Separate but equal was about physical segregation of minorities, not just about using different legal terms for the same thing. And, by the way, something that a ton of people don't know about the separate but equal doctrine (because it doesn't appear to be taught in American public schools): It actually refers to the government's legal authority to mandate that privately owned businesses provide separate nut equal facilities for blacks. That's a lot different than the usual portrayal of Brown vs. BoE, as the government stepping in an conquering private racism.