Bolling v. Sharpe

Following is the case brief for Bolling v. Sharpe, 347 U.S. 497 (1954)

Case Summary of Bolling v. Sharpe:

  • A group of African-American students were denied admission to a D.C. public school because of their race.  They sued, alleging that racial segregation violates due process guaranteed by the Fifth Amendment.
  • The District Court dismissed the complaint, and the Supreme Court granted certiorari without a Court of Appeals decision.
  • The Supreme Court handed down its decision the same day it handed down Brown v. Board of Education.
  • The Court held that racial segregation in public schools violates the due process clause of the Fifth Amendment.

Bolling v. Sharpe Case Brief

Statement of the Facts:

Petitioners, a group of African-American children, were denied admission to a public school in the District of Columbia solely because of their race.  Petitioners filed a complaint in the District Court for the District of Columbia, alleging that the denial was a violation of their due process rights under the Fifth Amendment.

Procedural History:

The District Court dismissed the complaint.  The Supreme Court granted certiorari, before the Court of Appeals could render a decision, because of the important constitutional question presented.

Issue and Holding:

Did segregation of the public schools in the District of Columbia violate the Fifth Amendment of the Constitution?  Yes.

Judgment:

The District Court’s decision was reversed, and the case was placed back on the Supreme Court’s docket for argument regarding the form of the Court’s order.

Rule of Law or Legal Principle Applied:

Racial segregation of the public schools in the District of Columbia violates the due process clause of the Fifth Amendment.

Reasoning:

The decision of Brown v. Board of Education, 347 U.S. 483 (1954), decided the same day as this case, holds that racial segregation in public schools violates the equal protection clause of the Fourteenth Amendment.  The schools in the District of Columbia, overseen by the Federal Government, pose a slightly different problem because the Fourteenth Amendment only applies to the States.

That said, the concepts of “due process” and “equal protection,” while not synonymous, are not mutually exclusive.  They both stem from the American notion of fairness.  Accordingly, racial segregation is so unjustifiable that it violates not only equal protection but due process as well.

Further, segregation in public schools is not reasonably related to any legitimate governmental objective.  Thus, it places such a burden on African-American students that it is a deprivation of liberty in violation of due process clause of the Fifth Amendment.

Significance:

Bolling v. Sharpe was a landmark decision, decided the same day as Brown v. Board of Education, marking the end of racial segregation in public schools.  Also, it created a concept called “reverse incorporation,” whereby the rights under the equal protection clause of the Fourteenth Amendment can be incorporated back to the federal government through the Fifth Amendment’s due process clause.

Student Resources:

https://supreme.justia.com/cases/federal/us/347/497/case.html

https://www.oyez.org/cases/1940-1955/347us497

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