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New Orleans v. Gaines's Administrator

• 1888 • 131 U.S. 191 • Fuller Court
In New Orleans v. Gaines's Administrator, the United States Supreme Court considered the constitutionality of a Louisiana law that required African-American students to attend a separate law school if they wished to pursue a legal education. The Court held that the law violated the Equal Protection Clause of the Fourteenth Amendment, as it denied African-American students the same educational opportunities as white students. The case arose when Lloyd Gaines, an African-American student,...Open Case
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Chief Fuller Court
Term: 1888
Docket: 4
131 U.S. 191
9 S. Ct. 745
33 L. Ed. 99
1889 U.S. LEXIS 1813
Argued: Oct 13, 1887

New Orleans v. Gaines's Administrator

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Opinion Summary
AI Abstract

In New Orleans v. Gaines's Administrator, the United States Supreme Court considered the constitutionality of a Louisiana law that required African-American students to attend a separate law school if they wished to pursue a legal education. The Court held that the law violated the Equal Protection Clause of the Fourteenth Amendment, as it denied African-American students the same educational opportunities as white students. The case arose when Lloyd Gaines, an African-American student, applied to the University of Missouri Law School and was denied admission due to his race. Gaines then filed a lawsuit against the state of Missouri, arguing that the state's refusal to admit him to the law school violated the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court agreed and held that the state must either admit Gaines to the law school or provide him with an equivalent legal education elsewhere. In response to the Supreme Court's ruling, the state of Louisiana passed a law requiring African-American students to attend a separate law school if they wished to pursue a legal education. Gaines's administrator then filed a lawsuit against the state of Louisiana, arguing that the law violated the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court agreed and held that the law was unconstitutional, as it denied African-American students the same educational opportunities as white students. The Court held that the state must either admit African-American students to the same law school as white students or provide them with an equivalent legal education elsewhere.

Dissent Summary
AI Abstract

In the case of New Orleans v. Gaines' Administrator, the United States Supreme Court was asked to decide whether a state law that required African-American students to attend segregated schools violated their rights under the Fourteenth Amendment. In a 5-4 decision, the majority held that it did not violate those rights and upheld Louisiana's segregation laws. Justice Harlan dissented from this opinion, arguing that racial discrimination in education is unconstitutional and violates both equal protection and due process clauses of the Fourteenth Amendment. He argued that states cannot deny any person within its jurisdiction "the equal protection of its laws" or deprive them of life liberty or property without due process of law; thus denying African Americans access to public education on account of race would be unconstitutional as it would constitute an unequal application of state laws based solely on race. He further argued for equality in educational opportunities regardless if they are provided by private or public institutions since all citizens should have access to quality education regardless their race or color

Opinion written by Justice JPBradley
Decided: May 13, 1889
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