Sweatt v. Painter

Last updated

Sweatt v. Painter, et al.
Seal of the United States Supreme Court.svg
Argued April 4, 1950
Decided June 5, 1950
Full case nameHeman Marion Sweatt v. Theophilus Shickel Painter
Citations339 U.S. 629 ( more )
70 S. Ct. 848; 94 L. Ed. 1114; 1950 U.S. LEXIS 1809
Case history
PriorCert. to the Supreme Court of Texas
Holding
Segregation as applied to the admissions processes for law school in the United States violates Equal Protection Clause of the Fourteenth Amendment, because separate facilities in legal education are inherently unequal. Texas Supreme Court reversed.
Court membership
Chief Justice
Fred M. Vinson
Associate Justices
Hugo Black  · Stanley F. Reed
Felix Frankfurter  · William O. Douglas
Robert H. Jackson  · Harold H. Burton
Tom C. Clark  · Sherman Minton
Case opinion
MajorityVinson, joined by unanimous

Sweatt v. Painter, 339 U.S. 629 (1950), was a U.S. Supreme Court case that successfully challenged the "separate but equal" doctrine of racial segregation established by the 1896 case Plessy v. Ferguson . The case was influential in the landmark case of Brown v. Board of Education four years later. [1]

Contents

The case involved a black man, Heman Marion Sweatt, who was refused admission to the School of Law of the University of Texas, whose president was Theophilus Painter, on the grounds that the Texas State Constitution prohibited integrated education. [2] The Supreme Court ruled in favor of law student Sweatt, reasoning that the state's racially separate law school was in fact unequal. Nonetheless, the Court limited its ruling in finding that it was not [yet] necessary to

reach [Sweatt]'s contention that Plessy v. Ferguson should be reexamined in the light of contemporary knowledge respecting the purposes of the Fourteenth Amendment and the effects of racial segregation. [2]

The decision was delivered on the same day as another case involving similar issues, McLaurin v. Oklahoma State Regents, also decided in favor of integrated graduate education. [3]

Procedural history

Heman Sweatt was originally refused admission to the University of Texas Law School in 1946, solely on the grounds that he was black. [4] Texas' 126th district court in Travis County, Texas, instead of granting the plaintiff a writ of mandamus , continued the case for six months in 1946 and 1947. [5] This allowed the state time to create a law school only for black students, which it established in Houston rather than in Austin. [6] The 'separate' law school and the college became the Thurgood Marshall School of Law at Texas Southern University. [a]

The Dean of the Law School at the time was Charles T. McCormick. He wanted a separate law school for black students. [7]

Texas Attorney General at the time was Price Daniel who advocated fiercely for racial segregation.

The trial court decision was affirmed by the Court of Civil Appeals and the Texas Supreme Court denied writ of error on further appeal. Sweatt and the NAACP next went to the federal courts, and the case ultimately reached the U.S. Supreme Court. Robert L. Carter and Thurgood Marshall presented Sweatt's case. [2]

U.S. Supreme Court

The Supreme Court reversed the lower court decision, saying that the separate school failed to qualify, both because of quantitative differences in facilities and experiential factors, such as its isolation from most of the future lawyers with whom its graduates would interact. The court held that, when considering graduate education, experience must be considered as part of "substantive equality." [2] The court's decision documented the differences between white and black facilities:

Legacy

On June 14, 2005, the Travis County Commissioners voted to rename the courthouse as The Heman Marion Sweatt Travis County Courthouse in honor of Sweatt's endeavor and victory. [8]

Lead attorney on Sweatt, Judge Robert L. Carter, with the then-dean of Fordham Law School, William Treanor Robert Carter and William Treanor.jpg
Lead attorney on Sweatt, Judge Robert L. Carter, with the then-dean of Fordham Law School, William Treanor

See also

Notes

  1. Known then as "Texas State University for Negroes"

References

  1. Lavergne, Gary M. (2010). Before Brown: Heman Marion Sweatt, Thurgood Marshall, and the long road to justice. Austin: University of Texas Press. ISBN   9780292722002.
  2. 1 2 3 4 Sweatt v. Painter, 339U.S.629 (Supreme Court of the United States1950).
  3. Fireside, Harvey (2017). Desegregating schools: Brown v. Board of Education. New York City: Enslow Publishing. p. 35. ISBN   9780766084230.
  4. "'Won't Upset System' – Daniel". Fort Worth Star-Telegram . Associated Press. June 6, 1950. p. 1.
  5. See Pace, Clint (May 19, 1947). "On Adding Some Blacks to the Southern Scene". The Austin American . p. 4.
  6. Hall, Douglas (March 20, 1948). "The Sweatts – A Family of Texas Fighters". The Afro-American . Baltimore. p. M-11.
  7. Stewart, Ollie (May 24, 1947). "Top Educators Flay Theory; Facts Cited: Lawyers for Heman Sweatt Appeal Ruling Barring Him from Texas U.". The Afro-American. pp. 1, 3.
  8. "Progress and Setbacks 140 Years After the Original Juneteenth". Austin American-Statesman . June 19, 2005. p. H2.
  9. Sipuel v. Board of Regents of University of Oklahoma, 332U.S.631 (1948).
  10. McLaurin v. Oklahoma State Regents , 339U.S.637 (1950).