When Browder came down, it was recognized that, as a matter of law, the entire doctrine of separate but equal was overruled without being limited to the reasons stated in Brown: the special and particular problems of segregated education, circumstance B. Changing social and judicial perspectives had rendered circumstance B—the driving force for the Brown decision, the necessity of giving children a proper education—now immaterial to the overarching problem of racial discrimination.

Ruggero J. Aldisert, Agatha D. Aldisert, Logic for Lawyers- A Guide …, loc. 1296