In the case of Gray et al. v. Board of Trustees of the University of Tennessee et al., African American students sought admission to a state-supported graduate school, The University Of Tennessee College Of Law, which was racially segregated at that time. The Supreme Court ruled in favor of the plaintiffs on June 4, 1951 stating that if there is no comparable law school for black students within the state then they must be admitted to this university under equal protection clause (14th Amendment). This decision followed previous rulings where segregation was deemed unconstitutional when "separate but equal" facilities were not truly equivalent or did not exist at all for one racial group.

In the dissenting opinion for Gray et al. v. Board of Trustees of the University of Tennessee et al., Justice Minton argued that by denying admission to African American students based on their race, the University was in violation of the Equal Protection Clause under Fourteenth Amendment. He believed that separate but equal doctrine established in Plessy v. Ferguson should not be applied to education because it inherently creates inequality and is therefore unconstitutional. Furthermore, he contended that waiting for states to voluntarily desegregate would only perpetuate racial discrimination and delay justice for African Americans who were entitled to equal educational opportunities immediately as per Constitution's mandate.