Feelings of Inferiority
The Brown decision [ BROWN v. BOARD OF EDUCATION, 347 U.S. 483 (1954) ], decided on May 17, 1954, and delivered by Chief Justice Warren in June, declared that state-funded public educational segregation of white and Negro students, even when the physical facilities of the segregated students are equal, violates the Fourteenth Amendment of the Constitution and is therefore unconstitutional. The ruling ended "separate but equal" educational policy based on the 1896 Supreme Court decision, Plessy v. Ferguson [PLESSY v. FERGUSON, 163 U.S. 537 (1896)].
The Court found that substantive equality of physical facilities did not provide equality before the law as required by the Fourteenth amendment. The issue of equality had to be judged in terms of an extended understanding of how learning occurs in education and the role of education in American life. Drawing upon scattered lower court findings [esp. Briggs v Elliott (see Dissenting Opinion of Judge Waites Waring ...), the Supreme Court concluded that inequality arises in the effect of segregated education on the quality of learning the student achieves and the opportunities opened to students by their schooling.
For segregated Black students, the mere fact of segregation means they are, in the view of white citizens and students, inferior to white students. Black students come to feel inferior. Their sense of inferiority lowers their motivation to learn, leaving them with an incomplete education. When they leave school, their incomplete education reduces their opportunities for success in American life. Their assumption of inferiority leads to the fact of inferiority, hence inequality.
Justice Warren quoted the key logic from a lower court decision:
"Segregation of white and colored children in public schools has a detrimental effect upon the colored children. The impact is greater when it has the sanction of the law; for the policy of separating the races is usually interpreted as denoting the inferiority of the negro group. A sense of inferiority affects the motivation of a child to learn. Segregation with the sanction of law, therefore, has a tendency to [retard] the educational and mental development of negro children and to deprive them of some of the benefits they would receive in a racial[ly] integrated school system."
A close look at this logic would reveal assumptions.
The Court assumed that separation would induce a feeling of inferiority; rather than separation providing the segregated students with the opportunity for self-defined fields to earn feelings of merit.
It also assumed that a feeling of inferiority would cripple motivation to compete and to succeed; rather than motivating a desire to compete and overcome odds.
We should point out here, as a theme to which we will return later, what the Court effectively did. The Court made the subjective feelings of the students the test of inequality. Those feelings would have objective products and indicators, such as diminished achievement in adult life, but the Court did not provide any reason to believe that lack of objective indicators of subjective feelings of inferiority would negate the existence of such feelings as the test of inequality.
The Supreme Court was aware that their assumptions might be challenged. They asserted, therefore, that their assumptions were proved to be fact by contemporary social science research. Oral and written testimony from social scientists had been presented to the Court when the case was argued before it. In the opinion, the Court made the following footnote reference (#10):
K. B. Clark, Effect of Prejudice and Discrimination on Personality Development (Midcentury White House Conference on Children and Youth, 1950); Witmer and Kotinsky, Personality in the Making (1952), c. VI; Deutscher and Chein, The Psychological Effects of Enforced Segregation: A Survey of Social Science Opinion, 26 J. Psychol. 259 (1948); Chein, What are the Psychological Effects of [347 U.S. 483, 495] Segregation Under Conditions of Equal Facilities?, 3 Int. J. Opinion and Attitude Res. 229 (1949); Brameld, Educational Costs, in Discrimination and National Welfare (MacIver, ed., (1949), 44-48; Frazier, The Negro in the United States (1949), 674-681. And see generally Myrdal, An American Dilemma (1944).
In our next article, we will start examining this cited social science literature and its authors.
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