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Reflections on the Promise of Brown and Multicultural Education

by Carl A. Grant - 1995

Examines the dual meaning of promise (hope and vow) in relation to "Brown v. Board of Education of Topeka, Kansas," discussing how the two conceptions are implemented in a desegregated school and explaining how multicultural education can help meet the dual expectations of "Brown" as promise/vow and promise/hope. (Source: ERIC)

This article examines the dual meaning of “promise”—hope and vow—in relation to Brown I and II. It then proceeds to discuss how these two conceptions of promise are carried out in a desegregated junior high school. The article concludes with a discussion of how multicultural education can help meet the dual expectations of Brown as promise/vow and promise/hope.

Desegregation is not and was never expected to be an easy task. Racial attitudes ingrained in our Nation’s childhood and adolescence are not quickly thrown aside. . . . But just as the inconvenience of some cannot be allowed to stand in way of the rights of others, so public opposition, no matter how strident, cannot be permitted to divert this Court from enforcement of . . . constitutional principles.

—Thurgood Marshall

I begin this article with a discussion of the notion of promise because its interpretation is central to our understanding and expectations of Brown v. Board of Education of Topeka, Kansas. The word promise has many different connotations in our language, some associated with fairly concrete definitions, others with more abstract definitions. Sometimes promise is used to make an explicit statement, or render a vow; other times promise is used to convey an implicit intention, or render hope. For some, Brown is a promise/vow to correct the injustices of a dual school system, while for others, Brown is a promise/hope to restructure U.S. policy and practices on race and ethnic relations. In Brown I and II the following promises/vows are stated:

Brown I:

Such an opportunity [education], where the state has undertaken to provide it, is a right which must be available to all on equal terms.

“‘Separate but equal’ has no place.”1

Brown II:

Full implementation of these constitutional principles many require solutions of varied school problems.

In fashioning and effectuating the decrees, the court will be guided by equitable principles.2

The promise/hope of Brown I is addressed implicitly in several of the statements in the 1954 decision. The Supreme Court said:

We must consider public education in the light of its full development and its present place in American life throughout the Nation.

Today, education is perhaps the most important function of state and local government.

Today it [education] is a principal instrument in awaking the child to cultural values, in preparing him for later professional training, and in helping him to adjust normally to his environment.3

The promise/hope of Brown is expressed poignantly in numerous reflections on the decision. Albert Blaustein and Clarence Ferguson note in their book that “this case [Brown] has had a greater impact upon American life than any other legal decision in our history.”4 Robert L. Carter, former counsel of the National Association for the Advancement of Colored People (NAACP) and the attorney who worked so closely with Thurgood Marshall in arguing Brown, states:

Brown will always stand at the highest pinnacle of American judicial expression because in guaranteeing equality to all persons in our society as a fundamental tenet of our basic law, it espouses the loftiest values of this nation. . . . It is an eloquent statement of our highest ethical values. Because it paints a composite picture of how we want the world to view us and how we like to view ourselves, Brown allows us to take pride in ourselves and in the greatness of the nation we live in, and to stand tall and apart from the most of the other countries of the world.5

In this article, I plan to examine the dual meanings of promise in connection to Brown. Following this examination I will discuss how Brown as a promise/vow and Brown as a promise/hope was carried out in a desegregated junior high school. Finally, I will discuss multicultural education and how it can help meet the dual expectations of Brown as promise/vow and promise/hope.


“Equal opportunity” is the key component in the Brown v. Board of Education decision. Equal opportunity to access and participation in American society, according to many constitutional scholars, is located in the Equal Protection Clause of the Fourteenth Amendment. In Brown, the Court argued that in our diverse society, segregation was unfair, and answered yes to the question: “Does segregation of children in public schools solely on the basis of race, even through the physical facilities and other ‘tangible’ factors may be equal, deprive African-American children of equal educational opportunity?” The Court’s response asserted that black students had the right to “access,” or, in other words, it vowed that black students could and would sit next to white students in school. The Court, however, did not declare that black students had a right to equal results in school. Specifically, the Court stated:

Segregation . . . has a detrimental effect upon the colored children. The impact is greater when it has the sanction of the law; for the policy of separating the races is usually interpreted as denoting the inferiority of the Negro group. A sense of inferiority affects the motivation of the children to learn. Segregation with the sanction of law, therefore, has a tendency to retard the educational and mental development of Negro children and to deprive them of some of the benefits they would receive in a racially integrated school system.6


Brown has been stifled in both categories of meanings of promise. The promise/vow of Brown is stifled by avoidance and delay tactics (especially invigorated by the “with all deliberate speed clause”) and the “whiteness as property” concept.

