Sweatt v. Painter
Headline: Black applicant must be admitted to the state law school; Court rejects separate, unequal law school and forces Texas to provide equal graduate legal education.
Holding: The Court held that the Fourteenth Amendment requires the State to admit a Black applicant to the University of Texas Law School because the separate law school was not substantially equal.
- Requires states to admit qualified Black applicants to existing professional schools.
- Prevents states from meeting equality by creating clearly inferior separate professional schools.
- Forces states to match faculty, libraries, accreditation, and reputation when segregating education.
Summary
Background
A Black man applied to the University of Texas Law School for the February 1946 term and was denied admission solely because he was Negro. At that time Texas had no law school that admitted Black students. The state created a separate law school for Black students while this case was pending. The University of Texas Law School had about 850 students, a large faculty, a library of over 65,000 volumes, a law review, moot court, scholarships, and strong alumni ties. The separate school initially had no independent faculty or full library and was not accredited; a later version had only five full-time professors and about 23 students.
Reasoning
The Court considered whether the State could lawfully keep qualified Black students out of its main law school by offering separate facilities. It compared the actual opportunities and intangible advantages of the two schools—faculty size, courses, library, accreditation, reputation, alumni influence, and practical connections. The Court concluded the separate school did not offer education substantially equal to that at the University of Texas. The result: the Black applicant effectively won and the State must admit him to the University of Texas Law School under the Fourteenth Amendment’s guarantee of equal protection.
Real world impact
The ruling requires Texas to provide the same graduate legal education to Black applicants as to white applicants and stops the State from meeting equality requirements by offering clearly inferior, separate professional schools. The decision focuses on the personal right to equal educational opportunity and orders admission in this case; it directs states to provide equal facilities as soon as they do so for other groups.
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