Runyon v. McCrary | |
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Argued April 26, 1976 Decided June 25, 1976 | |
Full case name | Runyon, et ux., dba Bobbe's School v. McCrary, et al. |
Citations | 427 U.S. 160 ( more ) 96 S. Ct. 2586, 49 L. Ed. 2d 415, 1976 U.S. LEXIS 7 |
Holding | |
Federal law prohibits private schools from discriminating on the basis of race. | |
Court membership | |
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Case opinions | |
Majority | Stewart, joined by Burger, Brennan, Marshall, Blackmun, Powell, Stevens |
Concurrence | Powell |
Concurrence | Stevens |
Dissent | White, joined by Rehnquist |
Laws applied | |
Civil Rights Act of 1866 |
This article is part of a series on |
Education in the United States |
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Summary |
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Runyon v. McCrary, 427 U.S. 160 (1976), was a landmark case by the United States Supreme Court, which ruled that private schools that discriminate on the basis of race or establish racial segregation are in violation of federal law. [1] Whereas Brown v. Board of Education barred segregation by public schools, this case barred segregation in private schools. This decision is built on Jones v. Alfred H. Mayer Co. another landmark civil rights case that affirmed the federal government's ability to penalize racist acts by private actors.
Dissenting Justices Byron White and William Rehnquist argued that the legislative history of 42 U.S.C. § 1981 (popularly known as the Civil Rights Act of 1866) indicated that the Act was not designed to prohibit private racial discrimination, but only state-sponsored racial discrimination (as had been held in the Civil Rights Cases of 1883).
Two African American students filed suit believing that they were denied admission to private schools in Virginia based on their race. Michael McCrary and Colin Gonzales were denied admission to Bobbe's School; Gonzales was also denied admission to Fairfax-Brewster School. A class action was filed against the schools by the parents of both students. A federal district court ruled for McCrary and Gonzales, finding that the school's admission policies were racially discriminatory. The United States Court of Appeals affirmed the decision.
Russell and Katheryne Runyon d.b.a Bobbe's School and Fairfax-Brewster School were schools in Northern Virginia. Bobbe's was founded in 1958 as a segregation academy with five European-American students. By 1972 it had grown to 200, but had never admitted a black child. [1] Fairfax-Brewster had a similar history from 1955.
In a 7–2 decision Justice Stewart wrote the opinion for the Court. The Court determined that the Ku Klux Klan Act prohibited the racially discriminatory policies of the schools. While the schools were private, Jones v. Alfred H. Mayer Co. held that the Ku Klux Klan Act applied to "purely private acts of racial discrimination". Further, Stewart wrote that the school's admission policies were "classical violation[s] of Section 1981". The Court acknowledged that parents had the right to send their children to schools that "promote the belief [of] racial segregation", but that neither parents' nor students' freedom of association was violated by the application of 42 U.S.C. §1981. [3] The Court cited Pierce v. Society of Sisters and the right of the State "reasonably to regulate all schools" to further justify the decision. [4]
Justice White was concerned about the potential far-reaching impact of holding private racial discrimination illegal, which, if taken to its logical conclusion, might ban many varied forms of voluntary self-segregation, including social and advocacy groups that limited their membership to blacks. [5]
Runyon's holding was severely limited by Patterson v. McLean Credit Union, [6] which narrowly construed Section 1981 as not applying to any discrimination occurring after the making of a contract, such as racial harassment on the job (although the Patterson majority expressly claimed that they were not overruling Runyon). In turn, Patterson was legislatively overruled by the Civil Rights Act of 1991.
The Voting Rights Act of 1965 is a landmark piece of federal legislation in the United States that prohibits racial discrimination in voting. It was signed into law by President Lyndon B. Johnson during the height of the civil rights movement on August 6, 1965, and Congress later amended the Act five times to expand its protections. Designed to enforce the voting rights protected by the Fourteenth and Fifteenth Amendments to the United States Constitution, the Act sought to secure the right to vote for racial minorities throughout the country, especially in the South. According to the U.S. Department of Justice, the Act is considered to be the most effective piece of federal civil rights legislation ever enacted in the country. The National Archives and Records Administration stated: "The Voting Rights Act of 1965 was the most significant statutory change in the relationship between the federal and state governments in the area of voting since the Reconstruction period following the Civil War".
