Brown v. Board of Education

Angelo Kramvis

Social Science in Brown

• 3 Points of Discussion:– Background of the case– Evaluation of two studies– Examining the relevancy and reasons for use

of social science

Background

• Legal precedent: Plessy v. Ferguson • Almost sixty years before Brown

• The Court held that state-enforced racial segregation did not violate the 14th Amendment, because separating people of different racial backgrounds did not, in and of itself, imply their inequality

• Reasoning: it is merely an “assumption that the enforced separation of the two races stamps the colored race with a badge of inferiority. If this be so, it is not by reason of anything found in the act, but solely because the colored race chooses to put that construction upon it.”

Background

• Procedural history and facts:– Consolidation of several cases from Kansas,

South Carolina, Virginia, and Delaware.– In each case, African-American students were

denied access to public schools on a non-segregated basis.

– Argument was that even assuming equal “tangible” factors, segregated schools are inherently unequal and violate the equal protection clause of the 14th Amendment.

Brown - Reasoning

• Chief Justice Warren: – emphasized three factual themes:

• the Court's inability to discern the intended historical scope of the Fourteenth Amendment;

• the development of public education since the adoption of the Amendment;

• the harmful social and psychological impact of racial segregation on black schoolchildren.

– Although many social scientists testified, the only mention of research was in one controversial footnote: the now infamous footnote 11.

Footnote 11

• Opinion text:– "Whatever may have been the extent of

psychological knowledge at the time of Plessy v. Ferguson, this finding [of segregation's harmful impact] is amply supported by modern authority."

– 7 sources cited, most not experiments– NAACP lawyers included the studies in their

brief to prove that segregation actually harmed black children.

Brown - Holding

• Segregated schools deprived minority students of equal educational opportunities and thus violated the equal protection clause of the 14th Amendment.

Dolls Study – Purpose

• “To investigate the development of racial identification and preferences of Negro children.”

• Conducted by Maime and Kenneth Clark– First source cited in footnote 11

Dolls Study – Procedure

• Subjects:– 253 African-American children between

the ages of 3 to 7.– The children were selected from 2

locations:• The southern group: taken from

segregated schools in Arkansas. Had no experience in racially mixed school situations.

• The northern group: taken from racially mixed schools in Massachusetts.

– Children were also classified by skin color

Dolls Study – Procedure

• Subjects presented with 4 dolls• Dolls were identical except for skin

color:– 2 white dolls with blond hair

– 2 brown dolls with black hair

• For half of the subjects, the dolls were presented in the order: – white, colored, white, colored

– The other half received a reversed order

Dolls Study – Procedure

• Subjects responded to 8 requests by choosing one of the dolls.

• Requests 1 through 4 revealed racial preferences:– 1. Give me the doll you like to

play with.

– 2. Give me the doll that is a nice doll.

– 3. Give me the doll that looks bad.

– 4. Give me the doll that is a nice color.

Dolls Study – Procedure

• Requests 5 through 7 indicated a knowledge of “racial differences”:– 5. Give me the doll that looks like a white child.

– 6. Give me the doll that looks like a colored child.

– 7. Give me the doll that looks like a Negro child.

• Request 8 intended to show self-identification:– 8. Give me the doll that looks like you.

Dolls Study – Procedure

• Order of questions was always from 1 to 8.– Preliminary investigation revealed

that children who already identified themselves with the colored doll had a marked tendency to indicate a preference for this doll.

– Researchers said that this did not reveal true preferences and would distort the data.

Dolls Study – Results

• The majority of the children were aware of “racial differences”:– 94% gave the white doll when asked– 93% gave the colored doll when asked– 72% gave the brown doll when asked for

the “Negro doll”• Explanation: white and colored are more

concrete concepts than “Negro”.

– Accuracy increased with age

Dolls Study – Results

• Racial Preferences:– About two-thirds of the subjects said that

they would like to play with the white doll in preference to the colored doll, that the white doll is a “nice doll,” and that the white doll was a “nice color.”

– Requests for the doll that “looks bad” resulted in 59% choosing the colored doll, 17% choosing the white doll, and 24% giving no response

• Compare to other questions where “no response” rate was around 1-5%

Dolls Study – Results

• Racial Preferences: North-South Differences– Southern children are less pronounced in

their preference for the white doll compared to the northern children’s preference for this doll, but difference only marginally significant.

– However, southern children less likely to reject the brown doll. A significantly higher percentage of northern children (71%), compared to southern children (49%), think that the brown doll “looks bad.”

Dolls Study – Results

• Racial self-identification:– After being asked for preferences, the

children were asked to self-identify with one of the dolls.

– About one-third of the children identified with the white doll.

• No North-South Differences• Light-skinned children (80%) identified

with the white doll much more than dark-skinned children (19%).

Dolls Study – Results

• Qualitative Data:– Some children, especially from the North, broke down

during the self-identification part.• Two children cried and ran out of the room.

– Many attempted to rationalize their identification with the brown doll.

• 5-year old: “I burned my face and made it spoil.”

• 7-year old: “I look brown because I got a suntan in the summer.”

