A Case Analysis of Plessy v. Ferguson Case and Brown v. Board of Education of Topeka on the Separate But Equal Doctrine in the United States

Case Facts: The Plessy v. Ferguson case deals with the "separate but equal" doctrine in the United States. It comes from the State of Louisiana, where they hold that passengers of different race must be provided with equal, but separate, accommodations in society. This case happened to deal with the seating situation on a train where the coaches were separated equally, by race, and a man who was of mixed decent.

Interestingly enough, Mr. Plessy was of majority Caucasian blood (7/8th), but he was seen as an African-American man (1/8th). By sitting in the white section ot the train, Mr. Plessy was subject to arrest, ejection from the train, or a fine decided by the court. He was ejected from the train by police force (541), because his portion African-American descent required him to sit separately, but equally, away from the white section of he train. This case made it through both the District and State Supreme Courts, before reaching the United States supreme Court. The Decision: Justice Brown wrote the decision of the court, and the vote was 7-to-1 in favor of Ferguson in this case. The question that is asked is whether or not the state law of Louisiana of segregation on trains unconstitutional on the grounds that it infringes on the equal protection clauses of the Fourteenth Amendment. In the opinion of Justice Brown, this case wishes to call into question the Constitutionality of the Fourteenth Amendment, and the separate but equal clause. The Court says here that in all actuality the Fourteenth Amendment was created to protect the African-American race from hostile legislation created in the United States (544).

They continue to read this Amendment as a way to create equality, but not a way to abolish separation of things based on color. The court affirmed that the state law of Louisiana was acceptable because it did not violate the separate but equal clause. "If the civil and political rights of both races be equal, one cannot be inferior to the other civilly or politically. If one race be inferior to the other socially, the Constitution of the United States cannot put them upon the same plane (552). So, the segregation of the states is not unconstitutional, as long as everything is placed upon an equal scale. Dissenting Opinion: Justice Harlan was the only Supreme Court justice to go against the majority in the Plessy v. Ferguson case. Justice Harlan felt that the law in Louisiana was inconsistent with the personal liberty of the citizens of that state. Regardless of their skin color, Harlan felt that their entire freedom was being slighted because of this legislation regarding "separate but equal" opportunities and locations in the United States. He felt that this went against the meanings of both the Thirteenth and Fourteenth Amendments, because they guaranteed the freedoms for all races, yet this law was prohibiting those freedoms that had been guaranteed (564).

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Case Name: Brown v. Board of Education of Topeka, 347 US 438 (1954) Case Facts: This case was based upon the "separate but equal" doctrine adopted in the Plessy v. Ferguson case. The court is asked to call into question whether Negro children are protected1 by the equal protection laws provided under the Fourteenth Amendment in regards to public schools. Before this case, the Fourteenth Amendment's interpreted stance had been inconclusive as to what it was supposed to do for the public education system in the United States. Should it be decided on a state-by-state basis? Or should the Federal government take the reins and finally set the regulations? This case wasn't solely based out of Kansas, and there were actually many other states wanting a ruling obtaining to similar legal questions. The court decided to have all case banded into one so their ruling would be all knowing for each state. Each case had to deal with "minors of the Negro race" seeking admission to public schools that were originally whites only (488).

No schools had ever been integrated because "separate but equal" had been determined legal under the Fourteenth Amendment, which stemmed from the Plessy v. Ferguson decision. The plaintiffs in this case claim that segregated schools cannot be equal, because the minority children are not given an equal opportunity to learn at a high level. There were three states to confirm that the "separate but equal" doctrine was legal in schools, but Delaware decided to admit Negro children into the white schools because they were superior (489). The court set out to decide how the "separate but equal" doctrine affected white and Negro children whose schools were segregated. The Decision: The decision was a unanimous decision, and Chief Justice Warren wrote the opinion. Chief Justice Warren is sure to point out that the doctrine of "separate but equal" did not appear in any court case, until the Plessy v. Ferguson decision, and he goes on to say that many cases have made it to the court dealing with this implied standard. However, WarTen says that the doctrine has never fully been applied to the education system, and if this doctrine does actually deprive the plaintiffs of equal protection of the laws. The question being asked within this opinion is: "Does segregation of children in public schools solely on the basis of race, even though the physical facilities and other "tangible factors may be equal, deprive the children of the minority group of equal educational opportunities?" The Court decides that it does, in fact, deprive minority students from receiving equal protection under the laws set forth by the Fourteenth Amendment.

The Court then concludes their argument by saying that the doctrine of "separate but equal" has no place in the public education systems (496). Their rationale in their determination is based on the grounds that the children may have a sense of inferiority since they are required to learn separately. The effect done to the Negro children through this "separate but equal" doctrine had done nothing but retard their ability to learn to their fullest extent. The long held doctrine that declared that separate facilities were equal facilities was rejected, and was a basic death sentence for state-maintained racial separation. Analysis Both the Plessy v. Ferguson and Brown v. Board of Education case dealt with the question of whether "separate but equal" was acceptable in society. In 1896, it was seen as an acceptable solution to keeping segregation alive. In 1954, however, this doctrine was viewed as rather outdated in its reasoning for keeping races separate. The ambiguity within these two cases, and how they interpreted the law, ended up being about the legality of the due process clause in the Fourteenth Amendment. The due process clause within the Fourteenth Amendment is placed there so no citizens can be denied freedom of life or liberty. The decisions of the court differ in the matter of whether or not this "separate but equal doctrine actually limits people's freedoms in society. The Court in 1896 established that it did not limit their freedoms as long as everything was on an equal plane.

The Court in 1954 established that it did limit their freedoms, because they were prohibiting minority children from receiving the same level of education as the white children. All in all these two cases were not similar in terms of context, (one was about a train car incident, and the other about school children) but the meaning behind them shaped how people dealt with segregation in the United States. It is also important to note that the Plessy case did not involve the protection of education under the "separate but equal" doctrine and for decades after this doctrine was protected under the Fourteenth Amendment. The protection stopped when the Court felt that just because something was separate did not necessarily make it equal. It was a sign that the times were changing in American society. Many Americans, and even the Supreme Court of the land finally understood the inequality in the society. The Supreme Court's values shifted over a period of five decades when the Brown v. Board of Education arrived. They saw the doctrine provided for in the Plessy case as outdated, and that helped them rewrite the laws regarding this doctrine.

The values of the Supreme Court were showcased within the opinion of Chief Justice Warren, because of some of the specific language he used when referring to this outdated situation. He now understands the significance of public education in society, and how the past decisions might not have retlected the importance of it. It's important to consider that since public education was not valued as highly during the time of the Plessy outcome, it could have been a major factor in overriding the decision in Brown. The change over time helped the Supreme Court view that not everything could be separate and equal at the same time, and they expressed their views towards changing that with the Brown v. Board outcome. These two decisions both greatly affected the racial discrepancy in society, but each had a very different outcome.

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