Milliken v. Bradley

Background

Black parents and students represented by the Detroit branch of the NAACP sued in 1970, saying the Detroit public schools were racially segregated by official action. They named the Detroit school board and several state officials (including the Governor and State Board of Education). The District Court found de jure segregation in Detroit and moved toward an areawide, metropolitan remedy that would include many suburban school districts.

Reasoning

The Court addressed whether a federal judge can order a cross-district, metropolitan desegregation plan when the record showed constitutional violations only inside one district. The Justices held that such sweeping relief is improper unless there is proof that neighboring districts or state action caused segregation across district lines, that district boundaries were deliberately drawn to segregate, or that affected districts were given a real chance to be heard. The Court emphasized that the scope of a remedy must match the nature and extent of the constitutional wrong and that local control over schools is an important factor.

Real world impact

The decision reverses the Court of Appeals and restricts federal judges from ordering metropolitan consolidation or forced cross-district busing based solely on imbalance in one city. It leaves intact a duty to fix segregation found in Detroit, but limits remedies to within Detroit unless additional interstate or statewide wrongful acts are shown. The case is sent back for a prompt Detroit-focused remedy.

Dissents or concurrances

Several Justices dissented, arguing the State and its agencies helped create Detroit’s segregation and that interdistrict relief was necessary and practical to prevent resegregation and achieve real desegregation.