Education in Maryland: Separate And Unequal


Thurgood Marshall, between 1935 and 1940In 1896, the Supreme Court decision in Plessy v. Ferguson legalized segregation in public accommodations, education, and transportation. Although the majority opinion denied that legalized segregation would produce inferior accommodations for either race, in reality, provisions for whites were generally superior to those created for blacks. 

In 1937, a suit was file on behalf of Margaret Williams, a fourteen year old African American who two years previous had  been denied enrollment in Catonsville High School by its principal, David W. Zimmerman, because of her race. At that time, there were twenty-four elementary schools for black children located across Baltimore County, but upon completion of elementary school, black school children had to attend one of three black high schools in Baltimore City -- Douglass High School, Booker T. Washington High School, and Dunbar High School -- because no high schools were available for black students in the county. 

The defendants in the case, who included the principal of Catonsville High School and the superintendent of the Baltimore County Board of Education, contended that the high schools were "... reasonably accessible, to the said colored pupils, and affording adequate courses for pupils and giving said pupils educational advantages in all respects equivalent to those afforded by the white schools." The defendants also argued that Margaret Williams was not disqualified from attending Catonsville High School because of her race, but had also failed to successfully pass necessary uniform examinations given at the end of seventh grade. Thurgood Marshall and Charles Houston, legal counsel for the petitioner, argued that Margaret Williams was not only qualified to attend the school, but that the denial of admission represented a violation of the equal protection of the laws guaranteed by the Fourteenth Amendment. The case was dismissed by the lower court and lost on appeal. 

Margaret received her high school education at St. Frances Academy in Baltimore. Because of the distance between the school and her home, Margaret traveled a couple of hours each day just to attend school. After graduation, Margaret attended nursing school and during World War II, she worked at the Glenn L. Martin factory. 

Segregation in education remained the norm in Maryland until Plessy v. Ferguson was struck down in 1954 as a result of Brown v. Board of Education.

National History Standards

Materials compiled in this document can be used by educators to fulfill the following National History Standards for Grades 5-12:

Era 7: The Emergence of Modern America (1890-1930)

STANDARD 3: How the United States changed from the end of World War I to the eve of the Great Depression.

Standard 3A: The student understands social tensions and their consequences in the postwar era. 

7-12: Examine rising racial tensions, the resurgence of the Ku Klux Klan, and the emergence of Garveyism. [Analyze cause-and-effect relationships] 

Era 8: The Great Depression and World War II (1929-1945)

Standard 3C: The student understands the effects of World War II at home. 

7-12: Evaluate how minorities organized to gain access to wartime jobs and how they confronted discrimination. [Formulate a position or course of action on an issue] 

Era 9: Postwar United States (1945 to early 1970s) 

STANDARD 3: Domestic policies after World War II. 

Standard 3A: The student understands the political debates of the post-World War II era. 

5-12: Evaluate Truman’s civil rights policies and their effect on splintering the Democratic party. [Assess the importance of the individual in history] 

STANDARD 4: The struggle for racial and gender equality and for the extension of civil liberties. 

Standard 4A: The student understands the “Second Reconstruction” and its advancement of civil rights.

7-12: Explain the origins of the postwar civil rights movement and the role of the NAACP in the legal assault on segregation. [Analyze multiple causation] 
5-12: Evaluate the agendas, strategies, and effectiveness of various African Americans, Asian Americans, Latino Americans, and Native Americans, as well as the disabled, in the quest for civil rights and equal opportunities. [Explain historical continuity and change] 

Primary Resources

  1. DESCRIPTION: U.S. Constitution: Fourteenth Amendment
    SOURCE: FindLaw

  2. DESCRIPTION: PLESSY v. FERGUSON, 163 U.S. 537 (1896) 163 U.S. 537
    : 1896
    SOURCE: FindLaw

  3. DESCRIPTION: Margaret Williams, et al. v. David W. Zimmerman, et al.
    SOURCE: BALTIMORE COUNTY CIRCUIT COURT (Miscellaneous Docket) Case no. 198, Docket WPC 3 pp. 245, 291 [MSA C 387-3, 2/49/12/20]
    REPOSITORY: Maryland State Archives

