Mississippi University for Women v. Hogan
|Mississippi University for Women v. Hogan|
|Argued March 22, 1982
Decided July 1, 1982
|Full case name||Mississippi University for Women v. Hogan|
|Citations||458 U.S. 718 (more)
102 S. Ct. 3331; 73 L. Ed. 2d 1090; 1982 U.S. LEXIS 157; 50 U.S.L.W. 5068; 29 Empl. Prac. Dec. (CCH) P32,868
|Prior history||Cert. to the United States Court of Appeals for the Fifth Circuit|
|The exclusion of men from enrollment in Mississippi University for Women's nursing school violated the Fourteenth Amendment to the United States Constitution's Equal Protection Clause.|
|Majority||O'Connor, joined by Brennan, White, Marshall, Stevens|
|Dissent||Powell, joined by Rehnquist|
Mississippi University for Women v. Hogan, 458 U.S. 718 (1982) was a case decided 5-4 by the Supreme Court of the United States. The court held that the single-sex admissions policy of the Mississippi University for Women violated the Equal Protection Clause of the Fourteenth Amendment to the United States Constitution.
Background of the case
The Mississippi University for Women was established in 1884 in Columbus, Mississippi and originally called the Industrial Institute and College, later changed to Mississippi State College for Women. It was the first state-supported women's college in the United States. In 1971, the School of Nursing was established, initially offering a two-year associate's degree, and later four-year baccalaureate degree and graduate degree programs.
In 1979, Joe Hogan, a registered nurse and nursing supervisor in Columbus who did not have a baccalaureate degree in nursing, applied for admission to the MUW School of Nursing's baccalaureate program. Although he was otherwise qualified, he was denied admission to the School of Nursing. School officials provided the option to audit courses in which he was interested, but he could not enroll for credit because he was male. Hogan could have attended classes and received credit in one of Mississippi's two public, coeducational programs leading to a Bachelor of Science in Nursing, but these were at the University of Southern Mississippi in Hattiesburg (178 miles from Columbus) and the University of Mississippi in Oxford (114 miles from Columbus). Hogan filed an action in the United States District Court for the Northern District of Mississippi, claiming the single-sex admissions policy of MUW's School of Nursing violated the Equal Protection Clause of the Fourteenth Amendment, and seeking injunctive and declaratory relief as well as compensatory damages.
The District Court ruled in favor of the Mississippi University for Women, concluding that maintenance of MUW as a single-sex school bears a rational relationship to the State's legitimate interest "in providing the greatest practical range of educational opportunities for its female student population." The court held that the admissions policy was not arbitrary: providing single-sex schools is consistent with a respected, though by no means universally accepted, educational theory that single-sex education affords unique benefits to students. Stating that the case presented no issue of fact, the court informed Hogan that it would enter summary judgment dismissing his claim unless he tendered a factual issue. When Hogan offered no further evidence, the District Court entered summary judgment in favor of the State.
The Court of Appeals for the Fifth Circuit reversed, holding that because the admissions policy discriminated on the basis of gender, a rational relationship test as improper, and the proper test was whether the gender-based admissions policy was substantially related to an important governmental objective. The court, while recognizing that the State has a significant interest in providing educational opportunities for all its citizens, found that the State failed to show that providing a unique educational opportunity for females but not for males had any substantial relationship to that interest.
The court's ruling did not require that the entire university become coeducational; however, the Board of Trustees of Mississippi State Institutions of Higher Learning ordered the university to change its policies to allow the admission of qualified males into all university programs. Today MUW’s student body is approximately 15% male.
The court's ruling also did not require the school to change the name of the school, and as a result the school remains "Mississippi University for Women." Suits have been filed against the university to change the name claiming that its name and mission discourage males from applying for admission. These suits were dismissed as groundless and had no effect on the name.
In 2002, the administration of the university considered changing the name and pursued efforts to do so, despite opposition, particularly from alumni. In her convocation speech on 11 August 2008, President Limbert announced a new proposal to remove "women" from the university's name.
- "Mississippi University for Women v. Hogan". Law.cornell.edu. Retrieved 2012-07-20.
- http://www.mensbiz.net/subpage%20mississippi%20university.html[dead link]
- "MUW". Muw.edu. 2002-11-19. Retrieved 2012-07-20.
- "MUW name change doesn’t sit well with some locals". Meridian Star. 2008-08-11. Retrieved 2012-07-20.
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