According to Charles Mills, he was.
I find the idea that racial tensions were actually thawing in the South prior to the Brown v. Board decision to be interesting,
On the other hand, I've heard it claimed that vagrancy laws were implemented in the postbellum period largely to re-enslave blacks. Whether or to what extent this was still true in the period immediately preceding the Brown decision I do not know, however. In any case, I suspect that Mills probably would underemphasize the role of such things, while traditional historical interpretation would overemphasize them, underemphasize progress that blacks were making prior to federal intervention, and overemphasize the positive impact on black civil rights that federal intervention had.
(This is, of course because the current zeitgeist is in favor of centralized intervention to secure their goals - federal when necessary, but preferably global).
That is all.