The More Public School Reform Changes, The More It Stays the Same:
A Framing Analysis of Brown v. The Board of Education
Anita Fleming-Rife and Jennifer M. Proffitt
Pennsylvania State University
Pennsylvania State University
College of Communications
304A James Bldg.
University Park, PA 16802
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Jennifer M. Proffitt
Pennsylvania State University
College of Communications
115 Carnegie Bldg.
University Park, PA 16802
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Minorities and Communications Division
Submitted to the Association for Education in Journalism and Mass
Minorities and Communications Division, Kansas City, MO, July/August 2003
The More Public School Reform Changes, The More It Stays the Same: A
Framing Analysis of Brown V. The Board of Education
Three salient frames emerged from the study of two Topeka newspapers, one
mainstream and one black: conflict, consequences and dominant/subordinate.
These frames told readers what and how to think about the United States
Supreme Court decision on Brown. This study finds that the reform measures
made in opposition to desegregation have survived for nearly 50 years and
are now framed as public education policy measures aimed to assist
disadvantaged students acquire improved educational access.
The More Public School Reform Changes, The More It Stays the Same: A
Framing Analysis of Brown v. The Board of Education
This paper is concerned with framing and its influences on public discourse
of educational policy. This study will locate the framing devices used in
two newspapers relevant to one of the most historically significant and
celebrated race relations story of the 20th century, Brown v. The Board of
Education, wherein the United States Supreme Court in 1954 decided what is
arguably the most important ruling in America's history. The Brown decision
effectively dismantled the legacy of Jim Crow in every institution except
its intended: public schools. Even schools that were successfully
desegregated are now re-segregated; today, more than 70 percent of all
African-American children attend schools that are predominantly black, and
the majority of these schools have poor educational resources (Cross &
To remedy this educational deficit in the country's poorest school
districts, various reform measures have been undertaken. This study finds
that two such measures—charter schools and school vouchers—had its roots in
the Deep South during the period under study. Furthermore, though the
Kerner Commission argued in 1968 that, "it is the responsibility of the
news media to tell the story of race relations in America" (p. 384), what
is clearly missing from the story of the public school education of blacks
is the link between these recommended measures and their racist origins.
This study will describe how educational policy is informed, shaped, and
conveyed by the use of frames. The organization of this paper is as
follows: We begin by providing background research that describes blacks'
quest for equal high quality education and the long and uphill battle that
it entailed. Next, we will examine the legal strategies used by the NAACP
in its fight for equal education rights. We will then investigate the
historical function of the black press and how African Americans have
historically been covered in mainstream newspapers. Then, we will review
the framing literature and finally provide analysis and discussion of the data.
Background: Blacks Value Education
Harriet Beacher Stowe in 1879 observed of the Freedman's campaign for
education: "They rushed not to the grog-shop but to the school room—they
cried for the spelling book as bread, and pleaded for teachers as a
necessity of life" (Anderson, 1988, p. 5). Others recalled similar
experiences. For example, a northern, white missionary teacher said of her
South Carolina students in 1863: "Vacations seemed like a hardship to these
students, who were so anxious to improve their readings and writings that
they begged not to 'be so punished again'" (Education among Freedmen, ca.
Both enslaved and free blacks recognized the importance of education.
Anderson (1988) offered this analysis of why blacks had such a high regard
for education: Three decades before the Civil War, blacks lived in a
society in which literacy was out of reach—it was outlawed for them. To
them, literacy symbolized a skill that contradicted the status of slaves.
This was the case so much so that blacks risked severe penalty for
violating this law. In 1860, five percent of enslaved people had learned to
Well before President Lincoln issued the Emancipation Proclamation in
1862, enslaved and free people of color had already begun to plan for
systematic instruction for illiterates. One such strategy was the
establishment of their own schools: One such school, Fortress Monroe, was
opened in 1861 under the tutelage of a black teacher, Mary Peake. According
to Anderson (1988), other schools for and operated by blacks preceded
Many of these early schools took the form of either native or Sabbath
school systems. In 1865, the national superintendent of schools for the
Freedmen's Bureau observed "the practice of what he called 'self-teaching'
and 'native schools' among the freed men and women" (Anderson, 1988, p. 6).
Throughout the South, he reported, colored people were attempting to
educate themselves. And not only were they determined to teach themselves
to read, but they also developed their own system of "native schools."
Native schools, founded and operated by the formerly enslaved, according to
the records of the Freedmen's Bureau, were commonplace. It is estimated
that in 1866, there were 500 native schools throughout the South.
What surprised many was that blacks favored black teachers over white.
According to Jones (in Anderson, 1988), northern, white teachers in Georgia
were "taken aback to discover that some blacks preferred to teach in and
operate their own schools without the benefit of northern largesse" (p.12).
In part, the northern, white missionaries who taught blacks perceived them
as members of a child-like race. A desire for self-determination, however,
fueled even more passion for schools. According to Anderson, blacks
initiated and sustained the "Sabbath" school system that operated in the
evenings and on weekends and provided basic literary instruction. These
schools were very common in formerly enslaved communities immediately
following the Civil War.
Anderson (1988) argued that in the history of black education, the
political significance of slave literacy reached beyond the antebellum
period. Many of the educators and leaders of post-antebellum years were men
and women who first became literate under slavery. Among them were many
prominent leaders, such as Frederick Douglass, Bishop Henry M. Turner and
Blacks Face Southern White Opposition
While blacks were determined to read, they also saw a need for education
to have a wider scope and reach. Anderson (1988) said: "Former slaves were
the first among native southerners to depart from the planter's ideology of
education and society to campaign for universal state-supported public
education" (p. 4). To effectively mobilize support for universal schooling,
they garnered the support of Republican politicians, the Freedmen's Bureau,
northern missionary societies, and the Union Army.
