Summary of Briggs v. Elliott
Citation: 342 U.S. 350 (1952)
Relevant Facts: One of several cases combined with Brown v. Board of Education, here the Court addressed the constitutionality of segregated schools in rural South Carolina. Harry and Eliza Briggs, residents of Summerton South Carolina, joined with other African-American families to attempt acquiring a school bus for their children. At that time, white children were bused to all-white schools, while African-American children were not provided with transportation to their all-black schools. Unable to secure a bus on their own, the Briggs met with school superintendent R.M. Elliot to request that a bus be provided. Elliot rebuffed their request, explaining both that buses were needed for white school children and that the African-American families did not pay sufficient taxes to warrant expenditures on buses for their children. The Briggs became named plaintiffs in a suit seeking equal access to bus service to school, joined by other families in the community. After securing funding for their cause, they eventually sought not only equal educational opportunities for the children, but the destruction of barriers that kept students in schools segregated by race. At trial, the District Court found that the schools were in fact unequal, and ordered that State officials provide equal educational opportunities. However, that Court did not find the segregated schools themselves unconstitutional. Plaintiffs appealed directly to the Supreme Court.
Issue: Does provision of vastly different resources to schools segregated by race violate the rights of students assigned to sub-standard schools on the basis of their race violate the Fourteenth Amendment? Does state maintenance of separate schools segregated by race violate the Fourteenth Amendment?
Holding: The Court did not resolve the substantive questions presented. The order below was vacated, and the case was remanded for additional factual inquiry and evaluation of steps the school district was taking to equalize the relative quality of separately maintained schools.
Reasoning: In a brief per curium opinion, the Court explained the District Court’s decision. Having found that separate schools were far from equal, that court ordered the defendants to raise the quality of black schools such that they would be on par with white schools. The District Court also ordered the school district to provide a progress report in six months’ time detailing steps it had taken and planned to take to comply with the court order. As the Supreme Court explained, the school district delivered the required report to the District Court after the case had been appealed to the Supreme Court, and the District Court deferred action on the basis of the report because the matter was now pending on appeal. The majority felt they could not proceed to the substantive questions presented until such time as the District Court had been afforded the opportunity to review the report and take action on that basis. Accordingly, the Court vacated the judgment below and remanded the case to District Court for further proceedings, pointing out that they may reconsider the substance of the case after the court below had taken additional action.
Dissent: Justices Black and Douglas dissented, arguing that whatever steps the District Court might take in response to the report were irrelevant to the constitutional issues presented. They would have set the case for argument on the substantive issues regarding constitutionality of school segregation.
Conclusion: Ultimately combined with other cases challenging racial segregation in schools, the Court here delayed a decision on the contentious constitutional issues involved. They revisited the issue two years later, declaring that “separate but equal" schools violated the Fourteenth Amendment.