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  • Implementing Brown v. Board of Education in West Virginia: The Southern School News Reports
  • Sam F. Stack Jr

On May 17, 1954, the Supreme Court of the United States ruled in Brown v. Board of Education of Topeka that segregated schools were unconstitutional. Chief Justice Earl Warren read the decision of the Court: “We come to the question presented: Does segregation of children in public school solely on the basis of race, even though the physical facilities and other tangible factors may be equal, deprive children of the minority group of equal educational opportunities? We believe that it does. We conclude that in the field of public education the doctrine of separate but equal has no place. Separate educational facilities are inherently unequal.”1 This ruling overturned Plessy v. Ferguson in which the court in 1896 had declared that separate facilities did not violate the Fourteenth Amendment.

The Plessy case did not involve education directly, but was a transportation case based on an 1890 Louisiana law that mandated separate railway cars for blacks and whites. Homer Plessy, who was one-eighth black, refused to vacate the white car and was imprisoned in a New Orleans parish jail. Plessy challenged that he had been denied his constitutional rights guaranteed by the Thirteenth and Fourteenth Amendments. The Supreme Court argued that in no way was Plessy being forced into a state of involuntary servitude by riding in a separate car. The court further stated that the Fourteenth Amendment, which protected “life, liberty, and property without due process of law,” was not being abridged. Even though Louisiana law mandated separate cars, the court found the railroad cars essentially no different. The constitutionality of separate but equal held until overturned by the Brown decision in 1954.2

The challenge to Plessy began years before the Brown decision in 1954 and was initiated through the work of Charles Hamilton Houston, a World War I veteran and graduate of Harvard Law School. The discrimination Houston faced as a black officer during the war, and the racism of American society upon his return, led him to attend Howard Law School, where he [End Page 59] eventually became dean. With the goal of overturning Plessy v. Ferguson, Houston began to train civil rights lawyers at Howard. Future Supreme Court Justice Thurgood Marshall was his best student.

Marshall headed the NAACP defense team that began the challenge, demonstrating that the separate but equal doctrine of Plessy did not hold for many law schools in the country. However, Marshall and his colleagues believed that simply showing schools were separate and unequal was not enough to overturn Plessy. They must prove that the segregation produced a badge of inferiority. The separation alone implied inferiority. Marshall and the defense team believed the psychological studies of Kenneth Clark could be applicable to their argument. Clark’s research explored how the impact of separation affected the self-image and potential for learning in African American children. Clark used dolls to show how children learn about race and identify themselves. The African American children in his study were shown four dolls from the same mold and dressed alike. Two dolls were boys, one black and one white, with the same configuration for the girl dolls. To determine racial preference Clark asked each African American child to give him the following: the doll you like to play with or the one you like best, the nice doll, the doll that looks bad, and the doll that is a nice color. Clark’s findings revealed that the African American children demonstrated a strong preference for the white dolls and a rejection of the black dolls. Clark and the NAACP defense team believed the research proved that black children learned early that American society preferred whiteness, implying that black meant inferior. Marshall convinced the Supreme Court during the Brown case that separation increased these deep psychological feelings of inferiority.3 The court agreed.

Following the 1954 Brown ruling, West Virginia Governor William C. Marland pledged to obey the Supreme Court edict and foresaw no serious difficulty in integrating West Virginia schools. State Superintendent of Schools W. W. Trent agreed, considering the adjustment as largely administrative. In a letter...


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