Pennsylvania v. Board of Directors of City Trusts of Philadelphia
Headline: Court reverses Pennsylvania ruling and bars state-run Girard College from excluding qualified Black applicants, ordering the case back to lower courts so the school must not refuse admission on race.
Holding: The Court held that the Board running Girard College, as a state agency, violated the Fourteenth Amendment by refusing admission to Black applicants and reversed the Pennsylvania court, remanding the case.
- Stops a state agency from excluding applicants because they are Black.
- Reverses Pennsylvania court and sends the case back for further proceedings.
- Makes clear state-administered trusts cannot practice racial exclusion.
Summary
Background
Stephen Girard’s will (probated 1831) created a trust to run a college that would admit "poor white male orphans" ages six to ten. The City of Philadelphia was named trustee and a state law later placed a Board of Directors in charge. The college opened in 1848 and the Board has administered it since 1869. In 1954 two applicants, Foust and Felder, met the school's requirements except that they were Negroes. The Board refused them admission because of their race. The applicants sued in the Orphans’ Court, the State and City joined the claim, and the Pennsylvania Supreme Court upheld the Board’s refusal.
Reasoning
The Court addressed whether the Board’s refusal was state discrimination prohibited by the Fourteenth Amendment. It treated the Board as an agency of the State, and concluded that denying admission because the applicants were Negroes was discrimination by the State and therefore unconstitutional. The opinion cites Brown v. Board of Education and reverses the Pennsylvania Supreme Court’s judgment.
Real world impact
The decision means the Board that runs Girard College may not exclude qualified applicants on the basis of race. The case is sent back to lower courts for further proceedings that must follow the Court’s ruling. The Court issued a per curiam opinion and ordered reversal and remand. This outcome directly affects the two applicants and the college’s admissions practices going forward.
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