideas with other students and faculty, with the result that his ability to learn his chosen profession, teaching, was hampered.

The Supreme Court also held that officials at the University of Oklahoma had violated the plaintiff’s right to equal protection of the laws by denying him an education that was equal to that of his peers. The court thus concluded that the Fourteenth Amendment precluded the enforcement of the Oklahoma statute that required African American students to be treated differently from other students.