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Cooper v. Aaron

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Cooper v. Aaron
Supreme Court of the United States
Argued September 11, 1958
Decided September 12, 1958
Full case nameWilliam G. Cooper, et al., Members of the Board of Directors of the Little Rock, Arkansas, Independent School District, and Virgial T. Blossom, Superintendent of Schools v. John Aaron, et al.
Citations358 U.S. 1 (more)
78 S. Ct. 1401; 3 L. Ed. 2d 5; 1958 U.S. LEXIS 657; 79 Ohio L. Abs. 452
Case history
PriorSuspension of order granted, 163 F. Supp. 13 (E.D. Ark 1958); reversed, 257 F.2d 33 (8th Cir. 1958); cert. granted, 358 U.S. 29 (1958).
SubsequentOpinion announced September 29, 1958
Holding
This Court cannot countenance a claim by the Governor and Legislature of a State that there is no duty on state officials to obey federal court orders resting on this Court's considered interpretation of the United States Constitution in Brown v. Board of Education (1954).
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black · Felix Frankfurter
William O. Douglas · Harold H. Burton
Tom C. Clark · John M. Harlan II
William J. Brennan Jr. · Charles E. Whittaker
Case opinions
MajorityWarren, Black, Frankfurter, Douglas, Burton, Clark, Harlan, Brennan, Whittaker
ConcurrenceFrankfurter
Laws applied
U.S. Const. amend. XIV; Supremacy Clause
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Cooper v. Aaron, 358 U.S. 1 (1958), was a landmark decision of the Supreme Court of the United States that denied the school board of Little Rock, Arkansas the right to delay racial desegregation for 30 months.[1] On September 12, 1958, the Warren Court delivered a decision that held that the states are bound by the Court's decisions and must enforce them even if the states disagree with them, asserting the judicial supremacy established in Marbury v. Madison (1803).[2] The decision in this case upheld the rulings in Brown v. Board of Education and Brown II that had held that the doctrine of separate but equal was unconstitutional.[3]

Background of the case

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See also: Little Rock Nine and Southern Manifesto

In the wake of Brown v. Board of Education (1954), the school district of Little Rock, Arkansas formulated a plan to desegregate its schools. Meanwhile, other school districts in the state opposed the Supreme Court's rulings and did not make any attempts to desegregate their schools. The Arkansas state legislature amended the state constitution to oppose desegregation and then passed a law relieving children from mandatory attendance at integrated schools.[4] During this time the school board of Little Rock still continued with desegregation.[5]

However, on February 20, 1958, five months after the integration crisis involving the Little Rock Nine, members of the Little Rock school board (along with the Superintendent of Schools) filed suit in the United States District Court for the Eastern District of Arkansas, seeking to suspend their plan for desegregation.[6] They alleged that public hostility to desegregation along with opposition by Governor Orval Faubus and the state legislature created "chaos, bedlam and turmoil".[7][8] 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 until January 1961. The district court granted the school board's request, but the United States Court of Appeals for the Eighth Circuit, sitting en banc, reversed that decision after the NAACP, represented by Thurgood Marshall, appealed.[9] Prior to the Eighth Circuit's decision, the Supreme Court had denied the defendants' request to decide the case without waiting for the appeals court to deliberate on the case. Once the court of appeals handed down its decision in favor of the defendants, the school board appealed to the Supreme Court, which met in a rare summer session to hear arguments.[8]

The court's decision

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On September 12, 1958, the Court issued an opinion jointly authored by all nine Justices — the only instance of that occurring on record, but primarily drafted by Justice Brennan,[10] the Court noted that the school board had acted in good faith, asserting that most of the problems stemmed from the official opposition of the Arkansas state government to racial integration.[11] Nonetheless, 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 US Constitution the supreme law of the land and Marbury v. Madison (1803) made the Supreme Court the final interpreter of the Constitution,[12] the precedent set forth in Brown v. Board of Education is the supreme law of the land and is therefore binding on all the states, regardless of any state laws contradicting it.[13] The Court therefore rejected the contention that the Arkansas legislature and Governor were not bound by the Brown decision.[14] The Supreme Court also rejected the doctrines of nullification and interposition in this case, which had been invoked by segregationists.[15] Segregation supporters argued that the states have the power to nullify federal laws or court rulings that they believe to be unconstitutional and the states could use this power to nullify the Brown decision. The Arkansas laws that attempted to prevent desegregation were Arkansas' effort to nullify the Brown decision. The Supreme Court held that the Brown decision "can neither be nullified openly and directly by state legislators or state executive or judicial officers nor nullified indirectly by them through evasive schemes for segregation."[16] Thus, Cooper v. Aaron held that state attempts to nullify federal law are ineffective.[15]

