PDK International | Phi Delta Kappan: Wraga V87 N6 Feb 2006

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The Heightened Significance of Brown v. Board of Education In Our Time

Most people associate Brown v. Board of Education solely with the issue of school desegregation. But the landmark decision also illuminated several other fundamental ideals of education in a democracy. Mr. Wraga fears that today's prevailing trends in education policy are a threat to those ideals.

By William G. Wraga

TWO YEARS ago, numerous commemorative essays and analyses retold the familiar and now-famous story. On 17 May 1954, the U.S. Supreme Court issued its landmark decision in the case of Brown v. Board of Education of Topeka,1 which struck down the "separate but equal" doctrine of the 1896 Plessy v. Ferguson decision. The Court claimed, "To separate them [African American children] from others of similar age and qualifications solely because of their race generates a feeling of inferiority as to their status in the community that may affect their hearts and minds in a way unlikely ever to be undone." The Court concluded that "in the field of public education the doctrine of 'separate but equal' has no place. Separate educational facilities are inherently unequal."2

The implications of this decision for the rights of African Americans and indeed for all of American society were profound and engendered decades of efforts to desegregate public schools. Although desegregation has yet to be satisfactorily achieved and gains toward that end stalled during the 1990s -- halted by federal court decisions -- the impact of the Supreme Court's 1954 Brown decision remains significant. The significance, however, extends beyond the ongoing and crucial project of achieving racial integration and equality in our schools. In the process of rendering "separate but equal" schooling illegal, the Court also articulated fundamental ideals of American education, which, in the current education reform environment, merit renewed consideration. Let us revisit three of these ideals.

Unifying Function of Public Schools

By insisting that all students attend school under the same roof, the High Court affirmed both the importance of the concept of equal educational opportunity and, implicitly, the unifying function of public education in a democracy. The potential unifying effect of schooling had long been advocated as a central purpose of American education. Lawrence Cremin observed, for example, that, during the mid-19th century, such reformers as Horace Mann conceived of the common school as "a school not common in the traditional European sense of 'for the common people,' but common in a new sense of common to all of the people."3 Cremin continued, "Only in a school where children of all economic classes, religious creeds, and political persuasions could meet on a free and equal basis did these leaders see the amelioration of divisive influences which threatened the social cohesion so necessary to the new Republic."4

During the early 20th century, educators extended the idea of the common school from the elementary to the secondary level. At this time, a debate raged over whether the United States should adopt a dual, European-style system in which 20% of the student population would attend academic high schools conducted by educators, while the remaining 80% of adolescents would attend trade schools controlled by business interests.5 Dewey spoke for many educators when he wrote, "Most of us have probably settled back in a conviction that the unity of the public school system is the best guarantee we possess of a unifying agency to deal successfully with the diversified heterogeneity of our population."6 This debate was decided in favor of the comprehensive high school model, which houses academic and vocational programs and students under one roof, thus expressly embracing a unifying function through which future citizens will "obtain those common ideas, ideals, and common modes of thought, feeling, and action that make for cooperation, social cohesion, and social solidarity."7

Prevailing social norms, of course, always determined the extent of social unification that was acceptable and therefore feasible in educational settings. Over time, however, visions of unification through public schooling became increasingly inclusive. Although by the mid-20th century educational leaders had extended the unifying function of education by calling for the public schools to mitigate the inequalities instigated by racism, it was not until the Brown decision that this ideal could begin to become a reality.8 One year after the Brown decision, the Court issued an implementation directive that left the logistical details to the states. Given the vagueness of the Court's directive, states and localities enjoyed wide latitude, which they exploited and which led, more often than not, to flagrant noncompliance.

School Choice and Segregation

Significantly for education reform in the early 21st century, one of the tactics employed during the 1950s and 1960s to dodge the High Court's desegregation order involved instituting "free choice" schemes, under which "any student assigned to a school where she was a member of the racial majority could transfer to a school where she would be in the minority."9 Even if such transfers did not occur, districts could claim to have ended de jure segregation. Diane Ravitch described the situation this way:

Deep South districts overwhelmingly submitted free-choice plans, permitting students to choose their schools, presumably to maintain segregation-by-choice or to establish token desegregation; the U.S. Civil Rights Commission identified 102 free-choice districts where not a single black student was in school with whites. Southern districts thought that the adoption of a free-choice plan fully satisfied the requirements of the Civil Rights Act, but the Office of Education considered free-choice only a means to the end of complete integration.10

Ravitch reported that such schemes resulted in the "resegregation" of schools. In addition, "voucher-like programs" were devised "to provide public support to private segregationist academies."11