Separate but equal was a legal doctrine in United States constitutional law, according to which racial segregation did not necessarily violate the Fourteenth Amendment to the United States Constitution, which nominally guaranteed "equal protection" under the law to all people. Under the doctrine, as long as the facilities provided to each race were equal, state and local governments could require that services, facilities, public accommodations, housing, medical care, education, employment, and transportation be segregated by race, which was already the case throughout the states of the former Confederacy. The phrase was derived from a Louisiana law of 1890, although the law actually used the phrase "equal but separate".
The Civil Rights Act of 1866 was the first United States federal law to define citizenship and affirm that all citizens are equally protected by the law. It was mainly intended, in the wake of the American Civil War, to protect the civil rights of persons of African descent born in or brought to the United States.
The Equal Protection Clause is part of the first section of the Fourteenth Amendment to the United States Constitution. The clause, which took effect in 1868, provides "nor shall any State ... deny to any person within its jurisdiction the equal protection of the laws." It mandates that individuals in similar situations be treated equally by the law.
The NAACP Legal Defense and Educational Fund, Inc. is an American civil rights organization and law firm based in New York City.
The Enforcement Acts were three bills that were passed by the United States Congress between 1870 and 1871. They were criminal codes that protected African Americans’ right to vote, to hold office, to serve on juries, and receive equal protection of laws. Passed under the presidency of Ulysses S. Grant, the laws also allowed the federal government to intervene when states did not act to protect these rights. The acts passed following the ratification of the Fourteenth Amendment to the US Constitution, which gave full citizenship to anyone born in the United States or freed slaves, and the Fifteenth Amendment, which banned racial discrimination in voting.
The Civil Rights Act of 1991 is a United States labor law, passed in response to United States Supreme Court decisions that limited the rights of employees who had sued their employers for discrimination. The Act represented the first effort since the passage of the Civil Rights Act of 1964 to modify some of the basic procedural and substantive rights provided by federal law in employment discrimination cases. It provided the right to trial by jury on discrimination claims and introduced the possibility of emotional distress damages and limited the amount that a jury could award. It added provisions to Title VII of the Civil Rights Act of 1964 protections expanding the rights of women to sue and collect compensatory and punitive damages for sexual discrimination or harassment. U.S. President George H. W. Bush had used his veto against the more comprehensive Civil Rights Act of 1990. He feared racial quotas would be imposed but later approved the 1991 version of the bill.
The Enforcement Act of 1871, also known as the Ku Klux Klan Act, Third Enforcement Act, Third Ku Klux Klan Act, Civil Rights Act of 1871, or Force Act of 1871, is an Act of the United States Congress that was intended to combat the paramilitary vigilantism of the Ku Klux Klan. The act made certain acts committed by private persons federal offenses including conspiring to deprive citizens of their rights to hold office, serve on juries, or enjoy the equal protection of law. The Act authorized the President to deploy federal troops to counter the Klan and to suspend the writ of habeas corpus to make arrests without charge.
The Montgomery Academy is a non-sectarian independent day school located in Montgomery, Alabama. The Lower School accommodates kindergarten through fourth grade and the Upper School fifth through twelfth. The school's current total enrollment is just under 900, of which approximately 300 are in the Upper School. Montgomery Academy was founded in 1959 as a segregation academy.
Segregation academies are private schools in the Southern United States that were founded in the mid-20th century by white parents to avoid having their children attend desegregated public schools. They were founded between 1954, when the U.S. Supreme Court ruled that segregated public schools were unconstitutional, and 1976, when the court ruled similarly about private schools.
