Mississippi University for Women v. Hogan
Encyclopedia
Mississippi University for Women v. Hogan, 458 U.S. 718
(1982) was a case decided 5-4 by the Supreme Court of the United States
. The court held that the single-sex admissions
policy of the Mississippi University for Women
violated the Equal Protection Clause
of the Fourteenth Amendment to the United States Constitution
. http://www.law.cornell.edu/supct/html/historics/USSC_CR_0458_0718_ZO.html
and previously named Industrial Institute and College and Mississippi State College for Women. It was the first state-supported women's college in the United States
. In 1971, the School of Nursing was established, initially offering a two-year associate's degree
and later four-year baccalaureate degree and graduate degree program.
In 1979, Joe Hogan, a registered nurse
and nursing supervisor in Columbus who did not have a baccalaureate degree in nursing, applied for admission to the MUW School of Nursing's baccalaureate program. Although he was otherwise qualified, he was denied admission to the School of Nursing. School officials provided the option to audit courses in which he was interested, but could not enroll for credit because he was male. Hogan could have attended classes and received credit in one of Mississippi's two public
, coeducation
al programs leading to a Bachelor of Science in Nursing
, but these were at the University of Southern Mississippi in Hattiesburg
(178 miles from Columbus) and the University of Mississippi
in Oxford
(114 miles from Columbus). Hogan filed an action
in the United States District Court for the Northern District of Mississippi
, claiming the single-sex admissions policy of MUW's School of Nursing violated the Equal Protection Clause of the Fourteenth Amendment and seeking injunctive
and declaratory relief
as well as compensatory damages.
to the State's legitimate interest "in providing the greatest practical range of educational opportunities for its female student population." The admissions policy was not arbitrary, providing single-sex schools is consistent with a respected, though by no means universally accepted, educational theory that single-sex education affords unique benefits to students. Stating that the case presented no issue of fact, the court informed Hogan that it would enter summary judgment
dismissing his claim unless he tendered a factual issue. When Hogan offered no further evidence, the District Court entered summary judgment in favor of the State.http://www.mensbiz.net/subpage%20mississippi%20university.html
The Court of Appeals for the Fifth Circuit reversed, holding that because the admissions policy discriminated on the basis of gender, a rational relationship test as improper, and the proper test was whether the gender-based admissions policy was substantially related
to an important governmental objective. The court, while recognizing that the State has a significant interest in providing educational opportunities for all its citizens, found that the State failed to show that providing a unique educational opportunity for females but not for males had any substantial relationship to that interest.
The court's ruling did not require that the entire university become coeducational; however, the Board of Trustees of Mississippi State Institutions of Higher Learning ordered the university to change its policies to allow the admission of qualified males into all university programs.http://www.ihl.state.ms.us/universities.html Today MUW’s student body is approximately 15% male.http://www.ihl.state.ms.us/research/fast_facts_0506.pdf
The court's ruling also did not require the school to change the name of the school, and as a result the school remains "Mississippi University for Women." Suits have been filed against the university to change the name claiming that its name and mission discourage males from applying for admission. These suits were dismissed as groundless and had no effect on the name.
The most recent administration of the university considered changing the namehttp://www.muw.edu/publicaffairs/2002_prnews/021119_name_change_1.html and pursued efforts to do so, despite opposition, particularly from alumni.http://meridianstar.com/local/x681116449/MUW-name-change-doesn-t-sit-well-with-some-locals In her convocation speech on 11 August 2008, President Limbert announced a proposal to change the name of the university, to remove "women" from the university's name.http://www.cdispatch.com/articles/2008/08/11/local_news/local02.txt
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1982) was a case decided 5-4 by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
. The court held that the single-sex admissions
Single-sex education
Single-sex education, also known as single-gender education, is the practice of conducting education where male and female students attend separate classes or in separate buildings or schools. The practice was predominant before the mid-twentieth century, particularly in secondary education and...