Avoidance and Delay Tactics

Brown is a promise/vow of access for black students and other students of color, but one that is conditioned by the “with all deliberate speed” clause. On May 31, 1955, when the Supreme Court included the “deliberate speed” clause in Brown II, it allowed opponents of racial justice to procrastinate with regard to its implementation.7 Carter maintains that “Brown II represented a break with tradition in constitutional law that constitutionally protected rights were regarded as ‘personal and present,’ the violation of which required immediate remediation.” He adds: “When Brown II directed the schools to desegregate with all ‘deliberate speed’ rather than immediately, it articulated a new and heretofore unknown approach to rectifying violations of constitutional rights—an approach that invited defiance and delay.”8

In the South, massive organized resistance campaigns leapfrogged across the region. Southern leaders used their political offices, the courts, their newspapers, and White Citizens’ Councils to avoid, delay, and evade compliance with Brown.9

Blaustein and Ferguson report that “there are no constitutional limitations to measurers of ‘avoidance.’ It is perfectly proper—at least as far as the courts are concerned—for an individual or a state full of individuals to attempt to ‘avoid.’ ”10 Avoidance tactics used to delay desegregation fell into four categories: (1) interposition and nullification, that is, circumventing Brown by arguing states’ rights over federal rights (see, for example, Bush v. Orleans Parish School Board); (2) disqualifying potential litigants, for example, enjoining the NAACP from any activities within the state, prohibiting the employment of any NAACP member by a state agency, and bringing criminal sanctions against an organization that instituted litigation in the state courts; (3) separation by race, but on factors other than race, such as scores on a scholastic achievement or aptitude test; and (4) separation of the operation of the school from state control, for example, establishment of private academies or “free choice” segregated schools for white students. Specific examples of avoidance and delaying tactics include the following.

In South Carolina, a three-judge panel provided an interpretation of Brown II that stated that integration was not required, only discrimination was forbidden. The judges said:

What has been decided, and all that has been decided, is that a state may not deny to any person on account of race the right to attend any school that it maintains. . . . The Constitution, in other words, does not require integration. It merely forbids discrimination. It does not forbid such segregation as occurs as a result of voluntary action. It merely forbids the use of governmental powers to enforce segregation.11

In communities throughout the South, segregationist organizations sometimes referred to as White Citizens’ Councils instructed white employers to fire black employees; white wholesalers were instructed to cut off credit and supplies to black retailers and customers; and white merchants were instructed to turn away black customers.12

Denial of the right of black children to enroll in Central High School in Little Rock, Arkansas, by the governor of the state is a prime example of white officials’ using their office to deny compliance with Brown.13 Other methods used to delay compliance with Brown, especially during the early years, included declaring that the schools were overcrowded, that there was a lack of funding, and that the curriculum would be disrupted if black students entered in January.14

In the decades following Brown II, avoidance and delay tactics also took several forms, including white flight, which left the urban areas populated predominately by minorities; negative reactions and resistance to busing of black students to previously white schools and an unwillingness to bus or noncompliance with busing of white students to previously all-black schools; the Department of Health, Education, and Welfare’s (HEW) weak enforcement efforts of school integration, especially during the Nixon administration; and the failure of the Supreme Court to support interdistrict integration.15

Whiteness as Property

The promise/vow of Brown was muffled, as Bell has noted, because “whites continued to expect society to recognize an unspoken but no less vested property right in their ‘whiteness.’ ”16 According to Harris: “Whiteness as property is derived from the deep historical roots of systematic white supremacy that has given rise to definitions of group identity predicated on the racial subordination of the ‘other,’ and that has reified expectations of continued white privilege.”17

