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Two Cheers for Brown v. Board of
Education
Clayborne
Carson
| My gratuitous
opinion of Brown v. Board of Education (1954) is somewhat
ambivalent and certainly arrives too late to alter the racial
policies of the past fifty years. But for those of us who practice
history, hindsight offers a far more reliable kind of wisdom than
does foresight. We see clearly now that while the Brown
decision informed the attitudes that have shaped contemporary
American race relations, it did not resolve persistent disputes
about the nation's civil rights policies. The Supreme Court's
unanimous opinion in Brown broke decisively with the racist
interpretations of traditional American values set forth in Scott
v. Sandford (1857) and Plessy v. Ferguson (1896),
offering instead the optimistic "American Creed" that Gunnar Myrdal
saw as the solution to "the Negro problem."1 Like the two earlier landmark
decisions, Brown overestimated the extent of ideological
consensus among Americans and soon exacerbated racial and regional
conflicts instead of resolving them. The Court's ruling against
school segregation encouraged African Americans to believe that the
entire structure of white supremacy was illegitimate and legally
vulnerable. But the civil rights struggles Brown inspired
sought broader goals than the decision could deliver, and that gap
fostered frustration and resentment among many black Americans. In
short, the decision's virtues and limitations reflect both the
achievements and the failures of the efforts made in the last half
century to solve America's racial dilemma and to realize the
nation's egalitarian ideals. |
1 |
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That the Brown decision spurred
subsequent civil rights progress seems apparent, but its impact and
its significance as a source of inspiration are difficult to
measure.2 Although the Court's initial
unwillingness to set firm timetables for school desegregation
undercut Brown's immediate impact, African Americans expanded
the limited scope of the decision by individual and collective
challenges to the Jim Crow system. Small-scale protests escalated
during the decade after 1954, becoming a sustained mass movement
against all facets of segregation and discrimination in the North as
well as the South. Civil rights protests and litigation prompted
Congress to pass the Civil Rights Act of 1964 and the Voting Rights
Act of 1965, both of which extended the Brown decision's
egalitarian principles well beyond education. The historic mass
struggle that followed Brown ultimately destroyed the legal
foundations of the Jim Crow system, and their destruction prepared
the way for a still more far-reaching expansion of prevailing
American conceptions of civil rights and of the role of government
in protecting those rights. During the past forty years, women and
many minority groups, including immigrants and people with
disabilities, have gained new legal protections modeled on the civil
rights gains of African Americans.3 |
2 |
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But the Brown decision also created
racial aspirations that remain unrealized. Although the decision may
have been predicated on the notion of a shared American creed, most
white Americans were unwilling to risk their own racial privileges
to bring about racial equality. The decision was neither universally
accepted nor consistently enforced. "Instead, it provoked
overwhelming resistance in the South and only tepid interest in the
North," the historian John Higham insisted. "In the South the
decision released a tidal wave of racial hysteria that swept
moderates out of office or turned them into demagogues. State and
local officials declined to obstruct a revival of the Ku Klux Klan.
Instead, they employed every conceivable device to maintain
segregation, including harassment and dissolution of NAACP chapters."4 By the 1970s, resistance to
school desegregation had become national. Northern whites in Boston
and elsewhere demonstrated their unwillingness to send their
children to predominantly black schools or to allow large-scale
desegregation that would drastically alter the racial composition of
"their" schools in "their" neighborhoods. Voters in the states of
Washington and California passed initiatives to restrict the right
of school boards (Washington) and state courts (California) to order
busing to achieve school desegregation (the Supreme Court later held
the Washington initiative unconstitutional). Nationwide, white
racial resentments encouraged an enduring shift of white voters from
the Democratic to the Republican party. The 1964 election would be
the last presidential contest in which the majority of black voters
and of white voters backed the same candidate. Since 1974, when the
Supreme Court's Milliken v. Bradley decision set limits on
busing, the legal meaning of desegregation has been scaled back to
conform to American racial and political
realities.5 |
3 |
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African Americans generally applauded the
Brown decision when it was announced, but the Court's failure
to realize Brown's bold affirmation of egalitarian ideals
fueled subsequent black discontent and disillusionment. Brown
cited studies that demonstrated the harmful psychological impact of
enforced segregation on black students, reporting, "To separate them
from others of similar age and qualifications solely because of
their race generates a feeling of inferiority as to their status in
the community that may affect their hearts and minds in a way
unlikely ever to be undone." Yet the Court did not offer an
effective means to correct the problem it had identified. During the
decades after Brown, most southern black children continued
to suffer the psychological consequences of segregation, while a
small minority assumed the often considerable psychological and
physical risks of attending newly integrated public schools. Rather
than bringing large numbers of black and white students together in
public schools, the Brown decision—and the subsequent years
of litigation and social conflict—enabled a minority of black
students to attend predominantly white schools. Ten years after the
Brown decision, according to data compiled by the U.S.