From the very beginning of the post-Civil War epoch, the South's landed
upper class opposed the idea of state-enforced public education. While the
Supreme Court had decided in the 1857 Dred Scott decision that blacks were
to be regarded as less than human, white landowners were opposed to
educating blacks for more than that reason. Perhaps the most palpable
reason was economics, a notion supported by W.E.B. DuBois (1935), who
argued that at "the crux of the issue was the symbiosis between racism and
capitalism . . . racist constraints on black educational opportunity. . .
(p. 328)." For example, Anderson (1988) cited a white planter who said in
1865, "learning will spoil the nigger for work" (p. 21). Post-emancipation,
Southern planters did whatever they could to maintain a labor-repressive
system. A number of state laws passed between 1865 and 1867 that enabled
the continued exploitation of black labor. Called the Enticement laws, they
were designed to control the black labor force.
By the time the Union Army pulled out of the South in 1877, nearly
three-fourths of the South's labor force was involved in agriculture, and
blacks were a very important source of field labor. In addition, there was
a heavy reliance on children as part of the labor pool. Once the Union Army
pulled out, the South chose to return to its labor-repressive system, which
required that blacks be denied an education. Southern planters immediately
began to present obstacles to any hope of laying down a foundation for
universal education in the South. And they were successful in managing to
under-develop universal education: They stressed low taxation, opposed
compulsory school attendance laws, blocked the passage of new laws that
would strengthen the Constitutional basis of public education, and
discouraged the expansion of public school opportunities. Their resistance
was so effective that it froze the formerly enslaved people's educational
campaign in its tracks (Anderson, 1988).
Although the universal education mission challenged the social power of the
South's dominant planter class, by 1880, there was some agreement that
blacks should attain some type of education as long as their training
served the interest of the white ruling class. This ideology is what
informed the philosophy of Booker T. Washington and his subsequent
"Hampton-Tuskegee Idea," which emphasized normal and industrial training.
At the beginning of the 20th century, the condition of schools for Negro
children in the South was only slightly improved over their condition in
1865 (Bond, 1932). Still, two-thirds of black elementary age children were
not enrolled in school (Anderson, 1988). While the number of black children
of school age increased by 25 percent, the proportion of those attending
school fell. Even against the most formidable odds, illiteracy among blacks
dropped to 70 percent in 1880 and down to 30 percent by 1910. It was
against this historical backdrop that the NAACP entered the picture.
NAACP on the Battlefield
From the NAACP's inception in 1909, its efforts were directed at
eliminating the system of racial subordination. It had accurately
identified the link between subordination and segregation, and segregation
to the legal doctrine of "separate but equal." It was their mission to
dismantle the legally entrenched practices of Jim Crow, which had been
established by the U.S. Supreme Court's unanimous decision in the famous
1896 Plessy v. Ferguson (163 U.S. 537, 1896).
Homer Plessy wanted to be treated as an equal; he did not want equal
accommodations, but the right to sit next to white people on the railroad
cars. Though blacks were often in proximity to whites in the South, it was
always on a subordinate level. Boxil (1997) argued that "if racial
segregation on railways was abolished, blacks would be in close proximity
to whites as fellow travelers and citizens, . . . where they could meet
whites on terms approaching equality" (p. 79). The Court, however, rejected
"social equality." Tushnet (1987) asserted that the Supreme Court found
this notion of equality problematic: "Justice Henry Billings Brown's
opinion for the Court distinguished between political equality, which was
guaranteed by the amendment and social equality, which 'in the nature of
things' could not be guaranteed by law" (p. 22). Implicit in Plessy's
argument against separate accommodations of trains was the notion that to
be segregated from whites meant that it placed a "badge of inferiority" on
him (Boxil, 1997, p. 80).
The NAACP was optimistic about its ability to systematically break down the
legal foundation of segregation that had been established by the Plessy
Court. It first secured funds to study black schools in the Deep South. The
organization found that by any measure that one would take, the black
schools were inferior to white schools. Their next challenge was to develop
a strategic legal plan of attack. On this, there was some organizational
disagreement (Tushnet, 1987).
Some within the organization argued that the legal route to dismantling
segregation in schools should include seeking from the courts simple
declarations of unconstitutionality rather than time-consuming, revolving
door orders directing that expenditures be equalized. The argument was that
"once the declarations were obtained, state officials could decide whether
to equalize or to desegregate the schools" (Tushnet, 1987, p. 27).
DuBois was among those who argued that there was too much for black
children to lose if schools were desegregated. In other words, he supported
equalization over desegregation. He proposed black empowerment instead of
giving power to state officials. For example, Du Bois (1935) explained that,
. . . the Negro needs neither segregated nor mixed schools. What he needs
is education. What he must remember is that there is no magic in either
mixed schools or segregated schools. A mixed school with poor and
unsympathetic teachers, with hostile public opinion, and no teaching of
truth concerning black folk, is bad. A segregated school with ignorant
placeholders, inadequate equipment, poor salaries, and wretched housing, is
equally bad. Other things being equal, the mixed school is the broader,
more natural basis for the education of all youth. It gives wider contacts;
it inspires greater self-confidence; and suppresses the inferiority
complex. But other things are seldom equal, and in that case, Sympathy,
Knowledge, and the Truth, outweigh all that the mixed school can offer (p.
To this end, there were others who wanted only equalization of resources.
This strategy may have resulted, in part, from the first lawsuit in which
the U.S. Supreme Court applied the "separate but equal" doctrine to
education: Cumming v. the Board of Education (175 U.S. 528, 1899). In
upholding the lower court's ruling, the Supreme Court decided against the
plaintiff's request for tax relief because the only black high school in
the state had been closed by the school board. These black parents were not
challenging segregation; they simply wanted equal resources. The NAACP may
have reckoned that had the Cumming's case been argued on the grounds of
equalization instead of tax relief, they would have won. By 1939, the NAACP
had restructured itself by creating the NAACP Legal and Educational Fund as
a functionally autonomous wing (Martin, 1998) and adopted equalization as
its initial strategy.
