Landmark Supreme Court Case: Missouri ex rel Gaines v. Canada (1938)
Missouri ex rel Gaines v. Canada (1938) is the 75th landmark Supreme Court case, eighth in the Politics, Society, Freedom and Equality module, featured in the KTB Prep American Government and Civics Series designed to acquaint users with the origins, concepts, organizations, and policies of the United States government and political system. The goal is greater familiarization with the rights and obligations of citizenship at the local, state, national, and global levels and the history of our nation as a democracy. While there is overlap, these landmark cases are separated into cases addressing:
- Foreign Policy
- Science & Technology
- Public Safety
- Death Penalty
- Speech, Press, and Protest
- Criminal Justice
- Politics, Society, Freedom, and Equality
The Supreme Court
The Supreme Court is the highest court in the United States. Article III of the U.S. Constitution created the Supreme Court and authorized Congress to pass laws establishing a system of lower courts. The Constitution elaborated neither the exact powers and prerogatives of the Supreme Court nor the organization of the Judicial Branch as a whole. Thus, it has been left to Congress and to the Justices of the Court through their decisions to develop the Federal Judiciary and a body of Federal law.
The number of Justices on the Supreme Court changed six times before settling at the present total of nine in 1869. Since the formation of the Court in 1790, there have been only 17 Chief Justices* and 102 Associate Justices, with Justices serving for an average of 16 years. On average a new Justice joins the Court almost every two years.
The Supreme Court of the United States hears about 100 to 150 appeals of the more than 7,000 cases it is asked to review every year. That means the decisions made by the 12 Circuit Courts of Appeals across the country and the Federal Circuit Court are the last word in thousands of cases.
Court of Appeals
In the federal court system’s present form, 94 district level trial courts and 13 courts of appeals sit below the Supreme Court. The 94 federal judicial districts are organized into 12 regional circuits, each of which has a court of appeals. The appellate court’s task is to determine whether or not the law was applied correctly in the trial court. Appeals courts consist of three judges and do not use a jury.
The appellate courts do not retry cases or hear new evidence. They do not hear witnesses testify. There is no jury. Appellate courts review the procedures and the decisions in the trial court to make sure that the proceedings were fair and that the proper law was applied correctly.
A court of appeals hears challenges to district court decisions from courts located within its circuit, as well as appeals from decisions of federal administrative agencies. In addition, the Court of Appeals for the Federal Circuit has nationwide jurisdiction to hear appeals in specialized cases, such as those involving patent laws, and cases decided by the U.S. Court of International Trade and the U.S. Court of Federal Claims.
The nation’s 94 trial courts are called U.S. District Courts. At a trial in a U.S. District Court, witnesses give testimony and a judge or jury decides who is guilty or not guilty — or who is liable or not liable. District courts resolve disputes by determining the facts and applying legal principles to decide who is right.
Trial courts include the district judge who tries the case and a jury that decides the case. Magistrate judges assist district judges in preparing cases for trial. They may also conduct trials in misdemeanor cases.
There is at least one district court in each state, and the District of Columbia. Each district includes a U.S. bankruptcy court as a unit of the district court.
Federal courts have exclusive jurisdiction over bankruptcy cases involving personal, business, or farm bankruptcy. This means a bankruptcy case cannot be filed in state court. Bankruptcy Appellate Panels (BAPs) are 3-judge panels authorized to hear appeals of bankruptcy court decisions. These panels are a unit of the federal courts of appeals, and must be established by that circuit. Five circuits have established panels: First Circuit, Sixth Circuit, Eighth Circuit, Ninth Circuit, and Tenth Circuit.
Missouri ex rel Gaines v. Canada (1938)
Missouri ex rel Gaines Facts:
Lloyd Gaines graduated from Lincoln University, a public university specifically for black students, in 1935. Because Lincoln University did not have a law school, he applied to the University of Missouri Law School.
The Registrar at the Law School of the University of Missouri, Silas Woodson Canada, refused admission to Lloyd Gaines because he was black and admitting him would be contrary to Missouri’s state constitution, laws, and public policy. At the time, blacks could attend no law school specifically in the state. Gaines cited that the refusal violated the Fourteenth Amendment though the State of Missouri had offered to pay for Gaines’s tuition at an adjacent state’s law school, which he turned down.
Gaines, assisted by the NAACP, sued the all-white university in 1935 to force the Board of Regents to admit him. The circuit court denied his petitions, and the Supreme Court of Missouri affirmed.
Q: Did Gaines’ denial of admission to the University of Missouri Law School violate the Equal Protection Clause of the Fourteenth Amendment?
A: Yes. The Court held that by establishing Lincoln University as a state university for black students, the state of Missouri established precedent for providing equal opportunity in higher education for both black and white students.; therefore, the denial of access to legal education was unlawful discrimination.
Missouri ex rel Gaines Conclusion
6-2 holding states that provide only one educational institution must allow blacks and whites to attend if there is no separate school for blacks. The state’s intent to eventually create a law school at Lincoln University was not enough to absolve the responsibility to provide a legal education in this case. The Court held that Missouri failed in its constitutional duty to provide equal protection under the law by failing to provide equal access to public education within the state.
States could satisfy this requirement by allowing blacks and whites to attend the same school or creating a second school for blacks.
The decision did not quite strike down separate but equal facilities, upheld in Plessy v. Ferguson (1896). Instead, it provided that if there was only one school, students of all races could be admitted. The decision struck down segregation by exclusion if the government provided just one school, making the decision in this case a precursor to Brown v. Board of Education (1954).
This marked the beginning of the Court’s reconsideration of Plessy. The Court did not overturn or violate the “separate but equal” precedents, but began to concede the difficulty and near-impossibility of a state maintaining segregated black and white institutions that could never be truly equal. Therefore, it can be said that this case helped forge the legal framework for Brown v. Board of Education (1954) which banned segregation in public schools.
Despite the initial victory claimed by the NAACP, after the Supreme Court had ruled in Gaines’ favor and ordered the Missouri Supreme Court to reconsider the case, Gaines was nowhere to be found. When the University of Missouri soon after moved to dismiss the case, the NAACP did not oppose the motion.
Next Politics, Society, Freedom, and Equality Case: Hirabayashi v. U.S. (1943)
Previous Politics, Society, Freedom, and Equality Case: Buchanan v. Warley (1917)
Next Case: Hague v. CIO (1939)
Previous Case: Erie Railroad v. Tompkins (1938)