Department of Education, almost 98 percent of southern black
students still attended predominantly black schools. Now, at the
beginning of the twenty-first century, the Court's ideal of
educational opportunity as "a right which must be made available to
all on equal terms" is still far from being realized. American
schools, both public and private, are still highly segregated.
According to a recent study, the typical Latino or black student in
the United States still attends a school where members of minority
groups are predominant.6 |
4 |
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Certainly, the Brown decision's most
significant deficiency is its failure to address the concerns of the
majority of African American students who have been unable or
unwilling to seek better educational opportunities by leaving
predominantly black schools for predominantly white ones. While it
opened the door for the Little Rock Nine, who desegregated Central
High School in 1957, the Brown decision offered little solace
to the hundreds of students who remained at Little Rock's all-black
Horace Mann High School. When Arkansas officials reacted to
desegregation by closing all of Little Rock's high schools, those
students were denied even segregated educational opportunities.7 With the encouragement of the
lawyers for the National Association for the Advancement of Colored
People's (NAACP) Legal
Defense and Education Fund, the Supreme Court largely abandoned
previous efforts to enforce the separate but equal mandate in order
to adopt a narrowly conceived strategy for achieving equal
educational opportunity through desegregation. The pre-Brown
equalization effort had encouraged social scientists to develop
increasingly sophisticated ways of measuring differences in the
quality of schools. But during the 1950s, pro–civil rights scholars
shifted their focus from the educational environment of black
students in black schools to the psychological state of black
students experiencing desegregation. The NAACP's initial strategy of
forcing southern states to equalize facilities at all-black schools
had resulted in tangible improvements, whereas the removal of racial
barriers in public schools was advertised as offering intangible
psychological gains. |
5 |
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For Thurgood Marshall, who headed the NAACP legal staff, the
equalization effort had always been a means of achieving the
ultimate goal of desegregation. After the Supreme Court decided in
Sweatt v. Painter (1950) that a makeshift segregated law
school at a black college could not provide educational
opportunities equal to those offered by the University of Texas Law
School, Marshall exulted, "The complete destruction of all
enforced segregation is now in sight." Despite having attended
predominantly black schools at every stage of his academic career,
he saw segregation as a racial stigma that could not be removed by
increased state appropriations for Jim Crow schools. In the early
1950s he noted that social scientists were "almost in universal
agreement that segregated education produces inequality." He
therefore concluded "that segregated schools, perhaps more than any
other single factor, are of major concern to the individual of
public school age and contribute greatly to the unwholesomeness and
unhappy development of the personality of Negroes which the color
caste system in the United States has
produced."8 |
6 |
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Few African Americans would wish to return
to the pre-Brown world of legally enforced segregation, but
in the half century since 1954, only a minority of Americans has
experienced the promised land of truly integrated public education.
By the mid-1960s, with dual school systems still in place in many
areas of the Deep South, and with de facto segregation a recognized
reality in urban areas, the limitations of Brown had become
evident to many of those who had spearheaded previous civil rights
struggles. The ideological gulf that appeared in African American
politics during the period was largely the result of efforts to draw
attention to the predominantly black institutions neglected in the
drive for racial integration. The black power movement arose in part
as an effort by African Americans to control and improve such
institutions. Some black power proponents exaggerated the benefits
of racial separatism, but their extremism can be best understood as
a reaction against the unbalanced post-Brown strategy of
seeking racial advancement solely through integration. Although
James S. Coleman's landmark 1966 study of equality of educational
opportunity found that black children attending integrated schools
did better than students attending predominantly black schools, it
was by no means clear that the gap was the result of interracial
interactions rather than of differences in the socioeconomic
backgrounds of the students involved. By the late 1960s, growing
numbers of black leaders had concluded that improvement of black
schools should take priority over school desegregation. In 1967,
shortly before the National Advisory Commission on Civil Disorders
warned that the United States was "moving toward two societies, one
white, one black—separate and unequal," Martin Luther King Jr.
