Sweatt v. Painter
Following is the case brief for Sweatt v. Painter, 339 U.S. 629 (1950)
Case Summary of Sweatt v. Painter:
- An African-American law school applicant was denied admission into the University of Texas Law School solely because of his race.
- Upon suit filed by the applicant, the university tried to set up a separate facility for African-American law students.
- The Texas courts found that having the separate law school for African-Americans satisfied the Equal Protection Clause.
- The U.S. Supreme Court disagreed, holding that the separate law school for African-Americans was inferior in a number of ways. Therefore, the Equal Protection Clause dictated that the applicant must be admitted to the University of Texas Law School.
Sweatt v. Painter Case Brief
Statement of the Facts:
The petitioner, an African-American applicant to the University of Texas Law School was denied admission to the school because of his race. Following an initial court proceeding, the university offered petitioner enrollment in a new law school specifically for African-American law students. Petitioner refused that offer.
Many differences separated the two schools. The University of Texas Law School had 16 full-time and three part-time professors, 850 students, a library with 65,000 volumes, a law review, distinguished alumni, and general prestige. The newly created school for African-Americans, by contrast, had five professors, 23 students, a library with 16,500 volumes, a legal aid association, and one alumnus admitted to the Texas Bar.
- Petitioner filed an action in Texas state court for an order that he be admitted to the University of Texas Law School.
- The trial court denied the request, holding that the newly established law school for African-Americans was “substantially equivalent” to the University of Texas Law School.
- The Texas Court of Civil Appeals affirmed, and the Texas Supreme Court chose not to hear the case.
- The U.S. Supreme Court granted certiorari.
Issue and Holding:
Can a State distinguish between students of different races in professional and graduate educational institutions consistent with the Equal Protection Clause? No.
The decision of the Texas Court of Civil Appeals is reversed and remanded.
Rule of Law or Legal Principle Applied:
The Fourteenth Amendment’s Equal Protection Clause limits the power of a State to discriminate based on race in professional and graduate educational institutions.
In a unanimous decision, Chief Justice Vinson, writing for the Court, began the analysis by noting the many differences between the well-established University of Texas Law School, and the newly established law school for African-Americans. In terms of staff, library resources, and other organizations and facilities at the two schools, the University of Texas Law School was far superior to the newly created law school. Accordingly, the schools were not “substantially equivalent” as the Texas courts held.
In addition, the University of Texas Law School had many intangible benefits compared to the new law school, in terms of reputation, experience of the staff, influence of alumni, and prestige. Indeed, the Court found it hard to believe that someone who was free to choose either would choose the new school over the Univ. of Texas Law School. Moreover, a school for only minorities would eliminate any chance that law students would be able to interact in school with the people with whom they will eventually practice, thereby further harming their careers.
The State, therefore, violated the Equal Protection Clause by not making available a legal education equivalent to that offered to white students. The Equal Protection Clause requires that petitioner be admitted to the University of Texas Law School.
Sweatt v. Painter is a landmark decision that began a robust use of the Equal Protection Clause to stop State governments from disadvantaging people based on race. While the Court did not expressly overrule the separate-but-equal doctrine in Plessy v. Ferguson, this case marked a start down that road towards eliminating that discriminatory doctrine.