A Publisher and a Plaintiff: Carl Murphy and Donald Gaines Murray

Two of the essays on this site take a single subject and hold to it. Brian Hill writes about Carl Murphy and the newspaper his father founded. Arkeema Reid writes about Donald Gaines Murray and the case that opened the University of Maryland law school to him. The two men crossed paths in the record: both were graduates of Frederick Douglass High School, and when Murray won, it was Murphy's paper that printed the editorial calling the university a school for white people only. They also suit two different kinds of writing. A publisher who ran a newspaper for thirty-five years is a subject for a biographical essay. A lawsuit decided by the Court of Appeals of Maryland is a subject for a case brief. This note looks at what the archive supplies for each, and where the two forms part company.

Carl Murphy: the facts the archive holds

The essay on Murphy and the Afro-American opens with the father. John Murphy, Sr. had been enslaved and gained his freedom in 1863; in 1892 he bought a newspaper for $200 and set it up as a print shop. His son Carl, a graduate of Douglass, Howard and Harvard, took over in 1922 after John's death and led the paper until his own death in 1957. Under him, the essay says, the Afro became one of the largest-circulating and most influential Black newspapers in the country, and each edition carried seven principles under the heading "What the Afro Stands For," among them Black police officers and firemen, Black representatives on boards of education, and equal pay for teachers regardless of color or sex.

The essay then shows the principles in action. In mid-1942 the paper ran a feature called "Nazi of the Week," equating those who denied Black citizens their rights with supporters of Hitler. With Lillie Jackson and the NAACP, the Afro backed suits against Maryland's race-based teacher salary scales, winning first in Montgomery County and filing in five more counties until the state removed the words "colored" and "white" from the law. And in the 1930s it covered the Eastern Shore lynchings in a way the Sun did not, running a front-page interview with George Armwood's mother and a photograph of Matthew Williams's sister. Other pages on this site add to the portrait. The March to Annapolis of April 23, 1942 was organized by Lillie May Jackson and Murphy, who publicized it in the paper, and the two were its lead speakers. The Douglass High School essay lists him among alumni who include Thurgood Marshall and Juanita Jackson Mitchell.

Shaping a biographical piece

A biography is not a list of everything known about a person. It is an argument about what the person was for, told through what they did. Here the argument is almost given: Carl Murphy used a newspaper as an instrument of civil rights, and the seven principles are the program he set himself. A writer could take those principles as a spine, pairing each with an episode. The teacher salary suits answer the third principle. The 1942 march and the "Nazi of the Week" feature answer the paper's broader claim to fight prejudice. The lynching coverage answers a principle that is not on the list but runs under all of them: that Black readers deserved to be reported on as people. Guidance on how to write a biographical essay describes this method, picking a controlling idea and then selecting the events that test it, and it fits Murphy's record well.

I measure a newspaper not in buildings, equipment and employees-those are trimmings. A newspaper succeeds because its management believes in itself, in God and in the present generation.

Two cautions apply, and both come from reading the essay closely. First, the most quotable passage on the page is not Carl's. The letter quoted above was written by John Murphy to his children, and a biographer of the son must say so. Second, the essay's own sources set the limits of what can be claimed. Its endnotes rest on a Pratt Library vertical file, a 2007 obituary, Sandy Shoemaker's 1994 article in Maryland Historical Magazine, and Sherrilyn Ifill's book on the lynchings. Those will support a portrait of Murphy as publisher and campaigner. They will not support claims about his private life, his temperament or his motives beyond what he printed, and a careful piece leaves those alone rather than filling the gap with invention.

Donald Gaines Murray: the facts of the case

The essay on Murray gives the facts a brief needs in roughly the order a brief uses them. Murray was born in Philadelphia, raised in Baltimore by his grandparents, and graduated from Douglass and then from Amherst College. In December 1934 he wrote to the dean of the University of Maryland's law school asking to be admitted. The refusal came from the university's president, R. A. Pearson, who suggested he attend the Princess Anne Academy, a separate institution for Black students that offered no legal training. The law school had graduated two Black students in 1889 and then excluded Black applicants; it had been private until 1920 and was by 1934 a state institution supported by taxpayers.

Murray could not afford a fight alone, and the NAACP took the case. According to the essay, Thurgood Marshall, counsel for the Maryland branch, introduced the argument in Baltimore City Court on June 18, 1935 before Judge Eugene O'Dunne, and Charles Hamilton Houston, the association's special counsel, argued it. They won because, as the essay puts it, the state had no provision for establishing another law school equal to the University of Maryland's. On January 15, 1936 the Court of Appeals of Maryland upheld O'Dunne's decision. The case is reported as Murray v. Pearson, the Pearson of the title being the university president who had signed the refusal. The Afro's editorial afterwards said the university had considered itself "a university for white people only" while taking more than a million dollars of public money every two years.

Writing the case brief: facts, question, holding, significance

A case brief is deliberately spare. It states the facts in a paragraph, poses the legal question in one sentence, gives the court's answer, summarizes the reasoning, and ends with why the decision matters. For Murray, the facts are above. The question is whether a state that operates one public law school and admits only white students may exclude a qualified Black applicant while offering him no equal alternative within the state. The holding is that it may not, and that the remedy is admission: O'Dunne ordered the university to admit Murray, and the Court of Appeals affirmed. The reasoning turns on the word "equal." Whatever the rule of Plessy v. Ferguson permitted in theory, it required an actual equal facility, and Maryland had none. An academy on the Eastern Shore with no law course was not one. A guide to writing a legal case brief sets out these parts in the same order, and it is worth following that order strictly, because the discipline of separating the question from the holding is what keeps a brief from drifting into narrative.

Significance is the section students most often get wrong, usually by claiming too much. Murray v. Pearson was decided by a state court, so it bound Maryland and no one else; it did not overturn Plessy, and the opinion worked within the separate-but-equal framework rather than rejecting it. Its importance is as a first step. It was an early NAACP courtroom victory in the campaign against segregated graduate and professional schools, a campaign Houston helped direct and that Marshall carried on through Missouri ex rel. Gaines v. Canada in 1938 to Brown v. Board of Education in 1954. Marshall himself, a Baltimore native and Douglass graduate, had gone to Howard for his law degree because Maryland's school did not admit Black students. Murray went on to graduate from the law school and practiced in Baltimore. A good brief says all of this in a few sentences and resists the temptation to make the case larger than the court made it.

Keeping the two forms apart

The biography and the brief draw on the same shelf of sources, and the subjects overlap more than once. Both men went to Douglass. The paper Murphy ran reported the case, and the timeline on this site lists both the 1936 ruling and the founding of the Afro in 1892 among its Baltimore entries. But the forms ask for different things. A biographical essay has room for judgment and for voice; it can say that the Afro's coverage of the lynchings was braver than the Sun's and defend the claim. A brief has no room for either. It records what a court decided and why, and leaves the reader to form a view.

What both forms share is their dependence on the students' endnotes. Hill cites Shoemaker for the paper's principles and standing and Ifill for the lynching coverage; Reid cites David Bogen's 1989 article, two 1986 obituaries from the Pratt files, and the Maryland State Archives for the December 14, 1934 letter from the president's office. A writer who takes either subject further should begin with those citations, confirm them, and only then add. The archive gives the skeleton of each piece. The sources behind it give the permission to write.

Questions

Also at the Research Desk: Researching Maryland Civil Rights History from This Archive · From a School Project to a College Essay