Chapter 2: Separate is Inherently Unequal: Rethinking Commonly Held Wisdom

In 1954 the Supreme Court under Chief Justice Earl Warren concluded that the doctrine of “separate but equal,” initiated in 1896 under Plessy, has no place in public education, and separate educational facilities are inherently unequal. Since the 1954 decision of Brown v. Board of Education Topeka, Kansas “separate is inherently unequal” has been the mantra used by advocates of desegregated schools. I argue that separate and equal are not mutually exclusive terms conceptually. In theory it is possible to have separation and equality exist at the same time. The difficulty in achieving such in practice, given the historical evidence from 1896 to 1954 where the American education system tried to adhere to Plessy’s mandate, is what I believe prompted the Warren Court to conclude that it was not possible. The rationale behind this impossibility seems to have been that the essential nature of separateness precluded achievement of equality of condition. Perhaps the social, political, and economic realities of competing resources in one society is what prevents theoretical possibilities from becoming practical realities. Interpreting the Brown decisions as the solution to a long history of marginalization and inequitable education for Black people is simplistic and was not, I posit, the intent of the civil rights advocates working toward desegregating schools. The categorization of “separate but equal” as bad and the use of “separate as inherently unequal” as the solution is problematic for at least three reasons. The first most obvious reason is that prior to 1954, “separate but equal” does not accurately describe education in the United States. We do not need to look far for evidence that Black schools were not funded equally to White schools (Anderson, 1988; Anderson, 2001; Walker, 1996). Schools are unequal when they are unequally supported. Instead of busing Black students to White schools, Anderson (2001) declares that the Supreme Court should have “bused” more money, better instructional materials, trained staff, and newer equipment to Black schools.