Sweatt v. Painter

Explanation and Analysis of the Document

The written decision in Sweatt v. Painter begins with a number of legalities typically found in a Supreme Court written decision. Usually, these introductory remarks are prepared by the justice’s clerk (often a recent law school graduate who does research for the justice). The opening paragraph, called the syllabus, is a brief description of the case. It identifies the petitioner (Sweatt) and the respondent (nominally Painter but in reality the University of Texas Law School) and summarizes the basis of the Court’s ruling and the ruling itself. A person can read the syllabus and get the essence of the case without having to read the entire decision. The word Reversed indicates that the Court has reversed the decision of the lower court, in this instance the Texas Court of Civic Appeals. What follows is a brief description of the case’s history, noting that it had begun in a Texas trial court, was appealed to the Texas Court of Civic Appeals, was returned to the trial court, and then was appealed to the Texas Supreme Court. The document states that the trial court “denied mandamus to compel [Sweatt’s] admission to the University of Texas Law School.” Mandamus is Latin for “we command” and is commonly used in law to refer to a court order requiring a lower court or a government official to perform a duty or to refrain from doing something. In this instance, the trial court refused to require the university law school to admit Sweatt, thus giving the state of Texas time to cobble together a law school for African Americans.

Further legalities follow. The document identifies the attorneys who argued the case for both the petitioner and the respondent. It then notes that amici curiae briefs were filed for both the plaintiff and the defendant. Amici curiae is a Latin expression meaning “friends of the court” and refers to briefs submitted by outside parties in support of one position or the other. In complex litigation, particularly a case with broad implications, it is common for individuals and organizations to attempt to sway the Court with analyses of the case and additional information that the Court might find useful. Typically, in a brief filed by one who appeals a case, in this instance Sweatt, the emphasis must be on legal errors that the lower courts made; the brief does not reargue the facts of the case or anything outside of the law. Amici curiae briefs often range widely in discussing the broader implications of the issues at hand.

With preliminaries disposed of, Vinson outlines the Court’s decision. In the first paragraph, he presents the legal question the case raises: “To what extent does the Equal Protection Clause of the Fourteenth Amendment limit the power of a state to distinguish between students of different races in professional and graduate education in a state university?” He goes on to note that “broader issues have been urged for our consideration,” likely a reference to the content of the amici curiae briefs, but Vinson indicates that he is going to rule on the case strictly in conformity with the law as he sees it. This is an indication that the Court was not going to reexamine Plessy v. Ferguson.

Paragraphs 2 and 3 summarize the facts of the case and refer again to its history, from the trial court through the Texas Supreme Court. Vinson notes that mandamus was denied, which gave the state time to establish a law school for African Americans. Sweatt, though, refused to enroll in the new law school. The Texas Court of Civic Appeals then returned the case to the trial court “without prejudice,” meaning that none of the rights or privileges of the persons involved was waived or lost. In other words, the court said that essentially the case was to begin again. In paragraph 4, Vinson notes that when the case was remanded, or sent back to the trial court, the court ruled that the new law school for African Americans was “substantially equivalent” to the University of Texas Law School. The Texas Court of Civic Appeals affirmed the ruling of the trial court, and the Texas Supreme Court refused to hear Sweatt’s appeal of this ruling. Accordingly, Sweatt appealed to the U.S. Supreme Court, which “granted certiorari,” a legal term that means the Court has required the lower court to turn over the trial records; it also indicates that the Court has agreed to hear the case.

With paragraphs 5 and 6, Vinson begins his analysis of the case. He notes that the facilities at the two institutions were markedly different. At the University of Texas, the faculty was larger, and the law library contained considerably more materials. In contrast, the law school for African Americans was not accredited, though Vinson points out in paragraph 7 that the school, three years after its formation, was on its way toward accreditation. He also mentions that the new law school lacked the prestige of the University of Texas; for example, the new law school did not have an Order of the Coif, a prestigious national scholastic society whose members have an inside track to the best jobs as attorneys. In paragraph 8, Vinson concludes that the University of Texas Law School was clearly superior in the opportunities it afforded students. He also notes that the University of Texas was superior in intangible features: “reputation of the faculty, experience of the administration, position and influence of the alumni, standing in the community, traditions and prestige.” Paragraph 10 goes on to point out another disadvantage that the African American students would face at a separate law school: They would be isolated from the 85 percent of the state’s population, including judges, other attorneys, officials, and others who were part of the environment in which a person would practice law.

Paragraph 10 responds to the state’s claim that excluding blacks from the University of Texas would be no different from excluding whites from the new law school. Vinson dismisses this argument by saying that as a practical matter, no University of Texas student would want to attend the new law school, given its obvious inferiority. Notice that Vinson cites Shelley v. Kraemer: “Equal protection of the laws is not achieved through indiscriminate imposition of inequalities.” In paragraph 11, Vinson cites other precedents, including Sipuel v. Board of Regents of the University of Oklahoma and Missouri ex rel. Gaines v. Canada, to emphasize that the equal protection clause of the Fourteenth Amendment requires states to provide equal opportunities in legal education for their citizens. Bowing to these precedents, Vinson concludes in paragraph 12 that the “petitioner may claim his full constitutional right: legal education equivalent to that offered by the State to students of other races.” Vinson rejects the view that Plessy v. Ferguson allowed the state to provide a pretense of equivalency. At the same time, he rejects the view that the Court should reexamine Plessy. Paragraph 13 concludes the decision: “We hold that the Equal Protection Clause of the Fourteenth Amendment requires that petitioner be admitted to the University of Texas Law School.”