Raney v. Board of Education of Gould School District
Headline: Justices reject a 'freedom-of-choice' plan as inadequate to desegregate a small Arkansas school district, reverse lower-court dismissals, and order the board to adopt realistic steps to end separate white and Black schools.
Holding: The Court held that the school board’s 'freedom-of-choice' plan was inadequate to dismantle a racially segregated system, reversed the lower courts’ dismissals, and remanded so a new, realistic desegregation plan can be adopted.
- Forces the school board to create a new plan to desegregate schools promptly.
- May require new attendance zones or reassigning school uses to mix students.
- Keeps federal court supervision in place until desegregation is achieved.
Summary
Background
A group of Black children (16 named plaintiffs and others) sued the local school board in Gould, Arkansas, challenging a racially segregated public school system. The district covers 80 square miles with about 3,000 people (1,800 Black and 1,200 white). There are two combined elementary and high school complexes ten blocks apart: the Gould Schools (almost all white) and the Field Schools (all Black). The board adopted a 1965 “freedom-of-choice” plan so pupils could annually choose between the two schools. In practice no white children chose Field, only 80–85 Black children attended Gould by 1967, and over 85% of Black children still attended the Field Schools. When the board refused enrollment to some Black applicants for certain grades, the children sued for relief including changes to where new school construction should be located.
Reasoning
The central question was whether a freedom-of-choice plan satisfied the board’s duty to eliminate a segregated school system. Relying on the Court’s decision in a companion case, the Court concluded the plan was inadequate: it left a dual system in place and shifted the burden of desegregation onto children and parents instead of the board. The Supreme Court held the District Court erred in dismissing the suit and rejected the Court of Appeals’ affirmance, reversed those rulings, and remanded so the board must adopt a realistic, effective plan (for example zoning or other steps) to convert promptly to a nonracial school system.
Real world impact
The ruling requires the local board to propose and implement concrete changes to end the separate white and Black schools and keeps federal court oversight available while those changes are made. Because the case is sent back to the district court, further hearings will decide exact remedies, so the outcome is not yet a final, single solution for how the schools will be reorganized.
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