policy of the Mississippi University for Women
Mississippi University for Women
Mississippi University for Women, also known as MUW or simply the "W" is a four-year coeducational public university located in Columbus, Mississippi. It was formerly known as Industrial Institute and College and later Mississippi State College for Women...
violated the Equal Protection Clause
Equal Protection Clause
The Equal Protection Clause, part of the Fourteenth Amendment to the United States Constitution, provides that "no state shall ... deny to any person within its jurisdiction the equal protection of the laws"...
of the Fourteenth Amendment to the United States Constitution
Fourteenth Amendment to the United States Constitution
The Fourteenth Amendment to the United States Constitution was adopted on July 9, 1868, as one of the Reconstruction Amendments.Its Citizenship Clause provides a broad definition of citizenship that overruled the Dred Scott v...
. http://www.law.cornell.edu/supct/html/historics/USSC_CR_0458_0718_ZO.html
Background of the case
The Mississippi University for Women was established in 1884 in Columbus, MississippiColumbus, Mississippi
Columbus is a city in Lowndes County, Mississippi, United States that lies above the Tombigbee River. It is approximately northeast of Jackson, north of Meridian, south of Tupelo, northwest of Tuscaloosa, Alabama, and west of Birmingham, Alabama. The population was 25,944 at the 2000 census...
and previously named Industrial Institute and College and Mississippi State College for Women. It was the first state-supported women's college in the United States
Women's colleges in the United States
Women's colleges in the United States are single-sex U.S. institutions of higher education that exclude or limit males from admission. They are often liberal arts colleges...
. In 1971, the School of Nursing was established, initially offering a two-year associate's degree
Associate's degree
An associate degree is an undergraduate academic degree awarded by community colleges, junior colleges, technical colleges, and bachelor's degree-granting colleges and universities upon completion of a course of study usually lasting two years...
and later four-year baccalaureate degree and graduate degree program.
In 1979, Joe Hogan, a registered nurse
Registered nurse
A registered nurse is a nurse who has graduated from a nursing program at a university or college and has passed a national licensing exam. A registered nurse helps individuals, families, and groups to achieve health and prevent disease...
and nursing supervisor in Columbus who did not have a baccalaureate degree in nursing, applied for admission to the MUW School of Nursing's baccalaureate program. Although he was otherwise qualified, he was denied admission to the School of Nursing. School officials provided the option to audit courses in which he was interested, but could not enroll for credit because he was male. Hogan could have attended classes and received credit in one of Mississippi's two public
Public university
A public university is a university that is predominantly funded by public means through a national or subnational government, as opposed to private universities. A national university may or may not be considered a public university, depending on regions...
, coeducation
Coeducation
Mixed-sex education, also known as coeducation or co-education, is the integrated education of male and female persons in the same institution. It is the opposite of single-sex education...
al programs leading to a Bachelor of Science in Nursing
Bachelor of Science in Nursing
The Bachelor of Science in Nursing is an American four year academic degree in the science and principles of nursing, granted by a tertiary education university or similarly accredited school...
, but these were at the University of Southern Mississippi in Hattiesburg
Hattiesburg, Mississippi
Hattiesburg is a city in Forrest County, Mississippi, United States. The population was 44,779 at the 2000 census . It is the county seat of Forrest County...
(178 miles from Columbus) and the University of Mississippi
University of Mississippi
The University of Mississippi, also known as Ole Miss, is a public, coeducational research university located in Oxford, Mississippi. Founded in 1844, the school is composed of the main campus in Oxford, four branch campuses located in Booneville, Grenada, Tupelo, and Southaven as well as the...
in Oxford
Oxford, Mississippi
Oxford is a city in, and the county seat of, Lafayette County, Mississippi, United States. Founded in 1835, it was named after the British university city of Oxford in hopes of having the state university located there, which it did successfully attract....
