Cooper v. Aaron

Cooper v. Aaron
Litigants	Cooper v. Aaron
ArgueDate	September 11, 1958
DecideDate	September 12, 1958
FullName	William G. Cooper, et al., Members of the Board of Directors of the Little Rock School District v. John Aaron, et al.
Citations	358 U.S. 1 (1958)
Holding	State officials are bound by the Supreme Court's interpretations of the Constitution and cannot nullify its orders. The desegregation plan for Little Rock Central High School must proceed without delay.
SCOTUS	1958
Majority	Warren
JoinMajority	Black, Frankfurter, Douglas, Clark, Harlan, Brennan, Whittaker, Stewart
LawsApplied	U.S. Const. amend. XIV; Brown v. Board of Education (1954, 1955)

Cooper v. Aaron

Cooper v. Aaron (1958) was a landmark decision of the Supreme Court of the United States that unanimously reaffirmed the authority of the federal judiciary and the binding nature of its rulings on state governments. The case arose from the defiance of Arkansas state officials, including Governor Orval Faubus, to the desegregation of Little Rock Central High School following the Brown v. Board of Education ruling. It established the critical principle that state officials cannot nullify Supreme Court decisions and must obey federal constitutional mandates, becoming a pivotal moment in the Civil Rights Movement's legal struggle against massive resistance.

Background and Legal Context

The case originated in the crisis surrounding the desegregation of Little Rock Central High School. In 1957, the Little Rock School District, under a court-approved desegregation plan stemming from Brown v. Board of Education, enrolled nine African American students, known as the Little Rock Nine. Arkansas Governor Orval Faubus mobilized the state's National Guard to block the students' entry, defying a federal court order. President Dwight D. Eisenhower subsequently federalized the guard and deployed elements of the 101st Airborne Division to enforce desegregation. In February 1958, the Little Rock School District petitioned the United States District Court for the Eastern District of Arkansas for a two-and-a-half-year delay in its desegregation plan, citing the chaos and hostility. The district court, presided over by Judge Harry J. Lemley, granted the delay. The NAACP Legal Defense Fund, representing the students including plaintiff John Aaron, appealed to the United States Court of Appeals for the Eighth Circuit, which reversed Lemley's decision and ordered immediate desegregation. The school board, led by President William G. Cooper, then appealed to the Supreme Court of the United States.

The Supreme Court Decision

The Supreme Court convened in a special session on September 11, 1958, and issued a *per curiam* opinion the following day, an extraordinary measure underscoring the case's urgency. The opinion was signed individually by all nine justices—Chief Justice Warren, Black, Frankfurter, Douglas, Clark, Harlan, Brennan, Whittaker, and Stewart—to emphasize their unanimous stance. The Court held that the violent opposition orchestrated by state officials could not justify suspending the constitutional rights of the black students. It forcefully declared that the Fourteenth Amendment's principles announced in Brown v. Board of Education were the "supreme law of the land" under Article VI of the Constitution. The ruling explicitly stated that state legislatures and officials, including governors, are bound by the Court's interpretations and cannot nullify them through evasion or force.

Immediate Aftermath and Enforcement

The Court's immediate, unambiguous ruling left no room for further delay. Despite this, the Little Rock School District and the Arkansas General Assembly, backed by Governor Orval Faubus, pursued a strategy of evasion. In response to the order, the school board and the state legislature passed laws allowing Faubus to close Central High and all of Little Rock's high schools for the 1958–59 academic year, a period known as "The Lost Year." This act of massive resistance deprived both white and black students of public education. The schools remained closed until the Supreme Court's ruling in *Aaron v. McKinley* (1959) and a subsequent recall election replaced segregationist school board members, leading to the phased reopening of the schools in August 1959.

Significance and Legacy

*Cooper v. Aaron is a cornerstone of American constitutional law, profoundly affirming judicial supremacy and national constitutional authority over state defiance. It established that the Supreme Court is the ultimate interpreter of the Constitution and that its rulings are binding on all state officials. The case served as a major legal and symbolic defeat for the doctrine of interposition and nullification championed by Southern segregationists. It reinforced the federal government's role, under the Eisenhower administration, in enforcing civil rights against states' rights arguments. The decision became a critical precedent cited in later civil rights battles, including *United States v. Mississippi* (1965) and *Bush v. Orleans Parish School Board* (1960).

Impact on School Desegregation

While the decision did not instantly dismantle school segregation across the South, it provided the NAACP Legal Defense Fund and other civil rights attorneys with an unassailable legal weapon. The ruling made it clear that violent resistance or political obstruction by state actors could not legally justify delaying desegregation. This precedent was used to the Civil Rights Act of 1964 and the Elementary and Secondary Education Act of 1965, which provided federal tools to compel compliance. However, widespread implementation through methods like busing and the fight against white flight continued for decades, illustrating the limits of court rulings alone to achieve social change.

Relationship to Federal and State Authority

The case represents a definitive resolution of a core conflict under the U.S. federal system. It rejected the Calhoun-era theories of nullification and interposition revived by Southern politicians like Senator Harry Byrd of Virginia. By asserting that the Fourteenth Amendment and the Supreme Court's interpretation of it constrained all state action, the decision reinforced the primacy of the federal government in protecting civil rights. This principle was later invoked during the Civil Rights Movement to justify federal intervention against state resistance, as seen in the integration of the University of Mississippi and the enforcement of the Voting Rights Act of 1965. The case remains a foundational citation in debates over federalism and the limits of state sovereignty.