Yet, since the 1980s, when proposals for vouchers and other forms of school choice began to be increasingly advocated as a veritable educational panacea, proponents of school choice have omitted these earliest cases of such strategies from their historical sketches. Instead, they have traced choice to the alternative schools movement of the 1960s and 1970s or presented it as a new idea justified by free-market ideology. Although school systems that implement choice plans endeavor to maintain racially balanced schools, the historical origins of free-choice schools as mechanisms of segregation should give policy makers and educators pause. In fact, at least in terms of access, racial bias tends to persist in school-choice arrangements, as well as in charter schools, a form of school choice.12 Furthermore, research points to the conclusion that "large-scale unregulated-choice programs are likely to lead to some increase in stratification."13

Moreover, segregation occurs not only along racial and socioeconomic lines. Proposals for school choice, charter schools, and magnet schools often promote segregation in a variety of ways, targeting students on the basis of academic or vocational ability, aptitude, or aspiration; gender; and even race. The organization of the curricula of magnet, charter, and choice schools around narrow themes or specializations -- such as the humanities, science and engineering, the performing arts, or even an Afrocentric focus -- can result in curricular fragmentation and balkanization and in academic and educational segregation of students. Such schools, like gated educational communities, fly in the face of the historical commitment to the unifying function of public schooling in the United States. Integration and multicultural understanding emerge from actual association.14 At a time when the nation's population continues to diversify and when socioeconomic divisions have been aggravated by two decades of economic policies that have increased disparities in income and wealth, the unifying function of a common school experience that the Supreme Court affirmed in Brown v. Board of Education becomes increasingly vital to the social fabric of the United States.15

Returning to the Brown decision, the High Court situated the case and its ruling squarely in the context of the history and purpose of public education in a democracy. The Court stated in Brown:

Today, education is perhaps the most important function of state and local governments. Compulsory school attendance laws and the great expenditures for education both demonstrate our recognition of the importance of education to our democratic society. It is required in the performance of our most basic public responsibilities, even in the armed services. It is the very foundation of good citizenship. Today it is a principal instrument in awakening the child to cultural values, in preparing him for later professional training, and in helping him adjust normally to his environment. In these days, it is doubtful that any child may reasonably be expected to succeed in life if he is denied the opportunity of an education. Such an opportunity, where the state has undertaken to provide it, is a right which must be made available to all on equal terms.16

This passage contains at least two additional fundamentally American educational ideals that we too often take for granted and that are currently threatened by education reform policies.

Educating Enlightened Citizens

One of these ideals holds that an important function of public education should be to educate enlightened citizens. Thomas Jefferson's reflections on this subject have been a touchstone for citizenship education in a democracy: "Every government degenerates when trusted to the rulers of the people alone. The people themselves are its only safe depositors. And to render them safe, their minds must be improved to a certain degree."17 For Jefferson, an enlightened citizenry not only would make informed decisions about common problems but also would serve as a check against the power of the government.

Recent reform efforts, however, have exalted academic achievement and the training of productive workers at the expense of the preparation of future citizens. The No Child Left Behind (NCLB) Act, for example, omits any mention of education for citizenship as part of its express purpose. Although Subpart 3 of NCLB, titled the "Education for Democracy Act," authorizes the secretary of education to award grants to organizations that promote civics education, even the purposes articulated in this passage make no reference to the kind of citizenship that Jefferson called for.18 In the current reform climate, the Supreme Court's affirmation in Brown of the role of public education in educating enlightened citizens for democracy warrants renewed attention.

Publicly Supported Education

A third ideal the Court affirmed in Brown v. Board of Education has become so ingrained in American thinking about education that it is surprising that thoughtful reformers can so brazenly dismiss it. Philosophers from Aristotle to Adam Smith long ago identified education as a primary function of the state.19 According to Cremin, for 19th-century education reformers in the United States, "Not only was this common school to serve the public, it was also to be supported and controlled by the public. In this way," he continued, "no child could ever be banned for poverty, and no partisan political, economic, or religious group could ever control the school for its own private purposes."20 Recognizing this imperative, during the 20th century, industrial democracies adopted state-supported systems of education.

Yet recently in the United States -- the first nation in history to provide universal access to publicly supported education -- efforts to commercialize and even privatize public education have proliferated.21 For example, NCLB authorizes the secretary of education to provide grants to for-profit organizations that engage in teacher recruitment and permits charter schools to use public money "to access private-sector capital" to invest in property or subsidize capital improvements.22 Vouchers and school choice were only the first such efforts. In recent years, numerous aspects of the school program -- from food and custodial services to curriculum and even wholesale management of schools -- have been privatized or contracted to private concerns. In the process, the public voice -- and possibly the public interest -- is in danger of becoming of secondary importance to private profit.

Moreover, the statistically unattainable expectations for "adequate yearly progress" mandated in NCLB can be understood, as Gerald Bracey put it, as part of "a campaign of shock and awe" intended to discredit the public schools, to erode public confidence in the institution, and ultimately to pave the way for privatization of our public education system.23 In an era in which powerful interests are poised to commercialize and even privatize a range of public services, including the public schools, the ideal of a publicly financed and governed system of education that the Supreme Court affirmed in Brown v. Board of Education deserves renewed commitment.

