 Houston and Marshall used "Murray v. Pearson" as the NAACP's first case to test Nathan Ross Margold's strategy to attack the 'separate but equal' doctrine using the equal protection clause of the Fourteenth Amendment to the U.S. Constitution.Margold concluded "such laws administering such a system were denying equal protection of law under the "Yick Wo v. Hopkins" ruling of 1886 and therefore were unconstitutional.At the circuit court hearing, Marshall stated that Maryland failed to provide a 'separate but equal' education for Murray as required by the Fourteenth Amendment (using the legal standard at that time).