I was about to come here and see if anyone had mentioned this yet--thanks for beating me to the punch and for the kind nod. I wondered if there was any chance of arriving at the correct response via the route of Constitutional law scholarship. I suspected the chances of doing so might be miniscule, given that the Gayle v. Browder per curiam opinion was not exactly a landmark decision. (The entirety of the decision is as follows: "Per Curiam: The motion to affirm is granted and the judgment is affirmed. Brown v. Board of Education, 347 U.S. 483; Mayor and City Council of Baltimore v. Dawson, 350 U.S. 877; Holmes v. Atlanta, 350 U.S. 879.") I suspected even that the Browder case would not be found in my Con law textbook. But I was wrong. Here is what Kathleen Sullivan and Gerald Gunther have to say, in their notes on the meaning and implications of Brown v. Board of Education:georgespelvin wrote:Robert K S just posted this on Facebook but hasn't posted it here yet, so I will give him the well-deserved credit for uncovering this. The Supreme Court decision in question in FJ is a per curiam affirmance of the District Court decision in "Browder v. Gayle". The Supreme Court decision does not even have an opinion tied to it, it's a summary affirmance and the Supreme Court title for the affirmance is "Gayle v. Browder" (as Gayle appealed). If you are a lawyer by trade and training, that likely would get in the way of your 30 second analysis of the clue because (at least this was true in my case) you probably start thinking of actual historic Supreme Court opinions as opposed to the historical milieu in which it happened (at least not at first). I think that this makes the FJ much more difficult for lawyers and law students. It's a case (no pun intended) of too much knowledge.
Of course, this brief mention still would not necessarily lead the Con law scholar to Mrs. Parks and Montgomery, Alabama. But, at least, it cannot be said that the astute Con law student would not have even had the chance to see the names "Gayle" and "Browder" in his or her studies.Segregation in other public facilities. Soon after the 1954 decision in Brown, the Court found legally mandated segregation in public facilities unconstitutional in contexts other than education. Despite the Court's emphasis on the school context in Brown, its results in the later cases were reached in brief per curiam orders, most simply citing Brown. See, e.g., Mayor of Baltimore v. Dawson, 350 U.S. 877 (1955) (beaches); Gayle v. Browder, 352 U.S. 903 (1956) (buses); Holmes v. Atlanta, 350 U.S. 879 (1955) (golf courses); New Orleans City Park Improvement Association v. Detiege, 358 U.S. 54 (1958) (parks). Cf. Turner v. Memphis, 369 U.S. 350 (1962) (municipal airport restaurant). Not until Johnson v. Virginia, 373 U.S. 61 (1963), reversing a contempt conviction for refusal to comply with a state judge's order to move to a section of a courtroom reserved for blacks, did the Court state: "[It] is no longer open to question that a State may not constitutionally require segregation of public facilities."
Most law students take Con law in their second year of law school. I saved it for my fourth year, and took my final exam the same day this Final aired. I had probably near 1,000 Con law cases and holdings in my head when I saw this Final, and still could not arrive at the correct response. Given the 1950s date, I suspected the correct response had something to do with Brown and the per curiam decisions that followed, but there was no way that I was going to be able to connect it up specifically with the bus boycott.
This was, I think, one of the hardest Final Jeopardy! clues in many, many years. But that should go without saying when it stumps arguably the best champion of all time, an attorney, and a guy who wrote the book on being a Jeopardy! champion.