An additional reason for the inconclusive nature of the Amendment’s history, with respect to segregated schools, is the status of public education at that time.[5] In the South, the movement toward free common schools, supported by general taxation, had not yet taken hold. Education of white children was largely in the hands of private groups. Education of Negroes was almost non-existent, and practically all of the race were illiterate. In fact, any education of Negroes was forbidden by law in some states. Today, in contrast, many Negroes have achieved outstanding success in the arts and sciences as well as in the business and professional world. It is true that public school education at the time of the Amendment had advanced further in the North, but the effect of the Amendment on Northern States was generally ignored in the congressional debates. Even in the North, the conditions of public education did not approximate those existing today. The curriculum was usually rudimentary; ungraded schools were common in rural areas; the school term was but three months a year in many states; and compulsory school attendance was virtually unknown. As a consequence, it is not surprising that there should be so little in the history of the Fourteenth Amendment relating to its intended effect on public education. In the first cases in this Court construing the Fourteenth Amendment, decided shortly after its adoption, the Court interpreted it as proscribing all state-imposed discriminations against the Negro race.[6] The doctrine of “separate but equal” did not make its appearance in this Court until 1896 in the case of _Plessy_ v. _Ferguson_, _supra_, involving not education but transportation.[7] American courts have since labored with the doctrine for over half a century. In this Court, there have been six cases involving the “separate but equal” doctrine in the field of public education.[8] In _Cumming_ v. _County Board of Education_, 175 U. S. 528, and _Gong Lum_ v. _Rice_, 275 U. S. 78, the validity of the doctrine itself was not challenged.[9] In more recent cases, all on the graduate-school level, inequality was found in that specific benefits enjoyed by white students were denied to Negro students of the same educational qualifications. _Missouri ex rel. Gaines_ v. _Canada_, 305 U. S. 337; _Sipuel_ v. _Oklahoma_, 332 U. S. 631; _Sweatt_ v. _Painter_, 339 U. S. 629; _McLaurin_ v. _Oklahoma State Regents_, 339 U. S. 637. In none of these cases was it necessary to re-examine the doctrine to grant relief to the Negro plaintiff. And in _Sweatt_ v. _Painter_, _supra_, the Court expressly reserved decision on the question whether _Plessy_ v. _Ferguson_ should be held inapplicable to public education.