Crawford v. Board of Ed. of Los Angeles

1982-06-30

Headline: California voters’ amendment limiting court-ordered busing is upheld, blocking state judges from ordering mandatory pupil reassignment or transportation unless a federal court could do the same.

Holding: The Court upheld California’s Proposition I, ruling state courts may not order mandatory student reassignment or transportation unless a federal court could impose the same remedy for a Fourteenth Amendment equal-protection violation.

Real World Impact:

Prevents state judges from ordering mandatory busing unless a federal court could do so.
Leaves school boards free to adopt voluntary reassignment and busing plans.
May end many state-court desegregation orders and shift enforcement to federal courts or politics.

Topics: school desegregation, court-ordered busing, state constitutional amendment, equal protection, education policy

Summary

Background

Minority students in the Los Angeles Unified School District sued in 1963 seeking desegregation. A trial court in 1970 found de jure segregation and ordered a desegregation plan; the California Supreme Court affirmed under the state constitution, and a large busing plan was implemented in 1978. Voters approved Proposition I in 1979, which forbids state courts from ordering mandatory pupil assignment or transportation unless a federal court could do so to remedy a Fourteenth Amendment violation. The District and other parties challenged the effect of Proposition I on the ongoing plan, and California courts split over whether Proposition I applied and whether it was constitutional.

Reasoning

The Supreme Court asked whether Proposition I itself violates the Fourteenth Amendment. The Court held it does not. The majority reasoned Proposition I is facially neutral: it aligns state-court remedies with the federal constitutional standard rather than creating a race-based classification. The Court noted California law still imposes state duties to pursue voluntary desegregation and that school districts may continue to adopt reassignment or busing plans voluntarily. The Court accepted the state appellate court’s findings that voters’ stated purposes were legitimate and that petitioners had not shown discriminatory intent.

Real world impact

As a result, state courts are limited from imposing mandatory busing or reassignment except where a federal constitutional violation would permit the same remedy. Local school boards remain responsible for taking reasonably feasible steps to alleviate segregation and may choose voluntary measures. The decision affirmed the Court of Appeal and alters how desegregation remedies can be enforced in California.

Dissents or concurrances

Justice Blackmun (joined by Brennan) concurred, distinguishing an earlier case about reallocation of decisionmaking. Justice Marshall dissented, arguing Proposition I strips courts of an effective remedy and burdens minorities.