As chief legal counsel, Charles Houston, Thurgood Marshall's mentor and
dean of Howard University's Law School, had a three-prong strategy to
dismantling Jim Crow in education: desegregation of public graduate and
professional schools, equalization of teachers' salaries, and equalization
of elementary and secondary schools. With regard to the desegregation of
graduate and professional schools, the degree of success varied depending
upon where the litigation took place. Determined to expand their reach, the
NAACP began fighting for equalization of teachers' salaries.
One of the more important teacher equalization cases was fought in Little
Rock, Arkansas (Anderson, 1988; Tushnet, 1987). As the teachers organized
themselves, they turned to the NAACP for legal assistance. Thurgood
Marshall was quite impressed with the organization of the teachers; he
remarked: "Boy, these Southern teachers have acquired brand new backbones"
(Tushnet, 1987, p. 90). The school board, arguing that it was providing a
remedy for the salary differential between black and white teachers, put
forth a point-system based upon "merit." Each white teacher received $3.00
per point and each black teacher received $1.50 per point. The school board
had successfully convinced the trial judge that "substantially all colored
teachers are worth less than substantially all white teachers" (p. 92). The
NAACP was successful in persuading the court of appeals that the trial
judge's findings were "clearly erroneous." The victory meant that teachers'
salaries were equalized in 1946.
Following important—but difficult to win—victories in equalizing teachers'
salaries, in the late 1940s, the NAACP decided on its next level of the
legal plan: equalization of elementary and secondary school facilities. The
NAACP faced its greatest obstacles at this front. Martin (1998) put forth five:
1. Local school districts admitted to disparities in educational funding,
but lied or exaggerated about efforts underway to ameliorate them.
2. States and local school districts were primarily responsible for public
school educational policy and funding inhibited litigation at the federal
3. There was the awesome weight of tradition and social custom; Plessy was
the precedent upon which Jim Crow rulings rested.
4. Because of the above, state courts did not consider state-sanctioned Jim
Crow to be in violation of the Fourteenth Amendment right of blacks to
equal protection under the law and therefore left Jim Crow intact.
5. The defendants and courts alike variously ignored, trivialized, masked,
neutralized, explained away, and accepted the pervasive reality of separate
Martin argued that all "these tactics naturalized Jim Crow as fundamental
to a 'higher law' of white supremacy, or integral to the organic order of
society" (p. 14). And as Derrick Bell (1992) maintained, the law functioned
to sustain white supremacy.
But there were competing factors at play that were to have some bearing on
the way in which the organization would modify its public school
equalization strategy. The NAACP Legal Defense team had begun to win a
number of cases with decisions outlawing segregation. At the same time,
there were increasing Cold War concerns. The Department of Justice had made
it clear that Jim Crow in the United States would work as an effective
propaganda tool for the Soviet Union (Martin, 1998). Then the federal
government, under President Truman, desegregated the armed forces. It
appeared to the NAACP legal team that the government was strongly opposed
to state-sanctioned racial segregation. This, according to Martin, set the
stage "for a full-fledged direct attack against Plessy-sanctioned
segregation: the 'road to Brown' was taking shape" (p. 27). No longer was
the equalization of resources the strategy; instead, the desegregation of
schools became the primary focus.
Crafting of Brown
Five cases were consolidated as Brown v. the Board of Education: Brown v.
the Board of Education of Topeka, Kansas, Briggs v. Elliott (Clarendon
County, South Carolina), Davis v. County School Board of Prince Edward
County (Virginia), Belton v. Gebhart (Delaware), and Bolling v. Sharpe
(District of Columbia). There was clear evidence that there were gross
material and funding disparities between white and black schools. The NAACP
decided to add the psycho-sociological dimension to their arguments in this
case. In other words, it would argue that there was psychosocial harm
inflicted on black school children as a result of Jim Crow.
Important in this regard was the expert witness of social psychologists
Kenneth and Mamie Clark (in Martin, 1998). They had devised a doll test as
a means of determining personality dysfunction among black children under
Jim Crow. When black, pre-school children were shown two dolls—one white
and one black—they preferred the white one. Because the children
overwhelming preferred white dolls more than black, the Clarks extrapolated
that the children had poor self-esteem that resulted from black inferiority
and white superiority. At the lower court level, Clarendon Country used
expert witnesses to rebut the sociological argument, and in Kansas, the
defendants questioned this argument's applicability to that specific
case. Unfortunately, the Supreme Court failed to fully scrutinize either
the validity of the Clark's research method or their interpretive conclusion.
Further, more practical evidence refuted this claim of poor self-esteem
and black inferiority. At this point in history, there were tremendous
success stories of black people who had graduated from these so-called
inferior schools to go on to competitive, predominantly white universities.
Among them was Charles Houston, framer of the legal strategy in Brown and a
Harvard graduate. There were many others, yet this argument of inferiority
was persuasive and pervasive.
The arguments in Brown were presented in three stages: (1) The initial
presentation of the case, which did not allow the justices sufficient time
to consider all of the presented evidence; (2) reargument on the intentions
of the Fourteenth Amendment's framers; and (3) finally, after the Court
struck down Plessy v. Ferguson (Brown I), called for arguments about the
remedy (Brown II). This study will pick up with Brown I in January of 1953
and conclude as the two sides try to determine a remedy in December 1954.
The Black Press
Wolseley (1990) defined the black press as that "which is written,
directed, produced and financed by blacks, located in a black community,
and uses the community as its reference point" (p.5). The black press dates
back to 1827. In its nascence as an advocacy paper, it campaigned for the
freedom of black enslaved people. Woseley argued that "it was a journalism
almost totally committed to a cause" (p. 24). Unlike its white counterpart,
the black press did not make the claim that it was objective. From its
inception, the black press had an overtly, one-sided mission "of serving,
publicizing, speaking and fighting for the colored minority," according to
Moses Newson, former executive editor of the Baltimore Afro-American
(Wolseley, 1990, p. 4). Furthermore, argued the late publisher of the
Philadelphia Tribune, E. Washington Rhodes, "the black press should be
about the business of securing for its readers absolute equality of
citizenship rights" (p. 4).
