Milliken v. Bradley
|Milliken v. Bradley
|Milliken v. Bradley on Wikipedia, the free encyclopedia.Milliken v. Bradley, 418 U.S. 717 (1974), was an important United States Supreme Court case dealing with the planned forced busing of public school students across district lines among 53 school districts in metropolitan Detroit. It concerned the plans to integrate public schools in the United States in the aftermath of the Brown v. Board of Education, 347 U.S. 483 (1954) decision. — Excerpted from|
Respondents brought this class action, alleging that the Detroit public school system is racially segregated as a result of the official policies and actions of petitioner state and city officials, and seeking implementation of a plan to eliminate the segregation and establish a unitary nonracial school system. The District Court, after concluding that various acts by the petitioner Detroit Board of Education had created and perpetuated school segregation in Detroit, and that the acts of the Board, as a subordinate entity of the State, were attributable to the State, ordered the Board to submit Detroit-only desegregation plans. The court also ordered the state officials to submit desegregation plans encompassing the three-county metropolitan area, despite the fact that the 85 outlying school districts in these three counties were not parties to the action and there was no claim that they had committed constitutional violations. Subsequently, outlying school districts were allowed to intervene, but were not permitted to assert any claim or defense on issues previously adjudicated or to reopen any issue previously decided, but were allowed merely to advise the court as to the propriety of a metropolitan plan and to submit any objections, modifications, or alternatives to any such plan. Thereafter, the District Court ruled that it was proper to consider metropolitan plans, that Detroit-only plans submitted by the Board and respondents were inadequate to accomplish desegregation, and that, therefore, it would seek a solution beyond the limits of the Detroit school District, and concluded that "[s]chool district lines are simply matters of political convenience, and may not be used to deny constitutional rights." Without having evidence that the suburban school districts had committed acts of de jure segregation, the court appointed a panel to submit a plan for the [p718] Detroit schools that would encompass an entire designated desegregation area consisting of 53 of the 85 suburban school districts plus Detroit, and ordered the Detroit Board to acquire at least 295 school buses to provide transportation under an interim plan to be developed for the 1972-1973 school year. The Court of Appeals, affirming in part, held that the record supported the District Court's finding as to the constitutional violations committed by the Detroit Board and the state officials; that, therefore, the District Court was authorized and required to take effective measures to desegregate the Detroit school system; and that a metropolitan area plan embracing the 53 outlying districts was the only feasible solution and was within the District Court's equity powers. But the court remanded so that all suburban school districts that might be affected by a metropolitan remedy could be made parties and have an opportunity to be heard as to the scope and implementation of such a remedy, and vacated the order as to the bus acquisitions, subject to its reimposition at an appropriate time.
Held: The relief ordered by the District Court and affirmed by the Court of Appeals was based upon erroneous standards, and was unsupported by record evidence that acts of the outlying districts had any impact on the discrimination found to exist in the Detroit schools. A federal court may not impose a multidistrict, area-wide remedy for single-district de jure school segregation violations where there is no finding that the other included school districts have failed to operate unitary school systems or have committed acts that effected segregation within the other districts, there is no claim or finding that the school district boundary lines were established with the purpose of fostering racial segregation, and there is no meaningful opportunity for the included neighboring school districts to present evidence or be heard on the propriety of a multidistrict remedy or on the question of constitutional violations by those districts. Pp. 737-753.
(a) The District Court erred in using as a standard the declared objective of development of a metropolitan area plan which, upon implementation, would leave "no school, grade or classroom . . . substantially disproportionate to the overall pupil racial composition" of the metropolitan area as a whole. The clear import of Swann v. Board of Education, 402 U.S. 1, is that desegregation, in the sense of dismantling a dual school system, does not require any particular racial balance. Pp. 739-741. [p719]
(b) While boundary lines may be bridged in circumstances where there has been a constitutional violation calling for inter-district relief, school district lines may not be casually ignored or treated as a mere administrative convenience; substantial local control of public education in this country is a deeply rooted tradition. Pp. 741-742.
(c) The inter-district remedy could extensively disrupt and alter the structure of public education in Michigan, since that remedy would require, in effect, consolidation of 54 independent school districts historically administered as separate governmental units into a vast new super school district, and, since — entirely apart from the logistical problems attending large-scale transportation of students — the consolidation would generate other problems in the administration, financing, and operation of this new school system. Pp. 742-743.
(d) From the scope of the inter-district plan itself, absent a complete restructuring of the Michigan school district laws, the District Court would become, first, a de facto "legislative authority" to resolve the complex operational problems involved, and thereafter a "school superintendent" for the entire area, a task which few, if any, judges are qualified to perform, and one which would deprive the people of local control of schools through elected school boards. Pp. 743-744.
(e) Before the boundaries of separate and autonomous school districts may be set aside by consolidating the separate units for remedial purposes or by imposing a cross-district remedy, it must be first shown that there has been a constitutional violation within one district that produces a significant segregative effect in another district; i.e., specifically, it must be shown that racially discriminatory acts of the state or local school districts, or of a single school district have been a substantial cause of inter-district segregation. Pp. 744-745.
(f) With no showing of significant violation by the 53 outlying school districts and no evidence of any inter-district violation or effect, the District Court transcended the original theory of the case as framed by the pleadings, and mandated a metropolitan area remedy the approval of which would impose on the outlying districts, not shown to have committed any constitutional violation, a standard not previously hinted at in any holding of this Court. P. 745.
(g) Assuming, arguendo, that the State was derivatively responsible for Detroit's segregated school conditions, it does not follow [p720] that an inter-district remedy is constitutionally justified or required, since there has been virtually no showing that either the State or any of the 85 outlying districts engaged in any activity that had a cross-district effect. Pp. 748-749.
(h) An isolated instance of a possible segregative effect as between two of the school districts involved would not justify the broad metropolitan-wide remedy contemplated, particularly since that remedy embraced 52 districts having no responsibility for the arrangement and potentially involved 503,000 pupils in addition to Detroit's 276,000 pupils. Pp. 749-750.
484 F.2d 215, reversed and remanded.
BURGER, C.J., delivered the opinion of the Court, in which STEWART, BLACKMUN, POWELL, and REHNQUIST, JJ., joined. STEWART, J., filed a concurring opinion, post, p. 753. DOUGLAS, J., filed a dissenting opinion, post, p. 757. WHITE, J., filed a dissenting opinion, in which DOUGLAS, BRENNAN, and MARSHALL, JJ., joined, post, p. 762. MARSHALL, J., filed a dissenting opinion, in which DOUGLAS, BRENNAN, and WHITE, JJ., joined, post, p. 781. [p721]