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The Troubled History of American Education after the Brown Decision

[From the February issue of The American Historian]

On May 17, 1954, when the Supreme Court ruled in the Brown v. Board of Education of Topeka decision that racial segregation in the public schools violated the Fourteenth Amendment, it sparked national reactions ranging from elation to rage. As some Americans celebrated this important ruling and its impact on democracy, their early belief in Brown’s power to eliminate racial inequities in the public schools now reflects a hopeful naiveté and the beginning of a decades-long struggle to fulfill its promise. Whether one supported or opposed the Brown decision, it would have a profound impact on the direction of the nation’s educational system that transcends its original intent. While this case led to the growth of the modern civil rights movement and the expansion of educational opportunities for children apart from race, such as those with special needs, its complex history also reflects our nation’s difficulties in overcoming systemic racism and class discrimination.

As Jim Crow segregation became the law of the land after Plessy v. Ferguson in 1896, white southern leaders questioned the need for the continuance of African American education and segregated schools remained unequally funded.[1] In an effort to alleviate these conditions, African American parents and educators relied upon what historian V. P. Franklin describes as cultural capital or non-financial assets to better the conditions of their schools. In these often one-room schools, parents worked with teachers to maintain the physical structures while also supporting cultural events and athletic programs. In addition to cultural capital, as historian James Anderson argues, these families often paid a “black tax” or a double tax because they had to pay local taxes and use their own funds to support their own underfunded black schools. Black teachers also knew that their duties went far beyond academic instruction; they were often required to use their own funds and working outside school grounds to help their students both inside and outside the classroom. Despite their lower salaries in comparison to white teachers, these educators held important positions within black communities. They reflected the human aspect of the concept of cultural capital as black communities during segregation placed the economic and social progress of their children in their hands.[2]

In the 1930s, Charles Hamilton Houston, Special Counsel for the National Association for the Advancement of Colored People (NAACP) and former chair of Howard University’s Law School, established the field of civil rights law as he developed an innovative and bold strategy that would eventually dismantle segregation in public universities and schools. After his former student, Thurgood Marshall, successfully sued the University of Maryland’s law school forcing it to admit a black student, Marshall joined Houston at the NAACP and sued for equity among black and white teachers. Relying upon the Fourteenth Amendment, they won most of their cases. Southern districts retaliated by developing unfair testing systems to determine salary ranges. The NAACP then sued graduate and professional programs and schools in southern public universities to admit black students, arguing that they had no other opportunities for equal training.[3]

Although Houston died in 1950, Thurgood Marshall took up his strategy to end segregation. This massive undertaking was not without criticism as some prominent black leaders thought that the NAACP should sue for equity for black schools instead. Marshall thought that an overall desegregation decision would eliminate the expensive and time-consuming need to go district by district. His case, based upon precedent from the 1946 Mendez v. Westminster case, combined five similar cases that grossly reflected racial discrimination. Marshall and his team of NAACP lawyers relied upon the expert legal, historical, and psychological testimonies from Pauli Marshall, John Hope Franklin, and Kenneth and Mamie Clark, whose famous doll test suggested that black children suffered low self-esteem due to learning in segregated environments.[4]

On May 17, 1954, when the Supreme Court ruled in the Brown case that segregation in the public schools was unequal, it caused an uproar. For southerners, this decision did not just call for the end of segregated schools, it also threatened the foundation of white supremacy, which was constructed upon destructive stereotypes of black intellectual inferiority and fears of black male sexuality. This extensive negative reaction coalesced into a strategy called “massive resistance.” In May 1956, 101 congressmen issued the “Southern Manifesto” that declared, “We pledge ourselves to use all lawful means to bring about a reversal of this decision which is contrary to the Constitution and to prevent the use of force in its implementation.”[5] On every level from the school board to the state house, southerners fought this decision. We are familiar with the case in Little Rock, Arkansas, where nine high school students who enrolled in all-white Central High School faced angry mobs and threats from the governor, eventually culminating in President Eisenhower’s call for military action to protect the students. While this case garnered national attention, most southern school officials quietly developed their own plans to delay or deny the implementation of desegregation, including grade-per-year plans, transfer plans, and school closings.[6]