Moreover, since public officials are required to swear an oath to uphold the Constitution (as per Article VI, Clause 3), the officials who ignored the supremacy of the Court's precedent in the Brown case violated their oaths.[17] Cooper also maintained that even though education is the responsibility of the state government, that responsibility must be carried out in a manner consistent with the requirements of the Constitution, particularly the Fourteenth Amendment.[18]

Critical response

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Despite all nine Justices signing the opinion, Justice Frankfurter published a separate, concurring, opinion. He was, however, dissuaded from announcing it the same day as the main opinion by Justices Brennan and Black, who felt a unanimous decision would emphasize how strongly the Court felt about the issue. Frankfurter's opinion did not directly contradict the majority opinion, but it did reemphasize the importance of judicial supremacy and expressed disdain for the Arkansas State Legislature's actions.[19]

Some legal scholars criticized the Court's rationale in Cooper. Perhaps the most famous criticism of the case was that of former US Attorney General Edwin Meese, in a law review article entitled The Law of the Constitution.[20] There, Meese accused the Court of taking too much power for itself by setting itself up as the sole institution responsible for the interpretation of the Constitution. He wrote that while judicial interpretation of the Constitution binds the parties of the case, it should not establish a supreme law of the land that must be accepted by all persons.

Significance

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Cooper v. Aaron was able to reaffirm the principle that the Supreme Court's decision has the final say, overriding all state and public officials. This case provided a clear message that any Supreme Court rulings are considered final say and whatever state or individual who tries to go against that will be deemed unconstitutional. [1] Cooper v. Aaron was a critical movement during this time and paved the way for the Federal government to primitive civil rights, especially in the South.

The state of Arkansas was adamant to delay the process of seggergation of Little Rock Central High School by using state powers, but that could only go so far. This was a monumental moment questioning how much power do states truly have. Arkansas actions was a direct defiance of the Supreme Courts ruling in Brown v. Board of Education. This case was beyond challenging a certain policy, it questioned how far states can go with enforcing constitutional mandates. [2]

The significant ruling justified that the U.S. Constitution is the "Supreme law of the land" and all states must uphold it. Cooper v. Aaron solidified the Supreme Court as the main interpreter of the U.S. Constitution. The Supreme Courts ruling strengthened the principle of federalism by ensuring that states cannot disregard federal decisions. [3]

