Buchanan Et Al. v. Evans Et Al.
Headline: Court summarily affirms injunction blocking parts of Delaware school-reorganization law that kept Wilmington separate, affecting school consolidation plans, though a Justice dissents as moot and questions the appeal’s authority.
Holding:
- Keeps a lower-court injunction blocking Delaware reorganization rules that had excluded Wilmington.
- Creates uncertainty about whether expired statutory provisions can be challenged.
- Raises questions about when three-judge courts and direct appeals are allowed.
Summary
Background
The dispute involves the Delaware State Board of Education and people challenging a 1968 state law called the Educational Advancement Act (EAA). The law set a timetable for reorganizing school districts but explicitly kept the City of Wilmington as a separate district. Local plaintiffs argued that excluding Wilmington in this way had the effect of keeping Black children confined to segregated city schools. A three-judge federal court found those EAA provisions unconstitutional and issued an order saying the state board was enjoined from relying on them when preparing consolidation plans.
Reasoning
The core question is whether the Court should leave in place the three-judge court’s injunction against using those EAA provisions and whether the Supreme Court can properly review broader consolidation issues on direct appeal. The Court issued a summary affirmance of the lower court’s action. Justice Rehnquist dissented, arguing the challenged EAA provisions expired by their own terms in 1969, so any injunction against enforcing them was moot because the state board no longer had the unilateral power to consolidate. He also argued that the statute allowing a direct appeal to this Court is narrow, and that the Court should have at least noted probable jurisdiction and heard argument on larger questions.
Real world impact
The practical effect is that the District Court’s order blocking the state board from relying on the cited EAA provisions stands for now, creating room for interdistrict consolidation plans that might include suburban areas. But because the Supreme Court affirmed without opinion, the scope and permanence of that ruling remain unclear, and important questions about whether expired laws can be enjoined and when direct appeals are proper are left unsettled.
Dissents or concurrances
Justice Rehnquist dissented, urging reversal of the injunction as moot, warning of serious jurisdictional problems, and criticizing the Court’s unexplained summary affirmance as procedurally unsatisfactory.
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