Although we usually think of “property” as our belongings or possessions, “property also consists of rights in things that are intangible, or whose existence is a matter of legal definition.”18 These include the products of one’s labor, potential earnings from a graduate degree, job entitlement, and occupational licenses. It also includes expectations (e.g., being treated a certain way, knowing your race will not work against you in opportunities for jobs and for other societal events) and privileges (e.g., the entitlement and advantages granted to an individual or group). White privilege, according to McIntosh, is like an invisible weightless knapsack of special provisions, maps, passports, codebooks, visas, clothes, tools, and blank checks.19 Simply put, before Brown the law gave holders of whiteness the same privileges and benefits it gave to holders of other types of property. Harris explains that “after legalized segregation was overturned, whiteness as property evolved into a more modern form through the law’s ratification of the settled expectations of relative white privilege as a legitimate and natural baseline.”20

Reflections on the promise/vow of Brown lead to the conclusion that, on the surface, Brown was a legal mandate to change national educational policy, but at its underbelly, it was a legal mandate guided by folkways and customs based on the notion of whiteness as property. The Supreme Court was willing to declare the dual school system racially unjust, but at the same time, it was hesitant to interrupt the privileges that accompany whiteness. Harris states:

Brown held that the Constitution would not countenance legalized racial separation, but Brown did not address the government’s responsibility to eradicate inequalities in resource allocation either in public education or other public services, let alone to intervene in inequities in the private domain, all of which are, in significant measure, the result of white domination. . . . What remained consistent was the perpetuation of institutional privilege under a standard of legal equality. In the foreground was the change of formal rules; in the background was the “natural” fact of white privilege that dictated the pace and course of any moderating change. What remained in revised and reconstituted form was whiteness as property.21


The promise/hope of Brown, although its effectiveness and benefits to African-American people have increasingly become an issue of debate (especially within African-American communities), is important to the welfare of black people, other oppressed people of color, white people, and the entire nation.22 The promise/hope of Brown is the dream stuff for nation building and citizen optimism.

Brown and Nation Building

Discussions of the promise/hope of Brown mainly focus on what the decision did for African Americans without giving attention to what the decision did for the nation at large. From K–12 textbooks, students most often learn that the Brown decision was singularly for and about African Americans. Rarely is there any discussion of the importance of the decision to the entire nation. It is not uncommon to find the discussion located in the section of history textbooks reserved for “minorities.” Also, in many instances the discussion of Brown is insipid. One history text reads:

In 1954 the Supreme Court made a landmark ruling in a case called Brown v. Board of Education of Topeka. The Court stated that laws requiring separate schools for blacks were unconstitutional. As a result, states could no longer legally segregate children in public schools.

The school board in Little Rock, Arkansas, made plans to place blacks and whites in the same schools. Arkansas Governor Orval Faubus objected, however. He tried to stop black students from attending Central High School in Little Rock. Many angry white protesters agreed with the governor. Then President Eisenhower sent troops to Little Rock to uphold the law. Under the soldiers’ protection, black students began to attend classes at the high school. . . . The Supreme Court’s Brown ruling was an important victory for blacks.23

The school student reading this information is educationally shortchanged regarding an understanding of the importance of Brown for all U.S. citizens. Also, when such a discussion is placed in a section on minorities, it becomes marginalized within a discussion of U.S. history.

Discussions of the importance of Brown to the nation are available, but most often they are located in legal or scholarly writings.

Carter describes the momentous impact of Brown on the nation:

While Brown specifically outlawed segregation in the nation’s public schools, what it really stated and [is?] perceived to have done is to have held that the Constitution of the United States guarantees civil equality to all of us in this country. African Americans are not accorded equal citizenship rights because local, state, or federal officials are kind public servants, or because of the liberality or generosity of government luminaries, or because equality for blacks is morally mandated. Brown stated unequivocally that equality is a birthright of all Americans.24

Harlem Congressman Adam Clayton Powell, Jr.’s earliest written comments on Brown were related to the nation’s welfare. He wrote that the Brown “decision was nothing less than democracy’s shining hour and communism’s worst defeat.”25 Similarly, Governor Hollings of South Carolina stated, “We of today must realize the lesson of one hundred years ago and move on for the good of South Carolina and our United States.26

