Lemon Grove Incident

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The Lemon Grove Case (Roberto Alvarez vs. the Board of Trustees of the Lemon Grove School District), commonly known as the Lemon Grove Incident, was the United States' first successful school desegregation case. The incident occurred in 1930 and 1931 in Lemon Grove, California, where the local school board attempted to build a separate school for children of Mexican origin. On March 30, 1931, the Superior Court of San Diego County ruled that the local school board's attempt to segregate 75 Mexican and Mexican American elementary school children was a violation of California state laws because ethnic Mexicans were considered White under the state's Education Code. Although often overlooked in the history of school desegregation,[1] the Lemon Grove Case is increasingly heralded as the first victory over segregative educational practices and as a testimony to the Mexican immigrant parents who effectively utilized the U.S. legal system to protect their children's rights.[1]


The segregation of Mexican and Mexican American children was commonplace throughout the Southwest in the early-to-mid 1900s.[2][3][4] While the California Education Code did not explicitly allow for the segregation of children of Mexican descent, approximately 80% of California school districts with substantial Mexican and Mexican American populations were segregated.[5] The other 20% of school districts maintained partial forms of segregation, such as segregated classrooms within mixed schools.[5] School boards in cities such as Pasadena, Santa Ana, Riverside, and Los Angeles offered various rationales for such segregation.[4] Many districts relied on linguistic arguments, claiming that segregation was necessary given English "language handicaps".[2] Others cited the need to train Mexican and Mexican American youth for "appropriate" jobs.[2] Several districts argued that "Americanization" schools were necessary to properly assimilate Mexican and Mexican American youth.[4] Authorities often promised that Mexican and Mexican American youth could be integrated upon their mastery of the English language and their complete Americanization; yet these pledges almost always went unfulfilled.[3] Records indicate that such "Mexican schools" had substandard facilities, shorter school years, and poorer quality of instruction.[3] Furthermore, in the city of Lemon Grove itself there was a growing resentment against its Mexican population due to the sudden rise in growth rates for this particular demographic as well as the overall fear of the loss of white collar jobs from US citizens and giving them to Mexican Americans.[6]

Case background[edit]

In this context, the integrated grammar school of Lemon Grove was an anomaly.[2] The Mexican and Mexican American students, children to the fifty-odd Mexican immigrant families from Baja California, accounted for about half of the school's 169 students.[1] Furthermore, the student population found within the Lemon Grove School District was approximately 75 Mexican and Mexican American students and 95 white students.[7] On July 23, 1930, the all-Anglo Lemon Grove school board decided to build a separate school for children of Mexican heritage without giving notice to their parents.[3] The plan was discussed by the school board and subsequently endorsed by the Chamber of Commerce and local PTA.[1] By August, the board felt that the "situation had reached emergency conditions" due to overcrowding and "sanitary and moral" issues stemming from the Mexican and Mexican American youth.[4] In this plan to separate these students from their peers, the school board expected that "the Mexican community would docilely separate itself and send its children to the new school."[6]

This "new school" where the students were to be separated was an old two room building that came to be known within the local Mexican American community as la caballeriza, meaning "the barn," on Olive Street.[8] After an emergency meeting between the board was conducted on August 13, the Mexican and Mexican American students of the school were expelled and later on their school supplies/belongings and desks were later transferred to the building.[1] On January 5, 1931, Lemon Grove Grammar School principal Jerome Green, acting under instructions from school trustees, turned away Mexican children at the schoolhouse door,directing them to the new school. In response, parents who were outraged at the response refused to send their children to the new school. Since they were not allowed back at the main schoolhouse, this resulted in a boycott.[5] Through this boycott, 75 students remained at home and the local press took note of this protest, writing this in the headlines as "the Mexican Student Strike."[9]

Despite their lack of representation in official channels of power such as the PTA or the Chamber of Commerce, the parents quickly organized El Comité de Vecinos de Lemon Grove (the Lemon Grove Neighbors Committee).[1] Parents would meet in the household of one of the families whose children were refused to be allowed in the school and would discuss plan on what was to be done against the separation of the Mexican students from the grammar school.[8] The parents sought the assistance of the Mexican consul in San Diego, Enrique Ferreira, who put them in touch with two attorneys.These two San Diego attorneys were Fred Noon and A. C. Brinkley.[4] Noon worked in the city since 1928 and knew Spanish well enough in order to communicate with parents on how to file for the court case.[1] The Comité also sought the support of the broader Mexican and Mexican American community on both sides of the border; the Mexican government also gave the parents and their organization full support as they protested against his decision made by the school board and the PTA.[6] The community responded with both moral and financial support that allowed the Comité to cover the costs of the upcoming lawsuit.[1] Other responses from the community included the support of Mexican and Spanish speaking news media from Mexico and the US; one particular news outlet known as La Opinion was able to closely follow and report on the legal actions and wrote editorials supporting the students involved in the strike. Through these media outlets, El Comité was able to gain significant support from "the community, the press and the Mexican Consul."[9]

Lawsuit and trial[edit]

