him, just to have him disappear." Lavergne has noted that the Gaines ruling by the US Supreme Court "[made] constitutional compliance in the absence of integration difficult to achieve," even though the issue was not forced at the Missouri Supreme Court, and the separate but equal doctrine was not directly challenged. He cited three aspects of the Supreme Court decision to this point: First, the Court held that Gaines's right was "a personal and individual one." Gaines was entitled to go to law school regardless of how little demand there was in Missouri by African Americans for legal education. Second, the state could not meet its constitutional burden by sending students out of state. "With Gaines, the idea of using out-of-state scholarships to meet the test of separate but equal legally ended forever and everywhere in the United States," Lavergne says. Third, "the Court said that the promise of future equality ... did not make temporary discrimination constitutional." Houston had hoped the effect of similar court rulings giving segregationist states a choice between full integration or duplication of programs for students of different races would lead many of them to choose the less expensive former option. But without Gaines, he could not carry through the next stage of his plan in the Missouri Supreme Court. In the short term, the abrupt dismissal of the case forced by Gaines's disappearance was a setback for efforts to legally challenge segregation. After having spent $25,000 ($ in current dollars) on the case, the NAACP had no money left. It could not support new plaintiffs, who were already difficult to find in the depressed economy. By the mid-1950s, the state closed Lincoln University School of Law, the only tangible result of the case, due to lack of students. Houston was ill with the tuberculosis that would end his life a decade later. He resigned from the NAACP to return to private practice; Thurgood Marshall took over for him. In the first five years after the war, the NAACP found more plaintiffs and challenged segregationist policies in public graduate schools with cases such as Sipuel v. Board of Regents of Univ. of Okla., Sweatt v. Painter, and McLaurin v. Oklahoma State Regents. The University of Missouri School of Law, bowing to pressure from the student body, finally admitted its first African-American student in 1951. Three years later the desegregation effort climaxed with Brown, overturning Plessy