The Unfinished Quest for Compliance
Although Brown v. Board of Education initiated the egalitarian revolution of the late 1950's and 1960's, principles developed in the progeny of this case pose a clear and present danger to the survival of predominantly Black institutions of higher learning. Brown's beneficial impact upon and galvanizing thrust to Black social, political and economic aspirations are difficult to overestimate. Yet it would be a perverse and paradoxical turn of constitutional law development if the seed of Brown produced vines which smothered the identity, historic mission, and very existence of predominantly Black colleges and universities. These institutions have been a national asset and have especially served the educational needs and aspirations of Blacks.
Tollett, 1981, p. 11
The Morrill Act of 1890 (Ch. 841, 26 Stat. 417) led to a proliferation of public institutions in the South with predominantly or exclusively black student enrollments. The Act served to solidify the already pervasive duality among blacks and whites. This duality was soon sanctioned by Plessy v. Ferguson ( 163 U.S. 537) in 1896. The essential thrust of the Supreme Court ruling in Plessy was that systemic de jure segregation was not violative of the U.S. Constitution, and that the "equal but separate accommodation for the white, and