Robert Carter, architect of Brown v. Board of Education decision, dead at 94

Judge Robert Carter, one of the NAACP lawyers responsible for winning the landmark Brown v Board of Education decision in 1954, has died at age 94:

The spotlight that favored Thurgood Marshall was often not expansive enough to include the contributions of Carter, who was seemingly without complaint as he labored so diligently and successfully in the shadows. It was his genius that figured so prominently in the victorious Brown v. Board of Education decision by the Supreme Court in 1954.


When Carter utilized the findings of the "Doll Test," developed by psychologists Kenneth and Mamie Clark, it was a daring and controversial strategy that proved pivotal in overturning the age-old Plessy v. Ferguson law. It ended the notion of "separate but equal"-which was never in any way equal, Carter contended.

"Some of the lawyers," Kenneth Clark said in a later interview, referring to Carter's colleagues, "felt the case should not be ‘contaminated' by psychological evidence. Other lawyers, particularly Robert Carter, argued that you couldn't overthrow [Plessy v. Ferguson] by just sticking to the law...you had to show that being segregated actually damaged children."

According to Clark, Carter felt that the test results were evidence of the damaging effect of segregation on children. Almost without exception, the Black children in the test selected white dolls as exemplifying goodness and Black dolls as bad.

In the end, Marshall agreed with Carter and they leaned on this evidence as a critical part of their argument before the Supreme Court.