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Law School Case Brief

Keyes v. Sch. Dist. - 413 U.S. 189, 93 S. Ct. 2686 (1973)

Rule:

A finding of intentionally segregative school board actions in a meaningful portion of a school system creates a presumption that other segregated schooling within the system is not adventitious. It establishes a prima facie case of unlawful segregative design on the part of school authorities, and shifts to those authorities the burden of proving that other segregated schools within the system are not also the result of intentionally segregative actions. This is true even if it is determined that different areas of the school district should be viewed independently of each other. The school authorities' burden is to adduce proof sufficient to support a finding that segregative intent was not among the factors that motivated their actions.

Facts:

In a school desegregation case brought by parents of Denver school children in the United States District Court for the District of Colorado, the District Court found that, for almost a decade, the Denver school board had engaged in an unconstitutional policy of deliberate racial segregation with respect to schools in the Park Hill area in northeast Denver; that the parents had failed to make a fresh showing of de jure segregation in other areas of the city, where the situation was "more like de facto segregation"; and that the thus-segregated core city schools were educationally inferior to the predominantly white schools in other parts of Denver. The district court ordered desegregation of the Park Hill schools and implementation of a remedial plan, short of all-out desegregation but aimed at achieving "substantial equality" of educational opportunities, for the core city schools. The United States Court of Appeals for the Tenth Circuit affirmed as to the Park Hill schools but reversed as to the core city schools. The parents filed a petition for certiorari review.

Issue:

Was there an unlawful segregative design on the part of school authorities thereby creating a presumption that other segregated schooling within the system is not adventitious?

Answer:

Yes

Conclusion:

The Court held that both lower courts erred. The Court held that a finding of intentionally segregative school board actions in a meaningful portion of a school system created a presumption that other segregated schooling within the system was not adventitious. It established a prima facie case of unlawful segregative design on the part of school authorities, and shifted to those authorities the burden of proving that other segregated schools within the system were not also the result of intentionally segregative actions. This was true even if it was determined that different areas of the school district should be viewed independently of each other.

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