Small letters as opposed to capital letters (upper case):the name may be typed in lower case[as modifier]:lower-case letters...
Of these we have given both the upper case and lower case versions of the 24 classical letters.
That author gave brown in lower case and Betty in upper case; and, in default of evidence to the contrary, it seems best to go along with the view that Betty is here a proper name.
Capital letters generally are larger than lower-case letters.
Origin
Referring originally to the lower of two cases of type positioned on an angled stand for use by a compositor (see upper case).