In response to the negative attacks on blacks by the New York Enquirer,
Samuel E. Cornish and John B. Russwurm founded the first paper, Freedom's
Journal (Wolseley, 1990). While not countering the black press' mission, it
is believed that this paper was designed with a white audience in mind—to
influence sympathetic white people who were in a position to help free the
black man. To do this, they also needed financial support since blacks were
not in a position to provide financial assistance.
The North Star was founded by Frederick Douglass in 1847. In its first
issue, "Douglass said, 'the object of the North Star will be to attack
slavery in all its forms and aspects, advocate Universal Emancipation . . .
promote . . . intellectual improvement of the colored people; and to hasten
the day of freedom . . . three million enslaved fellow countrymen" (p. 31).
Post-Civil War, the black press became, to some extent, more diversified
in its mission: some continued as crusaders, some supported reaction, and
others were more concerned with profit (Wolseley, 1990). But for the most
part, the post-World War II black press was still so single-minded that it
kindled sharp criticism and was likened to the Communist Daily Worker
(Wolseley, 1990). For example, Adam Clayton Powell, Jr., one-time editor of
the People Voice, founded in 1942 in New York City, stated:
He wished to use the press to correct what he considered the false ideas
held about the American black people; he wished to raise a militant voice
on behalf of the black society; and he desired to employ the press as an
educational force with the 'new' black citizens aroused to demanding more
democracy (Wolseley, 1990, p. 83).
Although Powell was a Baptist minister, his peers in the South were not as
forceful and visionary. Julius Thompson (1983) asserted in his study of the
black press in Mississippi that it was because most newspaper editors were
church pastors that they were not very aggressive. The subsequent news
content reflected this as their readers expected a "deep religious emphasis
in the press, if not in detail, at least in tone of publication of that
period" (p. 198).
Blacks in the White Press
Wolseley (1990) argued that white newspapers differ from black in that
while they are, for the most part, owned by whites, they want to have
diversity in readership and circulation. Even so, white papers are
"concerned with the problems of whites, the majority group readers, and
only incidentally with those of blacks" (p. 6). This, of course, was
substantiated by Gans (1979) and by the Kerner Commission (1968). In fact,
Watkins (2001) argued that though the white press considers itself detached
and objective, critical studies of the news media have found that news is
not an objective mirror of reality (See for example Tuchman, 1978; Fishman,
1980). And there is evidence that when it comes to race and groups outside
the majority culture, news coverage of these "deviant" groups become even
less objective (Shoemaker, 1982; Gitlin, 1980).
It is, however, important for the mainstream media to accurately portray
race because, as Martindale (1986) so aptly pointed out, "the way the media
portray black Americans and report on relations between the races strongly
influences the way the public perceives these aspects of American life"
(p. 1). She further argued that,
media reportage can promote attitudes of acceptance, or of hostility and
fear; it can increase understanding, or it can encourage repression; it can
expose problems and present suggested solutions, or it can ignore
uncomfortable situations until they explode into violence (p.1).
Johnson, Sears and McConahay (1971) have also noted the importance of
newspaper's role in reducing racial oppression.
Implicit in the arguments of both Martindale (1986), and Johnson, Sears and
McConahay (1971) is the idea that the press has a social responsibility to
its public. But, as Geiber (1960) had argued, journalists are not motivated
by social responsibility theory so much as they are influenced by newsroom
pressures. Of course, Breed (1955) had found this to be the case five years
earlier in his study of newsroom socialization.
Journalists face influences outside the newsroom in their roles as agents
of social control (Gans, 1979). In that role, they "help maintain social
order, warn against social disorder, and act as moral guardians" (p. 295).
At the same time, journalists are not independent of their place in the
societal structure. Jones (1986) argued that they are socialized in an
atmosphere of racial animus. Martindale (1986) asserted that "white
Americans live in a society that from its inception has created an
intricate system of rationalizations to justify inhuman treatment of people
of color for the white person's advantage" (p. 21). She further argued that
journalists cannot escape being affected by racism.
Hartmann and Husband (1974) asserted that, "color prejudice is
characterized by the belief that the white man is superior to the man of
color" (p. 36). They further observed that prejudice resides in the
culture. As a result, Martindale (1986) argued that journalists can't help
but to "express in news coverage and editorials the racist assumptions that
are accepted in white society of which they are part" (p. 22). She offered
an example from a study conducted in 1971 by Secrest. In his study of
editorials in South Carolina newspapers during the decade after the 1954
United States Supreme Court decision in Brown v. the Board of Education,
several newspaper editors approved the action of white mobs that had
successfully prevented voluntary desegregation in West Virginia and
Delaware. The editors advocated this type of disruption as a means to
resist integration. Stein (1994) found in his study that "the mainstream
media's coverage of people of color are riddled with old stereotypes,
offensive terminology, biased reporting and myopic interpretations" (p.
12). This type of bias in mainstream newspapers and in black newspapers
alike supports assertions by social psychologists Linville and Fischer
(1986) that individuals have a natural inclination to favor members of
their own group (ingroup) over members of other groups (outgroups).
One way in which this "favoritism" is manifested in news content is by the
absence of or misrepresentation of minority voices (Martindale, 1986;
Campbell, 1995; Johnson, 1987; & Shirley, 1992). At the same time, this
oversight is perceived as a by-product of a "commonsense" approach to
newsgathering that is based on identifiable values and practice codes whose
legitimacy and fairness are taken for granted (Mohamed & Fleming-Rife,
in-press). Marginalization is, thus, an outcome of this oversight
(Campbell, 1995). Consequently, Johnson, Sears and McConahay (1971)
maintained that black invisibility in the white press serves to facilitate
white exploitation of blacks by contributing to white ignorance of blacks
as people and their problems.
