Cooper v. Aaron
Citation and Court
358 U.S. 1 (1958). United States Supreme Court. Per curiam opinion signed individually by all nine Justices.
Facts
Following the Supreme Court’s landmark desegregation decisions in Brown v. Board of Education I (1954) and Brown II (1955), Arkansas Governor Orval Faubus ordered the National Guard to prevent Black students from entering Little Rock’s Central High School. President Eisenhower responded by federalizing the Guard and sending the 101st Airborne Division. The Little Rock School Board, citing the chaos and violence caused by state resistance, petitioned the federal district court for a two-and-a-half-year delay in implementing its desegregation plan. The district court granted the delay; the Eighth Circuit reversed.
Issue
May a state defer compliance with federal court desegregation orders on the ground that state officials oppose and are resisting the federal constitutional mandate?
Holding
No. State officials are bound by the Supreme Court’s constitutional interpretations. The Little Rock School Board could not be relieved of its duty to desegregate on account of the Governor’s obstruction.
Rule / Doctrine
Judicial Supremacy and Binding Effect of Constitutional Interpretations: Article VI of the Constitution makes federal law supreme, and Article III vests the judicial power in the federal courts. The Supreme Court’s interpretation of the Constitution in Marbury v. Madison and its progeny is the supreme law of the land, binding on all state officials under the Supremacy Clause and their oaths of office. State executives and legislatures have no power to nullify federal judicial interpretations of the Constitution.
Significance
Cooper v. Aaron is the most forceful judicial statement of federal judicial supremacy ever issued. The unusual unanimous per curiam opinion — signed individually by each Justice to emphasize personal commitment — was a direct rebuke of the Southern nullification doctrine. It affirmed that Brown was not merely advisory and that state resistance, however politically organized, could not delay constitutional compliance. The case remains a foundational authority on the binding force of Supreme Court decisions and the illegitimacy of state interposition.