Cooper v. Aaron
The Supreme Court, in an opinion personally signed by all nine justices, ruled that Little Rock could not delay desegregating Central High School even though the Governor and state legislature had stirred up violent resistance to integration.
The decision forcefully declared that state officials cannot ignore or nullify federal court rulings interpreting the Constitution, directly rejecting Arkansas's claim that it was not bound by Brown v. Board of Education.
“The constitutional rights of respondents are not to be sacrificed or yielded to the violence and disorder which have followed upon the actions of the Governor and Legislature.”
The Court's central holding that state-caused unrest cannot excuse delaying desegregation.
How it got here: A federal district court approved a two-and-a-half-year delay in desegregation; the Eighth Circuit reversed; the School Board sought Supreme Court review, which was granted on an expedited basis.
The Case in Depth
What happened
After Brown v. Board of Education outlawed school segregation, the Little Rock School Board adopted a gradual desegregation plan approved by federal courts. Arkansas's Governor and Legislature instead fought integration, and when nine Black students tried to attend Central High School in 1957, the Governor sent National Guard troops to block them, prompting federal intervention and mob violence. The School Board later asked to delay desegregation because of the resulting turmoil.
The question before the Court
Did Arkansas's governor and legislature have to obey a federal court's school desegregation order, or could the school board delay integration because of the resulting unrest?
Why it matters
The ruling meant Little Rock's Black students had to be allowed back into Central High School despite the hostility and violence state officials had encouraged. More broadly, it told every state that officials cannot use public disorder, state laws, or defiance to escape federal court orders enforcing constitutional rights, cementing the Supreme Court's role as final interpreter of the Constitution.
What changes now
The Supreme Court's judgment was final and took effect immediately, reinstating the desegregation plan and requiring the Black students to be readmitted to Central High School without further delay. The opinion left no room for further litigation over whether Arkansas could resist Brown v. Board of Education, though the broader struggle over school desegregation across the South continued in other cases for years afterward.
What this does not decide
The Court did not rule on any general timetable for desegregation elsewhere or address every method of resistance to Brown; it decided only that hostility and disorder deliberately caused by state officials could not justify suspending this specific court-approved desegregation plan in Little Rock.
Concurrences and dissents
Concurrence — Justice Frankfurter
Justice Frankfurter joined the Court's opinion in full but wrote separately to emphasize that yielding to violent resistance would mean law bows to force, calling this profoundly subversive of constitutional government. He stressed that criticism and dissent from Brown remain lawful, but active defiance is not, and that compliance with Supreme Court rulings has always depended on good-faith support from state and local officials.
How the Court got there
The legal reasoning, step by step
- The Court first asked whether the chaos at Central High School could excuse pausing the desegregation plan, and found that the turmoil was itself caused by the State's own officials — the Governor's deployment of troops and the Legislature's defiance — rather than by anything the School Board did wrong.
- Because the disorder was state-created, the Court held that state actors cannot use the very disruption they caused as a legal excuse to delay constitutional rights; otherwise, officials hostile to a ruling could nullify it simply by fostering unrest.
- The Court then confronted the broader claim that Arkansas's Governor and Legislature were not bound by Brown v. Board of Education. It invoked the Supremacy Clause of Article VI, which makes the Constitution, and the Supreme Court's interpretation of it, binding on every state official.
- Drawing on Marbury v. Madison's principle that the judiciary has final authority to say what the Constitution means, the Court reasoned that this interpretive authority has been a permanent feature of the constitutional system since 1803.
- Applying that principle here, the Court concluded that no governor, legislator, or state judge can lawfully refuse to follow the Supreme Court's constitutional rulings, and that Brown's holding banning school segregation was therefore the binding law of the land in Arkansas just as anywhere else.
Doctrinal impact
Cases affected by this decision
Reaffirms Brown v. Board of Education (347 U.S. 483)
The Court unanimously reaffirmed Brown's ban on school segregation as binding law that Arkansas could not evade.