(114 miles from Columbus). Hogan filed an action
Lawsuit
A lawsuit or "suit in law" is a civil action brought in a court of law in which a plaintiff, a party who claims to have incurred loss as a result of a defendant's actions, demands a legal or equitable remedy. The defendant is required to respond to the plaintiff's complaint...
in the United States District Court for the Northern District of Mississippi
United States District Court for the Northern District of Mississippi
The United States District Court for the Northern District of Mississippi is a federal court in the Fifth Circuit with facilities in Aberdeen, Ackerman, Clarksdale, Cleveland, Corinth, Greenville, and Oxford....
, claiming the single-sex admissions policy of MUW's School of Nursing violated the Equal Protection Clause of the Fourteenth Amendment and seeking injunctive
Injunction
An injunction is an equitable remedy in the form of a court order that requires a party to do or refrain from doing certain acts. A party that fails to comply with an injunction faces criminal or civil penalties and may have to pay damages or accept sanctions...
and declaratory relief
Declaratory relief
Declaratory relief is a judge's determination of the parties' rights under a contract or a statute, often requested in a lawsuit over a contract. In theory, an early resolution of legal rights will resolve some or all of the other issues in the matter....
as well as compensatory damages.
Case history
The District Court ruled in favor of the Mississippi University for Women, concluding that maintenance of MUW as a single-sex school bears a rational relationshipRational basis review
Rational basis review, in U.S. constitutional law, refers to a level of scrutiny applied by courts when deciding cases presenting constitutional due process or equal protection issues related to the Fifth Amendment or Fourteenth Amendment. Rational basis is the lowest level of scrutiny that a...
to the State's legitimate interest "in providing the greatest practical range of educational opportunities for its female student population." The admissions policy was not arbitrary, providing single-sex schools is consistent with a respected, though by no means universally accepted, educational theory that single-sex education affords unique benefits to students. Stating that the case presented no issue of fact, the court informed Hogan that it would enter summary judgment
Summary judgment
In law, a summary judgment is a determination made by a court without a full trial. Such a judgment may be issued as to the merits of an entire case, or of specific issues in that case....
dismissing his claim unless he tendered a factual issue. When Hogan offered no further evidence, the District Court entered summary judgment in favor of the State.http://www.mensbiz.net/subpage%20mississippi%20university.html
The Court of Appeals for the Fifth Circuit reversed, holding that because the admissions policy discriminated on the basis of gender, a rational relationship test as improper, and the proper test was whether the gender-based admissions policy was substantially related
Intermediate scrutiny
Intermediate scrutiny, in U.S. constitutional law, is the second level of deciding issues using judicial review. The other levels are typically referred to as rational basis review and strict scrutiny ....
to an important governmental objective. The court, while recognizing that the State has a significant interest in providing educational opportunities for all its citizens, found that the State failed to show that providing a unique educational opportunity for females but not for males had any substantial relationship to that interest.
The court's ruling did not require that the entire university become coeducational; however, the Board of Trustees of Mississippi State Institutions of Higher Learning ordered the university to change its policies to allow the admission of qualified males into all university programs.http://www.ihl.state.ms.us/universities.html Today MUW’s student body is approximately 15% male.http://www.ihl.state.ms.us/research/fast_facts_0506.pdf
The court's ruling also did not require the school to change the name of the school, and as a result the school remains "Mississippi University for Women." Suits have been filed against the university to change the name claiming that its name and mission discourage males from applying for admission. These suits were dismissed as groundless and had no effect on the name.
The most recent administration of the university considered changing the namehttp://www.muw.edu/publicaffairs/2002_prnews/021119_name_change_1.html and pursued efforts to do so, despite opposition, particularly from alumni.http://meridianstar.com/local/x681116449/MUW-name-change-doesn-t-sit-well-with-some-locals In her convocation speech on 11 August 2008, President Limbert announced a proposal to change the name of the university, to remove "women" from the university's name.http://www.cdispatch.com/articles/2008/08/11/local_news/local02.txt
See also
- Gender equalityGender equalityGender equality is the goal of the equality of the genders, stemming from a belief in the injustice of myriad forms of gender inequality.- Concept :...
- List of gender equality lawsuits
- List of United States Supreme Court cases, volume 458