Board of Educ. v. Dowell

498 U.S. 237



Injunctions entered in school desegregation cases are not intended to operate in perpetuity. Local control over the education of children allows citizens to participate in decisionmaking, and allows innovation so that school programs can fit local needs.


Several black students and their parents brought suit in 1961 in the United States District Court for the Western District of Oklahoma against the board of education of Oklahoma City, and sought to end alleged, de jure segregation of the city's public schools. Petitioner school board sought dissolution of a decree of desegregation of its schools. The lower court agreed that the court-ordered desegregation should end, but the dissolution was reversed on appeal.


Was the school board operating in compliance with the 1977 order?




Order reversing dissolution of desegregation decree was reversed and remanded for determination of whether petitioner had complied with decree in good faith and whether vestiges of past discrimination had been eliminated to the extent practicable. The Court held that desegregation injunctions were not intended to operate in perpetuity. A desegregation decree could be dissolved after local authorities had operated in compliance with it for a reasonable period of time as a federal court's regulatory control of a school system was not to extend beyond the time required to remedy the effects of past discrimination. In deciding whether to dissolve the decree, good faith compliance with the desegregation decree and a determination of whether the vestiges of past discrimination had been eliminated to the extent practicable were relevant inquiries.

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