Missouri ex rel. Gaines v. Canada

Missouri ex rel. Gaines v. Canada
Supreme Court of the United States
Argued November 9, 1938 Decided December 12, 1938
Full case name	State of Missouri ex rel. Gaines v. Canada, Registrar of the University of Missouri, et al.
Citations	305 U.S. 337 (more) 59 S. Ct. 232; 83 L. Ed. 208; 1938 U.S. LEXIS 440
Prior history	The Circuit Court denied the writ. The Missouri Supreme Court upheld the judgment against Gaines, 113 S. W.2d 783.
Subsequent history	Remanded to lower courts
Holding
States that provide only one educational institution must allow blacks and whites to attend if there is no separate school for blacks.
Court membership
Case opinions
Majority	Hughes, joined by Brandeis, Stone, Roberts, Black, Reed
Dissent	McReynolds, joined by Butler
Laws applied
U.S. Const. amend. XIV

Missouri ex rel. Gaines v. Canada, 305 U.S. 337 (1938), was a United States Supreme Court decision holding that states that provided a school to white students had to provide in-state education to blacks as well. States could satisfy this requirement by allowing blacks and whites to attend the same school or creating a second school for blacks.

The Registrar at the Law School of the University of Missouri, Cy Woodson Canada, refused admission to Lloyd Gaines because he was an African-American. At the time there was no law school specifically for African-Americans within the state. Gaines cited that this refusal violated his Fourteenth Amendment right. The state of Missouri had offered to pay for Gaines’ tuition at an adjacent state’s law school, which he turned down.

In light of the equal protection clause of the 14th Amendment, does Missouri violate this clause when it affords whites the ability to attend law school in state while not affording the same right to blacks and instead forcing them to attend adjacent states for their law education?

Writing for the majority, Chief Justice Charles Evans Hughes held that when the state provides legal training, it must provide it to every qualified person to satisfy equal protection. It cannot send them to other states, nor can it condition that training for one group of people (such as blacks) on levels of demand from that group. Key to the court’s conclusion was that there was no provision for legal education of blacks in Missouri, which is where Missouri law guaranteeing equal protection applies. To the court, sending Gaines to another state would have been irrelevant. Justice James C. McReynolds's dissent emphasized a body of case law with sweeping statements about state control of education before suggesting the possibility that—despite the majority opinion—Missouri could still deny Gaines admission.

This decision does not quite strike down separate but equal education as upheld in Plessy v. Ferguson (1896). Instead, it provides that if there is only a single school, students of all races are eligible for admission, thereby striking down segregation by exclusion where the government provides just one school. Though this case didn’t go as far as Brown v. Board of Education (1954) would, it was a step in that direction.