Massive Resistance: A Brief History of Massive Resistance

In handing down its ruling in the 1954 Brown v. Board of Education case, the U.S. Supreme Court ordered that American school districts end the practice of racial segregation and integrate white students and Black students "with all deliberate speed." “Massive resistance” refers to a phrase uttered by Virginia Senator Harry F. Byrd Sr. to fight back against the Supreme Court's order to integrate America's public school systems. Byrd and his allies urged white Virginians to engage in willful disobedience and disruption to block any form of school desegregation.

In 1956, Byrd and several colleagues issued what they called the Declaration of Constitutional Principles, but which was colloquially known as the "Southern Manifesto." The manifesto declared the Brown ruling to be a “clear abuse of judicial power” and a violation of the states' rights described in the tenth amendment to the Constitution. In all, nineteen senators and 82 U.S. representatives from Southern states co-signed Byrd's manifesto, which called for "all lawful means to bring about a reversal of this decision which is contrary to the Constitution and to prevent the use of force in its implementation."

The Southern white strategy of massive resistance began in response to the Supreme Court decision in Brown v. Board of Education, and it continued for over a decade.

• Rejecting the Brown decision: Beginning with the Court's 1954 decision in Brown v. Board of Education of Topeka, numerous federal court rulings declared that school segregation was unconstitutional and that federal law required integrated schools. A follow-up decision, known as Brown II, ordered desegregation to be implemented "with all deliberate speed," a vague command that provided for legal challenges and loopholes. From the outset, white segregationists balked at the ruling.
• The Gray Commission: Shortly after the Brown ruling in 1954, U.S. Senator Harry F. Byrd appointed Virginia state senator Garland Gray to chair an all-white public education commission that came to be known as the Gray Commission. In 1955, the commission presented the Gray Plan, which recommended several strategies aimed at slowing the desegregation of the state’s public schools.
• School integration begins: Slowly, in the aftermath of the Brown decision, public schools throughout the South began admitting Black American students. Yet from the outset, politicians and mobs took action to keep Black students out of previously all-white schools. In Little Rock, Arkansas, Gov. Orval Faubus used his state's national guard to block nine Black teenagers from attending the city's Central High School. These students, known in the Civil Rights Movement as the Little Rock Nine, only gained admittance when President Dwight Eisenhower sent U.S. Army troops to directly escort them into the building each day.
• Massive resistance in Virginia: In 1956 and 1957, under the leadership of Byrd, Virginia became the epicenter of white massive resistance. The Virginia General Assembly in Richmond passed a series of laws aimed at nipping school integration in the bud. A series of laws nicknamed the “Stanley Plan” for then-governor Thomas Stanley cut off state funds for integrated Virginia schools, gave the governor direct control over public education (which he used to close certain schools), and issued tuition grants to white children to attend segregated private schools known as academies.
• A flurry of lawsuits: Following the state’s election of governor J. Lindsay Almond in 1958, Virginia segregationists brought a number of lawsuits aimed at overturning school integration and cementing the Jim Crow laws that had kept schools segregated for decades. Almond attempted to close integrated elementary schools and high schools in Virginia cities ranging from Norfolk to Charlottesville to Front Royal in Warren County. In the 1959 case Harrison v. Day, the Virginia Supreme Court declared that Almond had overstepped the bounds of his office and ordered closed schools to reopen. Meanwhile, Black attorneys affiliated with the NAACP—including Thurgood Marshall and Oliver W. Hill—filed lawsuits in federal district courts that led to a steady stream of integrated schools.
• Stall tactics: Routinely defeated in court cases and slipping in public approval, segregationists attempted to stall integration by seeking higher court injunctions and appealing verdicts again and again. Finally, in the 1964 case Griffin v. County School Board of Prince Edward County, the U.S. Supreme Court put an end to the endless appeals process and ordered Prince Edward County schools to abide by its 1954 Brown verdict. Still, some school districts replaced formal massive resistance tactics with “freedom of choice” plans, which allowed parents to choose which schools they wanted their children to attend. While technically in compliance with desegregation rulings, these plans effectively allowed schools to remain segregated.
• Massive resistance declared illegal: The massive resistance movement met its formal end in the 1968 Supreme Court ruling Green v. County School Board of New Kent County, which deemed that nearly all of the segregationist tactics were in violation of federal law. Massive resistance did continue to function on an unofficial level, as districts cut property taxes that funded public schools, and white home-owning parents used their tax savings to enroll their children in all-white academies. In some cases, public schools that had once been all-white ended up all-Black.
• Aftermath of massive resistance: Seeming to accept the finality of Green v. County School Board of New Kent County, Virginia voters elected Linwood Holton as governor in 1969. Holton had made his name as a moderate battling Harry Byrd, mass resistance, and white supremacy.
• Legacy: Despite these efforts, many parts of the American South continued to see white backlash to school integration. This took the form of lawsuits, school closings, evictions of Black families, procedural delays, physical blockades, and mob violence. Today, the legacy of school segregation continues in many parts of America, including Northern cities like New York, Boston, and Chicago. The trend remains particularly strong in the South where Black children predominantly attend public schools while private academies cater to white children, much as they did in the days of massive resistance.

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