In addition, school boards also funneled money and supplies to existing facilities and constructed new black schools to dispute claims that they were underfunded and quell the desire for integration. When this strategy failed and federal court orders forced school districts to develop new desegregation plans, black teachers faced massive job losses as white school boards closed black schools. African American principals, who once held one of the most powerful and prestigious positions within African American communities, also received demotions or lost their jobs as their schools were eliminated.[7]

After the NAACP returned to the Supreme Court in Brown II, the Court ruled that desegregation should proceed with “all deliberate speed.”[8] Despite the continuous legal actions of civil rights lawyers, this term did not reflect the depths of southern resistance as most children still attended segregated schools in 1964. This year also marked the passage of the Civil Rights Act. This groundbreaking legislation made desegregation a pre-requisite to school funding. A year later, congress passed the Elementary and Secondary Schools Act, a component of President Lyndon B. Johnson’s War on Poverty that appropriated money to public schools to fund educational programs and resources for poor children. This funding could also be removed if school systems did not desegregate. Under Johnson, the Department of Health, Education, and Welfare also helped monitor desegregation plans. While the federal government intervened in the area of education regarding desegregation and poverty, the government’s role in education had increased since the end of World War II. Cold War fears of the Soviet Union surpassing the United States, especially after the 1957 Sputnik mission, sparked massive funding increases to support science and engineering in the nation’s public colleges and influential initiatives such as the new math in public schools.[9]

Despite the federal government’s growing influence, civil rights lawyers sometimes encountered violence and loss of economic support as they attempted to force these districts to comply with the Brown decision. After the Supreme Court’s decisions in Green v. County School Board of New Kent County (1968) and Alexander v. Holmes County Bd. of Ed. (1969) forced school districts to develop more viable and extensive desegregation plans, the enforcement of these decisions now lay in the hands of federal judges. Some of these officials, such as James McMillian, a federal judge for the Western District of North Carolina, faced public derision when he ordered the Charlotte Mecklenburg Board of Education to produce desegregation plans that met court standards.[10]

After the housing shortages from WWII led to the emergence of the suburbs, city planners and local government officials designed new settlements in former rural areas. Scholar Ansley Erickson argues that city developers reinforced segregation by working with school districts to construct new schools in predominately-white suburban neighborhoods. With the support of the GI Bill and the availability of Federal Housing Association (FHA) mortgages, thousands of families moved to the suburbs. While this marked a watershed moment in city planning or urban development, the FHA, leery of influencing neighborhood composition, seldom offered loans to blacks with the same criteria and these neighborhoods remained all white. For working-class whites, moving to the suburbs also reflected a symbol of rising class status and a new version of the American dream that included sending their children to quality neighborhood schools.[11]

One of the biggest problems affecting desegregation involved the neighborhoods where children lived. Most children lived in racially segregated communities and the most feasible way to achieve desegregation beyond voluntary transfers was to transport children to schools outside their neighborhoods. Civil rights attorney Julius Chambers and his colleagues successfully made this argument before the Supreme Court in Swann v. Charlotte Mecklenburg County Board of Education in 1971. Prior to Swann, school systems in rural areas had transported white students out of their neighborhoods to attend school for decades, while black students were sometimes denied access to public school transportation. Although studies reflected that a majority of white parents did not object to black students attending school with their children, they drew the line when it came time for their children to attend schools in what they deemed as unsafe black neighborhoods. Working-class whites also argued that affluent whites were unfairly exempted from busing plans. As a result, antibusing protests emerged across the nation and newly-created private schools also developed as an option for parents to escape busing. As whites fled urban school districts and busing in what officials call white flight, suburban areas experienced more economic development as urban areas lost some of their tax base. Despite the objections to busing, southern cities such as Charlotte prided itself on its success in busing. While scholars often view desegregation through a southern lens, busing reflected the racial inequities in the nation’s public schools as white parents protested against busing in cities as diverse as Boston and Detroit. Busing also exhibited the gendered nature of racism as angry white mothers across the nation shouted racial epithets at black children on the buses.[12]

While President Johnson supported desegregation efforts, the Nixon administration reflected a conservative turn in educational policy as President Richard M. Nixon spoke openly against busing. He ordered limited federal funding to districts to purchase buses despite their requests. Although a national issue, the resentment over busing was one of several important factors that led to the resurgence of the Republican party in the south as it became a safe haven for those angry with busing and what they saw as increased intervention by the federal government.[13]

