Education as Property: Gong Lum v. Rice and Intersections of Chinese, Black, and Choctaw Education

• In Event: Race, Ethnicity, and Civil Law

Abstract

In 1924, Chinese students Martha and Berda Lum were barred from attending public school in Mississippi due to their status as non-white. Though facing their share of struggles, Asian children like the Lums appeared to integrate into Southern education systems while schools for Black and Indigenous children sustained strict hierarchies of race and civility. Yet, the subsequent Supreme Court ruling of Gong Lum v. Rice (1927) suggested otherwise, as it granted states the permission to decide who was “colored” or not. As such, this study illuminates Gong Lum v. Rice as a pivotal moment reflecting racial dynamics in education. By studying intertwined experiences of Chinese, Black, and Indigenous communities, I uncover how Chinese Americans perpetuated anti-Blackness and Indigenous erasure while facing subjugation themselves. I weigh the tensions between education as, on one hand, the hallmark of change and social mobility, and on the other hand, as a tool of colonization and oppression. My study presents two findings. First, I find that the argument of tax entitlement legitimized the rights of Chinese American students to pursue public education. Comparing media coverage, I conversely find that Indigenous and Black education were regarded as burdensome and undeserving, validating efforts to divest from their schools. Second, originally, racial triangulation concerns how those considered “in between” Black and White negotiate space and belonging. I expand the interrogation of Asian American identity on both Black-White and Native-Settler spectrums. In that manner, Gong Lum v. Rice attempted to position Chinese Americans on the White and Settler ends of the spectrum, utilizing their economic prosperity to justify educational inclusion and incorporation into America. As current rhetoric centering Chinese Americans in education features opposition to affirmative action for Black and Indigenous students, these findings trace the origins of this conflict to early battles for visibility and belonging.

Author

• Mia Xia, Johns Hopkins University