Frames "are organizing principles that are socially shared and persistent
over time, that work symbolically to meaningfully structure the social
world" (Reese, 2001, p. 11). Given the universe of news and information,
journalists and media practitioners are critical to framing the social
world into meaningful and understandable structures, or as what Goffman
(1974) and later Tuchman (1978) called "strips." These strips represent
"any arbitrary slice of cut from the stream of ongoing activity" (Goffman,
1974, p. 10); implicit in this process is selection, omission and emphasis.
Journalists work in concert with their sources, with whom they have a
symbiotic relationship. Together they frame our understanding of the social
But it is the news media that are the ultimate news frame producers. In his
1994 study, Gandy reported the data were "surprisingly consistent in
suggesting that the press prefers to present differences between the
fortunes of whites and blacks . . .high probability of black loss—bad news
for and about blacks" (p. 47). Valkenburg & Semetko (1999) found that news
frames give the audience direction on how to conceive of a specific issue
or event. They argued that "news media have the capacity not only to tell
the public what issues to think about but also how to think about them" (p.
17). Fine (1992) found that public reaction to equal opportunity programs
are affected by how these programs are presented to the public. That point
had been articulated by Entman in 1990. He argued that the way race is
treated in the news may influence public support or rejection of public
The news media play an active role in framing public policy issues
(D'Angelo, 2002; Pan & Kosicki, 1993). Pan and Kosicki (1993) posited that
news discourse operates within a domain that consists of shared beliefs
about society. These beliefs are known and accepted by the majority and
considered commonsense. In fact, they are so pervasive that they move into
what Hall (1995) would call "the realm of naturalness"—taken for granted.
As such, they provide the broad parameters from which news discourse in
constructed, transmitted, and developed.
Every news story has a theme that functions as the central organizing idea.
Schudson (1989) provided further explication of the functionality of
frames. He asserted that frames are the vehicle by which activists and
reformers shape meanings and convey their claims, grievances and proposals.
They use cultural resources-beliefs, ideologies, values and myths to make
their goals persuasive. Furthermore, activists and reformers strive to make
their proposals "resonate" among a certain audience by connecting them to
popular beliefs, whether by amplifying previously muted themes or
re-expressing old ideas in new idioms.
Consequently, Thomas (1993) argued that news frames one culture as
subordinate to the dominant. This depiction takes on the character of a
social myth and creates actions directed toward the subordinate culture.
These myths reproduce power relations, establishing boundaries between the
dominant and subordinate culture (see also Santos & Proffitt, 2002).
News is also framed as conflict. The conflict frame emphasizes conflict
between individuals, groups, or institutions (Neuman et al., 1992).
Valkenburg & Semetko (1999) reported that this kind of coverage makes
winning and losing the central concern. The language of wars, games, and
competition are featured. For purposes of this paper, a subframe of
conflict that has been reported in the literature is protest. For example,
Shoemaker (1982) found that "deviant" political groups are considered
illegitimate. Gitlin (1980) also reported that news media trivialized and
marginalized a student group opposed to the status quo.
McLeod (1995) noted that social movements are marginalized in media content
by ignoring or discounting its accomplishments. He argued that journalists
are reluctant to deal with social issues. When they do, the issues are
often trivialized or over-simplified. In this case, journalists prefer to
deal with protest rather than the nuances of the issues that spur such
resistance. Campbell also (1995) found that minority groups are
marginalized. It is manifested in content when minorities are voiceless and
others speak for them. Finally, Gamson (1988) reported that the consequence
frame has been used to make an issue relevant to its audience.
As aforementioned, news is framed in such a way as to influence public
support or rejection of public policy. For this reason, the present study
will examine how newspapers framed the 1954 Brown v. the Board of
Education, Topeka, Kansas. This decision has influenced public school
policy ever since; in fact, this study will show that contemporary remedies
for public school ills were first articulated in the Deep South in 1953/54.
Reese (2001) suggested further framing work be of a comparative nature.
Therefore, this study compares a mainstream and a Black press newspaper of
Topeka, Kansas. It describes the framing devices used in the two newspapers
prior to and after the United States Supreme Court decision in Brown and
asks the following research questions:
Research question 1: How was public discourse about desegregation in 1953
and 1954 framed in the Topeka Daily Capital (mainstream newspaper) and the
Topeka Plaindealer (a black press newspaper)?
Research question 2: Were the same frames used, and if so, did the frames
have different meanings in the two newspapers?
To compare the news frames found within a black press newspaper with a
white newspaper, we chose the Plaindealer, a weekly newspaper recognized as
"the most successful Black-owned newspaper in Kansas and one of the
strongest in the nation" (Kansas State Historical Society, 2003), and the
Topeka Daily Capital, a white daily newspaper founded in 1879. The
Plaindealer was the most complete and accessible black newspaper in Kansas
for the time period studied, and it had an outstanding reputation for the
region. In addition, the majority of black newspapers were weeklies; thus,
for purposes of this study, comparing a weekly newspaper with a daily
newspaper is reasonable. These two newspapers were also chosen for analysis
because of the significant role Topeka had in the desegregation battle:
Though Brown v. Board of Education ultimately combined five cases, the
namesake of the Supreme Court case was Linda Brown, a third-grade student
from Topeka, Kansas.
We chose to analyze the years 1953/54 because these were the years that
articulations of desegregation became most prominent in news media. For
each newspaper, we collected every news article and editorial from 1953 to
1954 that discussed secondary or elementary school desegregation. In total,
the Plaindealer had 91 such articles in this two-year period and the Topeka
Daily Capital had 111. We then analyzed each article to determine the most
salient frames and found that though the perspectives of each newspaper
differed, three overarching frames emerged in the news coverage of both
newspapers: conflict, consequences, and domination/subordination.
