What did McLaurin v Oklahoma do?

Working with the National Association for the Advancement of Colored People (NAACP), black Oklahomans in the 1940s increasingly tested laws and state policies that upheld segregation, including segregated education. While Oklahoma had a relatively small African American population (about 8 percent at the time of statehood in 1907), a majority of early white Oklahomans had southern roots and thoroughly embraced the concept of white supremacy.

The first legislature, meeting in 1907, had established separate schools for African Americans and heavy fines for administrators, teachers, and students who broke the law. In the state's higher education system the allblack Langston A&M College, created during the territorial era, offered African Americans many programs leading to a bachelor's degree, but Langston had no graduate programs. Instead, the state provided out-of-state educational grants for African American students who wished to go to graduate school. Approximately 2,000 black Oklahomans received such grants between 1907 and 1946. However, such a system was not acceptable to many of the state's African American students, one of whom was George McLaurin, an instructor at Langston who wished to pursue a graduate degree within the state.

McLaurin became a pioneer in the national civil rights movement when he, along with five other African Americans, applied for admission to the all-white University of Oklahoma's graduate program in January 1948. Denied admission, McLaurin applied again in September. Still denied, he sought a remedy in federal court, which ordered the university to admit McLaurin. The ruling, however, did not specifically void the state's segregation laws.

University president George Lynn Cross, who did not personally oppose integration, worked with regents to admit McLaurin while also obeying the state's segregation laws. However, the implemented plan was dehumanizing. The university made arrangements for McLaurin to take his courses in room 104 in the Carnegie Building. Workers constructed an alcove (the NAACP's lawyer, Thurgood Marshall, who, with Robert L. Carter and Amos T. Hall, argued the case before the Supreme Court, called it a "broom closet"), with wooden railings that separated McLaurin from the rest of the class. He had a separate entrance and exit to and from the hall. Mc- Laurin also found that the university had given him a separate-but-equal men's room, a separate table in the student union, a separate table in the campus cafeteria, and a separate library study table with his name on it. These arrangements satisfied neither McLaurin nor the NAACP, whose legal appeal argued that such on-campus segregation hampered Mc- Laurin's ability to study, to take part in class discussions, and to interact further with other students. On June 5, 1950, the U.S. Supreme Court agreed and ordered the university to end the on-campus segregation of McLaurin.

With this victory, McLaurin v. Oklahoma joined a train of precedents, including Missouri ex. rel. Gaines v. Canada (1938), Sweatt v. Painter (a 1950 Texas case), and Sipuel v. Board of Regents University of Oklahoma (1945), which integrated the University of Oklahoma Law School and led to the Supreme Court's historic Brown v. The Board of Education of Topeka decision of 1954 and the eventual integration of schools nationwide.

James M. Smallwood Oklahoma State University

Fisher, Ada Lois Sipuel. Matter of Black and White: The Autobiography of Ada Lois Sipuel Fisher. Norman: University of Oklahoma Press, 1996.

Franklin, Jimmie Lewis. Journey toward Hope: A History of Blacks in Oklahoma. Norman: University of Oklahoma Press, 1982.

Smallwood, James. Blacks in Oklahoma. Stillwater: Oklahoma State University Press, 1981.

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339 U.S. 637

70 S.Ct. 851

94 L.Ed. 1149

McLAURINv.

OKLAHOMA STATE REGENTS FOR HIGHER EDUCATION et al.

No. 34.

Argued April 3, 4, 1950.

Decided June 5, 1950.

Messrs. Amos T. Hall, Tulsa, Okl., Robert L. Carter, Washington, D.C., for appellant.

Mr. Fred Hansen, Oklahoma City, Okl., for appellees.

Mr. Chief Justice VINSON delivered the opinion of the Court.

1

In this case, we are faced with the question whether a state may, after admitting a student to graduate instruction in its state university, afford him different treatment from other students solely because of his race. We decide only this issue; see Sweatt v. Painter, 339 U.S. 629, 70 S.Ct. 848.

