Can We Please Stop Saying the Brown Case Was Atextual?

My constitutional law casebook says that Chief Justice Earl Warren's opinion in Brown v. Board of Education ""relied on neither the text nor the "inconclusive" original intent of the Fourteenth Amendment." The latter is certainly true. The former is, I think, pretty clearly false. They suggest that emphasis was placed on sociological inquiries, such as whether segregation as such created a feeling of inferiority among black schoolchildren. Well, yes. Because the thing about the Equal Protection Clause is that, perhaps more than with any other provision of the Constitution, you need to know what's actually going on in order to know how to apply it. Consider the following passage from Brown:

"We conclude that in the field of public education the doctrine of "separate but equal" has no place. Separate educational facilities are inherently unequal. Therefore, we hold that the plaintiffs and others similarly situated for whom the actions have been brought are, by reasons of the segregation complained of, deprived of the equal protection of the laws guaranteed by the Fourteenth Amendment."

That strikes me as pretty direct textual analysis. Segregated schools are inherently unequal; therefore, their creation by law constitutes a denial of the equal protection of the laws, which as the Fourteenth Amendment states in so many words no state may do to any person within its jurisdiction. Case closed, relying only on very literally the exact words of the Amendment in question. The only sticking-point is the factual one, i.e. the claim that separate educational facilities are inherently unequal. Now, you could argue some sort of formalistic test, sort of like the one the Plessy Court used, and say, "look, the law says to both whites and blacks that they cannot attend schools with students from the other race." Or you could do what the Brown Court does, and actually notice the thing where the whole frickin' point of segregation is to keep the black race in a state of inferiority, and that school segregation is arguably the linch-pin of that system. But that choice is not about textualism! In either case you are merely trying to determine whether what's going on in these cases is a denial of the equal protection of the laws, and honestly, once you notice the social facts of Jim Crow, it's just about the world's most straight-forward application of that language.

Now, Plessy is staggeringly atextual, basically saying that of course the Fourteenth Amendment doesn't prohibit segregation, everyone liked segregation just before it was passed and who can suppose they meant to actually change anything? (That's also ahistorical, as anyone who knows anything about the 1860s in this country should know.) This is one of the weird things about originalists, that they claim to be all about the text but when push comes to shove they're always keen to incorporate into the so-called text all the little ways that the country failed to live up to the text right after it was written. But as someone who just happens to share my last name said fifty-three years ago (on the first page of the article no less!), it's obvious that the phrase "no state shall...deny to any person within its jurisdiction the equal protection of the laws" forbids what the Southern states were doing to black people circa 1954, very much including school segregation. Warren spends most of his time establishing that there is real equality here because the Court had previously used the formalist standard to deny that this was so, and Warren needed to give good reason for not following their lead, and because he knew that "if equality then violation" was the most iron-clad inference from the plain text of the Fourteenth Amendment possible.