The plaintiffs complained that the Richmond County Board of Education used public school funds to assist in maintaining a high school for white children without providing a similar high school for colored children. According to the record as described by the Court, the Board had suspended the colored high school temporarily for economic reasons. The Board concluded that maintaining a separate high school for about sixty colored children would prevent it from providing primary-school educational facilities to about three hundred colored children who were then unprovided for. The plaintiffs sought an injunction that would stop support for the white high school.
Issue
Whether the state court's refusal to enjoin the Board of Education from maintaining and supporting a high school for white children, while a colored high school had been temporarily suspended for economic reasons, denied the plaintiffs equal protection or other rights secured by the Fourteenth Amendment.
Rule
Where education in tax-supported schools is a matter belonging to the States, federal judicial interference with state school management is not justified unless there is a clear and unmistakable disregard of rights secured by the Constitution. On the record presented, a state court does not deny equal protection or privileges of national citizenship by refusing to enjoin support for a white high school when the suspension of a colored high school appears temporary, economically motivated, and untainted by bad faith, abuse of discretion, or hostility to the colored race.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Macon, Georgia, the Alder County School Council faced a budget shortfall. It suspended its public secondary program for Black students for one year and used the same funds to open several elementary classrooms for many more Black children who otherwise would have had no public schooling, while continuing to subsidize an existing public secondary program for white students. A group of Black taxpayers sued only to enjoin the subsidy to the white secondary program.
How should a court most likely rule on the requested injunction under the controlling doctrine?
Explanation. The majority held that federal judicial interference with state management of tax-supported schools is justified only in a clear and unmistakable case of constitutional violation. Where the record shows a temporary suspension for economic reasons, with funds redirected to primary education for a larger number of Black children, and no bad faith, abuse of discretion, or racial hostility, a court should not enjoin support for the white school. The requested relief would only take educational opportunities from white children without adding them for Black children. (Derived from Cumming v. Richmond County Board of Education (1899).)