Facts
- Heman Marion Sweatt, a Black applicant, sought admission to the University of Texas Law School and was denied solely because of race under Texas segregation policy.
- Sweatt filed a state-court mandamus action to compel admission.
- The trial court delayed the case to allow Texas to create a separate law school for Black students and then denied relief based on that new program.
- Texas established a separate law school for Black students; Sweatt declined to enroll.
- State appellate courts upheld the denial, concluding the separate school was substantially equivalent.
- The U.S. Supreme Court granted review to determine whether the admissions scheme satisfied the Fourteenth Amendment’s Equal Protection Clause.
- The University of Texas Law School was substantially larger and more established (including more faculty, more students, and a larger library) and had institutional features such as a law review and a developed alumni network and reputation.
- The separate school had markedly fewer faculty and students, a smaller library, minimal alumni influence, and segregated Sweatt from most future professional contacts in Texas legal practice.
Issues
- Whether Texas violated the Equal Protection Clause by refusing to admit a Black applicant to the University of Texas Law School while offering admission to a newly created separate law school for Black students.
- Whether “substantial equality” in professional education requires consideration of both measurable resources (faculty, library, size) and non-quantifiable characteristics (reputation, alumni influence, professional interaction).
Decision
- The Supreme Court unanimously reversed the state court judgment.
- The Court held that the separate law school for Black students was not substantially equal to the University of Texas Law School.
- The Court ordered that Sweatt be admitted to the University of Texas Law School.
- The Court compared both tangible disparities (faculty, library, student body, institutional offerings) and intangible disparities (standing, traditions, prestige, alumni influence, and exclusion from the broader legal community).
Legal Principles
- Equal protection in graduate and professional education requires substantially equal educational opportunity, not merely a formally separate option.
- In assessing equality between institutions, courts must consider intangible factors—such as reputation, alumni influence, traditions, and professional networking opportunities—alongside physical and quantitative resources.
- A state cannot satisfy equal protection by creating a separate professional school that, in combined tangible and intangible respects, provides an inferior legal education to that available at the established institution.
Conclusion
The Court held that Texas’s separate law school for Black students was materially inferior in both resources and educational attributes that shape professional training, so the Equal Protection Clause required Sweatt’s admission to the University of Texas Law School.