2

Appellant is a Negro citizen of Oklahoma. Possessing a Master's degree, he applied for admission to the University of Oklahoma in order to pursue studies and courses leading to a Doctorate in Education. At that time, his application was denied, solely because of his race. The school authorities were required to exclude him by the Oklahoma statutes, 70 Okl.Stat. (1941) §§ 455, 456, 457, which made it a misdemeanor to maintain or operate, teach or attend a school at which both whites and Negroes are enrolled or taught. Appellant filed a complaint requesting injunctive relief, alleging that the action of the school authorities and the statutes upon which their action was based were unconstitutional and deprived him of the equal protection of the laws. Citing our decisions in State of Missouri ex rel. Gaines v. Canada, 1938, 305 U.S. 337, 59 S.Ct. 232, 83 L.Ed. 208, and Sipuel v. Board of Regents, 1948, 332 U.S. 631, 68 S.Ct. 299, 92 L.Ed. 247, a statutory three-judge District Court held, 87 F.Supp. 526, that the State had a constitutional duty to provide him with the education he sought as soon as it provided that education for applicants of any other group. It further held that to the extent the Oklahoma statutes denied him admission they were unconstitutional and void. On the assumption, however, that the State would follow the constitutional mandate, the court refused to grant the injunction, retaining jurisdiction of the cause with full power to issue any necessary and proper orders to secure McLaurin the equal protection of the laws.

3

Following this decision, the Oklahoma legislature amended these statutes to permit the admission of Negroes to institutions of higher learning attended by white students, in cases where such institutions offered courses not available in the Negro schools. The amendment provided, however, that in such cases the program of instruction 'shall be given at such colleges or institutions of higher education upon a segregated basis.'1 Appellant was thereupon admitted to the University of Oklahoma Graduate School. In apparent conformity with the amendment, his admission was made subject to 'such rules and regulations as to segregation as the President of the University shall consider to afford Mr. G. W. McLaurin substantially equal educational opportunities as are afforded to other persons seeking the same education in the Graduate College,' a condition which does not appear to have been withdrawn. Thus he was required to sit apart at a designated desk in an anteroom adjoining the classroom; to sit at a designated desk on the mezzanine floor of the library, but not to use the desks in the regular reading room; and to sit at a designated table and to eat at a different time from the other students in the school cafeteria.

4

To remove these conditions, appellant filed a motion to modify the order and judgment of the District Court. That court held that such treatment did not violate the provisions of the Fourteenth Amendment and denied the motion. 87 F.Supp. 528. This appeal followed.

5

In the interval between the decision of the court below and the hearing in this Court, the treatment afforded appellant was altered. For some time, the section of the classroom in which appellant sat was surrounded by a rail on which there was a sign stating, 'Reserved For Colored,' but these have been removed. He is now assigned to a seat in the classroom in a row specified for colored students; he is assigned to a table in the library on the main floor; and he is permitted to eat at the same time in the cafeteria as other students, although here again he is assigned to a special table.

6

It is said that the separations imposed by the State in this case are in form merely nominal. McLaurin uses the same classroom, library and cafeteria as students of other races; there is no indication that the seats to which he is assigned in these rooms have any disadvantage of location. He may wait in line in the cafeteria and there stand and talk with his fellow students, but while he eats he must remain apart.

7

These restrictions were obviously imposed in order to comply, as nearly as could be, with the statutory requirements of Oklahoma. But they signify that the State, in administering the facilities it affords for professional and graduate study, sets McLaurin apart from the other students. The result is that appellant is handicapped in his pursuit of effective graduate instruction. Such restrictions impair and inhibit his ability to study, to engage in discussions and exchange views with other students, and, in general, to learn his profession.

8

Our society grows increasingly complex, and our need for trained leaders increases correspondingly. Appellant's case represents, perhaps, the epitome of that need, for he is attempting to obtain an advanced degree in education, to become, by definition, a leader and trainer of others. Those who will come under his guidance and influence must be directly affected by the education he receives. Their own education and development will necessarily suffer to the extent that his training is unequal to that of his classmates. Stateimposed restrictions which produce such inequalities cannot be sustained.

9

It may be argued that appellant will be in no better position when these restrictions are removed, for he may still be set apart by his fellow students. This we think irrelevant. There is a vast difference—a Constitutional difference—between restrictions imposed by the state which prohibit the intellectual commingling of students, and the refusal of individuals to commingle where the state presents no such bar. Shelley v. Kraemer, 1948, 334 U.S. 1, 13-14, 68 S.Ct. 836, 842, 92 L.Ed. 1161, 3 A.L.R.2d 441. The removal of the state restrictions will not necessarily abate individual and group predilections, prejudices and choices. But at the very least, the state will not be depriving appellant of the opportunity to secure acceptance by his fellow students on his own merits.

10

We conclude that the conditions under which this appellant is required to receive his education deprive him of his personal and present right to the equal protection of the laws. See Sweatt v. Painter, 339 U.S. 629, 70 S.Ct. 848. We hold that under these circumstances the Fourteenth Amendment precludes differences in treatment by the state based upon race. Appellant, having been admitted to a state-supported graduate school, must receive the same treatment at the hands of the state as students of other races. The judgment is reversed.