See also

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Notes

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  1. ^ Freyer, Tony A. (March 2008). "Cooper v. Aaron (1958): A Hidden Story of Unanimity and Division". Journal of Supreme Court History. 33 (1): 89–109. doi:10.1111/j.1540-5818.2008.00180.x. ISSN 1059-4329. S2CID 143700384.
  2. ^ Harriger, Katy J. (2016). "In Defense of Cooper v. Aaron: Distinguishing among Judicial Supremacy Claims". The Review of Politics. 78 (3): 443–465. doi:10.1017/S0034670516000346. ISSN 0034-6705. S2CID 148135292.
  3. ^ Freyer, Tony (2009). Cooper v. Aaron. Oxford University Press. ISBN 978-0199891511.
  4. ^ Cooper v. Aaron, vol. 358, September 12, 1958, p. 1, retrieved December 1, 2018
  5. ^ Freyer, Tony A. (March 2008). "Cooper v. Aaron (1958): A Hidden Story of Unanimity and Division". Journal of Supreme Court History. 33 (1): 89–109. doi:10.1111/j.1540-5818.2008.00180.x. ISSN 1059-4329. S2CID 143700384.
  6. ^ Freyer, Tony A. (March 2008). "Cooper v. Aaron (1958): A Hidden Story of Unanimity and Division". Journal of Supreme Court History. 33 (1): 89–109. doi:10.1111/j.1540-5818.2008.00180.x. ISSN 1059-4329. S2CID 143700384.
  7. ^ Cooper v. Aaron, vol. 358, September 12, 1958, p. 1, retrieved December 1, 2018
  8. ^ a b Harriger, Katy J. (2016). "In Defense of Cooper v. Aaron: Distinguishing among Judicial Supremacy Claims". The Review of Politics. 78 (3): 443–465. doi:10.1017/S0034670516000346. ISSN 0034-6705. S2CID 148135292.
  9. ^ Epperson, Lia (September 1, 2014). "Brown's Dream Deferred: Lessons on Democracy and Identity From Cooper v. Aaron to the 'School-to-Prison Pipeline'". Wake Forest Law Review. 49: 687–702 – via ebscohost.
  10. ^ Farber, Daniel A. (1982). "The Supreme Court and the Rule of Law: Cooper v. Aaron Revisited". University of Illinois Law Review. 2 (1): 387–412. doi:10.2307/1340770. JSTOR 1340770.
  11. ^ Cooper v. Aaron, vol. 358, September 12, 1958, p. 1, retrieved December 1, 2018
  12. ^ The Court claimed that Marbury

    ... declared the basic principle that the federal judiciary is supreme in the exposition of the law of the Constitution, and that principle has ever since been respected by the Court and the country as a permanent and indispensable feature of our constitutional system. 358 U.S. 1, 18

    Chief Justice John Marshall wrote in Marbury,

    it is emphatically the province and duty of the judicial department to say what the law is. Those who apply the rule to particular cases must of necessity expound and interpret that rule. U.S. (1 Cranch) at 177

    For a different understanding of Marbury see Pryor, William. "The Unbearable Rightness of Marbury v. Madison: Its Real Lessons and Irrepressible Myths" Archived September 10, 2015, at the Wayback Machine, Engage, Vol. 12, Iss. 2, p. 94 (2011).
  13. ^ Harriger, Katy J. (2016). "In Defense of Cooper v. Aaron: Distinguishing among Judicial Supremacy Claims". The Review of Politics. 78 (3): 443–465. doi:10.1017/S0034670516000346. ISSN 0034-6705. S2CID 148135292.
  14. ^ Cooper v. Aaron, vol. 358, September 12, 1958, p. 1, retrieved December 1, 2018
  15. ^ a b Freyer, Tony A. (March 2008). "Cooper v. Aaron (1958): A Hidden Story of Unanimity and Division". Journal of Supreme Court History. 33 (1): 89–109. doi:10.1111/j.1540-5818.2008.00180.x. ISSN 1059-4329. S2CID 143700384.
  16. ^ Cooper v. Aaron, vol. 358, September 12, 1958, p. 1, retrieved December 1, 2018
  17. ^ Freyer, Tony (2009). Cooper v. Aaron. Oxford University Press. ISBN 978-0199891511.
  18. ^ Cooper v. Aaron, vol. 358, September 12, 1958, p. 1, retrieved December 1, 2018
  19. ^ Farber, Daniel A. (1982). "The Supreme Court and the Rule of Law: Cooper v. Aaron Revisited". University of Illinois Law Review. 2 (1): 387–412. doi:10.2307/1340770. JSTOR 1340770.
  20. ^ Meese, Edwin. "The Law of the Constitution", Tulane Law Review, Vol. 61, p. 979 (1986-1987).

Sources

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  • Farber, Daniel A.; Eskridge, William N., Jr.; Frickey, Philip P. Constitutional Law: Themes for the Constitution's Third Century. Thomson-West Publishing, 2003. ISBN 0-314-14353-X
  • Hall, Kermit L. ed. The Oxford Companion to the Supreme Court of the United States, Second Edition. Oxford University Press, 2005. ISBN 978-0-19-517661-2
  • Freyer, Tony A. Little Rock on Trial: Cooper v. Aaron and School Desegregation. Lawrence (KS), 2007.
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