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Sweatt v. Painter, decided in 1950, was one of the court cases that was a precursor to the much more famous Brown v. Board of Education case four years later. Sweatt was used as a way of building towards the ruling that the NAACP wanted in Brown.
The NAACP wanted to have segregation in schools declared unconstitutional. The major legal stumbling block in the way was the Plessy decision from 1896. In that case, the Court had held that racial segregation was legal so long as the accommodations for the races were “separate but equal.” In the years after that, it became very clear that African Americans were not being given equal schools of their own. Sweatt was about that issue.
In this case, Heman Sweatt was rejected for admission to the University of Texas law school because he was black. When Sweatt sued, Texas tried to create a new law school for African Americans as there was no such school at that time. They presented this school as equal to the University of Texas law school even though it was new and had no history and no alumni. This was an interesting claim to make in front of Associate Justice Tom Clark, who was a Texas alumnus and probably felt that his law school was better than a brand new school and who surely knew the value of an alumni network.
For these sorts of reasons, the Court ruled that a separate law school could not be equal. It could never have the prestige of the University of Texas law school and could therefore not satisfy the “separate but equal” rule. The NAACP used this ruling to help move the Court towards ruling that all segregation in education was illegal in 1954.
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