View of the Girls Bathroom at Botetourt High School
1948
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This photograph comes from the court case Alice Lorraine Ashley v. School Board of Gloucester County. It was one of several cases that lawyers from the Virginia chapter of the National Association for the Advancement of Colored People (NAACP) brought to U.S. District Courts across Virginia to attempt to equalize educational opportunities for Black and white students.
The plaintiffs entered this photograph as evidence (Exhibit No. 28) in the case to show the unequal facilities at schools for white and Black students in Gloucester County, Virginia. This image shows a girls bathroom at Botetourt High School, a white school, with at least five private indoor stalls, a small vanity mirror, and running water. At the Gloucester Training High School, the school for Black students, the boys bathroom was a single stall located outside with no running water.
Botetourt had central heating, central plumbing, and smaller classroom sizes. Gloucester Training School had outdoor bathrooms, no central heat, and overcrowded classrooms. The school district spent significantly more money in the white school than they did in the Black school. The average annual cost per student at Botetourt was $81.63, versus $51.49 at Gloucester Training High School.
Judge Charles Sterling Hutcheson, U.S. District Court Judge for the Eastern District of Virginia, ruled that the school district was discriminating against Black students and teachers and that school officials needed to equalize the schools. Though, he emphasized that the court would not be enforcing the ruling.
Cases like Alice Lorraine Ashley v. School Board of Gloucester County contributed to the NAACP’s larger national campaign – the equalization strategy – which aimed to erode white support for segregated schools by demonstrating the financial cost of funding separate but equal schools for both Black and white students.
Judge Hutcheson’s ruling demonstrated the shortcomings of the NAACP’s equalization strategy, however. He recognized that the school district was discriminating against Black students and teachers but offered no solution or path forward to equity. He articulated the NAACP’s thesis that fulfilling the "separate but equal" doctrine would make it too costly for school districts to maintain separate and equal facilities, but the toothless ruling left it up to the school district to decide how to equalize.
After 1950, the NAACP abandoned the equalization strategy and filed lawsuits directly challenging the constitutionality of the "separate but equal" doctrine. One such case was Dorothy E. Davis, et al. v. County School Board of Prince Edward County, Virginia, one of the five cases combined into Brown v. Board of Education that ruled segregation in schools unconstitutional.
The plaintiffs entered this photograph as evidence (Exhibit No. 28) in the case to show the unequal facilities at schools for white and Black students in Gloucester County, Virginia. This image shows a girls bathroom at Botetourt High School, a white school, with at least five private indoor stalls, a small vanity mirror, and running water. At the Gloucester Training High School, the school for Black students, the boys bathroom was a single stall located outside with no running water.
Botetourt had central heating, central plumbing, and smaller classroom sizes. Gloucester Training School had outdoor bathrooms, no central heat, and overcrowded classrooms. The school district spent significantly more money in the white school than they did in the Black school. The average annual cost per student at Botetourt was $81.63, versus $51.49 at Gloucester Training High School.
Judge Charles Sterling Hutcheson, U.S. District Court Judge for the Eastern District of Virginia, ruled that the school district was discriminating against Black students and teachers and that school officials needed to equalize the schools. Though, he emphasized that the court would not be enforcing the ruling.
Cases like Alice Lorraine Ashley v. School Board of Gloucester County contributed to the NAACP’s larger national campaign – the equalization strategy – which aimed to erode white support for segregated schools by demonstrating the financial cost of funding separate but equal schools for both Black and white students.
Judge Hutcheson’s ruling demonstrated the shortcomings of the NAACP’s equalization strategy, however. He recognized that the school district was discriminating against Black students and teachers but offered no solution or path forward to equity. He articulated the NAACP’s thesis that fulfilling the "separate but equal" doctrine would make it too costly for school districts to maintain separate and equal facilities, but the toothless ruling left it up to the school district to decide how to equalize.
After 1950, the NAACP abandoned the equalization strategy and filed lawsuits directly challenging the constitutionality of the "separate but equal" doctrine. One such case was Dorothy E. Davis, et al. v. County School Board of Prince Edward County, Virginia, one of the five cases combined into Brown v. Board of Education that ruled segregation in schools unconstitutional.
This primary source comes from the Records of District Courts of the United States.
National Archives Identifier: 159139394
Full Citation: View of the Girls Bathroom at Botetourt High School; 1948; Civil Action No. 174; Alice Lorraine Ashley, et al. v. School Board of Gloucester Co. and J. Walter Kenny, Division Superintendent; Civil Case Files, 1941 - 12/31/1998; Records of District Courts of the United States, Record Group 21; National Archives at Philadelphia, Philadelphia, PA. [Online Version, https://www.docsteach.org/documents/document/botetourt-girls-bathroom, December 4, 2024]Activities that use this document
- Separate and Unequal: Analyzing Photographs of Virginia Schools
Created by the National Archives Education Team
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