Facts
- George W. McLaurin, a Black Oklahoma resident with a master’s degree, sought admission to the University of Oklahoma’s state-supported graduate program to pursue a doctorate in education.
- Oklahoma law effectively barred integrated education, and the University denied McLaurin admission solely because of race.
- A three-judge federal district court ruled the State had a constitutional duty to provide McLaurin the graduate education it provided to others and held the exclusionary statutes unconstitutional as applied, while retaining jurisdiction.
- Oklahoma amended its law to permit Black students to attend white institutions when no comparable program existed elsewhere, but required segregated instruction.
- McLaurin was admitted but subjected to state-imposed segregation within the institution, including separate seating in classrooms and separate tables in the library and cafeteria.
- The district court refused to order removal of these internal segregation measures and upheld the University’s arrangements.
- McLaurin appealed directly to the U.S. Supreme Court.
Issues
- Whether a State violates the Equal Protection Clause by imposing racial segregation on a Black student within a public graduate school after admitting him, including physical separation in classrooms, the library, and the cafeteria.
Decision
- The Supreme Court unanimously reversed.
- The Court held that, once admitted to a state-supported graduate school, a student must receive the same treatment as students of other races.
- The Court concluded that the imposed segregation impaired McLaurin’s ability to study, participate in discussions, exchange views, and learn, and therefore denied him equal protection.
- The Court distinguished state-imposed separation from private choices by students, holding that the constitutional violation lies in State barriers to intellectual association.
Legal Principles
- A State may not provide different treatment to an admitted student in a public institution of higher education solely because of race.
- Equal protection in higher education includes access to the full educational experience, including opportunities for discussion, interaction, and intellectual exchange, not merely formal admission.
- State-imposed segregation within an integrated institution is unconstitutional when it restricts a student’s educational opportunities based on race, even if private social separation might persist absent State action.
Conclusion
The Court held that Oklahoma’s internal segregation of an admitted Black graduate student in classrooms, the library, and the cafeteria denied equal protection because it imposed race-based barriers that materially reduced his educational opportunities within the University.