acknowledged the need to refocus attention, at least in the short
run, on "schools in ghetto areas." He also insisted that "the drive
for immediate improvements in segregated schools should not retard
progress toward integrated education later." Even veterans of
theNAACP's legal campaign had second thoughts. "Brown has
little practical relevance to central city blacks," Constance Baker
Motley commented in 1974. "Its psychological and legal relevance has
already had its effect."9 |
7 |
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Black power advocates sometimes sought to
replace the narrow strategy of achieving racial advancement through
integration with the equally narrow strategy of achieving it through
racial separatism. In both instances, claims of psychological gains
often substituted for measurable racial advancements, but the
continued popularity of Afrocentric educational experiments
indicates that many African Americans now see voluntary segregation
as psychologically uplifting. Having personally experienced the
burden of desegregating numerous classrooms and having watched my
son move with great success from a predominantly black college to a
predominantly white law school, I am skeptical of sweeping claims
about the impact of racial environment on learning. While believing
that debates among African Americans during the last half century
about their destiny have been useful, I regret that those debates
have often exacerbated ideological conflict rather than encouraging
us toward collective action. Rather than having to choose between
overcoming racial barriers and improving black community
institutions, we should be able to choose
both. |
8 |
In hindsight, the nation would have been
better served if the Brown decision had evinced a more
realistic understanding of the deep historical roots of America's
racial problems—perhaps a little more familiarity with the writings
of W. E. B. Du Bois and Carter G. Woodson as well as those of Myrdal
and his colleagues. Rather than blandly advising that desegregation
of public schools be achieved with "all deliberate speed," the
Supreme Court—and the NAACP
lawyers who argued before it—should have launched a two-pronged
attack, not only against racial segregation but also against
inferior schools, whatever their racial composition. Such an attack
would have heeded the admonition that Du Bois offered in 1935, soon
after his forced resignation as editor of the
NAACP's journal, the
Crisis:
Theoretically, the Negro needs neither segregated
schools nor mixed schools. What he needs is Education.... Other
things being equal, the mixed school is the broader, more natural
basis for the education of all youth. It gives wider contacts; it
inspires great self-confidence; and suppresses the inferiority
complex. But other things seldom are equal, and in that case,
Sympathy, Knowledge, and the Truth, outweigh all that the mixed
school can offer.10 |
9 |
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Because the Brown decision was a
decisive departure from Plessy's separate but equal
principle, it was an important turning point in African American
history. Nevertheless, fifty years later the Court's assumptions
about the psychological consequences of legally enforced segregation
seem dated. The Jim Crow system no longer exists, but most black
American schoolchildren still attend predominantly black public
schools that offer fewer opportunities for advancement than typical
predominantly white public schools. Moreover, there is no
contemporary civil rights movement able to alter that fact. Yet, if
Brown represents a failed attempt to achieve comprehensive
racial advancement, the opinion nonetheless still challenges us by
affirming egalitarian ideals that remain relevant: "In these days,
it is doubtful that any child may reasonably be expected to succeed
in life if he is denied the opportunity of an education. Such an
opportunity, where the state has undertaken to provide it, is a
right which must be made available to all on equal terms."11 |
10 |
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Notes
Clayborne Carson is professor of
history and director of the Martin Luther King, Jr., Papers Project
at Stanford University.
Readers
may contact Carson at <ccarson@stanford.edu>.
1 Scott v. Sandford, 19 How. 393 (1857);
Plessy v. Ferguson, 163 U.S. 537 (1896); Brown v. Board of
Education, 347 U.S. 483 (1954); Gunnar Myrdal, An American
Dilemma: The Negro Problem and Modern Democracy (2 vols., New
York, 1944).