The Comité, with the assistance of the two attorneys, filed a suit against the Lemon Grove School Board in the Superior Court of California in San Diego on February 13, 1931. Submitted in the name of Mexican American student Roberto Alvarez, the petition accused the school board of "an attempt at racial segregation… by separating and segregating all the children of Mexican parentage".[1] The suit also pointed out that 95% of the children who the school board sought to segregate were U.S. citizens and thus "entitled to all the rights and privileges common to all citizens of the United States.[1] Alvarez and ten other students gave their recounts that proved that their separation of the school was actually built on inaccurate information concerning the intelligence and learning capabilities of Mexican and Mexican American students and a prejudiced assumption that these students didn't have an understanding of the English language. Alvarez himself was chosen to be named as the plaintiff for this court case due to the fact that his academic records proved to be a counter to what the school board was presenting to the court case.[9] The attorneys during the trial also questioned the teachers who were to teach in the segregated, whether or not they were fully capable in being able to teach all these students. In once such situation, the attorneys questioned a newly experienced teacher who was expected to teach four grades in one classroom. The attorney then questioned how was teaching students from four different grade levels in one class in the segregated building would create a different learning experience than having one teacher teach one grade in the other school with all the students integrated together. As a result the claim from these teachers assigned to teach at the segregated school was similar to the ones the school board presented, claiming that it would provide more individualized attention to the students.[8]

The Lemon Grove school board denied all of the suit's allegations and, asking school boards throughout the Southwest, insisted that the separate facility was designed for the benefit of the Mexican and Mexican American youth.[1] The Board maintained that the school was not designed to segregate Mexican children; rather, it argued: 1) that the new facility could house up to 85 pupils and that it boasted a fully equipped playground, 2) that the facility was located in the predominantly Mexican area of town so that children could travel safely to school without risking the walk across the main road, 3) that the majority of the children lacked sufficient knowledge of English and could benefit from special attention, and 4) that it was an Americanization school in which "backward and deficient" children could receive better, and more appropriate, instruction.[1] The evidence revealed in trial challenged the "backward and deficient" characterization of the Mexican and Mexican American children and, most pointedly, the board's location and language arguments.[1]

The landmark lawsuit resulting from the "Lemon Grove Incident" became the first successful school desegregation court decision in the history of the United States.[1] On March 30, 1931, the presiding Judge Chambers issued his ruling in favor of Roberto Alvarez. The judge repudiated each of the school board's claims. Although allowing that the school board could "separate a few children to offer special instruction," he wrote, "to separate all the Mexicans in one group can only be done by infringing the laws of the State of California."[10] In the decision, the judge ruled that children of Mexican origin could not be segregated under the laws of the state of California, because they were "of the Caucasian race", and laws allowing the segregation of "Oriental", "Negro", and "Indian" children therefore did not apply.The judge also ruled in favor of Alvarez during this court case since he believed that "the pedagogical and curricular segregation" that the board wanted to implement actually inhibited on how these students needed to learn and in fact needed to be exposed to other American children which in his words was "so necessary to learn the English language."[11]

Decision and results[edit]

The decision was not appealed, in large part due to the perceived risk of further financial burdens to the district and negative public image.[4] For decades, the only official mention of the court case in local records came in the notes of a post-trial school board meeting, "All members of the board present. On account of having lost the court decision there was some discussion about the return of Mexican (children) pupils but only a spirit of good will prevailed, and it was decided that everything was to continue exactly as it did prior to January 5th."[1] Not even the history of the Lemon Grove School from 1880 to 1966, prepared by a former superintendent, referenced the case.[1]

The ruling did result in the immediate re-entrance of the Mexican and Mexican American students to the grammar school; yet, the ruling did not have concrete implications for desegregation in other segregated California schools.[4] It was not until over a decade later, with Mendez v. Westminster, that schools desegregated statewide.


Despite its initial obscurity and limited broader impact, the Lemon Grove Case has increasingly gained recognition for its place in the trajectory of school desegregation as the first successful desegregation case.[1] Moreover, scholars agree that the case constitutes a testament to the Mexican immigrant families who, despite a hostile political climate,[1][10] refused to accept separate and inferior educations for their children and who leveraged the U.S. legal system to challenge such a violation of their children's rights.[1][2] [12] As noted by historian Robert Alvarez Jr., "This was the first situation when a group of immigrants had gotten together, challenged a school board and won."[10] Some scholars also believe that the case may have contributed to the defeat of a bill in the California state legislature (commonly known as the "Bliss Bill") that would have made it legal to segregate children of Mexican descent under the state's education code.[4] In looking at this bill in further detail, the plan of this legislation was to redefine Mexicans as "Indians" rather than "white", thus making it permissible to follow segregation laws against Mexicans in California.[8]

Another aspect that this court case left behind was the issue regarding classifying Mexican Americans as being "white." Particularly concerning Judge Chamber's ruling on the students' being classified "of the Caucasian race."[1] The verdict that came as a result from this case "did not challenge racial segregation per se" which meant that this exception would not span out to all students of color; in a sense these students weren't categorized under a group that enabled them to be permitted under the law to be segregated by districts and schools.[7] The judge's ruling for the students in favor of the students in this court case was viewed as that the learning capability of these students "would help them overcome their colored status" through their education.[11] Since this court case did not expand or create an effect that led to the eventual desegregation of other schools in the nation, at the local level, the case has received recognition.[9]

