Brown Was Decided in 1954, and Making It Real Took Much Longer

In April 1951, a sixteen-year-old named Barbara Johns walked out of Robert Russa Moton High School in Farmville, Virginia, and took most of the student body with her. Moton was the Black high school of Prince Edward County, so overcrowded that some classes met in tar-paper shacks heated by stoves, while the white high school across town had a proper building. The students wanted a new school. The lawyers who came to help them, from the NAACP, told them the honest truth: they would only take a case that attacked segregation itself. The students agreed. Their lawsuit, Davis v. County School Board of Prince Edward County, became one of the five cases the Supreme Court bundled together and decided on May 17, 1954, under the name of a Kansas girl named Linda Brown. Keep Prince Edward County in mind. It is where the story of Brown goes when it stops being about a ruling and starts being about whether anyone will obey it.

In short: Brown v. Board of Education declared school segregation unconstitutional in 1954, but the Court's 1955 follow-up asked only for "all deliberate speed," and Southern states used the gap to resist for years. It took federal troops at Little Rock in 1957, the Civil Rights Act of 1964 and a string of later rulings to turn the decision into real change, and some of that change has since slipped away.

The ruling that said what, and left out how

The Brown decision was short, unanimous and written by Chief Justice Earl Warren, who had spent months making sure every justice signed on. A split decision on segregation, he believed, would invite defiance. The opinion held that separate educational facilities are inherently unequal, and so a state that separated children by race in public schools denied them the equal protection of the laws promised by the Fourteenth Amendment. A companion case from Washington, D.C., Bolling v. Sharpe, reached the same result for the federal capital through the Fifth Amendment's due process clause, since the Fourteenth binds only states.

What the opinion did not say was what should happen next. That was deliberate. The Court asked for another round of arguments about remedy, and a year later, on May 31, 1955, it issued what is usually called Brown II. The answer was to send the cases back to the federal district courts, which would supervise local school boards as they moved toward admitting children on a nondiscriminatory basis "with all deliberate speed."

Those three words did a great deal of work. The phrase was meant to signal both urgency and patience: the justices thought that local judges, who knew local conditions, could push districts along without provoking open revolt. In practice, segregationist officials read the weight as falling on "deliberate," and many treated the absence of a deadline as an invitation to wait indefinitely.

Why the justices hedged

It is tempting to read Brown II as a failure of nerve, and many civil rights lawyers said so at the time. The fairer reading is that the Court understood the limits of its own power. Courts do not run schools. They have no budget, no police and no army. A ruling that ordered every district in the South to integrate by September would have been just as unenforced, and perhaps more so, because it would have given resisters a crisp target and a story about judicial tyranny.

There was also a political calculation. President Dwight Eisenhower was lukewarm about the decision, and Congress, where Southern Democrats held powerful committee chairs, was not going to pass enforcement legislation in the mid-1950s. The justices were betting that a gradual, judge-by-judge approach would build compliance over time.

The bet looks worse in hindsight than it might have at the moment, but it still lost. Leaving the "how" to local federal judges meant leaving it to men who often belonged to the same communities, clubs and politics as the school boards in front of them. Some were courageous. Many were not.

Massive resistance, by design

The reaction in much of the South was not confusion. It was strategy. In March 1956, about a hundred Southern members of Congress signed the Declaration of Constitutional Principles, better known as the Southern Manifesto, which called Brown an abuse of judicial power and praised states that resisted it by lawful means. Virginia's senior senator, Harry F. Byrd, gave the effort its name: massive resistance.

Legislatures across the region passed laws designed to make integration slow, expensive or impossible. Some created pupil placement boards that assigned children one at a time using criteria that never mentioned race but somehow always produced segregated schools. Some offered tuition grants for white children to attend private academies. Some authorized closing any public school ordered to integrate.

That last tool brings us back to Farmville. When federal courts finally required Prince Edward County to desegregate, the county's board of supervisors refused to fund public schools at all. From 1959 to 1964, the county had no public schools. White children went to a private academy set up for them. Most Black children went without formal schooling for years, though some were sent to relatives in other places and some attended makeshift classes organized by churches and volunteers. The students who had walked out with Barbara Johns asked for a better school; the county's answer, years later, was no school.

The Supreme Court ended this in 1964, in Griffin v. County School Board of Prince Edward County, holding that closing public schools to avoid desegregation while supporting private segregated ones violated equal protection. The opinion said, in effect, that the time for "deliberate speed" had run out. It was ten years after Brown.

Little Rock, September 1957

The most famous test of whether Brown meant anything came in Arkansas. The Little Rock school board had adopted a modest, slow plan to desegregate Central High School, starting with a handful of Black students in the fall of 1957. Nine were chosen. They would become known as the Little Rock Nine.

Then Governor Orval Faubus intervened. Citing the threat of violence, he called out the Arkansas National Guard, and the soldiers turned the Black students away from the school. On the first morning one of them, fifteen-year-old Elizabeth Eckford, arrived alone because she had not gotten word of the plan for the students to come together. Photographs of her walking calmly past a jeering crowd went around the world.

For nearly three weeks the standoff continued. A federal judge ordered the Guard withdrawn; when the students finally entered the building, a mob gathered outside, and they had to be taken out for their safety. At that point Eisenhower, who had never warmly endorsed Brown, concluded that the question was no longer school policy. It was whether a state governor could use force to defy a federal court order. On September 24, 1957, he federalized the Arkansas National Guard and sent soldiers of the 101st Airborne Division to Little Rock. The next day, the nine students walked into Central High under armed escort.

