Landmark Supreme Court Case: Sweatt v. Painter (1950)
Sweatt v. Painter (1950) is the 94th landmark Supreme Court case, twelfth 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
- 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.
Sweatt v Painter (1950)
In 1946, Heman Marion Sweatt, a black man, applied for admission to the University of Texas Law School whose President was Theophilus Painter. The Texas state constitution prohibited integrated education; thus, restricted access to the university to whites resulting in the automatically rejection of Sweatt’s application due to his race.
When Sweatt asked the state courts to order his admission, the state district court in Travis County, Texas, instead of granting the plaintiff a right of mandamus, continued the case for six months. This allowed the state time to create a law school only for black students, which it established in Houston, rather than in Austin. The ‘separate’ law school and the college became the Thurgood Marshall School of Law at Texas Southern University (known then as “Texas State University for Negroes”).
The trial court decision was affirmed by the Court of Civil Appeals and the Texas Supreme Court denied writ of error on further appeal. Sweatt and the NAACP next went to the federal courts, and the case ultimately reached the U.S. Supreme Court.
Q: Did the Texas admissions scheme violate the Equal Protection Clause of the Fourteenth Amendment?
A: Yes. The Equal Protection Clause of the Fourteenth Amendment required Sweatt’s admission to the University of Texas Law School
Unanimous holding the Equal Protection Clause of the Fourteenth Amendment requires that petitioner be admitted to the University of Texas Law School. The Supreme Court reversed the lower court decision, saying that the separate school failed to qualify, both because of quantitative differences in facilities and experiential factors, such as its isolation from most of the future lawyers with whom its graduates would interact. The court held that, when considering graduate education, experience must be considered as part of “substantive equality.” The documentation of the court’s decision includes the following differences identified between white and black facilities:
- The University of Texas Law School had 16 full-time and 3 part-time professors, while the black law school had 5 full-time professors.
- The University of Texas Law School had 850 students and a law library of 65,000 volumes, while the black law school had 23 students and a library of 16,500 volumes.
- The University of Texas Law School had moot court facilities, an Order of the Coif affiliation, and numerous graduates involved in public and private law practice, while the black law school had only one practice court facility and only one graduate admitted to the Texas Bar.
The Court argued that the separate school would be inferior in a number of areas, including faculty, course variety, library facilities, legal writing opportunities, and overall prestige. The Court also found that the mere separation from the majority of law students harmed students’ abilities to compete in the legal arena.
Next Politics, Society, Freedom and Equality Case: Brown v. Board of Education (1954)
Previous Politics, Society, Freedom, and Equality Case: Shelley v. Kraemer (1948)
Next Case: Dennis v. United States (1951)
Previous Case: Wolf v. Colorado (1949)