Missouri ex rel. Gaines v. Canada

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

Background
The Registrar at the Law School of the University of Missouri, Silas Woodson Canada, refused admission to Lloyd Gaines because he was black. At the time, Black students could attend no law school specifically in the state. Gaines cited that the refusal violated the Fourteenth Amendment. The State of Missouri had offered to pay for Gaines's tuition at an adjacent state's law school, which he turned down.

Gaines, assisted by the NAACP, sued the all-white university in 1935. The issue was whether Missouri violated the Equal Protection Clause of the Fourteenth Amendment by affording white people, not Black people, the ability to attend law school within the state.

Trial
The initial trial started in Columbia, Missouri in Boone County.

Decision
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 can neither send them to other states, nor condition that training for one group of people, such as Black people, on levels of demand from that group. Key to the court's conclusion was that there was no provision for legal education of Black people in Missouri so Missouri law guaranteeing equal protection applied. 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.

The decision did not quite strike down separate but equal facilities, upheld in Plessy v. Ferguson (1896). Instead, it provided that if there was only one school, students of all races could be admitted. The decision struck down segregation by exclusion if the government provided just one school, making the decision in this case a precursor to Brown v. Board of Education (1954).

This marked the beginning of the Supreme Court's reconsideration of Plessy. The Supreme Court did not overturn Plessy v. Ferguson or violate the "separate but equal" precedents, but began to concede the difficulty and near-impossibility of a state maintaining segregated Black and white institutions that could never be truly equal. Therefore, it can be said that this case helped forge the legal framework for Brown v. Board of Education, which banned segregation in public schools.

Despite the initial victory claimed by the NAACP, after the Supreme Court had ruled in Gaines' favor and ordered the Missouri Supreme Court to reconsider the case, Gaines was nowhere to be found. When the University of Missouri soon after moved to dismiss the case, the NAACP did not oppose the motion.