While the majority of African American parents supported busing to expedite desegregation, their children often bore the burden as they left their homes very early in the morning to attend schools sometimes twenty or more miles from their homes. While integration meant that black children could now attend schools with greater resources, they sometimes encountered racism from their white peers and teachers. Black children who lived in suburban neighborhoods also had to overcome stereotypes of racial inferiority promoted by white students and teachers. They also had to navigate class differences among black children bused in from poor neighborhoods. Attending schools far from their communities caused additional problems for black parents and students. For example, students could not do extra-curricular activities and parents could not attend teacher conferences or participate in the PTA if they did not have a ride home.[14] Additionally, teachers also had to contend with court decisions mandating faculty desegregation that called for every school to be 80 percent white and 20 percent black. These rulings ordered the transfers of hundreds of black teachers to white schools. With their move, these teachers suddenly lost their status as they assumed their roles of new faculty in white schools.[15]

The loss of black teachers also decimated black institutions as the character of these schools suddenly disappeared. By the late 1970s, African Americans, once proponents of busing, now became wary as they saw their beloved neighborhood schools deteriorate or close. They wanted desegregation to be a two-way street, not a process for dismantling their schools. In the North, black parents also wrestled with school boards to gain community control. The supportive relationship between black parents and teachers regarding discipline also disintegrated as protective black parents viewed discipline through a racialized lens as black children were often punished for minor offenses in greater degrees than white ones. By the 1990s, antipathy towards busing transformed into a community schools movement that advocated for neighborhood schools and pushed school districts to abandon their desegregation plans.[16]

While Brown continues to be celebrated as a civil rights milestone, as we look at the problems of poverty and racial segregation in today’s public schools, some people argue that the decision resulted in dismal failure as some 80 percent of black children now attend segregated schools nationally. Despite this view, today’s schools are not as resegregated as they once were in the South. From 1954 to the late 1980s, the rate of black children attending white schools rose tremendously in the South, from 0 percent in 1954, to 43.5 percent by 1988, only declining after the dismantling of court ordered desegregation plans to 23.2 in 2011. The South remains the least segregated area of the nation. The current resegregation of the public school are due more to the declining support for desegregation by local districts, the federal government, and the Supreme Court. In 2007 Chief Justice John G. Roberts Jr. stated the following in his majority opinion in two court cases that used race in determining transfer policies and school plans to foster desegregation: “The way to stop race discrimination on the basis of race is to stop discriminating on the basis of race.”[17] This decision turned a blind eye to decades of racial discrimination in public schools and struck a deathblow to Brown. The federal government’s focus on assessment testing in the 1980s also placed less emphasis on enforcing desegregation. We must also analyze the impact of economic class status on the push for racial desegregation. As a result of Brown, black children, while no longer legally barred from attending white schools, are now limited by class status and neighborhood location. Although busing attempted to overcome residential segregation, it could not withstand the national backlash. While Brown addressed discrimination against blacks, today Latino children comprise the majority of several large urban school districts in the U.S. Although they were not legally segregated by race in most areas, Latino children continue to face discrimination despite the advent of policies such as bilingual education that helps all immigrant children. Most black and Latino children in these areas attend schools with the double segregation of race and poverty.[18]

Historically, public schools accepted children regardless of class status, but now they face competition from more selective charter schools and other school choice initiatives that affect racial diversity goals as well as class. Also, children who grew up in the suburban middle class are moving to gentrified urban neighborhoods and sending their children to private schools. In major urban cities across the nation, middle-class parents, regardless of race, have abandoned the public schools due to fears of limited quality and violence, negatively affecting desegregation goals. Charter schools and voucher programs have emerged as options for parents who wish to avoid sending their children to poorly functioning public schools, but their results remain mixed. While as a democratic nation we appreciate Brown’s demand to end racial segregation in schools and cite the benefits of diversity, the initial ambitions of Brown remains unfinished and its legacy complicated. As education officials debate the merits and impact of school choice initiatives, we must not abandon the need for diversity in the public schools.[19]

Sonya Ramsey is an associate professor of history and women’s and gender studies at the University of North Carolina at Charlotte. She specializes in African American gender history, the history of education, and southern history. She is the author of several historical works including Reading, Writing, and Segregation: A Century of Black Women Teachers in Nashville (2008). She currently is completing her upcoming book manuscript, After the Marches: Bertha Maxwell-Roddey’s Educational Activism, Reconfiguring Civil Rights in the Desegregated South, which is under contract with the University Press of Florida.

