While interpreting and applying Fordice will be arduous for the federal court and the Department of Education, the future of historically black colleges and universities rooted in the desegregation agenda will not go away. . . . The measures used by [former Adams states] serve as a placebo--not a panacea--for many segregative and discriminatory practices.
M. C. Brown, 1995b, p. 30
Prior to the American Civil War there were few mainstream educational opportunities for African Americans with the exception of historically black institutions established by abolitionists for nonslaves. With the postwar shift to industrialization, America recognized the need to educate its former slaves and their progeny. However, after decades of significant progress, the races still remained "separate" and their education "unequal."
In 1954, the United States Supreme Court's ruling in Brown v. Board of Education of Topeka ( 347 U.S. 483) overturned the prevailing doctrine of separate but equal introduced by Plessy v. Ferguson ( 163 U.S. 537) fifty-eight years prior. By the time Brown was decided many states had created dual collegiate structures of public education, most of which operated exclusively for Caucasians in one system and African Americans in the other. Although Brown fo-