Cape Fear Academy is a private, coeducational PK3–12 school in Wilmington, North Carolina, that was established on September 11, 1967, as a segregation academy. It was named for Cape Fear Military Academy, an independent school for boys in Wilmington that operated from 1868 until 1916. The present school's first class graduated in 1971.
Reitman v. Mulkey, 387 U.S. 369 (1967), was a United States Supreme Court decision that set an important legal precedent that held that a state could not authorize invidious discrimination by private landlords without entangling itself in the ensuing discriminatory private decisions. Thus, the state constitutional amendment by referendum purporting to authorize landlord freedom was unconstitutional.
Coit v. Green, 404 U.S. 997 (1971), was a case in which the United States Supreme Court affirmed a decision that a private school which practiced racial discrimination could not be eligible for a tax exemption.
Lemuel Augustus Penn was the Assistant Superintendent of Washington, D.C. public schools, a decorated veteran of World War II and a Lieutenant Colonel in the United States Army Reserve who was murdered by members of the Ku Klux Klan, nine days after the passage of the Civil Rights Act of 1964.
Housing discrimination in the United States refers to the historical and current barriers, policies, and biases that prevent equitable access to housing. Housing discrimination became more pronounced after the abolition of slavery in 1865, typically as part of Jim Crow laws that enforced racial segregation. The federal government didn't begin to take action against these laws until 1917, when the Supreme Court struck down ordinances prohibiting African-Americans from occupying or owning buildings in majority-white neighborhoods in Buchanan v. Warley. However, the federal government as well as local governments continued to be directly responsible for housing discrimination through redlining and race-restricted covenants until the Civil Rights Act of 1968.
School segregation in the United States was the segregation of students in educational facilities based on their race and ethnicity. While not prohibited from having or attending schools, various minorities were barred from most schools that admitted white students. Segregation was enforced legally in the U.S. states, primarily in the Southern United States, although segregation could occur in informal settings or through social expectations and norms. Segregation laws were met with resistance by Civil Rights activists and began to be challenged in 1954 by cases brought before the U.S. Supreme Court. Segregation continued longstanding exclusionary policies in much of the Southern United States after the Civil War. Jim Crow laws codified segregation. These laws were influenced by the history of slavery and discrimination in the US. Secondary schools for African Americans in the South were called training schools instead of high schools in order to appease racist whites and focused on vocational education. School integration in the United States took place at different times in different areas and often met resistance. After the ruling of Brown v. Board of Education, which banned segregated school laws, school segregation took de facto form. School segregation declined rapidly during the late 1960s and early 1970s as the government became strict on schools' plans to combat segregation more effectively as a result of Green v. County School Board of New Kent County. Voluntary segregation by income appears to have increased since 1990. Racial segregation has either increased or stayed constant since 1990, depending on which definition of segregation is used. In general, definitions based on the amount of interaction between black and white students show increased racial segregation, while definitions based on the proportion of black and white students in different schools show racial segregation remaining approximately constant.
The Farifax-Brewster School was a private K-6 elementary school in Bailey's Crossroads, Virginia. The school was founded in 1954 by Stuart A. Reiss and Robert S. Reiss, with Robert's wife Olga also serving in an administrative role. The school began operating in 1955 with an average enrollment of 21 students. The Fairfax-Brewster School opened a summer camp the following year, also serving students in Kindergarten through 6th grade. By 1962, 21 students attended the summer camp.
Central Alabama Academy was a segregation academy in Montgomery, Alabama in 1970. The school opened at 3152 Debby Drive, Montgomery and subsequently moved to 6010 Vaughn Road, Montgomery. The site was taken over by Saint James School. The school adopted the name of a Methodist institution in Birmingham of the same name that existed 1866-1923. There is no evidence that this school was associated with the Methodist Church.
Coffey v. State Educational Finance Commission (1969) was a federal case that addressed state support of segregation academies in Mississippi. More broadly, it established the standards the Internal Revenue Service would use to determine the tax-exempt status of private schools based on their segregation policies.