Sweatt v. Painter (1950) case brief

WWU, PLSC 415

July 17, 2014

CITATION: Sweatt v. Painter, 339 U.S. 629 (1950)

LEGAL ISSUE:

Whether the Equal Protection Clause of the Fourteenth Amendment guarantees black students, namely Sweatt, equal educational opportunities granted to white students in Texas universities.

APPLICABLE LAWS:

• Equal Protection Clause, Fourteenth Amendment
• Texas statute barring black college applicants 

RATIONALE: [Chief Justice Vinson]

After the University of Texas Law School acknowledged its discrimination practices, the state administrators “hastily established” an interim law school specifically for black students. A decade earlier, Missouri ex rel Gaines v. Canada (1938) upheld that states must provide equal accommodations and access to all citizens. Texas did not satisfy the Separate but Equal Doctrine by “hastily establishing” an interim law school for black students. Although Texas erected a law school exclusively for black students a year after Sweatt’s discrimination claim, the institutional accommodations offered to black students were clearly disproportional in contrast to the privileges of white students.

The interim law school for black students did not sufficiently accommodate its students. Texas neglected the institution for black students with a lack of facility funding, proper staff, and a minimal library collection. The credentialed curriculum and academic prestige did not match the tier standard of University of Texas Law School for white students. The court reasoned that Texas’ reputable white law school was substantially more superior to Sweatt’s black law school which “lacked accreditation”.

The Supreme Court applied strict-scrutiny assessment towards state-sanctioned racial discrimination. The Fourteenth Amendment safeguards black students from institutional practices that deprive persons on the account of race; Texas infringes Sweatt’s equal access. As a constitutional guarantee, the Equal Protection Clause encompasses all states to promote societal fairness. This judgment holds precedent over other racial state-statutes barring citizens from equal access and accommodations. Chief Justice Vinson posits the irony that legally-minded Texas administrators deliberately used racial classification to stint equal educational opportunities and privileges, also afforded to them

HOLDING:

Yes, the Equal Protection Clause of the Fourteenth Amendment nullifies Texas’ discriminatory statute which barred Sweatt’s university enrollment on account of race. The Texas Supreme Court’s decision is reversed.