- Date:
- November 21, 1927
- Location:
- United States
Gong Lum v. Rice
-
What was the Gong Lum v. Rice case about?
In Gong Lum v. Rice, the U.S. Supreme Court ruled on November 21, 1927, that a Mississippi school board did not violate the Fourteenth Amendment when it classified Martha Lum, a student of Chinese descent, as "colored" and barred her from attending a white high school.
Martha's father, Gong Lum, sued after the superintendent, acting on the orders of the board of trustees, told Martha she would not be allowed to return to the school because she was of Chinese descent and not a member of the white race.
The Supreme Court upheld the Mississippi Supreme Court's decision, citing the state constitution, which called for separate schools for white and "colored" students. The U.S. Supreme Court also cited Plessy v. Ferguson (1896), which upheld the "separate but equal" doctrine in public education. In 1954, the U.S. Supreme Court overturned Cumming with its decision in Brown v. Board of Education of Topeka.
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Who were the main people involved in the case?
The main individuals involved in Gong Lum v. Rice were Martha Lum, a Chinese-American student barred from attending a white school in Mississippi, and her father, Gong Lum, who filed the lawsuit on her behalf. The legal battle reached the U.S. Supreme Court, which included the justices who rendered the decision. The Mississippi school board and superintendent were also involved, as they enforced the state's segregation policies.
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Why did Martha Lum want to attend a white school?
Martha Lum, a nine-year-old Chinese-American girl, was barred from attending the Rosedale Consolidated School because she was not considered white. Her father, Gong Lum, sued the school board, leading to the Gong Lum v. Rice Supreme Court case. The Mississippi Supreme Court had classified Martha as belonging to the "Mongolian or yellow race" and therefore not white. This classification was rooted in the state's laws that mandated separate schools for white and "colored" students. The desire to attend the white school stemmed from the belief that she, as a U.S. citizen, should not be excluded based on race.
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How did the Supreme Court rule in the case?
In Gong Lum v. Rice, the U.S. Supreme Court ruled 9–0 that a Mississippi school board did not violate the Fourteenth Amendment when it classified Martha Lum, a student of Chinese descent, as "colored" and barred her from attending a white high school.
The Supreme Court referenced Cumming v. Richmond County Board of Education (1899), which upheld state laws allowing separate high schools for Black and white students, and Plessy v. Ferguson (1896), which upheld the "separate but equal" doctrine in public education. The Court held that classifying students by race for education was within Mississippi's constitutional power and protected from federal judiciary intervention. The Mississippi Supreme Court's decision was thus upheld. In 1954, the U.S. Supreme Court overturned Cumming with its decision in Brown v. Board of Education of Topeka.
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What reasons did the Court give for its decision?
In Gong Lum v. Rice, the U.S. Supreme Court ruled that the Mississippi school board didn't violate the Fourteenth Amendment when it classified Martha Lum, a student of Chinese descent, as "colored" and barred her from attending a white high school.
The Court cited Cumming v. Richmond County Board of Education (1899), which stated that education in state-funded schools is a matter for the states to regulate. Interference from the federal judiciary was only justified in cases of clear disregard of rights secured by the supreme law of the land. The Court also referenced Plessy v. Ferguson (1896), upholding the "separate but equal" doctrine. The Court held that classifying students by race for education was within Mississippi's constitutional power and protected from federal intervention.
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How did this case affect school segregation laws in the United States?
The Gong Lum v. Rice case upheld existing school segregation laws, specifically confirming that the separation of students based on race was constitutional under the Fourteenth Amendment. The Supreme Court's ruling stated that as long as equal educational opportunities were provided to all students regardless of race, segregation was permissible. This reinforced the "separate but equal" doctrine established in Plessy v. Ferguson (1896).
However, the Gong Lum ruling was later overturned by Brown v. Board of Education (1954), which declared state-sponsored segregation in public schools unconstitutional, marking a turning point in the fight against racial segregation.
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Gong Lum v. Rice, case in which the U.S. Supreme Court on November 21, 1927, ruled (9–0) that a Mississippi school board had not violated the Fourteenth Amendment’s equal protection clause when it classified a student of Chinese descent as “colored” and barred her from attending a white high school.
Gong Lum, a taxpaying resident of Rosedale, Mississippi, was the father of nine-year-old Martha Lum. Martha, a native-born citizen of the United States, attended the first day of school at the all-white Rosedale Consolidated School. However, at the noon recess, the superintendent, acting on an order issued by the board of trustees, notified her that she would not be allowed to return to the school because “she was of Chinese descent, and not a member of the white or Caucasian race.” Martha’s father subsequently filed suit.
A state trial court entered a mandamus order in favour of Gong Lum, directing officials to readmit his daughter. It held that Martha should not have been classified as “colored.” The Supreme Court of Mississippi, however, reversed, citing the state constitution, which called for separate schools for white and “colored” students. Furthermore, the court held that Martha was of “the Mongolian or yellow race” and could not be considered white.
The case was argued before the U.S. Supreme Court on October 12, 1927. It began its review by noting “the right and power of the state to regulate the method of providing for” public education. The court then cited Cumming v. Richmond County Board of Education (1899), in which it had upheld a state law that allowed separate high schools for black and white students. That opinion also stated that “the education of the people in schools maintained by state taxation is a matter belonging to the respective states.” According to Cumming, any interference on the part of the federal judiciary with the management of the schools could not be justified “except in the case of a clear and unmistakable disregard of rights secured by the supreme law of the land.”
The Supreme Court next addressed whether Martha had been denied equal protection when educational officials classified her among the “colored” races and “furnished facilities for education equal to that offered to all,” no matter what “color.” The court pointed out that since that was not a new question, it did not call for a full argument. Instead, it cited a long list of cases, notably Plessy v. Ferguson (1896), which upheld the “separate but equal” doctrine in public education. According to the court, the classification of students on the basis of race to receive the benefit of education is within the constitutional power of the state legislature of Mississippi; still further, the U.S. Constitution protected that action from the intervention of the federal judiciary. The decision of the Supreme Court of Mississippi was upheld.
In 1954 the U.S. Supreme Court overturned Cumming with its decision in Brown v. Board of Education of Topeka.