Facts of the Case
The Governor and the Legislature of Arkansas openly resisted the Supreme Court's decision in Brown v. Board of Education. On February 20, 1958, five months after the integration crisis involving the Little Rock Nine, members of the school board (along with the Superintendent of Schools) filed suit in the United States District Court for the Eastern District of Arkansas, urging suspension of its plan of desegregation. The relief the plaintiffs requested was for the African American children to be returned to segregated schools and for the implementation of the desegregation plan to be postponed for two and a half years. The district court granted the school board's request, but the United States Court of Appeals for the Eighth Circuit reversed.
Questions
Were Arkansas officials bound by federal court orders mandating desegregation?
Conclusions
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In a signed, unanimous per curiam opinion, the Court held that the Arkansas officials were bound by federal court orders that rested on the Supreme Court's decision in Brown v. Board of Education. While the Court noted that the school board had acted in good faith, that most of the problems stemmed from the official opposition of the Arkansas state government to racial integration in both word and deed, it was constitutionally impermissible under the Equal Protection Clause to maintain law and order by depriving the black students of their equal rights under the law. More importantly, the Court held that since the Supremacy Clause of Article VI made the U.S. Constitution the supreme law of the land, and Marbury v. Madison made the Supreme Court the final interpreter of the Constitution, the precedent set forth in Brown v. Board of Education was the supreme law of the land and was therefore binding on all the states, regardless of any state laws contradicting it. The Court therefore rejected the contention that the Arkansas legislature and Governor were not bound by the Brown decision.
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