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Belton (Bulah) v. Gebhart

In Delaware, this case was actually two cases that were heard as one. Filed by Sarah Bulah and Ethel Belton, the complaints addressed the lack of access to nearby white schools, which forced black children to endure long commutes. The Delaware Supreme Court affirmed that the plaintiffs were entitled to equal educational facilities immediately.

Belton (Bulah) v. Gebhart is one of the five cases consolidated into the landmark Supreme Court decision in Brown v. Board of Education. This case specifically addressed the issue of school segregation in Delaware and is notable for its unique outcome at the state level, which favorably ruled on the side of the plaintiffs prior to the involvement of the Supreme Court, providing a contrasting context to the other cases involved in Brown.


The case was brought forward by Ethel Louise Belton (Bulah) and six other parents on behalf of their children in Claymont, Delaware. It was filed in 1951, the same year as several other cases that would eventually be consolidated into Brown v. Board of Education. The parents, represented by attorney Louis L. Redding, Delaware’s first African American attorney, and backed by the NAACP, challenged the segregation of Delaware’s public schools. They argued that the black schools were inferior to the white schools and that their children were entitled to equal educational opportunities.

The Plaintiffs

The plaintiffs in the Belton case were part of a broader movement challenging segregation in public schools across several states. Ethel Louise Belton, and Sarah Bulah, who filed a similar petition, were concerned about the conditions of the segregated schools and the long distances their children had to travel to attend these schools, while white children had access to a nearby, better-equipped school.

Legal Strategy

The legal strategy for Belton (Bulah) v. Gebhart centered on proving the tangible inequalities between the black and white schools in terms of facilities, resources, and teacher qualifications. This strategy aligned with the NAACP’s broader goal to challenge the constitutionality of segregation by demonstrating that segregated facilities were inherently unequal.

Court Proceedings

The case was first heard in Delaware’s Court of Chancery, where Chancellor Collins J. Seitz found clear inequality in the educational facilities available to black and white students. In a departure from other states’ decisions, Seitz ruled that the plaintiffs were entitled to immediate relief and ordered the children to be admitted to the white schools. This decision was groundbreaking, as it was one of the only rulings at the state level that directly favored desegregation prior to the Supreme Court’s decision in Brown.

The state of Delaware appealed the decision, and the case was combined with another Delaware case, Gebhart v. Belton, as it went to the Supreme Court.

Supreme Court Decision

When reviewed by the Supreme Court as part of the consolidated Brown cases, Belton (Bulah) v. Gebhart contributed significantly to the overall context of the decision. The Delaware case provided a concrete example of a judicial acknowledgment of the inequality inherent in segregated schools and a precedent of a court mandating immediate desegregation.

Impact and Legacy

The Belton case is particularly important for its role in setting a judicial precedent that supported the NAACP’s arguments against segregation. The initial ruling by Chancellor Seitz that segregation was inherently unequal helped pave the way for the unanimous Supreme Court decision in Brown that “separate educational facilities are inherently unequal.”


Belton (Bulah) v. Gebhart, while often less highlighted than Brown v. Board of Education of Topeka, played a critical role in the desegregation of American public schools. Its outcomes at the state and national levels demonstrated the variability in judicial perspectives on segregation at the time and helped establish a critical foundation for the arguments that ultimately led to the end of legalized racial segregation in public education across the United States.

Wilmington, Delaware (Gebhart v. Belton)