The conflict frame was defined as articles that, as Neuman et al. (1992)
suggested, emphasized struggle between individuals (e.g., lawyers;
authorities), groups (e.g., NAACP v. school boards), or institutions (e.g.,
desegregation v. segregation; constitutionality of the 14th Amendment and
of Jim Crow). Implicit in a conflict frame is the notion of compliance: One
side must win while the opposing side must lose or give in so that social
control can be recreated and maintained. This frame also includes protest,
or resistance, which pits the mainstream against the marginalized and
ultimately emphasizes resistance to change and maintenance of the status
quo. The prominence of protest worked to marginalize or trivialize the
views of those persons and groups who supported the Supreme Court's decision.
The consequences frame was defined as articles that accentuated the
potential penalties that would occur if the Court ruled in favor of
desegregation. This frame was used as a way to reassure or to brace the
audience for what was perceived as short term and long term consequences of
the impending decision, a decision that would severely disrupt the status quo.
The domination/subordination frame was defined as articles that reproduced
existing power relations; that is, the voices, the accomplishments, and the
needs of the subordinate culture—in this case, the black community—were
delegitimized or ignored while the power of the dominant culture was
re-legitimized and validated.
It was not until April of 1953 that we began to see school
segregation/desegregation articles in the Topeka Daily Capital. Conflict
was by far the dominant news frame emerging from the analysis of the news
stories in the Topeka Daily Capital. While conflict was the dominant frame
in the Plaindealer, compliance was often emphasized.
Segregation v. desegregation was the most salient dispute used in the Daily
Capital to demonstrate that the existing status quo was at odds with both
the Supreme Court and the NAACP, but imbedded within the larger frame of
conflict were subframes where protest, resistance, and interference
attributes were used. For example, a November 26, 1953 headline read:
"Fatzer will Defend State Racial Law." In the body of the text it is
reported: ". . .we are defending the Kansas statute enacted by the
Legislature many years ago establishing that the policy of segregated
schools should be left up to the local governments" (p. 31). Implicit here
is the conflict between states rights and the federal government.
Furthermore, resistance to a potential change in policy (or disruption of
the status quo) is manifested in this story by arguing that because the
schools could not be expected to integrate immediately, a gradual end to
segregation would be best. Another example of such protest was found in a
November 27, 1953 article that reported that Georgia and South Carolina
would resist this upcoming new law by abolishing public schools.
Another conflict that emerged was between the Republicans and the
Democrats. A November 29, 1953 headline reads: "South Rages Over
Segregation Brief." In the body of the story, it is stated that Republicans
would never have foothold in the South again because they supported the
abolishment of school segregation. The South thus declared one represented
party: Democrat. The language of war is used here, and the Democrats were
"declared" the winners of this battle. Other examples were found in the
December 6, 1953 issue of the paper: "Segregation arguments to resume;"
"Second round of oral arguments;" "Momentous issue of whether to declare
the separation of Negro and white pupils in public schools
unconstitutional" (p. 8a). These statements work to pit two opposing sides,
and ultimately, one side would win.
There was also conflict in terms of the interpretation of the 14th
amendment: For example, a December 9, 1953 editorial headline read: "14th
Amendment Under Attack." The proponents of segregation argued the
unconstitutionality of the amendment, positing that the amendment was
originally a Republican endeavor: "Not one Democrat in Congress voted for
the 14th Amendment and only one Democrat in all the state legislatures." On
the other hand, anti-segregation forces, it is noted in this editorial,
argued the validity and protection of the 14th Amendment. It stipulates:
"No state shall make or enforce any law which shall abridge the privileges
or immunities of citizens of the United States, nor shall any state . . .
deny to any persons within its jurisdiction equal protection of the law"
The final way in which conflict is made salient to readers is through the
pronouncement in the December 14, 1953 Daily Capital that "South Carolina,
Georgia and Mississippi have taken steps to do away with their public
schools . . . to appropriate money for educating children, perhaps to be
used for scholarships or payments to parents who would hand it over to
whoever who would run the schools" (p. 8). This frame picked up steam. A
March 8, 1954 article proclaimed that "Voters in [South Carolina] state
last year overwhelmingly approved a referendum to remove from its
Constitution the requirement that South Carolina provide free schools for
its children" (p. 8). Georgia's governor, in conflict with the Supreme
Court, was reported as stating: "[R]egardless of what the Supreme Court may
rule, there will be no mixing of the races . . . while I am governor" (p.
8). This frame continued throughout the time period under study.
Interestingly, this notion of extending money to parents for educating
children wherever they deem appropriate continues to be debated in the 21st
century under the guise of "school vouchers." Furthermore, charter schools
fit the description of the "private" schools that the governors called for
as resistance to the desegregation decision.
Conflict as protest also became an issue post-Brown when the 1954-55 school
year began. Headlines read: "White Pupils Protest Negro Enrollment"
(September 17); "Delaware School Absentees Mount" (September 30);
"Segregation Riots Spread to Capital" (October 5); and "500 Students Refuse
to Call Off Desegregation Strike" (October 7). Though Kansas had begun
desegregation in several parts of the state, including Topeka, the use of
the topic of conflict creates controversy, but at the same time reassured
Topekans that they were much more "civilized" than those areas protesting
The Plaindealer began reporting on desegregation January 23, 1953. In the
Plaindealer, conflict was framed as "fighting" for desegregation. For
example, in one editorial, the salient theme is that "NAACP attorneys
challenged the validity of . . . segregation laws" (p. 7). On page one,
February 27, 1953, the paper posited that "the fight is for desegregation
opposed to inequality" (p. 1). But generally conflict is framed in the
Plaindealer as desegregation v. equalization. While the NAACP Legal Defense
team, headed by Thurgood Marshall, argued for desegregation, there were
blacks that believed as did W.E. B. DuBois that public school funding
should be equalized. The Plaindealer was clearly supportive of the NAACP
and framed those opposed to desegregation as "Uncle Toms" (November 20,
1953, p. 7). There were others who simply believed that it was going to be
difficult to enforce desegregation; therefore, equalization of resources
should be sought (May 8, 1953).
