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Washington v. Seattle School District No. 1

Supreme Court of the United States · 1982 · Constitutional Law

Constitutional LawEqual ProtectionPolitical Process DoctrineSchool DesegregationEqual Protection ClauseHunter v. EricksonLee v. Nyquistpolitical restructuring

Facts

Seattle School District No. 1 adopted the Seattle Plan, which used pairing, triading, attendance zones, and feeder patterns to reduce racial imbalance caused by segregated housing patterns. Opponents formed CiVIC and sponsored Initiative 350, which generally required students to attend the geographically nearest or next nearest school but preserved broad exceptions for many nonracial reasons while specifically barring key assignment methods used for desegregative busing. The District Court found that the initiative was carefully tailored to interfere only with desegregative busing, that almost all existing busing for nonracial reasons remained permitted, and that the measure would prevent or undermine integration efforts in Seattle, Tacoma, and Pasco. Washington law otherwise vested broad educational and student-assignment authority in local school boards.

Issue

Whether Washington's Initiative 350 violated the Equal Protection Clause by removing from local school boards the authority to order mandatory student assignments for racial integration, while leaving local control over most other student-assignment decisions and educational policies intact. More specifically, the question was whether the State impermissibly restructured the political process by singling out a racial issue for different and more burdensome treatment.

Rule

A State may generally restructure political decisionmaking on neutral principles, even if doing so makes favorable legislation harder to obtain for everyone. But the Equal Protection Clause is violated when the State allocates governmental power nonneutrally by using the racial nature of an issue to determine the decisionmaking process, thereby placing special burdens on racial minorities' ability to achieve legislation in their interest.

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

Ohio law ordinarily leaves student-assignment decisions to local school boards. After the Dayton board adopts a plan that redraws attendance zones to reduce racial isolation, voters pass a statewide initiative providing that any reassignment plan adopted for the purpose of reducing racial imbalance must be approved by the statewide electorate, while reassignment plans for overcrowding, safety, language programs, and special education remain fully within local control.

Under the majority's rule, is the initiative constitutional?

Explanation. The measure likely violates equal protection under the political process doctrine. The majority held that a State may not use the racial nature of an issue to restructure decisionmaking in a way that places special burdens on minorities' ability to obtain beneficial legislation. Here, authority over desegregative assignments alone is moved from the local board to a more remote statewide forum, while similar nonracial assignment issues remain locally controlled. Facial neutrality does not save a law whose practical operation is carefully tailored to affect only race-related integration efforts, and the doctrine does not require proof of each voter's subjective bias.