Sweatt v. Painter
Encyclopedia
Sweatt v. Painter, , was a U.S. Supreme Court
case that successfully proved lack of equality, in favor of a black applicant, the "separate but equal
" doctrine of racial segregation
established by the 1896 case Plessy v. Ferguson
. The case was also influential in the landmark case of Brown v. Board of Education
four years later.
The case involved a black
man, Heman Marion Sweatt, who was refused admission to the School of Law
of the University of Texas, whose president was Theophilus Painter
, on the grounds that the Texas State Constitution prohibited integrated education. At the time, no law school in Texas would admit black students, or, in the language of the time, "Negro" students.
The state district court in Travis County, instead of granting the plaintiff a writ 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, Texas
, rather than in Austin. The 'separate' law school and the college became today's Texas Southern University
; the law school is known as the Thurgood Marshall School of Law
. (On June 14, 2005, the Travis County Commissioners voted to rename the courthouse after Mr. Sweatt; the courthouse in which Mr. Sweatt first sought justice is now The Heman Marion Sweatt Travis County Courthouse.)
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. W.J. Durham and Thurgood Marshall
presented Sweatt's case.
The Supreme Court reversed the lower court decision, saying that the separate school failed to qualify, both because of quantitative differences in facilities and intangible 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, intangibles 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:
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...
case that successfully proved lack of equality, in favor of a black applicant, 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 of racial segregation
Racial segregation
Racial segregation is the separation of humans into racial groups in daily life. It may apply to activities such as eating in a restaurant, drinking from a water fountain, using a public toilet, attending school, going to the movies, or in the rental or purchase of a home...
established by the 1896 case 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...
. The case was also influential in the landmark case of 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...
four years later.
The case involved a black
African American
African Americans are citizens or residents of the United States who have at least partial ancestry from any of the native populations of Sub-Saharan Africa and are the direct descendants of enslaved Africans within the boundaries of the present United States...
man, Heman Marion Sweatt, who was refused admission to the School of Law
University of Texas School of Law
The University of Texas School of Law, also known as UT Law, is an ABA-certified American law school located on the University of Texas at Austin campus. The law school has been in operation since the founding of the University in 1883. It was one of only two schools at the University when it was...
of the University of Texas, whose president was Theophilus Painter
Theophilus Painter
Theophilus Shickel Painter was an American zoologist known for his work in identifying genes in fruit flies...
, on the grounds that the Texas State Constitution prohibited integrated education. At the time, no law school in Texas would admit black students, or, in the language of the time, "Negro" students.
The state district court in Travis County, instead of granting the plaintiff 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...
, 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, Texas
Houston, Texas
Houston is the fourth-largest city in the United States, and the largest city in the state of Texas. According to the 2010 U.S. Census, the city had a population of 2.1 million people within an area of . Houston is the seat of Harris County and the economic center of , which is the ...
, rather than in Austin. The 'separate' law school and the college became today's Texas Southern University
Texas Southern University
Texas Southern University is a historically black university located in Houston, Texas, United States....
; the law school is known as the Thurgood Marshall School of Law
Thurgood Marshall School of Law
The Thurgood Marshall School of Law is an ABA accredited law school in Houston, Texas, that awards J.D. . It is part of Texas Southern University.-History:...
. (On June 14, 2005, the Travis County Commissioners voted to rename the courthouse after Mr. Sweatt; the courthouse in which Mr. Sweatt first sought justice is now The Heman Marion Sweatt Travis County Courthouse.)
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
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...
next went to the federal courts, and the case ultimately reached the U.S. Supreme Court. W.J. Durham and Thurgood Marshall
Thurgood Marshall
Thurgood Marshall was an Associate Justice of the United States Supreme Court, serving from October 1967 until October 1991...
presented Sweatt's case.
The Supreme Court reversed the lower court decision, saying that the separate school failed to qualify, both because of quantitative differences in facilities and intangible 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, intangibles 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 libraryLaw libraryA law library is a library designed to assist law students, attorneys, judges, and their law clerks and anyone else who finds it necessary to correctly determine the state of the law....
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 courtMoot courtA moot court is an extracurricular activity at many law schools in which participants take part in simulated court proceedings, usually to include drafting briefs and participating in oral argument. The term derives from Anglo Saxon times, when a moot was a gathering of prominent men in a...
facilities, an Order of the CoifOrder of the CoifThe Order of the Coif is an honor society for United States law school graduates. A student at an American law school who earns a Juris Doctor degree and graduates in the top 10 percent of his or her class is eligible for membership if the student's law school has a chapter of the...
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.
See also
- List of United States Supreme Court cases, volume 339
- Sipuel v. Board of Regents of Univ. of Okla.Sipuel v. Board of Regents of Univ. of Okla.Sipuel v. Board of Regents of Univ. of Okla., 332 U.S. 631 is a United States Supreme Court case that dealt with the Fourteenth Amendment to the United States Constitution....
- - McLaurin v. Oklahoma State RegentsMcLaurin v. Oklahoma State RegentsMcLaurin v. Oklahoma State Regents, 339 U.S. 637 , was a United States Supreme Court case that reversed a lower court decision upholding the efforts of the state-supported University of Oklahoma to adhere to the state law requiring African-Americans to be provided graduate or professional education...
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