McLaurin v. Oklahoma ( 1950)

In  From Jim Crow to Civil Rights ( Oxford, 2004) Michael Klarman investigates the Supreme Court decision in the civil rights case McLaurin v. Oklahoma. Klarman elaborates on the social, political, and economic factors that shaped the judicial rulings on this case, as well as the many ways in which the final landmark decision to desegregate graduate and upper level schooling helped shape a changing world for the black civil rights movement.

In McLaurin v. Oklahoma  (available through Lexis-Nexis)George McLaurin of an African American citizen of Oklahoma gained admittance to the Graduate School of  University of Oklahoma State as a candidate for a doctorate in education.  He was permitted to use the same classroom, library and cafeteria as white students however, at the time Oklahoma state law functioned under the commonly accepted law of “separate but equal” which instructed that black studentsin institutions of higher education must function on a segregated basis. This therefore only allowed him to eat at a specific table in the cafeteria, study at a predetermined space in the library, and sit in an assigned seat in each classroom.  McLaurin decided to file a suit under the assertion that the conditions under which he was required to receive his education deprived him of his personal right to the equal protection of the laws; and the Fourteenth Amendment eliminates racially biased treatment by the State (638-642). This case brought up several important issues: First, it limited and impaired  McLaurin’s freedoms within the academic community such as his ability to study, to engage in discussions and exchange views with other students, and, in general, to learn his profession(640-641). Second, it violated the Constitution, specifically the Fourteenth Amendment because the “State which prohibited the intellectual commingling of students and the refusal of students to commingle where the State presents no such bar “(641). Finally, McLaurin was admitted to a state-supported graduate school, and therefore should have received the same treatment from the State as students of other races(642).

While Klarman briefly introduces the McLaurin v. Oklahoma he leaves out many of the details of the actual case as well as an important in depth analysis of this effects this decision had on overturning Plessy. John P. Roche’s article, published by the  University of Pennsylvania Law Review, Education, Segregation and the Supreme Court. A Political Review( Vol. 99: May 1951, available through google scholar, Jtor, or ILLIAD) offers a impressive summary of the case as well as a perspective on Judicial review and Judicial self-restraint. The article also examines the McLaurin case as a microcosm for desegregation all over the country.  Another important article cited by over 115 other articles is Robert L. Carter’s article: The Warren Court and Desegregation(Vol 67. : May 1968, available through google scholar, Jstor, or ILLIAD). This article provides an interesting perspective on “the Warren Court” and carefully tracks the trends in legal decision making up through the Brown v. Board of Education (available through Lexis-Nexis)decision. He meticulously deconstructs the McLaurin case and deems it important context for the much larger scale decisions that were to be made about desegregation under Chief Justice Warren.  This article takes Klarman’s analysis of the reasoning behind the justices in the McLaurin decisions a little further( Justices: Hugo Lafayette Black, Harold Burton, Tom C. Clark, William O. Douglas, Felix Frankfurter, Robert H. Jackson, Sherman Minton, Stanley Forman Reed, Fred Moore Vinson [writing for the Court]) . Klarman attributed the judges decision to social and political changes like the desegregation of major league baseball, the gradual desegregation of the military and the memo asking for the overturn of Plessy by the Court’s first black law clerk, William T. Coleman(209).  He also added that the Truman administration “intervened in these cases to urge that Plessy be overruled , invoking the Cold War imperative for racial change”(210).

A book that sheds important contextual light on the McLaurin v. Oklahoma case is one by Berkley professor Waldo E. Martin, Brown v. Board of Education: A Brief History With Documents (NY: Bedford, 1998 segments also available through google books). This book received several book reviews praising it for the important use of primary source documents.  He has several letters within this book to the Chicago Defender Newspaper from black southerners expressing their views on segregated education as well as their desires for better opportunities within the colleges. Many of these letters exemplify the attitudes of the time that finally culminated in McLaurin v. Oklahoma.

While not many sources are available specifically on the case the few mentioned above provide a good start to understanding the complexity of the desegregation issue at this time. Ultimately the verdict in the McLaurin v. Oklahoma case overturned Plessy and therefore increased momentum toward the final decision in Brown v. Board of Education. Finally a good place to search for further primary source documentation is the Oklahoma State University archives. The online archival site offers an accurate case summary as well as photos. The website also indicates that the archives make primary source documentation on the case like newspaper articles, student responses, statistics, and letters available at the actual University or through mail by special request. The contact number for the archives is : (405)325-9685.

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