[1] Plessy v. Ferguson, 163 U.S. 537 (1896).

[2] V. P. Franklin and Julian Carter Savage, Cultural Capital and Black Education: African American communities and the funding of Black Schooling, 1865 to the Present (2004), xv; James Anderson, The Education of Blacks in the South (1988), 156.

[3] Genna Rae McNeil and A. Leon Higginbotham, Groundwork: Charles Hamilton Houston and the Struggle for Civil Rights, (Philadelphia: University of Pennsylvania Press, 1984), 63–76; Mark V. Tushnet, The NAACP Legal Action Against Segregated Education, 1925–1950 (1987), 21–34.

[4] Mendez V. Westminster School District of Orange County 64 F. Supp. 544 (C.D. Cal. 1946); Tushnet, The NAACP Legal Action, 105–38; Brown v. Board of Education of Topeka, 347 U.S. 483 (1954).

[5] “Southern Manifesto on Integration,” Congressional Record, 84 Cong., 2 sess., vol. 102, part 4, (1956), 4459–60. Primary source materials from the Supreme Court, (2008),

[6] James T. Patterson, Brown V. Board of Education; A Civil Rights Milestone and Its Troubled Legacy (2001), 86–147.

[7] Michael Fultz, “The Displacement of Black Educators Post-Brown: An Overview and Analysis,” History of Education Quarterly, 44 (Spring 2004), 11–45.

[8] Brown v. Board of Education, 349 U.S. 294 (1955).

[9] Gary Orfield, “The Civil Rights Act and American Education,” 89–129 in Bernard Grofman, ­ed., Legacies of the Civil Rights Act of 1964 (2001); Elizabeth Cascio and Sarah Reber, “The K-12 Battle,” 66-93, in Martha J. Bailey and Sheldon Danziger, Legacies of the War on Poverty (2013).

 [10] For more information on James McMillan see, Davidson Douglas, Reading, Writing, and Race, The Desegregation of the Charlotte Schools (1995).

[11] Ansley T. Erickson, Making the Unequal Metropolis, School Desegregation and Its Limits, (Chicago: University of Chicago Press, 2016), 120–51.

[12] Swann v. Charlotte-Mecklenburg Board of Education, 402 U.S. 1 (1971), Douglas, Reading, Writing, and Race, 130–90.

[13] Matthew Lassiter, The Silent Majority, Suburban Politics in the Sunbelt South, (Princeton, NJ: Princeton University Press, 2007), 148-198.

[14] Matthew Delmont, Why Busing Failed, Race, Media, and the National Resistance to School Desegregation (2016), 169–190; Erickson, Making the Unequal Metropolis, 210–44.

[15] Sonya Ramsey, Reading, Writing and Segregation: A Century of Black Women Teachers in Nashville (2008), 102–35.

[16] Ibid. Gary Orfield, Susan E. Eaton, and The Harvard Project on Education, Dismantling Desegregation: The Quiet Reversal of Brown v. Board of Education (1996).

[17] Linda Greenhouse, “Justices Limit the Use of Race in School Plans for Integration,” The New York Times, June 29, 2007,

[18] U.S. Department of Education, National Center for Education Statistics, Common Core of Data (CCD), Public Elementary/Secondary School Universe Survey Data. Data prior to 1991 obtained from the analysis of the Office of Civil Rights data in Gary Orfield, Public School Desegregation in the United States, 1968-1980 (1983). Cited in Brown at 60: Great Progress, A Long Retreat, and Uncertain Future, by Gary Orfield and Erica Frankenberg, with Jongyeon Ee and John Kuscera, The Civil Rights Project (2014), 21, 23–24.

[19] For more information on gentrification and school choice initiatives and the legacy of Brown, see Jennifer Burns Stillman, Gentrification and Schools: The Process of Integration When Whites Reverse Flight (2012); Lisa Stulberg, Race, Schools, and Hope: African Americans and School Choice after Brown, (2008).