In The Fifties, Halberstam reports that Justice Jackson’s reason for supporting Brown was that racism by the Nazis had caused a sense of revulsion among American people. Tushnet, however, believes that Jackson’s support of Brown was political. Regardless of which author is correct, neither reports that Jackson’s rationale was to make educational life better for black students. For Tushnet, Justice Jackson did not want to bring the Supreme Court into ill repute. Similarly, Halberstam notes that one of the arguments used to convince Justice Reed, the remaining holdout against Brown, to support the decision was the idea that his dissent would damage the Supreme Court as an institution.27

In the final chapter of their book Desegregation and the Law: The Meaning and Effect of the School Segregation Cases, Blaustein and Ferguson, state that “Brown was far more than a ‘discrimination-in-education case.’ By declaring unconstitutional all state sanctioned racial discrimination, it created the guidepost for determining all issues involving racial classification in all areas.”28

Brown: Uplifting People of Color

Discussions of Brown as promise/hope for African Americans and other oppressed people are well documented. Carter reports that Brown gave African Americans a positive feeling. He states: “As soon as the message Brown conveyed was absorbed by African Americans, the submissive supplicant black stereotype was replaced by a militant demanding, assertive black.”29 Greenberg states: “Brown decreed an end to school segregation but also transformed how blacks were seen and treated, by law and by society in general, not only in school but in many other areas of life.”30 Kenneth Clark, not too long before he died, addressed the importance of Brown to race relations when he said: “When the historic 1954 Brown decision pronounced racial segregation illegal, it inspired an optimistic outlook tantamount to euphoria. I felt that was the beginning of major positive change in American race relations.”31

Similarly, Chambers reports that Brown, with all its flaws, set the stage to build a country that would fulfill its promise of equality and justice for people of color.32 Jones contends that the Brown decision planted the seed of hope in the minds and hearts of many other marginalized groups. He states: “This [Brown] was without doubt the most momentous decision of the century. The great Brown decision has been the locomotive of the train onto which a number of aggrieved groups and individuals have hitched their claims.”33


In 1978, two colleagues and I were invited to help the staff and students at a desegregated mainstream junior high school to become more responsive to the race, class, gender, and disability challenges they were facing. This invitation developed into a three-year ethnographic case study that provided an opportunity to learn and understand how the promise (vow and hope) of Brown was being carried out. The case study is reported elsewhere, so I will confine my discussion to how the school responded to the three generations of desegregation efforts since Brown.34

The first generation of desegregation focused on bringing students of all races together under one school house roof; the second generation of desegregation focused on inequities within school (e.g., access to classroom and programs, suspensions and dropouts among minority students); and the third generation focused on the achievement of equal learning opportunity and outcomes for all students.35 The school, Five Bridges, was located in a working-class urban community in a midwestern city. The community had been racially integrated since 1976, so the student population at the school was racially mixed. At the time of this study the racial composition of the 580-member student body was 67.5 percent white, 28 percent Hispanic, 2 percent African-American, 2 percent Native American, and 0.5 percent Asian American. Of the forty-six certified teachers at the school, thirty-six were white, three were Hispanic, and two were African-American; twenty-four were male and twenty-two were female. The principal was a white male and the two assistant principals were white, one male and one female. One counselor was a Mexican-American male, and the other counselor was a white female. The educational goals at Five Bridges were multicultural education and increased student academic achievement.


The faculty and staff at Five Bridges were supportive of the desegregation mandate. When the researchers asked faculty members what they considered the strengths of Five Bridges, two typical responses were:

Our number one strength, we’re not all white, we’ve got handicapped, Mexican-American, GLD students, and I find this a very nice situation. (White Counselor)

The community supports the school and the diversity of people that are here. (Assistant Principal)

The school had achieved most of the first-generation desegregation responsibilities, each student had access to all opportunities within the school. Open-seating arrangements existed in most classes, and although students usually separated themselves along gender lines, the seating patterns were racially integrated and students with disabilities integrated themselves within this seating pattern. Racially mixed groups of students usually worked together on curriculum projects and socially; students believed that having friendship groups that were of more than one race was fun.