Compliance did not occur as a frame in the Daily Capital, for the most
part, until post-Brown when states began to decide whether they should
comply or resist the Court's order. For example, on May 21, 1954 the
headline read: "Kansas will Comply with Ruling" (p. 2). For the next two
days, there were reports of other states, including Southern states, that
had decided to comply, but the compliance frame was generally juxtaposed
against resistance. In the Plaindealer, however, compliance was a common
attribution. In fact, one story noted that white students could come to
their school in an all black town if they wanted to, for the black
community was certainly going to comply with the Supreme Court decision.
In the Daily Capital, "consequence" was generally treated in two ways. It
suggested that blacks would suffer the negative consequences in the form of
losing their jobs—while, at the same time, it reassured the larger white
community that their jobs would be secure. For example, a page one story on
April 6, 1953 was headlined: "Negro Teacher Purge Begins in Kansas: Board
Anticipates End of Segregation." The story focused on the firing of Negro
teachers because there would not be a need for them when the schools are
desegregated. The next day, there are three stories: A page one headline
reads: "Firing Negro Teachers To Be Contested: Validity of Board Meeting an
Issue." On page two are side-by-side articles; the headlines read:
"Consequences of Desegregation NAACP: Full Integration," and "Schools Hire
20 Teachers." There is an editorial about teacher shortages in the same
issue. The first of the adjacent news stories is written from the
perspective of the NAACP, which called for full integration and noted the
consequences of integration as the loss of teaching jobs for blacks. The
second story reported that efforts were underway to remedy the white
teacher shortage; black teachers were clearly not being considered to fill
the need. The juxtaposition of the two stories clearly makes the issue of
desegregation relevant to the audience by reporting the bad news for and
about blacks. In this way, it is reassuring Topeka Daily Capital readers
that the real losers in this desegregation battle are Negro teachers and
that the dominant social order is in control. For example an April 21, 1953
headline read: "Board Rejects Bid to Rehire Negroes Here: Motion Killed,
3-3, By School Officials." The status quo was thus maintained.
The day after the U.S. Supreme Court hearing for Brown, the Daily
Capital's lead story was accompanied by a photo of the lead counsel
representing defendants in South and North Carolina, a North Carolina
defense attorney, and its attorney general. The lead attorney argued that
"Negroes may lose more than they gain if segregation is ended in public
schools." He further posited that if public school segregation is
abolished, "the results would not be pleasing." This thinly veiled threat
is cloaked as a negative consequence to blacks.
Another way in which consequence was framed in the Topeka Daily Capital
was by examining "far-reaching" consequences. When this frame was engaged,
the newspaper sought to brace its public for potential threat to its way of
life. Stories along this line suggested that Jim Crow in all public places,
not just schools, would be dismantled and this would disrupt social life as
they knew it. For instance, it told its readers that the impending Supreme
Court decision would mean the removal of all vestiges of Jim Crow in
society (November 27, 1953). That point was made again (December 10, 1953)
when it reported that "segregated schools were not all that were under
attack" (p. 4).
In the Plaindealer, the consequence frame was used much like it was in the
Daily Capital in terms of what blacks stood to lose if the Supreme Court
outlawed segregation. For example, on April 10, 1953 the page one story was
headlined: "Negro Teachers in Kansas Face Unemployment, if Jim Crow Ends."
In terms of "far-reaching," negative consequences, there were a number of
stories and editorials that predicted that historically-black colleges
would be negatively impacted by desegregation. For example, there was an
editorial in the May 8, 1953 issue that read: "Morehouse Colleges Head
Foresees Harm if Nation Okays School Jim Crow."
In the fall of 1953, the Topeka school board, in anticipation of the
Supreme Court ruling, had already begun desegregating public schools, so
the Daily Capital, on page one, argued the day after the decision, May 18,
1954, that there would be little effect on Topeka. However, amongst four
front-page stories, one suggested that a local black industrial school may
be without funding as a result of the decision. In fact, the story noted
that "an attempt to abolish the training school for Negroes nearly
succeeded in 1953." It was reported that "the State Board of Regents and
the Legislature has refused to allot any funds to KTI [Kansas Technical
The first issue of the Plaindealer post-Brown did not mention consequences
in any of its stories. Not until May 28, a week later, is consequence a
frame. The frame highlights the fate of North Carolina Negro teachers. For
instance, the lead reads: "North Carolina believed to have the largest
number of Negro teachers in the nation must consider the problem of
employment in studying the effect of the Supreme Court desegregation" (p. 6).
The majority culture was framed as dominant or superior whereas "Negroes"
were framed as subordinate or inferior. The Daily Capital emphasized the
domination/subordination frame on July 18, 1954, at the same time it used
the aforementioned framing devices. The lead coupled the conflict frame
with domination frame to read: "Some time this fall the Supreme Court of
the United States probably will run head-on into Herman Eugene Talmadge,
advocate supreme of 'white supremacy.'" The article continued to emphasize
Talmadge's positioning, reporting that he "inherited his devotion to 'white
supremacy' from his father." Furthermore, the article informed its audience
that Talmadge referred to blacks as "hordes" (p. 9A).
