Lloyd Gaines and His Quest for Educational Equality

Lloyd Lionel Gaines applied to the University of Missouri School of Law in 1936. Despite an outstanding scholastic record, Gaines was denied admission based solely on the grounds that Missouri’s Constitution called for “separate education of the races.” Because Missouri had no public law school that admitted Black applications, state law required the state to pay Gaines’ tuition at public universities in Iowa, Kansas or Nebraska. Attorneys from the National Association for the Advancement of Colored People (NAACP) identified Gaines’ case as a good vehicle to begin the incremental process of challenging the ignominious precedent of “separate but equal” established in Plessy v. Ferguson in 1896. Together, they sued the University of Missouri seeking an order granting him admission to its Law School.

In 1938, Gaines won his case before the United States Supreme Court in State of Missouri ex rel Gaines v. Canada . Although the Court did not order that he be admitted to the Law School, it did hold that Missouri’s lack of an in-state law school for Black students violated the U.S. Constitution’s guarantee of equal protection of the laws. Missouri complied with the order by setting aside limited funds for the creation of a Black law school at Lincoln University. Gaines and the NAACP continued to challenge Missouri’s minimal efforts to comply with the Supreme Court’s opinion in the courts.

As the legal battle unfolded, Gaines disappeared under mysterious but unmistakably suspicious circumstances. In March 1939, at age 28 and only three months after his Supreme Court victory, Gaines went missing while living in Chicago. Lloyd Gaines was never seen or heard from again. Without Gaines, the NAACP was forced to drop the case. Not only did Gaines never have the chance to attend the University of Missouri, but neither did any other Black student until 1950. The Law School at the University of Missouri-Columbia did not admit its first Black students until the late 1960s.

Despite its limitations, Gaines’ victory before the Supreme Court paved the way for a series of cases that would lead to the decision in Brown v. Board of Education that outlawed segregation in public education. Thurgood Marshall, who argued before the Supreme Court in Brown and many other cases challenging official discrimination, later called Gaines one of the NAACP’s “greatest victories.” In 2006, the Law School awarded Lloyd Gaines an honorary degree, and the Missouri Supreme Court issued him a posthumous law license.

This project seeks to illuminate Lloyd Gaines' life, document his pioneering pursuit of true equal rights to a legal education, and memorialize the long overdue, posthumous recognition of his personal sacrifice in the advancement of civil rights. By gathering together these primary and secondary source materials pertinent to his life and his case, we hope to tell more of Lloyd Gaines' story to the world. The University of Missouri School of Law Library is pleased to make these resources freely available for scholars, researchers and others to advance their knowledge and understanding of the struggle for civil rights in Missouri in the early twentieth century.

The digital collection includes:
*The last letter Lloyd Gaines wrote to his mother before his disappearance
*Family photographs and correspondence
*The U.S. Supreme Court decision in the Gaines case
*Lloyd Gaines’ honorary law degree and admission to the Missouri Bar Association.

For questions or suggestions about this project, contact us at (573) 884-6362 or by email at mulawlloydgaines@missouri.edu.