Was the disappearance of Gaines a result of his lawsuit and subsequent victory against the University of Missouri? We may never know the answers.
Lloyd Lionel Gaines, born in 1911 — disappeared March 19, 1939
Gaines was born in Water Valley, Mississippi. In 1926, He and his family moved to St. Louis, Missouri after his father died. In school, he performed well and was a top student at Vashon High School. He earned a Bachelor's degree in history from Lincoln University in 1935, which was Missouri's segregated undergraduate school for black students. He was also a member of the Alpha Phi Alpha fraternity and president of his class.
Gaines applied to the only law school in Missouri at the time. His application was denied because it was "contrary to the constitution, laws and public policy of the state" for the University of Missouri to admit a Negro. At that time, Missouri’s Constitution called for separate education of the races. This certainly is not the case today. The university did offer to pay his tuition to universities in other states such as Kansas, Nebraska, Iowa, or Illinois.
Gaines was refused admission by the Registrar at its Law School, Silas Woodson Canada. The decision was based on his skin color. Gaines believed it violated his Fourteenth Amendment rights.
Gaines turned down the State of Missouri’s offer to pay his tuition at another state’s law school that had no racial restrictions. With the help of the NAACP, he sued the university in 1936. The question was, did Missouri violate the Equal Protection Clause of the Fourteenth Amendment? The initial trial was held in Columbia, Missouri (Boone County). Gaines' appeal wouldn't reach the United States Supreme Court for three years.
The lawsuit
Gaines was a plaintiff in an important case tied to a civil rights action in 1938, entitled Missouri ex rel. Gaines v. Canada, 305 U.S. 337 (1938). Ultimately, the United States Supreme Court decision held that a school providing white students an in-state education had to do the same for black students too. States could meet this requirement, or they could build a second school for black students.
The case helped forge the legal framework for the U.S. Supreme Court’s landmark 1954 decision, Brown v. Board of Education, which banned segregation in public schools. (Source.)
Ultimately, the Supreme Court ruled in Gaines’ favor. He had to either be admitted to the University of Missouri or the state had to set up a separate law school for black students. The Missouri General Assembly decided on the second option. The Lincoln University School of Law was established which housed mostly black students.
In early 1939, Missouri legislators proposed a bill to provide Lincoln University with $275,000 to establish a black law school. The bill was signed into law in the spring and the law school opened in the fall. Of the 30 students who showed up for classes, Gaines wasn’t one of them.
Gaines’ NAACP attorneys had planned to argue that Lincoln Law School wasn’t equal to the University of Missouri’s program. In October 1939, the attorneys started taking depositions and realized that nobody had heard from Gaines in months.
The disappearance of Gaines is still a mystery
Before classes were to begin Gaines was traveling from St. Louis to Kansas City and on to Chicago looking for work. Gaines told an acquaintance he intended to spend a few days in Chicago and return to St. Louis.
He performed odd jobs and also gave speeches to local NAACP chapters. While in Chicago, he was staying at a fraternity house. He left one evening to buy stamps and never came back.
Efforts were made to locate him. Photographs were published in newspapers across the country to no avail. There was speculation concerning his whereabouts ranging from sightings in Mexico to reports of his death. Gaines was last seen leaving a fraternity house in Chicago.
Due to Gaines usually traveling alone without sharing his plans, his absence wasn’t immediately apparent. In 1939, when lawyers for the NAACP couldn’t locate him for the taking of depositions in a state court rehearing, that’s when his absence became more significant. The lawsuit associated with that matter was later dismissed since Gaines couldn’t be located.
Family members believed that since he won the Supreme Court case three months earlier, that foul play could have been involved. Others thought maybe he grew tired of his role in the civil rights movement and moved to start over somewhere else like Mexico City or New York. He was only 28.
Visit here to read the 2007 article, FBI Asked To Reopen Lloyd Gaines Case. KBIA, the National Public Radio member station in Columbia, Missouri reported in 2018 that since there wasn’t a body, the FBI and Department of Justice never performed a formal investigation. Requests for investigation were made, and some pursued their own investigations.
University of Missouri
Eventually, despite all the unknown circumstances surrounding the whereabouts of Gaines, the University of Missouri’s School of Law honored him.
In 2006, the Law School awarded Lloyd Gaines an honorary degree, and the Missouri Supreme Court issued him a posthumous law license.
Visit here to view the 2012 Mizzou Law Black Law Students Association Commemorative Video: Lloyd L. Gaines. In 2015, it was reported by the Columbia Missourian, that a portrait of Gaines was hung in the lobby of the Gaines/Oldham Black Culture Center, which was named in his honor and that of Marian O’Fallon Oldham who had also been denied admittance to the university. Oldham’s portrait is alongside that of Gaines.
The Black Culture Center having been established in 1972 added the names of Lloyd L. Gaines and Marian O’Fallon Oldham (1927–1994) to its name in 2000 since they pioneered civil rights at the University of Missouri. Oldham later served on the University of Missouri Board of Curators.
Visit here to read and browse the Lloyd L. Gaines Digital Collection at the University of Missouri. It’s both extensive and interesting. While his disappearance remains a cold mystery, his memory continues to be lifted.
Thanks for reading.
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