Another way in which the subordinate frame is reified is in reference to
black teachers: A September 8, 1954 Daily Capital editorial's lead read:
"Are the parents of white children in the North prepared to accept an
influx of black teachers to take over many of the classrooms hitherto
occupied by white teachers?" (p. 4). It also asked its white readers if
they could accept "more and more Negro teachers in classrooms where white
children predominate" (p. 4). In this way, it suggests inequality, while at
the same time, suggests that their white readers have a measure of control
to determine the outcome for blacks. It further suggests that the quality
of teaching would be undermined if black teachers were allowed to teach
white children. Additionally, while the headline, "Anti-Negro School
Measure Approved," is clearly resistance, imbedded in that frame is the
issue of subordination, for the lead says, "Negroes could be 'humbled' into
accepting continued segregation" (September 15, 1954, p. 6). Also, the
subordinate frame is laced with threats in the previous headline, as well
as in this lead, which reads in part: "white people [would] put 'great
economic strain on [the] Negro race'" (p. 6).
The Topeka Daily Capital engaged the subordination frame again when it
reported on the school board meeting September 26, 1954: ". . . our board
will proceed on the assumption that the majority of people in Topeka will
not want to employ Negro teachers next year for white children" (p. 25A).
Also, it reported the progress of one of its first-class cities: "Atchison,
foremost pro-slavery hotbed during the days of "Bleeding Kansas," opened
its doors this fall with a Negro, teaching all white classes" (p. 25A).
In both the Daily Capital and the Plaindealer, the inferiority frame is
pervasive, perhaps because the NAACP Legal Defense team used as legal
strategy the Clark doll study as evidence that black children experience
"inferiority" complexes because they were denied the opportunity to mix
with white children. Inferiority was manifested in news content in several
ways: "Chief Justice Earl Warren said, 'Segregation generates in the hearts
and minds of children feelings of inferiority'" (Plaindealer, May 21, 1954,
p. 1). In the same article, Chief Justice Roger Taney (Dred Scott decision
of 1857) was cited: "Negroes have no rights the white man had to respect."
Other examples from this same issue included: "Negro schools (colleges)
need funds from whites to survive;" "Segregation inflicted psychological
injury on pupils;" and the local NAACP assertion that "denial of freedom of
equality has plagued our self-respect and our very existence" (May 21,
1954, p. 7). These examples imply that blacks were dependent upon and
inferior to the "mainstream" white race.
Three salient frames emerged from the study of two Topeka newspapers, one
mainstream and one black press. Conflict, consequences and
dominant/subordinate frames were used to frame public discourse about
desegregation in 1953 and 1954. They told their readers what to think and
how to think about desegregation. For the most part, readers were told to
think about conflict. Subsumed under the conflict frame were the attributes
of protest, resistance, and compliance.
Protest and resistance were most often engaged in the Topeka Daily Capital,
employed to emphasize the struggle to maintain the status quo. The actions
suggested (through the coverage of outspoken, resistant white Southern
leaders) to show white resistance to the desegregation decision were
two-fold: to dismantle public schools altogether and to provide funding for
individual students or for private entities to run public schools, a notion
eerily similar to the current calls for school voucher systems and funding
of charter schools.
While the Plaindealer also used the conflict frame, it was used to show
opposition within group: The black community held different views on public
school options for its students. Compliance was another attribute used
most often in the Plaindealer, for it appears that the paper sided with the
NAACP's strategies for desegregation.
Interestingly, the Topeka Daily Capital, in late summer of 1953, in
anticipating the decision of the Court, began running stories that
suggested compliance; however, there were alternate frames of resistances
imbedded within these news articles. That is, each story that discussed
compliance also reported resistance. This implies that though Topekans and
the state of Kansas would comply with the Court's ruling, the coverage of
the protests that abounded throughout the nation was not only
sensationalism that gained reader interest, but also a reassurance to
Kansans: By complying, they were "good" citizens.
The consequences frame as utilized in the mainstream Daily Capital
reassured white readers that even though their way of life was being
threatened, social order would still be maintained, for the real losers in
the battle over desegregation were black teachers and black students. The
consequence frame was also used as a way to brace white readers for the
potential long term changes that could occur once the desegregation door
was opened. This frame served as a warning to readers so that they would
have time to prepare themselves for whatever would come next, and thus,
social order could be maintained in the end. For the Plaindealer, however,
the consequences frame highlighted the fate of black teachers and the
potential for a lack of funding for historically-black colleges. Though
such consequences were obviously devastating, in the long run, the legal
mandate for desegregation of the public schools was viewed as a significant
victory over Jim Crow.
There was clearly a difference in how the dominant and subordinate frame
played in the two papers. In the mainstream paper, control was the device
used to show that it had power to hire and fire teachers and to define
black identity. In the black newspaper, there was an acceptance that blacks
were under the control of the white power structure, because notions of
inferiority continued to be perpetuated.
The nature of society in 1953/54 influenced the dominant/subordinate frame,
but there is also the possibility that the nature of the NAACP's
socio-psychological evidence further perpetuated the notion of inferiority
and superiority. Also prominent in the Brown case was the fact that Plessy,
which established Jim Crow, was decided based upon the precedent set in the
1857 Dred Scott decision. Thus, the legal definition of separate but equal
had a long history, a tradition that would prove to be difficult, but not
impossible, to rupture.
This study shows how public school desegregation policy was framed in two
Kansas newspapers in the year before and after the United States Supreme
Court decided Brown and explored how its subsequent policy implications
still resonate today. The reform measures made in opposition to
desegregation have survived for nearly 50 years and are now framed as
public education policy measures aimed to assist disadvantaged students
acquire improved educational access.
The limitations of this study are that it considers only one of two
mainstream daily newspapers in Topeka and it was compared to only one of
the weekly black press paper for only a two-year period. While this study
included AP and UPI, and other wire stories, the majority of the coverage
only refers to the one community, Topeka, in Kansas not to coverage of the
state or the nation.
We would suggest examining other newspaper coverage of Brown, particularly
in areas in which school desegregation cases were being fought and
comparing that coverage to the newspapers of record, the New York Times and
the Washington Post. In addition, as Reese (2001) suggests, comparison to
other sources of data about this issue may be instructive.
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