Murray v. Pearson
Encyclopedia
Pearson v. Murray was a Maryland Court of Appeals
decision which found "the state has undertaken the function of education in the law, but has omitted students of one race from the only adequate provision made for it, and omitted them solely because of their color." On January 15, 1936, the court affirmed
the lower court ruling which ordered the university to immediately integrate its student population.
sought admission to the University of Maryland School of Law
on January 24, 1935, but his application was rejected on account of his race
. The rejection letter stated, "The University of Maryland does not admit Negro
students and your application is accordingly rejected." The letter noted the university's duty under the Plessy v. Ferguson
doctrine of separate but equal
to assist him in studying elsewhere, even at a law school located out-of-state. Murray appealed this rejection to the Board of Regents of the university, but was refused admittance.
The nation's oldest black collegiate fraternity
, Alpha Phi Alpha
, initiated Pearson v. Murray on June 25, 1935 as part of its widening social program, and retained Belford Lawson
to litigate the case. By the time the case reached court, Murray was represented by Charles Hamilton Houston
and Thurgood Marshall
of the Baltimore National Association for the Advancement of Colored People
(NAACP). Houston and Marshall used Pearson v. Murray as the NAACP's first case to test Nathan Ross Margold's strategy to attack the 'separate but equal
' doctrine using the equal protection clause
of the Fourteenth Amendment
to the U.S. Constitution. Margold concluded "such laws administering such a system were denying equal protection of law under the Yick Wo v. Hopkins
ruling of 1886 and therefore were unconstitutional.
At the circuit court hearing, Marshall stated that Maryland failed to provide a 'separate but equal' education for Murray as required by the Fourteenth Amendment (using the legal standard at that time). Since laws differ from state to state, a law school located in another state could not prepare a future attorney for a career in Maryland. Marshall argued in principle that "since the State of Maryland had not provided a comparable law school for blacks that Murray should be allowed to attend the white university" and stated
The circuit court judge issued a writ of mandamus
ordering Raymond A. Pearson, president of the university, to admit Murray to the law school.
. The NAACP's legal strategy of attacking segregation by demanding equal access to public facilities that could not be easily duplicated was followed in later lawsuits with mixed results. In Williams v. Zimmerman, a case appealed to the Maryland Court of Appeals, Marshall in 1937 failed in an effort to desegregate a high school in Baltimore County, which had no public high schools for black teenagers. The legal strategy was successful in the desegration of Baltimore City's Baltimore Polytechnic Institute
in 1952. It was not until 1954 until Brown v. Board of Education
mandated desegregation
across the whole of the United States
. Brown also overturned the Plessy v. Ferguson 'separate but equal' standard as comporting with the Equal Protection Clause of the Fourteenth Amendment as used in Murray.
Maryland Court of Appeals
The Court of Appeals of Maryland is the supreme court of the U.S. state of Maryland. The court, which is composed of one chief judge and six associate judges, meets in the Robert C. Murphy Courts of Appeal Building in the state capital, Annapolis...
decision which found "the state has undertaken the function of education in the law, but has omitted students of one race from the only adequate provision made for it, and omitted them solely because of their color." On January 15, 1936, the court affirmed
Affirmation in law
In law, an affirmation is a solemn declaration allowed to those who conscientiously object to taking an oath. An affirmation has exactly the same legal effect as an oath, but is usually taken to avoid the religious implications of an oath...
the lower court ruling which ordered the university to immediately integrate its student population.
Circuit court case
Donald Gaines MurrayDonald Gaines Murray
Donald Gaines Murray, Sr. was the first African-American to enter the University of Maryland School of Law since 1890 as a result of winning the landmark civil rights case Murray v...
sought admission to the University of Maryland School of Law
University of Maryland School of Law
The University of Maryland Francis King Carey School of Law is the second-oldest law school in the United States by date of establishment and third-oldest by date of first classes. The school is located on the campus of the University of Maryland, Baltimore in Downtown Baltimore's West Side...
on January 24, 1935, but his application was rejected on account of his race
Black people
The term black people is used in systems of racial classification for humans of a dark skinned phenotype, relative to other racial groups.Different societies apply different criteria regarding who is classified as "black", and often social variables such as class, socio-economic status also plays a...
. The rejection letter stated, "The University of Maryland does not admit Negro
Negro
The word Negro is used in the English-speaking world to refer to a person of black ancestry or appearance, whether of African descent or not...
students and your application is accordingly rejected." The letter noted the university's duty under the Plessy v. Ferguson
Plessy v. Ferguson
Plessy v. Ferguson, 163 U.S. 537 , is a landmark United States Supreme Court decision in the jurisprudence of the United States, upholding the constitutionality of state laws requiring racial segregation in private businesses , under the doctrine of "separate but equal".The decision was handed...
doctrine of separate but equal
Separate but equal
Separate but equal was a legal doctrine in United States constitutional law that justified systems of segregation. Under this doctrine, services, facilities and public accommodations were allowed to be separated by race, on the condition that the quality of each group's public facilities was to...
to assist him in studying elsewhere, even at a law school located out-of-state. Murray appealed this rejection to the Board of Regents of the university, but was refused admittance.
The nation's oldest black collegiate fraternity
Fraternities and sororities
Fraternities and sororities are fraternal social organizations for undergraduate students. In Latin, the term refers mainly to such organizations at colleges and universities in the United States, although it is also applied to analogous European groups also known as corporations...
, Alpha Phi Alpha
Alpha Phi Alpha
Alpha Phi Alpha is the first Inter-Collegiate Black Greek Letter fraternity. It was founded on December 4, 1906 at Cornell University in Ithaca, New York. Its founders are known as the "Seven Jewels". Alpha Phi Alpha developed a model that was used by the many Black Greek Letter Organizations ...