It is worth sitting with how strange that is. The president of the United States, a career soldier, deployed paratroopers inside an American city so that nine teenagers could attend a public high school. The troops did not end harassment inside the building, which the students endured for the rest of the year. Still, they established that the federal government would, in the end, enforce the Court's judgment.

The school board then asked a federal court to postpone integration for years, citing the turmoil. The case reached the Supreme Court as Cooper v. Aaron, decided in 1958. The justices refused the delay and declared that state officials are bound by the Court's interpretation of the Constitution. To underline the point, all nine justices signed the opinion individually, an unusual gesture meant to show there was no daylight among them. Arkansas responded by closing Little Rock's high schools for the 1958-59 school year, a period remembered locally as the Lost Year.

What actually moved the needle

For a decade after Brown, the number of Black children in the South attending school with white children stayed tiny. The ruling had changed the law; it had not, on its own, changed the classrooms. What changed them was a combination of forces that arrived in the mid-1960s.

The first was Congress. Title VI of the Civil Rights Act of 1964 barred discrimination in programs receiving federal money, and the Elementary and Secondary Education Act of 1965 made federal money much larger. Suddenly a district that kept its schools segregated risked real dollars. The executive branch wrote guidelines, and enforcement shifted from slow lawsuits to administrative pressure.

The second was the Court losing patience. In Green v. County School Board of New Kent County, decided in 1968, the justices looked at a Virginia district that had adopted a "freedom of choice" plan: any child could, in theory, choose either school. In practice, no white children had chosen the Black school, and most Black children stayed where they were. The Court held that such plans were not enough. School boards had an affirmative duty to dismantle the dual system and produce a plan that worked, now. The next year, in a Mississippi case, the Court said the era of all deliberate speed was over.

The third was remedy at scale. In Swann v. Charlotte-Mecklenburg Board of Education, in 1971, the Court approved busing, rezoning and other tools that district courts could order to undo segregation. In the years that followed, Southern schools became among the most integrated in the country.

The point is not that the Court failed and Congress succeeded. It is that each branch did something the others could not. The Court supplied the principle and, eventually, the insistence. Congress supplied money and enforcement machinery. The presidency supplied, at least once, soldiers. None of it happened quickly, and none of it happened without Black families, students and lawyers taking risks year after year.

The retreat, and what it teaches

The arc did not keep bending in one direction. In Milliken v. Bradley, decided in 1974, the Court ruled five to four that a federal court could not order a desegregation remedy across the line between Detroit and its suburbs without proof that the suburbs had themselves caused the segregation. Since white families were moving to the suburbs, the decision left many urban districts with no realistic way to integrate. Segregation in American schools increasingly became a matter of district lines and housing patterns rather than explicit law.

Later decisions made it easier for districts to exit court supervision, and in 2007, in Parents Involved in Community Schools v. Seattle School District No. 1, a divided Court limited how districts could voluntarily use a student's race in assignments. Researchers who track enrollment have documented that many schools have grown more racially and economically isolated in recent decades, particularly where desegregation orders were lifted.

Here is the argument this history supports, and it is an argument, not a neutral finding: a court ruling is the start of a fight, not the end of one. Brown was correct and essential. It gave the civil rights movement a constitutional foundation and moral authority. But the gains came when ruling, legislation, money and organized people all pushed in the same direction, and they faded when that alignment weakened.

The other side of this debate deserves a fair hearing. Many parents, Black and white, came to oppose long bus rides and wanted neighborhood schools, and some scholars argue that funding and school quality matter more than racial mix. Those concerns were often real, not just cover. The honest response is that neighborhood schools reproduce neighborhood segregation, and neighborhood segregation was itself built by policy: redlining, exclusionary zoning and highway routes. Progressives who want integrated schools also have to want integrated, affordable neighborhoods, which means supporting more homes in places that have long kept them out. That is harder politics than a court case, and it is where much of the work is now.

The people who carried it

Barbara Johns did not stay in Farmville. After the strike, threats against her family led her parents to send her to live with an uncle in Alabama, the minister and activist Vernon Johns. She finished school, married, became a librarian and lived a mostly private life. She died in 1991. In recent years Virginia has honored her: a statue representing her stands at the state Capitol's civil rights memorial, and the state chose her to represent Virginia in the U.S. Capitol's Statuary Hall collection, replacing Robert E. Lee.

The Little Rock Nine went on to lives as varied as any nine people's: careers in business, journalism, education, public service. Several have spoken for decades about what that year cost them and what it made possible. The children of Prince Edward County who lost years of schooling were not so lucky; many never recovered the time, and Virginia later created a scholarship program for people whose education the closures interrupted.

These are the people the phrase "all deliberate speed" was measured against. When we talk about Brown as a turning point, we are talking about them, and about the many parents in towns no one remembers who signed petitions knowing they might lose their jobs.

What you can do

The fight over who gets a good public school is still mostly local, and it still runs through courts, legislatures and school boards.

1. Follow the Court's current cases. Our court watch page lists Supreme Court opinions this term with the Court's own summaries, along with the emergency docket and Senate votes on judges, so you can see which equal protection and education questions are on the docket.
2. Read the wider story. The courts topic page and the education topic page gather current reporting on school funding, desegregation and the judiciary.
3. Support the groups doing the work. The organizations directory lists civil rights, legal aid and education nonprofits in every state, including many that monitor school discipline, funding and district boundaries.
4. Show up locally. Attend a school board meeting when attendance zones or new school sites are on the agenda. District lines decide more about integration today than any statute does, and the meetings are often nearly empty.
5. Back housing near good schools. When your city considers allowing apartments or smaller homes in neighborhoods with strong schools, say so in public comment. It is one of the most direct ways to widen access that Brown promised.

Brown said the door was open. It took seventy years of other people's courage to keep pushing it, and it will take more.