## Facts

- Black schoolchildren and parents in Clarendon County, South Carolina challenged a state-mandated racially segregated public-school system.
- South Carolina’s constitution and statutes required separate schools for white and Black children and prohibited children of one race from attending schools for the other race.
- The local school system provided materially inferior facilities and resources to Black students; school authorities admitted the facilities were not substantially equal.
- The litigation began with demands for equal school-bus transportation for Black students and expanded into a direct constitutional challenge to segregation itself.
- Plaintiffs presented expert testimony that segregation harmed Black children and that race reflected no educationally relevant differences; defendants did not present opposing experts.
- A three-judge federal district court found inequality and ordered the school authorities to begin equalizing facilities, but refused to invalidate the segregation mandate.
- The Supreme Court vacated and remanded so the district court could consider additional facts concerning the school board’s equalization report and take further action it deemed appropriate.
- On remand, the district court reinstated its earlier approach; the case returned to the Supreme Court and was argued in December 1952 as part of the group of school-segregation appeals later decided together.

## Issues

1. Whether state constitutional and statutory provisions requiring separate public schools by race violate the Equal Protection Clause even if the state attempts to equalize tangible facilities.
2. Whether a district court may deny injunctive relief against segregation itself while ordering prospective equalization as the remedy for unequal schools.
3. What role unrebutted expert testimony about the harms of segregation may play in determining whether segregation denies equal protection.

## Decision

- The Supreme Court vacated the district court’s judgment and remanded for consideration of additional facts regarding the school board’s steps toward equalization and for any further action the district court deemed appropriate.
- The Court did not resolve, in that disposition, the ultimate constitutional validity of state-mandated school segregation.
- The segregation question presented in this appeal was later resolved in the consolidated public-school segregation decision that held race-based separation in public education violates equal protection because separate educational facilities are inherently unequal.

## Legal Principles

- When material postjudgment developments may affect the appropriate relief in an equity case, the Supreme Court may vacate and remand for the lower court to consider additional facts and determine appropriate action.
- Equal protection challenges to school segregation may be framed as attacks on segregation mandates themselves, not merely on unequal facilities within a segregated system.
- Evidence regarding the real-world effects of segregation on students may be relevant to assessing whether a state-imposed racial classification in public education denies equal protection.

## Conclusion

The Supreme Court’s 1952 disposition required further fact development on the school district’s asserted equalization efforts without finally deciding the constitutionality of South Carolina’s segregation mandate; the mandate’s validity was later rejected when the Court held that state-imposed racial segregation in public schools violates the Equal Protection Clause.


Briggs v. Elliott, 342 U.S. 350 (1952)