Brown II was the 1955 follow-up ruling to the Supreme Court’s landmark 1954 decision in Brown v. Board of Education, which had declared racial segregation in public schools unconstitutional. While Brown I made clear that segregated schools violated the Equal Protection Clause of the 14th Amendment, it did not provide a specific plan or timeline for how schools should implement desegregation. This left federal courts, school boards, and communities uncertain about what was expected and how to enforce the decision.
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To address this gap, the Supreme Court issued a second ruling—Brown II—on May 31, 1955, to lay out the procedure for carrying out desegregation. In this decision, the Court directed federal district courts to supervise the desegregation process in each affected community. These local courts were told to oversee changes in school systems and to ensure that desegregation proceeded “with all deliberate speed.” The Court chose this deliberately cautious phrase as a compromise to account for local complexities, political resistance, and logistical concerns, especially in Southern states.
However, the phrase “all deliberate speed” was so vague that many segregationist school districts used it to delay or avoid integration altogether. In Prince Edward County, Virginia, for example, officials took advantage of this ambiguity by refusing to desegregate and instead shut down the entire public school system in 1959. White students attended private, all-white academies subsidized by public funds, while Black students were left without access to formal education. It wasn’t until the Supreme Court’s Griffin v. Prince Edward County decision in 1964 that this extreme response was declared unconstitutional.
In this way, Brown II was meant to clarify and enforce Brown I, but its cautious wording unintentionally gave legal and political space to those committed to resisting desegregation—delaying justice for thousands of Black students, especially in places like Prince Edward County.