  4. DESCRIPTION: Margaret Williams, et al. v. David W. Zimmerman, et al. 

    SOURCE: COURT OF APPEALS (Briefs) April Term 1938 No. 28 [MSA T 2088, 1/53/5]
    REPOSITORY: Maryland State Archives

  5. DESCRIPTION: Margaret Williams, infant, by Joshua B. Williams, Jr., her father and next friend, and Joshua B. Williams, Jr., individually vs. David W. Zimmerman, Clarence G. Cooper, Henry M. Warfield, et al.
    SOURCE: COURT OF APPEALS (Opinions) , April Term 1937 No. 28 [MSA S 393-236, 1/65/14/85]
    REPOSITORY: Maryland State Archives

  6. DESCRIPTION: Maryland Reports, 172 Md. 563 
    SOURCE: COURT OF APPEALS (Maryland Reports) MdHR 821528, Location: 02/06/10/46, J848
    REPOSITORY: Maryland State Archives

  7. DESCRIPTION: Photograph, Catonsville High School's "new building" on Bloomsbury Avenue near Frederick Road was designed by Smith and May and opened in 1925. Photograph shows the front view as seen from Bloomsbury Avenue. A line of 1920s period coupes and sedans is seen out front.
    DATE CREATED/PUBLISHED: November 14, 1930
    REPOSITORY: Baltimore County Public Library Legacy Web

  8. DESCRIPTION: Photograph, Thurgood Marshall
    DATE CREATED/PUBLISHED: [between 1935 and 1940]
    NOTES: How To Order Copies of This Item
    SOURCE: Visual Materials from the National Association for the Advancement of Colored People Records
    REPOSITORY: Library of Congress

See also:

Additional Media Resources

Today in History: May 18 -- Plessy v. Ferguson. From American Memory.

Additional Instructional Resources

From Jim Crow to Linda Brown, Gr. 9-12

Fighting Jim Crow in the Schools, Gr. 7-8

Secondary Resources

Bishop, David W. "Plessy V. Ferguson: A Reinterpretation" The Journal of Negro History, Vol. 62, No. 2. (Apr., 1977), pp. 125-133.

Bogen, David S. "Why the Supreme Court Lied in Plessy." Villanova Law Review, Volume 52, Number 3, Villanova, Pennsylvania, 2007.

Groves, Harry E. "Separate but Equal -- The Doctrine of Plessy v. Ferguson" Phylon (1940-1956), Vol. 12, No. 1. (1st Qtr., 1951), pp. 66-72. 

Groves, Harry E. "A Re-examination of the 'Separate but Equal' Doctrine in Public Education" The Journal of Negro Education, Vol. 20, No. 4. (Autumn, 1951), pp. 520-534. 

Kousser, J. Morgan. "Separate but not Equal: The Supreme Court's First Decision on Racial Discrimination in Schools" The Journal of Southern History, Vol. 46, No. 1. (Feb., 1980), pp. 17-44. 

McGuinn, Henry J. "The Courts and Equality of Educational Opportunity" The Journal of Negro Education, Vol. 8, No. 2. (Apr., 1939), pp. 150-163. 

________. Equal Protection of the Law and Fair Trials in Maryland The Journal of Negro History, Vol. 24, No. 2. (Apr., 1939), pp. 143-166.

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Teaching American History in Maryland is a collaborative partnership of the Maryland State Archives and the Center for History Education (CHE), University of Maryland Baltimore County (UMBC), and the following sponsoring school systems: Anne Arundel County Public Schools, Baltimore City Public School System, Baltimore County Public Schools, and Howard County Public Schools.

Other program partners include the Martha Ross Center for Oral History, Maryland Historical Society, State Library Resource Center/Enoch Pratt Free Library, with assistance from the National Archives and Records Administration and the Library of Congress. The program is funded through grants from the U.S. Department of Education.

This document packet was researched and developed by Dr. Edward C. Papenfuse and Dr. M. Mercer Neale, prepared with the assistance of R. J. Rockefeller, Lynne MacAdam, Maryland State Archives.


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