In deciding to render "separate but equal" educational facilities unconstitutional, the Supreme Court affirmed fundamental educational ideals: implicitly, the unifying function of common schooling and explicitly, the imperatives for citizenship education and for a publicly supported system of education. The justices took these fundamental ideals, which formed the basis of the Brown decision, as givens. No longer can these ideals be taken for granted. Taking our cue from the High Court, it is time that we reaffirm our commitment to the unifying function of common schooling, to the necessity for citizenship education, and to the imperative for a publicly supported system of education. At a time when such fundamental ideals have become increasingly vulnerable, the sage judgment of the Court in Brown assumes heightened significance.

1. Brown v. Board of Education, 347 U.S. 483 (1954).

2. lbid., pp. 495-96.

3. Lawrence A. Cremin, "The Curriculum Maker and His Critics: A Persistent American Problem," Teachers College Record, February 1953, p. 235.

4. Ibid.

5. Committee on Industrial Education, Report of the Committee on Industrial Education (New York: National Association of Manufacturers, 1915).

6. John Dewey, "Splitting Up the School System," in Jo Ann Boydston, ed., John Dewey: The Middle Works, vol. 8 (Carbondale: Southern Illinois University Press, 1985), p. 123.

7. Commission on the Reorganization of Secondary Education, Cardinal Principles of Secondary Education, Department of the Interior, Bureau of Education, Bulletin 1918, No. 35, p. 21.

8. For calls that preceded Brown, see, for example, Educational Policies Commission, Education for ALL American Youth (Washington, D.C.: National Education Association, 1944), pp. 16, 79, 233; and Hollis L. Caswell, ed., The American High School: Its Responsibility and Opportunity (New York: Harper & Row, 1946), p. 137.

9. Brian Gill et al., Rhetoric vs. Reality: What We Know and What We Need to Know About Vouchers and Charter Schools (Santa Monica, Calif.: RAND Corporation, 2001), p. 159.

10. Diane Ravitch, The Troubled Crusade: American Education, 1945-1980 (New York: Basic Books, 1983), p. 164. In 1968, the Supreme Court ruled that "free choice" schemes were inadequate responses to segregation.

11. Gill et al., p. 159.

12. Gill et al., op. cit.; and Jeffrey R. Henig, "School Choice Outcomes," in Stephen D. Sugarman and Frank R. Kemerer, eds., School Choice and Social Controversy: Politics, Policy, and Law (Washington, D.C.: Brookings Institution Press, 1999), pp. 68-110.

13. Gill et al., p. 204.

14. Robert E. Slavin, "Integrating the Desegregated Classroom: Action Speaks Louder Than Words," Educational Leadership, February 1979, pp. 322-24; and idem, "Effects of Biracial Learning Teams on Cross-Racial Friendships," Journal of Educational Psychology, vol. 71, 1979, pp. 381-87.

15. Harold Hodgkinson, "Educational Demographics: What Teachers Should Know," Educational Leadership, December 2000/January 2001, pp. 6-11; and Kevin Phillips, Wealth and Democracy (New York: Broadway Books, 2002).

16. Brown v. Board of Education, p. 493.

17. Thomas Jefferson, "Notes on the State of Virginia" (1781/1785), in Gordon C. Lee, ed., Crusade Against Ignorance: Thomas Jefferson on Education (New York: Teachers College Press, 1961), p. 97.

18. No Child Left Behind Act of 2001 (P.L. 107-110, 8 January 2002), United States Statutes at Large, pp. 1662-66. For the purpose of the act, see p. 1439.

19. The Politics of Aristotle, trans. Benjamin Jowett (Oxford: Clarendon Press, 1885), Book VIII, p. 244; and Adam Smith, An Inquiry into the Nature and Causes of the Wealth of Nations (New York: Modern Library, 1937), pp. 734-37, 768.

20. Cremin, pp. 235-36.

21. For the wider trend, see Paul Krugman, The Great Unraveling: Losing Our Way in the New Century (New York: Norton, 2003), esp. pp. 6, 216. For discussions of efforts to commercialize and privatize public schools, see Alex Molnar, Giving Kids the Business: The Commercialization of America's Schools (Boulder, Colo.: Westview Press, 1996); and Gerald W. Bracey, The War Against America's Public Schools: Privatizing Schools, Commercializing Education (Boston: Allyn and Bacon, 2002).

22. No Child Left Behind, pp. 1656, 1801.

23. Gerald W. Bracey, "The 13th Bracey Report on the Condition of Public Education," Phi Delta Kappan, October 2003, p. 149.

WILLIAM G. WRAGA is a professor in the Department of Lifelong Education, Administration, and Policy, College of Education, University of Georgia, Athens. He wishes to thank Elizabeth DeBray for constructive suggestions on an earlier version of this article.