McDaniel v. Barresi
Headline: Court allows a Georgia school district to use race-conscious attendance zones and limited busing to desegregate elementary schools, overturning a state court block and letting the plan continue.
Holding: The Court reversed, holding that a local school board may consider students’ race when drawing attendance zones to dismantle a segregated system, and that Title IV does not bar such student assignments.
- Allows school boards to use race-conscious attendance zones to desegregate elementary schools.
- Permits limited busing of students from segregated neighborhoods to achieve racial balance.
- Affirms local authority to assign students as part of desegregation remedies.
Summary
Background
Parents of children in Clarke County, Georgia sued the local superintendent and school board after the board adopted a student-assignment plan to desegregate elementary schools. The 1969 plan used new geographic attendance zones and moved children from five heavily Black neighborhoods to other schools. Most elementary schools then had between 20% and 40% Black enrollment, with two at about 50%. A Georgia court blocked the plan, saying it treated students differently because of race and violated federal law.
Reasoning
The Supreme Court addressed whether a local school board may consider students’ race when drawing lines to end a segregated system and whether Title IV of the Civil Rights Act bars transporting students to achieve balance. The Court said school boards have a duty to dismantle dual, segregated systems and that taking race into account in drawing attendance zones can be a necessary remedial step. The Court also explained that the parts of Title IV relied on apply to federal officials and do not prevent state or local school authorities from assigning students this way. The Court therefore reversed the state court and allowed the desegregation plan to go forward.
Real world impact
The ruling lets the Clarke County plan operate and confirms that local districts may use attendance zones and limited busing to achieve more racially balanced elementary schools. It affects students and families who may be assigned to different schools and gives school boards guidance when designing remedies to end segregation. Because the decision approves race-conscious remedies in this context, other districts and courts may look to it when evaluating similar plans.
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