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American Latino Heritage
Los Angeles, California
Before the U.S. Supreme Court ruled racial segregation in public institutions unconstitutional in Brown v. Board of Education, Méndez v. Westminster helped end racist policies in California’s school districts. This 1946 class-action lawsuit challenged the constitutionality of separate schools for Mexican American students in Southern California. The lawsuit threatened the “separate but equal” doctrine that supported segregation in the United States and the appeals court’s decision ended public segregation of Mexican Americans in the Ninth Circuit. The site of the trial was the U.S. District Court of Southern California, at the historic U.S. Court House & Post Office building, a National Historic Landmark, in Los Angeles.
For over 50 years after the Supreme Court ruled that “separate but equal” was constitutional in 1896, California school districts legally separated Chinese, Japanese, and American Indian children from white children. The doctrine meant that the separation of racial groups was legal as long as the facilities for each group were equal. Though Mexican Americans were “white” under the 1940 U.S. census, more than 80% of Mexican American children in Orange County, California attended segregated non-white schools by World War II. Separating Mexican American children from “whiter” children was widespread in the southwestern United States at the time. Schools segregated Mexican American children because of their Latino surnames and the presumption they had little or no English language skills.
By the 1940s, virtually all agricultural workers in California were Mexicans or Mexican Americans, and they were the largest minority group in the State. School authorities presumed Mexican American children would only need skills for low-wage labor, so the schools only taught Hispanic children vocational skills and did not offer higher-level classes. California’s Mexican American schools had inferior resources compared to white schools and only employed English-speaking teachers. In 1947, a Federal court’s decision in Méndez et al v. Westminster School District of Orange County etc al ended Mexican American primary school segregation in California and supported later civil rights struggles to end all segregation nationally.
When the children of Gonzolo Méndez tried to enroll at an Orange County, California school in 1943, the school denied them entry because of their Mexican heritage. The same day the school administrators rejected his children, they admitted Gonzolo’s niece and nephew, fair-skinned Alice and Edward Vidaurri. Administrators at the school district told the family that Mexican Americans needed their own schools because of cultural and language differences. The Méndez children enrolled at Hoover, the local Mexican American school, but Gonzolo was not satisfied. He knew “separate but equal” did not legally apply to his children and the school district was violating their rights. The Méndez family organized with four other fathers whose children faced similar discrimination. William Guzmán, Frank Palomino, Thomas Estrada, and Lorenzo Ramirez joined Gonzolo to launch the first class-action case in a Federal court in American civil rights history that would challenge primary school segregation.
As the lead defendant, Gonzolo Méndez sued four school districts and superintendants on the grounds that his children and the children of other Mexican Americans were legally white, therefore entitled to attend white schools. The Méndez lawyer filed the lawsuit at the U.S. Court for the Southern District of California, where they could argue that the State of California violated the children’s right to the Constitution’s Equal Protection Clause of the 14th Amendment. The U.S. Constitution states that no State can “deny to any person within its jurisdiction the equal protection of the laws.” The lawyer also used social science expert witnesses to explain that segregating children threatened their self-esteem and segregated school districts invented an inferior class of citizens where one did not exist. As a result, Méndez v. Westminster was the first Federal lawsuit openly to challenge “separate but equal” segregation in K-12 schools. In Courtroom No. 8 of the historic U.S. Court House and Post Office of Los Angeles, Judge Paul J. McCormick decided in favor of Méndez.
The Westminster school district appealed McCormick’s decision and the U.S. Ninth Circuit Court of Appeals in San Francisco heard the appeal in 1947. By this time, the case had attracted national attention. If an appeal went to the U.S. Supreme Court, it had the potential to overturn public segregation throughout the nation. At the appeals level, the American Civl Liberties Union (ACLU), the National Lawyers Guild, and the Japanese American Citizens League filed a joint brief in support of Méndez. The National Association for the Advancement of Colored People (NAACP), American Jewish Congress, and the Attorney General of California also submitted briefs. Together, these briefs challenged the logic of all racial segregation in the United States, as well as the legality of segregating Mexican Americans in California. The Ninth Circuit Court’s decision did not overturn racial segregation in its district, but it did uphold the core of McCormick’s decision and ruled that it is unconstitutional to segregate Americans because of their heritage. Two months after the trial, California Governor Earl Warren, who later presided over Brown v. Board as Chief Justice of the U.S. Supreme Court, signed a bill that made California the first State to outlaw all public school segregation.
The national significance of Méndez v. Westminster rests on its influence on the Civil Rights movements of the 1950s and ‘60s, and its effect on the lives of Mexican Americans in the Ninth Circuit. The brief the NAACP filed for Méndez was the forerunner to the organization’s legal arguments in Brown v. Board of Education, when the U.S. Supreme Court overturned the “separate but equal” doctrine in 1954. After Méndez set the precedent, the landmark case helped strike down policies of segregating Mexican Americans in the Ninth Circuit. Mexican Americans in the Southwest took their school districts to court to challenge the legality of separate schools for their children and won. Using Méndez, district courts in Texas and Arizona ruled to end segregation for Mexican Americans before the U.S. Supreme Court decided that all state-sponsored segregation is unconstitutional in Brown.
The lawsuit that started the movement was a five-day trial held at the U.S. Court House and Post Office in Los Angeles. Built in 1940, this historic building was only five years old during Méndez v. Westminster. The building is a 17-story, Depression-era Moderne style Federal courthouse and post office. It is a steel-frame building, reinforced with concrete, with recessed windows. The exterior has a light-pink, textured ceramic veneer, and gray Minnesota granite with pink veining adorns at its base. Wide concrete steps lead from the sidewalks to the court house entrances on Spring Street and Main Street. U.S. District Courtroom No. 8, the site of the trial, is on the second floor where all District courtrooms were at the time. The high, white-plaster ceiling rises through the third floor. The walls feature five-foot-high American walnut wainscoting, with black walnut detail, with white acoustic tiles above it. Walnut paneling surrounds the double-door entry and lines the recessed area behind the judge’s bench. The bench, gallery bench, jury seating, press seating, and lecterns also feature a walnut veneer. The U.S. General Services Administration made few major alterations to the building after its construction and has made minimal changes to Courtroom No. 8 since 1945, apart from replacing ceiling lights, flooring, and minor aspects of the courtroom furniture.
In 1966, the U.S. Court for the Southern District of California moved to San Diego and the Court for the Central District of California (western division) moved into the Los Angeles U.S. Court House & Post Office Federal building.
The legacy of Méndez v. Westminster is the precedent it set for future cases, its impact on the lives of the people oppressed by segregation, and the inspiration it gave to later civil rights struggles. Overshadowed by Brown v. Board for decades, a resurgence of public recognition of the case in the early 21st century rightly called attention to its significance. PBS aired a documentary, Mendez vs. Westminster: For All the Children/Para Todos los Niño', in 2003. The U.S. Postal Service released a stamp in 2007 to commemorate the landmark case. Once turned away from her Orange County school in 1943, Sylvia Méndez, in 2011, received the Presidential Medal of Freedom for her role in the ongoing struggle for freedom and justice in the United States.