Morrill Act in 1890, 7 U.S.C. sec. 323 (1994), appropriating more funds for land grant colleges and requiring that they be divided 'equitably' between white and black colleges, Georgia established in 1891 the Georgia State Industrial College for Colored Youth in Savannah, but its all-white board of directors confined its curriculum to manual work. O'Brien said "until 1926, the college trained teachers for elementary schools, taught trades, and offered almost no post-secondary course work."
Until the 1960s, the controlling constitutional legal authority was the separate but equal doctrine enunciated by the Supreme Court in Plessy v. Ferguson, 163 U.S. 537 (1896). The first breakthrough for blacks in higher education was a case brought by the National Association for the Advancement of Colored People (NAACP) against the State of Missouri, Missouri ex rel. Gaines v. Canada, 305 U.S. 337 (1938), reh'g denied, 305 U.S. 676 (1939), in which the Supreme Court held that a black applicant was entitled to be admitted to the University of Missouri Law School bec
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