, initiated Pearson v. Murray on June 25, 1935 as part of its widening social program, and retained Belford Lawson
Belford Lawson, Jr.
Belford Vance Lawson, Jr. was an American attorney and civil rights activist who made at least eight appearances before the U.S. Supreme Court...
to litigate the case. By the time the case reached court, Murray was represented by Charles Hamilton Houston
Charles Hamilton Houston
Charles Hamilton Houston was an African American lawyer, Dean of Howard University Law School and NAACP Litigation Director who played a significant role in dismantling the Jim Crow laws and trained future Supreme Court Justice Thurgood Marshall.Houston was born in Washington, D.C. His father...
and Thurgood Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
of the Baltimore National Association for the Advancement of Colored People
National Association for the Advancement of Colored People
The National Association for the Advancement of Colored People, usually abbreviated as NAACP, is an African-American civil rights organization in the United States, formed in 1909. Its mission is "to ensure the political, educational, social, and economic equality of rights of all persons and to...
(NAACP). Houston and Marshall used Pearson v. Murray as the NAACP's first case to test Nathan Ross Margold's strategy to attack the 'separate but equal
Separate but equal
Separate but equal was a legal doctrine in United States constitutional law that justified systems of segregation. Under this doctrine, services, facilities and public accommodations were allowed to be separated by race, on the condition that the quality of each group's public facilities was to...
' doctrine using 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
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...
to the U.S. Constitution. Margold concluded "such laws administering such a system were denying equal protection of law under the Yick Wo v. Hopkins
Yick Wo v. Hopkins
Yick Wo v. Hopkins, 118 U.S. 356 , was the first case where the United States Supreme Court ruled that a law that is race-neutral on its face, but is administered in a prejudicial manner, is an infringement of the Equal Protection Clause in the Fourteenth Amendment to the U.S...
ruling of 1886 and therefore were unconstitutional.
At the circuit court hearing, Marshall stated that Maryland failed to provide a 'separate but equal' education for Murray as required by the Fourteenth Amendment (using the legal standard at that time). Since laws differ from state to state, a law school located in another state could not prepare a future attorney for a career in Maryland. Marshall argued in principle that "since the State of Maryland had not provided a comparable law school for blacks that Murray should be allowed to attend the white university" and stated
The circuit court judge issued a writ of mandamus
Mandamus
A writ of mandamus or mandamus , or sometimes mandate, is the name of one of the prerogative writs in the common law, and is "issued by a superior court to compel a lower court or a government officer to perform mandatory or purely ministerial duties correctly".Mandamus is a judicial remedy which...
ordering Raymond A. Pearson, president of the university, to admit Murray to the law school.
Appeal to Maryland Court of Appeals
The ruling was appealed to Maryland's highest court, the Court of Appeals. This court, in a unanimous decision, affirmed the lower court ruling in 1936. The decision did not outlaw segregation in education throughout Maryland, but noted the state's requirement under the Fourteenth Amendment, as it was understood at that time, to provide substantially an equal treatment in the facilities it provides from public funds. Since Maryland chose to only provide one law school for use by students in the state, that law school had to be available to all races.Impact of the decision
The decision of the Court of Appeals was never taken to the U.S. Supreme Court, and as such the ruling was not binding outside of Maryland; the Supreme Court addressed the same issue in 1938 in Missouri ex rel. Gaines v. CanadaMissouri ex rel. Gaines v. Canada
Missouri ex rel. Gaines v. Canada, 305 U.S. 337 , was a United States Supreme Court decision holding that states that provide a school to white students must provide in-state education to blacks as well...
. The NAACP's legal strategy of attacking segregation by demanding equal access to public facilities that could not be easily duplicated was followed in later lawsuits with mixed results. In Williams v. Zimmerman, a case appealed to the Maryland Court of Appeals, Marshall in 1937 failed in an effort to desegregate a high school in Baltimore County, which had no public high schools for black teenagers. The legal strategy was successful in the desegration of Baltimore City's Baltimore Polytechnic Institute
Baltimore Polytechnic Institute
Baltimore Polytechnic Institute is a US public high school founded in 1883. Though established as an all-male trade school,it now is a institution that emphasizes mathematics, the sciences, and engineering. It is located on a tract of land in North Baltimore at Falls Road and Cold Spring Lane,...
in 1952. It was not until 1954 until Brown v. Board of Education
Brown v. Board of Education
Brown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court that declared state laws establishing separate public schools for black and white students unconstitutional. The decision overturned the Plessy v. Ferguson decision of 1896 which...
mandated desegregation
Desegregation
Desegregation is the process of ending the separation of two groups usually referring to races. This is most commonly used in reference to the United States. Desegregation was long a focus of the American Civil Rights Movement, both before and after the United States Supreme Court's decision in...
across the whole of the United States
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
. Brown also overturned the Plessy v. Ferguson 'separate but equal' standard as comporting with the Equal Protection Clause of the Fourteenth Amendment as used in Murray.
See also
- Yick Wo v. HopkinsYick Wo v. HopkinsYick Wo v. Hopkins, 118 U.S. 356 , was the first case where the United States Supreme Court ruled that a law that is race-neutral on its face, but is administered in a prejudicial manner, is an infringement of the Equal Protection Clause in the Fourteenth Amendment to the U.S...
- Missouri ex rel. Gaines v. CanadaMissouri ex rel. Gaines v. CanadaMissouri ex rel. Gaines v. Canada, 305 U.S. 337 , was a United States Supreme Court decision holding that states that provide a school to white students must provide in-state education to blacks as well...
- Brown v. Board of EducationBrown v. Board of EducationBrown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court that declared state laws establishing separate public schools for black and white students unconstitutional. The decision overturned the Plessy v. Ferguson decision of 1896 which...