Dolls Study – Criticisms

• Order of requests:– Asking for the “nice” doll first and the

“bad” doll second may affect responses– dissonance created in self-identification

part

• Requests presupposed that one and only one doll must be chosen:– did not prompt for “both” or “neither”

responses

Dolls Study – Criticisms

• Lack of any control groups:– Test white children– Test other minority groups– Test other identity concepts (e.g. gender)– Test neutral concepts (e.g. school grade)

• Does not show segregation is the culprit for negative racial attitudes:– Northern children rejected the brown doll

more than southern children.– Confounding factors: racially-prejudiced

environment outside of school / de facto segregation

Coloring Test – Procedure

• Same 5 to 7 year-olds from Doll study (excluded 3-4 year-olds)

• Gave subjects a paper with outline drawings of a leaf, an apple, an orange, a boy, and a girl.

• A box of crayons with the usual assortment, along with brown, black, white and tan, was given to each child

Coloring Test – Procedure

• Each child first asked to color the objects and the mouse.– If they did so realistically, they proceeded

to the next portion the test.– 160 stable responses obtained

• Subjects then asked to color the boy (or girl) “the color that you are.”

• Last, the child was asked to color the remaining boy (or girl) “the color you like little boys (or girls) to be”.

Coloring Test – Coding

– For the self-identification task, responses were coded:• “Reality,” if the color was reasonable related to their own

skin color

• “Phantasy,” if the color was markedly different (e.g. white or yellow)

• “Irrelevant or escapist,” if the color was “bizarre” (e.g. purple, red, green, etc.)

– For the preference task, responses were coded:• “Brown,” “White,” or “Irrelevant color”

Coloring Test – Results

• Racial Identification:– The majority of children colored themselves

realistically – 88% total.• Compare to 66% accuracy in Doll study.

– The accuracy of identification became almost 100% by age 7.

– No significant differences between North-South groups or different skin tones.

Coloring Test – Results

• Racial Preferences:– Of all subjects, only 48% colored their

preferences in brown.• 36% indicated a preference for white

• 16% used a “bizarre or irrelevant color”

– Preference for brown increased with age – 37% of 5-year olds vs. 65% of 7-year olds.

• However, 25% of 7-year olds still selected white.

Coloring Test – Results

• North-South differences:– A majority (70%) of Southern children

indicated a preference for brown compared to only 36% of Northern children.

– Northern children also made more irrelevant responses than Southern children (20% vs. 5%)

– Researchers interpreted this as evidence of more emotional turmoil on the part of Northern children.

Coloring Test – Criticisms

• Coding decisions:– Labeling responses which did not prefer brown or

white as “bizarre or irrelevant” does not necessarily provide information about racial attitudes.

• Could be considered as having no preference.• Other coding could be considered subjective.

• Lack of control groups– Compare to white/other minority groups.– Presence of confounding factors of environment/ de

facto segregation.

Coloring Test – Criticisms

• North-South differences cut against an argument that enforced segregation is the culprit for racial preferences.– Significantly more children in Southern group

preferred brown.

• Criticism of Clark, the researcher in both studies, as being more of a social activist than scientist.

More Criticisms – Both Studies

• Small sample sizes

• Experiment performed solely by Clarks– No witnesses or recording of experiment– Not conducted blind to purpose of study– Possibility of experimenter influence

• No independent measures of self esteem

Merits of the Studies

• Offerered evidence that black children understood the social meanings of black inferiority

• Qualitative evidence – spontaneous comments and explanations – back up experimenter’s interpretations

• Studies were likely conceptually sound but methodologically flawed.

Responding to Critics

• In response to the problem of North-South differences, Clark argued that Northern schools were de facto segregated, and children did not make distinctions between this and de jure segregation.– However, if this is true, then there is no

control group at all to compare segregated vs. non-segregated children in either study.

The Use of Social Science

• Criticisms of Court– Studies cited were flawed– Court should have not rested such an important

decision on the shaky and ever-changing nature of social science

– Court entering area where it lacks expertise– Segregation would be wrong even if black student’s

self-esteem was not affected.• What if the research in Brown had demonstrated that

the segregated schools were superior. Would the Court have ruled differently?

The Use of Social Science

• Was the evidence relevant to the Court’s decision?– Evidence points to “NO”:

• Court’s cursory treatment of the studies suggests that it did not take the social science evidence into account in reaching its decision.

• Earl Pollock, a clerk to Chief Justice Warren, says that footnote 11 was irrelevant to the Court’s decision.

• Records of the justices discussions indicates that they did not debate the use or merits of the studies.

• Court makes it clear 10 years later: says that Brown did not rest on social science but on constitutional principles.

The Use of Social Science

• If footnote 11 was irrelevant, then why bother?– Court was over turning a huge precedent at a

time of national controversy– Motive to legitimate decision

• Court did not want to offend the South by declaring segregation had always been wrong

• Court wanted to support its “living Constitution” interpretational style

• Court in search of “facts” to support its policy-making function.

Now v. Then

• Today, it is conventional wisdom that the social science relied upon in Brown was not social science at all

• Notion that segregation causes psychological illness might be rejected by many African-Americans today.– Many blacks have abandoned the integrationist goal

for ideals of black identity and afro-centrism.– However, replications of the “Doll Study” reveal

disturbingly similar results.