GAINES, LLOYD L. (1911–disappeared 19 March 1939), plaintiff in Missouri ex rel. Gaines v. Canada (1938), a groundbreaking civil-rights case that began to erode the legal pillars on which segregation in the Jim Crow South was based.
Born in Mississippi, where he received barely any schooling, Gaines moved with his mother to St. Louis in 1926 and entered the fifth grade at age fifteen. He excelled in his new environment and became active in the debate club and student government. He graduated from high school in 1931 and studied history, education, and English at Lincoln University in Jefferson, Missouri. There he also joined the ranks of the Junior NAACP.
Gaines’ longtime ambition was to attend law school, but he encountered a formidable barrier: the University of Missouri Law School was restricted to White students. As it happened, NAACP lawyer Charles Hamilton Houston was looking for a plaintiff for a case challenging Missouri’s Jim Crow laws. And so when Gaines applied and was denied admission on racial grounds in 1936 (the university’s board explaining that, though segregation was statewide policy, Gaines could attend an out-of-state law school at the state’s expense), Houston and the NAACP filed a petition against the State of Missouri, claiming that the law school’s refusal to admit Gaines, an otherwise qualified candidate, based on his race was a violation of his rights.
In the ensuing trial the judge ruled in favor of the state, whereupon Houston appealed to the Missouri Supreme Court, which upheld the decision. Houston then appealed to the United States Supreme Court, which ruled six to two in Gaines’ favor, ordering the State of Missouri to either admit Gaines to the law school or build another school with similar standing.
Though with Gaines v. Canada the court did not dismantle the “separate but equal” segregationist doctrine that had been enshrined since its 1896 decision Plessy v. Ferguson, the case did considerably complicate states’ efforts to institutionalize it. By requiring the State of Missouri either to integrate its existing institution or empty its coffers building a comparable new one, the court gave the lie to separate-but-equal and paved the way for Brown v. Board of Education (1954), which finally put an end to segregated public schools in the South.
Gaines attended graduate school in Michigan while the case dragged on and received a master’s degree in economics. He still hoped to attend law school at the University of Missouri pending a legal victory, but to comply with the ruling the State of Missouri chose to build a new law school for Black students in St. Louis rather than integrate the current one. The NAACP planned to continue to fight for Gaines’ right to attend the University of Missouri, arguing that the new institution would almost certainly be inferior. However, Gaines was increasingly ambivalent about his role as a poster child of racial progress and worried about the potential dangers of being a high-profile Black student in a white environment should he ever be admitted. He said he simply wanted to be “an ordinary man.”
Ultimately Gaines decided not to attend law school in Missouri and left St. Louis for Chicago in 1939, staying with old family friends, at a YMCA, and in a fraternity house. Then on March 19, less than a year after the Supreme Court ruling in his favor, he disappeared.
It took several months for word of Gaines’ disappearance to spread. Perhaps owing to a well-founded distrust of the police, his family did not file a missing-persons report. By August Houston had gone to Chicago looking for him, to no avail. The NAACP too tried frantically to find Gaines; without him it could not continue its case. Gaines’ photograph was published in newspapers around the country; rumors circulated that he had gone to Mexico, committed suicide, or been paid to disappear. FBI chief J. Edgar Hoover wrote privately that he did not believe the case fell under his agency’s jurisdiction. In 1940 the NAACP’s case was dismissed on the grounds that the plaintiff was absent.
In 1950 Ebony magazine renewed the search for Gaines but found little new information. Decades later, when the St. Louis Riverfront Times revisited his disappearance, reporter Chad Garrison found evidence to support the theory that Gaines had lived out the rest of his life in Mexico. Despite Gaines’ family’s initial willingness to accept this narrative, his great-niece Tracy Berry has publicly stated that she believes he was murdered.