Missouri ex rel. Gaines v. Canada facts for kids
Quick facts for kids Missouri ex rel. Gaines v. Canada |
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| Argued November 9, 1938 Decided December 12, 1938 |
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| Full case name | State of Missouri ex rel. Gaines v. Canada, Registrar of the University of Missouri, et al. |
| Citations | 305 U.S. 337 (more)
59 S. Ct. 232; 83 L. Ed. 208; 1938 U.S. LEXIS 440
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| Prior history | The Circuit Court denied the writ. The Missouri Supreme Court upheld the judgment against Gaines, 113 S.W.2d 783 (Mo. 1937); cert. granted, 305 U.S. 580 (1938). |
| Subsequent history | Rehearing denied, 305 U.S. 676 (1939); remanded, 131 S.W.2d 217 (Mo. 1939). |
| Holding | |
| States that provide only one educational institution must allow blacks and whites to attend if there is no separate school for blacks. | |
| Court membership | |
| Case opinions | |
| Majority | Hughes, joined by Brandeis, Stone, Roberts, Black, Reed |
| Dissent | McReynolds, joined by Butler |
| Laws applied | |
| U.S. Const. amend. XIV | |
Missouri ex rel. Gaines v. Canada was an important case decided by the U.S. Supreme Court in 1938. The Court ruled that if a state offered a public school for white students, it also had to provide the same education for black students within that state. This meant states could either let black and white students attend the same school or create a separate, equal school for black students.
Contents
Why This Case Happened
Lloyd Gaines and Law School
The story began with Lloyd Gaines. He was a black student who wanted to study law. He applied to the Law School at the University of Missouri. However, the school's Registrar, Silas Woodson Canada, turned him away because Gaines was black.
At that time, there was no law school specifically for black students in Missouri. The state offered to pay for Gaines to attend law school in a nearby state. But Gaines refused this offer.
The Fight for Equal Rights
Gaines believed that being denied admission violated his rights under the Fourteenth Amendment. This amendment says that states must give everyone "equal protection of the laws."
With help from the NAACP, Gaines sued the university in 1935. The main question was: Did Missouri violate the Equal Protection Clause by offering law school to white students but not to black students within the state?
The Supreme Court's Decision
What the Court Ruled
Chief Justice Charles Evans Hughes wrote the main opinion for the Supreme Court. The Court decided that if a state provides legal training, it must offer it to all qualified people. This is necessary to ensure equal protection.
The Court said that states could not send black students to other states for their education. They also could not make the education of one group, like black students, depend on how many people from that group wanted it.
A key part of the Court's decision was that Missouri had no law school for black students. Because of this, Missouri's law promising equal protection applied directly. Sending Gaines to another state was not an acceptable solution.
Different Opinions
Justice James C. McReynolds disagreed with the majority. He believed states should have more control over their education systems. He even suggested that Missouri might still be able to deny Gaines admission, despite the majority's ruling.
Impact of the Decision
Separate but Equal?
This decision did not completely get rid of the idea of "separate but equal" facilities. That idea had been upheld in an earlier case called Plessy v. Ferguson (1896).
However, Gaines v. Canada made an important change. It said that if there was only one school for a certain type of education, then students of all races had to be allowed to attend it. This meant that if the government only provided one school, it could not keep people out based on their race.
A Step Towards Equality
This case was a very important step. It helped set the stage for Brown v. Board of Education in 1954. That later case finally banned segregation in public schools across the United States.
Gaines v. Canada showed that the Supreme Court was starting to rethink the "separate but equal" rule. The Court began to see how difficult, and almost impossible, it was for states to truly keep black and white schools equal. This case helped build the legal foundation for the later fight against segregation.
What Happened to Lloyd Gaines?
After the Supreme Court ruled in Gaines's favor, the case was sent back to the Missouri Supreme Court. However, Lloyd Gaines could not be found. When the University of Missouri later asked to close the case, the NAACP did not object.
