Law School Case Brief
Missouri v. Jenkins - 495 U.S. 33, 110 S. Ct. 1651 (1990)
Remedial powers of an equity court must be adequate to the task, but they are not unlimited, and one of the most important considerations governing the exercise of equitable power is a proper respect for the integrity and function of local government institutions. Especially where those institutions are ready, willing, and - but for the operation of state law curtailing their powers - able to remedy the deprivation of constitutional rights themselves.
In an action under 42 U.S.C. § 1983, the District Court found that the Kansas City, Missouri, School District (KCMSD) and petitioner State had operated a segregated school system within the KCMSD. The court issued an order detailing a desegregation remedy and the financing necessary to implement it. The State was then ordered to increase the property taxes to pay for costs of desegregating KCMSD. The appellate court affirmed the order with some modifications. Petitioner then challenged the court’s authority to impose taxes under U.S. Const. art. III, U.S. Const. amend. X, and principles of federal/state comity.
Did the federal district court have the authority to impose the tax increase?
The Court held that the district court abused its discretion in imposing the tax increase, which contravened the principles of comity. While a district court should not grant local government carte blanche, local officials should at least have the opportunity to devise their own solutions to such problems. In the present case, KCMSD was ready, willing, and, but for the operation of state law, able to remedy the deprivation of constitutional rights itself.
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