Missouri Ex Rel. Gaines v. Canada

1938-12-12

Headline: Missouri’s race-based law school exclusion blocked as Court orders equal in-state access or equivalent in-state training, forcing states to admit qualified Black applicants or create equal law programs rather than send them out-of-state.

Holding: The Court ruled that Missouri violated the equal protection clause by denying a qualified Black applicant in-state legal training and must admit him to the state law school unless the State provides equivalent in-state legal education.

Real World Impact:

Requires states to provide in-state legal training to qualified Black residents or admit them to state law schools.
Stops states from sending qualified Black students out-of-state to avoid integrating law schools.
Affirms individual equal protection rights over state convenience or cost arguments.

Topics: segregation in higher education, equal protection, law school admissions, state education policy

Summary

Background

Petitioner Lloyd Gaines, a Black man and Missouri resident, applied to the University of Missouri’s law school but was denied admission solely because of his race. He had graduated from Lincoln University, the State’s separate school for Black students, which had no law department. State law allowed the university curators to pay tuition for Black students to attend law schools in nearby States instead of building a Missouri law school for Black students. The Missouri courts upheld that policy.

Reasoning

The Court considered whether sending a qualified Black student out of State for training satisfied the State’s constitutional duty to give equal opportunities. It emphasized that equal protection is an individual right and that a State must provide equality within its own borders. The Court held that Missouri could not deny in-state legal training to Black residents while offering that training to white residents and then rely on out-of-state scholarships to justify the difference. The judgment of the Missouri Supreme Court was reversed.

Real world impact

As a practical matter, the ruling requires Missouri to give qualifying Black applicants the same access to legal education that white applicants receive, either by admitting them or by establishing equivalent in-state programs. The decision limits a State’s ability to avoid integration by paying for out-of-state schooling. It affects all states that use separate institutions or out-of-state tuition to meet segregation policies for professional training. The case was sent back to state court for action consistent with this ruling.

Dissents or concurrances

Justice McReynolds dissented, arguing that the State had reasonably exercised discretion, that offering out-of-state tuition was a practical solution, and that courts should not override state education policy lightly.