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Freeman v. Pitts

Supreme Court of the United States · 1992 · Constitutional Law

Constitutional LawSchool DesegregationEqual ProtectionEquitable Remediesunitary statusincremental withdrawalpartial relinquishmentschool desegregation

Facts

DeKalb County School System had operated a de jure dual school system and came under federal court supervision in 1969 under a desegregation plan that closed former black schools and reassigned students to neighborhood schools. By 1986, the District Court found the system had achieved unitary status in student assignments, transportation, physical facilities, and extracurricular activities, but not in teacher and principal assignments, resource allocation, and quality of education. The record showed dramatic demographic changes between 1969 and 1986, including a rise in black student enrollment from 5.6% to 47% and significant residential shifts between the northern and southern parts of the county. The District Court found that these demographic shifts, not the school system's prior unconstitutional conduct, caused the existing racial imbalance in student assignments, and that DCSS had nevertheless taken steps such as boundary review, majority-to-minority transfers, and magnet programs to combat those effects.

Issue

May a federal district court relinquish supervision and control over discrete aspects of a school system in which a desegregation decree has been satisfied, even though other aspects remain noncompliant? Relatedly, did the court of appeals err by requiring continued systemwide supervision and racial balancing in student assignments until all Green factors were satisfied simultaneously for several years?

Rule

In supervising school desegregation decrees, a federal court has discretion to withdraw supervision incrementally in areas where the school district has achieved full and satisfactory compliance, while retaining jurisdiction over areas still requiring relief. In deciding whether partial withdrawal is proper, the court should consider whether there has been full and satisfactory compliance in the area at issue, whether continued control over that area is necessary or practicable to achieve compliance elsewhere, and whether the district has shown a good-faith commitment to the entire decree and to constitutional guarantees. The court may decline to order further remedies for student assignments when current racial imbalance is not traceable in a proximate way to the prior de jure violation but instead results from independent demographic forces.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

A federal court has supervised the Redstone Unified School District in Birmingham, Alabama, for 20 years after a finding that it once operated a de jure dual system. The district now shows full compliance in transportation, facilities, and extracurricular activities, but teacher assignments remain racially imbalanced and resource allocation issues persist.

If the district court finds the compliant areas are fully remedied, what is the best statement of its authority?

Explanation. The majority held that a federal court may relinquish supervision incrementally in discrete areas where the district has achieved compliance, while retaining jurisdiction and continuing oversight in areas still requiring relief. The Court rejected the rule that all Green factors must be satisfied at the same time for several years before any supervision may be withdrawn.