Before there was a Brown v. Board of Education, there was a complaint, and a young lawyer at the NAACP Legal Defense Fund wrote it. Her name was Constance Baker Motley.
She joined the Legal Defense Fund in 1946 as a staff attorney and stayed more than twenty years. In 1950 she drafted the original complaint in Brown. She argued ten civil rights cases before the United States Supreme Court and won nine. In 1962 she won James Meredith’s case and walked him into the University of Mississippi as its first Black student, and she was the first Black woman ever to argue at the Court.
Then she did what almost no litigator does. She went to the other side of the bench. New York State Senate in 1964. Manhattan Borough President in 1965. And in 1966, the United States District Court for the Southern District of New York, the first Black woman federal judge in the country. She ran that court as chief judge from 1982 to 1986.
What I take from Motley is not the history, though the history is enormous. It is the method. She tried cases in Southern courtrooms where the judge, the jury, and the sheriff were arrayed against her client and often against her. She could not win on charm. She won on the record. Every fact nailed down, every witness prepared, every document in the file before she stood up, so that the only way to rule against her was to ignore the law in writing. Preparation was her weapon because it was the one weapon nobody could take away.
That is the lesson for anyone who walks into a hostile room. You do not need the room to like you. You need the record to be so complete that the room has no honest way out.
Constance Baker Motley (1921 to 2005), attorney at the NAACP Legal Defense Fund (1946 to 1965), New York State Senator (1964), Manhattan Borough President (1965), United States District Judge for the Southern District of New York (1966 to 2005) and its chief judge (1982 to 1986).