2 On Brown's direct and indirect
consequences, see, for example, Michael J. Klarman, "How
Brown Changed Race Relations: The Backlash Thesis,"
Journal of American History, 81 (June 1994), 81–118. Klarman
correctly points out that Brown had limited impact on school
desegregation, especially in the Deep South, and stimulated southern
white resistance to racial reform. He concludes that the
contributions of Brown to the broader civil rights struggle
were mostly indirect.
3 Cf. Hugh Davis Graham, The Civil Rights
Era: Origins and Development of National Policy, 1960–1972 (New
York, 1990); Hugh Davis Graham, Collision Course: The Strange
Convergence of Affirmative Action and Immigration Policy in
America (New York, 2002); and John D. Skrentny, The Minority
Rights Revolution (Cambridge, Mass.,
2002).
4 John Higham, "Introduction: A Historical
Perspective," in Civil Rights and Civil Wrongs: Black-White
Relations since World War II, ed. John Higham (University Park,
1997), 4. See also Klarman, "How Brown Changed Race
Relations"; Numan V. Bartley, The Rise of Massive Resistance:
Race and Politics in the South in the 1950s (Baton Rouge, 1969);
and Neil McMillen, The Citizens' Council: Organized Resistance to
the Second Reconstruction, 1954–1964 (Urbana, 1971).
5 See Ronald P. Formisano, Boston against
Busing: Race, Class, and Ethnicity in the 1960s and 1970s
(Chapel Hill, 1991); and J. Anthony Lukas, Common Ground: A
Turbulent Decade in the Lives of Three American Families (New
York, 1985). Washington v. Seattle School District, 458 U.S.
457 (1982); Crawford v. Los Angeles Board of Education, 458
U.S. 527 (1982); Milliken v. Bradley, 418 U.S. 717 (1974).
See Gary Orfield and Susan E. Eaton, Dismantling Desegregation:
The Quiet Reversal of Brown v. Board of Education (New York,
1996).
6 Brown v. Board of Education, 347 U.S.
at 494, 493; Gary Orfield and Chungmei Lee, "Brown at Fifty: King's
Dream or Plessy's Nightmare?," Jan. 17, 2004, The Civil Rights
Project, Harvard University <http://www.%20civilrightsproject.harvard.edu/research/reseg04/resegregation04.php>
(April 4, 2004). In every region of the nation, at least 30% black
students still attend schools with less than 10% white enrollment.
Ibid.
7 Cf. Melba Beals, Warriors Don't Cry: A
Searing Memoir of the Battle to Integrate Little Rock's Central
High (New York, 1995); and Melba Beals, White Is a State of
Mind: A Memoir (New York, 1995).
8 Sweatt v. Painter, 339 U.S. 629
(1950); Baltimore Afro-American, June 17, 1950, quoted in
Juan Williams, Thurgood Marshall: American Revolutionary (New
York, 1998), 195; Thurgood Marshall, "An Evaluation of Recent
Efforts to Achieve Racial Integration in Education through Resort to
the Courts," Journal of Negro Education, 21 (Summer 1952),
316–27, esp. 322.
9 J. S. Coleman et al., Equality of
Educational Opportunity (Washington, 1966), passim; Report of
the National Advisory Commission on Civil Disorders (New York,
1968), 1; Martin Luther King Jr., Where Do We Go from Here: Chaos
or Community? (New York, 1967), 228. For Constance Baker
Motley's statement (quoted from theNew York Times, May 13, 1974),
see James T. Patterson, Brown v. Board of Education: A Civil
Rights Milestone and Its Troubled Legacy (New York, 2001), 168.
10 Brown v. Board of Education, 349
U.S. 294 (1955); W. E. B. Du Bois, "Does the Negro Need Separate
Schools?," Journal of Negro Education, 4 (July 1935), in
The Oxford W. E. B. Du Bois Reader, ed. Eric J. Sundquist
(New York, 1996), 431.
11 "Brown v. Board of Education of
Topeka: Opinion on Segregation Laws," in Civil Rights and
African Americans: A Documentary History, ed. Albert P.
Blaustein and Robert L. Zangrando (Evanston, 1991), 436. |
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