When students were asked who their close friends were both inside and outside of school, and what their race was, three-fourths of the students named close friends of more than one race. The following comment from an eighth grade student was typical:

Hal (White): In our gang [a friendship group] we have blacks, Mexicans, and we’re gonna have a Korean. None of my friends are prejudiced here.

Many of the procedures associated with second-generation desegregation policies were being addressed: academic expectations were the same for all students; suspensions, expulsions, and discipline referrals were the same across race, gender, and socioeconomic levels. In fact, discipline was not a serious problem, according to both students and teachers, and the disciplinary infractions that did occur were usually handled with after-school detention. These detention classes usually lasted only one-half hour and were not especially populated with any particular race, gender, or socioeconomic group of students.36

There were organized sports for both boys and girls and all race, gender, and socioeconomic groups of students were active in the same extracurricular activities (e.g., chess club).

Many of the third-generation desegregation policies were being addressed. Equal learning opportunities and outcomes for all students were available across race, gender, and socioeconomic levels. Teachers treated boys and girls the same in the classroom, and very few teachers were ever heard making sexist statements.

In sum, the students were not only physically desegregated at Five Bridges, they were integrated across race, class, and gender lines, and they believed it was more fun and exciting when different groups of students of color attended school together and socialized together.


Although the promise/vow of desegregation seemed to have been met, what about the promise/hope of desegregation?

At Five Bridges, although the students were integrated both within and outside of the school, very little was done to capitalize on the racial integration that had taken place within the community. Students were not formally taught about the community’s different cultural groups’ histories, cultures, and contributions to the United States. The curriculum privileged the white students with its Eurocentric focus and there were few materials that focused attention on women or on sex-role socialization. Discussions about power and knowledge, the nature of prejudice in society, the causes of racism and sexism, were muted. Albeit the students were living in a social system (community and school) that challenged racism and claimed multicultural education as a goal, they were not receiving the knowledge or the social-action skills in school to contest racism outside of their own community.

Teachers treated all students equally without regard to race, gender, or socioeconomic status. Students had access to all courses and activities within the school, but the education offered to students—whites and minorities—was mediocre. It mainly dealt with remediation and basic skills. Teachers primarily used ditto sheets, workbooks, and some easy-reading, high-interest material. Teachers’ expectations of the students were low.




What kinds of things do you think should be taught to the Five Bridges students?

(Administrative Intern/Assistant Principal): Everyday type things . . . that might be baby sitting and I know some people don’t think that is our function but I think we’d survive better if we just okay this as part of what we are doing. . . . I think we do a fairly good job of the hands-on type things, the metal shop, graphic arts, home economics. . . . I think our seventh-grade life skill program is good.

(Social Studies Teacher): One of the things I am trying to tell them, is the things I am trying to teach you are things you are going to need in the real world. . . . I want them to know practical things. How to write a budget, how to write a check, how to balance your checkbook.

Students, on the other hand, described most school work as boring and not challenging.





Why do you say [social studies] is boring?

Because I just sat there. We just sit down and listen to him and that gets boring.

Tell me about your English class.

We always do a certain thing through the week. Like the first day we do these little things, we read and then we have to answer questions about it. And the second day, he’s got it planned day through day so if you miss Tuesday you know what you did Tuesday because you always do the same thing. Tuesday we have to work out of a workbook. And, Wednesday we finish up the workbook, turn in the assignment and start on our spelling test. Like we write down words and get their meanings and stuff. And it goes on like that. It’s boring in his class.

Students were not acquiring the knowledge to compete successfully for money, power, and status in society, or to exercise control of their destiny and future, nor were they being taught to examine traditional gender, race, and class relationships. Although the notion of equal opportunity and open access existed among all students within the school, the notion of achieving equality of results with their peers at other more affluent schools was not an expectation the teachers held for the students or a school goal.

