1938’s Missouri ex rel. Gaines v. Canada, requiring states either to provide their black students with separate (but “equal”) graduate and professional school programs or to allow them to integrate the white schools. Some states, like Virginia, simply refused to comply: in 1936, a black student from Richmond named Alice Jackson Houston applied to the University of Virginia to study French, but she was denied admission. The NAACP sued on her behalf, and in response, the state of Virginia set up a tuition reimbursement fund, subsidizing the graduate educations of black students in any place but
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