In 1986, PBS with the collaboration of an ethnic studies professor in UCSD, Robert Alvarez, made a documentary film highlighting historical footage and interviews in order to portray the actions done by parents and students as part of the protest against the school board.[13] On March 9, 2007, the Lemon Grove School District recognized Roberto Alvarez, the schoolboy who was the lead plaintiff in the case. The auditorium at the Lemon Grove Middle School, which is on the site of the former grammar school, was dedicated in his honor.[14][15] In the year 2011 to commemorate the 80 years since this trial occurred, a professor from Palomar college arranged for the screening of a documentary focusing on the lives of Mexican Americans living during the time period this court case was held and titled this as "The Lemon Grove Oral History Project."[16] On May 5th 2016, in order to commemorate the 85 years since the court case was ruled a bill was created in acknowledging March, 30th as being a historic date to remember concerning the City of Lemon Grove.[17]

See also[edit]

  • Mendez v. Westminster: a 1946 case in Orange County, CA that also dealt with the issue of segregating Mexican Americans into separate schools.


  1. ^ a b c d e f g h i j k l m n o p q r s t Alvarez, Jr., Robert R. (Spring 1986). "The Lemon Grove Incident: The Nation's First Successful Desegregation Court Case". The Journal of San Diego History. 32 (2). Retrieved 25 March 2019.
  2. ^ a b c d e Bowman, Kristi (2004). "A Different Shade of Brown: Latinos and School Desegregation". Judicature. 88 (85). Retrieved 25 March 2019.
  3. ^ a b c d Ferg-Caldina, James A. (2004). Black, White, and Brown: Latino School Desegregation Efforts in the Pre- and Post-Brown vs. Board of Education Era. Mexican American Legal Defense and Educational Fund. Retrieved 25 March 2019.
  4. ^ a b c d e f g h Madrid, E. Michael (Spring 2008). "The Unheralded History of the Lemon Grove Desegregation Case" (PDF). Multicultural Education. 15 (3): 15–19. Retrieved 25 March 2019.
  5. ^ a b c Bowman, Kristi (2001). "The new face of school desegregation". Duke Law Journal. 50 (6): 1751–1808. doi:10.2307/1373047. JSTOR 1373047. Retrieved 25 March 2019.
  6. ^ a b c Alvarez Jr, Robert R. (1987). La Familia: Migration and Adaptation in Baja and Alta California. Los Angeles: University of California Press. pp. 150–152. ISBN 978-0520073890.
  7. ^ a b Ladson-Billings, Gloria (October 2004). "Landing on the Wrong Note: The Price We Paid for Brown". Educational Researcher. 33 (7): 3–13. doi:10.3102/0013189X033007003. JSTOR 3700092.
  8. ^ a b c d The Lemon Grove Incident | EXPLORE San Diego, retrieved 2019-04-04
  9. ^ a b c d Guevarra Jr., Rudy P. (2012). Becoming Mexipino: Multiethnic Identities and Communities in San Diego. New Jersey: Rutgers University Press. pp. 80–81. ISBN 9780813553269.
  10. ^ a b c Sanchez, Leonel (May 18, 2004). "Before Brown: 23 years prior to landmark decision, Mexican-Americans win suit against Lemon Grove school board that had banned their children". San Diego Union Tribune. Retrieved 25 March 2019.
  11. ^ a b Donato, Reuben; Hanson, Jarrod S. (Summer 2012). ""Legally White, Socially "Mexican": The Politics of De Jure and De Facto School Segregation in the American Southwest"". Harvard Educational Review. 82 (2): 202–326. doi:10.17763/haer.82.2.a562315u72355106 – via ProQuest.
  12. ^ Ruiz, Vicki L. (Winter 2001). "South by Southwest: Mexican Americans and Segregated Schooling, 1900-1950" (PDF). OAH Magazine of History. 15 (2): 23–27. doi:10.1093/maghis/15.2.23. Retrieved 25 March 2019.
  13. ^ "Jan. 5, 1931: Lemon Grove Incident". Zinn Education Project. Retrieved 2019-04-03.
  14. ^ Lemon Grove School District Dedicates Auditorium to Civil Rights Hero Robert Alvarez, Lemon Grove School District Website Announcement, archived September 29, 2007
  15. ^ Sanchez, Leonel (March 7, 2007). "School to honor desegregation pioneer". San Diego Union-Tribune. Retrieved 25 March 2019.
  16. ^ "A celebration of the nearly forgotten 'Lemon Grove Incident'". San Diego Union-Tribune. 2011-03-26. Retrieved 2019-04-03.
  17. ^ "Bill Text - ACR-146 Civil rights: Roberto Alvarez v. Board of Trustees of the Lemon Grove School District". leginfo.legislature.ca.gov. Retrieved 2019-04-03.