Students were being taught to accept Eurocentric culture as the principal culture and to believe Eurocentric interpretations of reality through the school curricula. Most students did not understand socioeconomic class division or the struggle of poor people to earn better wages. They were also uninformed about the reasons for the race riots in many U.S. cities that had taken place just a little over a decade ago. They knew that family incomes varied, but did not seem aware of the extent of the gap in income and privileges and power between rich, middle-income, and poor people. Some of the boys did have knowledge of the salaries paid to professional athletes, but that knowledge was not accompanied with a realistic understanding of how hard it is to become a professional athlete, or the short career of most professional athletes.

At Five Bridges the promise/vow of Brown was being addressed but the promise/hope of Brown was not. Perhaps, because the faculty was pleased to work in a desegregated school, they did not understand the promise of Brown for each student and the nation. The success of the community to achieve integration, when many other communities across the nation were using avoidance tactics to maintain white privilege, was muted or marginalized during classroom discussion. The idea that Five Bridges could be a showcase for the nation in regard to successful integration within the school was not considered. The school staff lacked an understanding of what the school’s goals of implementing multicultural education and increased student academic achievement meant for them.


The promise/vow/hope of Brown requires an education that advocates and affirms the belief that equality and equity should be active in all institutions in this country, and will be received by all students. The education best suited for achieving this goal is an education that is multicultural and social-reconstructionist. The phrase “education that is multicultural,” as I explained in 1978, means that all aspects of schooling should reflect the diverse racial groups in the country; and that schools should be the location where knowledge is analyzed, where the activities of power brokers are critiqued, and skills and knowledge are acquired to enable students to take charge of their life circumstances and develop a positive self-identity.37 Curriculum, instruction, staffing, testing, and so forth, must be multicultural. Although Sleeter and I have discussed this and other approaches to multicultural education elsewhere,38 it is important to elaborate on at least two features of this approach here—curriculum and instruction—to explain what I mean.

A curriculum that is multicultural begins with the academic needs and interests of the students. It highlights the history and contribution of all Americans and is infused throughout the entire kindergarten through twelfth-grade program. It also highlights who we are as Americans and how that identity is represented throughout the world. Students are taught about oppression and social equality based on race, class, gender, and disability. Some curriculum concepts are organized around current social issues, including racism, classism, and sexism, and offer discussions about how these and other oppressive dynamics operate in school to produce knowledge and self-identity. Concepts are taught in a manner that includes the experiences and perspectives of several different ethnic groups and uses students’ life experiences as a starting point for analyzing oppression. Also, the curriculum includes discussions about the relationship between knowledge and power and how both are acquired. Additionally, the curriculum includes activities that explain the importance of student participation in democratic decision making and the development and use of social-action and coalition-building skills.

Instruction encourages the deconstruction of knowledge and fosters the interrogation of popular events and images (e.g., Columbus Day celebrations). It builds on students’ learning skills, thinking, and life experiences and adapts to their skill level. Also, instruction provides students with insights into the role of subject matter (e.g., math and science) within the contexts of society. Additionally, critical-thinking skills are taught; methods for analyzing alternative viewpoints are presented; and students are taught how to develop democratic decision-making and social-action skills.

Education that is multicultural and social-reconstructionist is an education for all students. It requires that schools truly serve all students, especially those who are marginalized. Its objective is to help students acquire the knowledge, skills, power, and positive self-identity to pursue their life goals and remove the barriers that prevent them from achieving the best that life has to offer, including helping others. Education that is multicultural and social-reconstructionist prepares students to grow up to make changes in society so that it better serves the interests and needs of all citizens, especially those who are of color, poor, and female. According to Brameld, a reconstructionist approach to education is visionary. Realistic visions that inspire hope; understanding of personal, cultural, and national identity; and understanding of how to achieve knowledge and power are needed to help students of color take charge of and give meaning to their lives, and fulfill the promise/hope of Brown.

Finally, if Brown was seen by the Supreme Court as a way not only of interpreting the law but of shaping the sociocultural conscience of the nation, then as we move into the twenty-first century, an education that is multicultural and social-reconstructionist is necessary to make real the belief that the United States is a “Plural Terrain and the Peoples’ Domain” inherent in the constitutional ideal of “We the People.”

Cite This Article as: Teachers College Record Volume 96 Number 4, 1995, p. 707-721
https://www.tcrecord.org ID Number: 37, Date Accessed: 5/27/2022 5:49:12 PM

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