Griffin v. Prince Edward Co (1964)

Introduction

In 1951, African American students at Robert Russa Moton High School in Farmville, Virginia organized a mass walkout in protest of the Prince Edward County School Board’s policy of racial segregation. Barbara Johns, a sixteen-year-old junior at Moton and the niece of civil rights leader Vernon Johns, organized the strike and formulated a committee of students and parents that worked with NAACP attorneys to petition the county to desegregate its schools. The suit was eventually incorporated into the 1954 Brown v. Board of Education of Topeka case in which the Supreme Court held that segregation of public schools on the basis of race denied African American students equal protection under the Fourteenth Amendment. In response, Virginia Senator Harry F. Byrd called for a campaign of “massive resistance” to forced integration and the Virginia Assembly passed a set of laws known as the Stanley Plan that gave the governor the power to close schools intending to desegregate. In 1959, state and federal courts struck down the Stanley Plan as unconstitutional and several Virginia counties began to cooperate with federal desegregation orders. Prince Edward County continued to resist, closing its schools and redirecting county and state taxes into tuition grants that white students used to attend private academies. African American students were left without access to any formal education options. In 1962, a District Court ordered the county to fund its public schools, but the Fourth Circuit Court reversed the decision. When the Supreme Court took up the case in early 1964, Prince Edward County was the only remaining county in Virginia to keep its public schools closed. In its decision, the Court held that by closing its schools and funding segregated private institutions in their place, state and county officials deprived African American students of equal protection under the law. It then remanded the case back to the District Court to oversee the reopening of the schools and levying of taxes to fund them. In September, the county public schools reopened to all students for the first time in five years, though it would be decades before the schools fully integrated. Today, the Robert Russa Moton Museum in Farmville stands as one of Virginia’s most important Civil Rights landmarks and is a testament to the ongoing battle for racial equality and equity in public education. Constitutional Issue Raised in the Case Did Prince Edward County’s decision to close public schools and redirect funds to all-white private schools deny African American students equal protection under the Fourteenth Amendment?

Citation and Decision

Griffin v. County School Board of Prince Edward County, 377 U.S. 218 (1964) | Full Decision

In a 7-2 decision, the Court held that while governments have the power to close schools, they cannot do so for the purpose of denying education to a group of students on the basis of race. Writing for the majority, Justice Hugo Black held that to prevent further delays, the District Court could exercise its power to require the Prince Edward County government to reopen and fund its public schools without racial segregation. Justices Tom Clark and John Marshall Harlan disagreed with the holding that the federal courts were empowered to order the reopening of the public schools, but otherwise joined in the Court's opinion.

Discussion Questions

1. How did the activism of Vernon Johns influence his niece, Barbara Johns, to spearhead a protest of racial segregation at Robert Russa Moton High School?

2. How did the Griffin case build on the 1954 Supreme Court decision in Brown v. Board of Education of Topeka?

3. What was the Stanley Plan, and how did it seek to put Senator Byrd’s call for “massive resistance” into practice in Virginia?

4. In what ways did Prince Edward County represent a last stand of “massive resistance” in Virginia after the Stanley Plan was found unconstitutional?

5. How long were the public schools closed in Prince Edward County, and how did that impact the lives of African American students?

6. Why did Justices Harlan and Clark disagree with Justice Black’s holding that federal courts were empowered to order the reopening of public schools?

7. How is the fight for racial integration in its public schools remembered in Farmville today?

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