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Pasadena City Board of Education v. Spangler

Supreme Court of the United States · 1976 · Constitutional Law

Constitutional LawSchool DesegregationEquitable ReliefMootnessFourteenth Amendmentschool desegregationunitary systemattendance zones

Facts

Students and parents sued the Pasadena Unified School District alleging unconstitutional segregation, and the United States intervened. In 1970 the District Court found Fourteenth Amendment violations and ordered a desegregation plan requiring that by September 1970 no school in the district have a majority of any minority students; the court approved the Pasadena Plan, which initially achieved that result. In later years, however, demographic changes caused several schools to exceed 50% black enrollment, even though the approved plan had established a racially neutral assignment system. In 1974 the successor school board sought relief from the continuing "no majority of any minority" requirement, but the District Court refused and interpreted its decree to require ongoing annual adjustment of attendance zones.

Issue

Whether this case remained justiciable after the original student plaintiffs no longer had a personal stake, and whether the District Court could continue to require annual adjustment of school attendance zones to ensure that no school had a majority of minority students after a racially neutral assignment plan had been implemented and later demographic shifts were not shown to result from segregative acts of the school authorities.

Rule

The United States' intervention under 42 U.S.C. § 2000h-2 keeps a school desegregation case from becoming moot even when the original private plaintiffs' claims have become moot. A district court may impose an initial desegregation remedy for proven unconstitutional segregation, but once a racially neutral student assignment system has been implemented, the court may not require perpetual year-by-year attendance-zone readjustments to maintain a specified racial balance absent a showing that later racial imbalances were caused by segregative official action. Injunctions remain subject to modification when circumstances or governing law change.

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

Parents and students sued the River Glen School District in federal court in Oregon over unconstitutional school segregation. The United States intervened under 42 U.S.C. § 2000h-2, but years later all named students had graduated, no class had ever been certified, and the district argued the entire case was moot.

How should the federal court rule on mootness?

Explanation. The majority held that where the United States intervenes under 42 U.S.C. § 2000h-2, its continued participation can keep the controversy alive even though the original private plaintiffs' claims have become moot and no class was certified. The private plaintiffs alone would not preserve the case, but the United States' presence does.