United States v. State of Louisiana Earl Benjamin Bush v. Orleans Parish School Board Harry K. Williams v. Jimmie H. Davis
The Supreme Court refused to pause a lower court's order striking down a series of Louisiana laws designed to block school desegregation, laws based on the theory that a state could 'interpose' itself between federal courts and local school boards.
The Court reaffirmed that states have no constitutional power to defy federal court desegregation orders, relying on its earlier ruling in the Little Rock schools case.
“If taken seriously, it is illegal defiance of constitutional authority.”
The Court's description of Louisiana's 'interposition' theory as unconstitutional defiance.
How it got here: A three-judge federal district court nullified Louisiana's interposition laws and enjoined their enforcement; the state asked the Supreme Court to stay that injunction.
The Case in Depth
What happened
Louisiana's legislature passed a series of laws asserting that the state had 'interposed' itself into the field of public education and could resist federal court orders requiring desegregation of the Orleans Parish schools. A three-judge federal district court struck down these laws as unconstitutional defiance of federal authority, and Louisiana officials asked the Supreme Court to stay that injunction while they pursued further review.
The question before the Court
Could Louisiana block school desegregation by claiming a state power to "interpose" itself against federal court orders?
Why it matters
The ruling let a federal injunction against Louisiana's segregation laws take immediate effect, clearing the way for New Orleans school desegregation to proceed without further delay from state interference. It also signaled to other Southern states that similar 'interposition' laws and resistance tactics would not survive Supreme Court review.
What changes now
With the stay denied, the district court's injunction against Louisiana's interposition laws remained in force immediately, allowing desegregation efforts in the Orleans Parish schools to continue. The underlying litigation over enforcement of desegregation orders in Louisiana continued in the lower courts, but this order removed any temporary shield the state laws might have provided.
How the Court got there
The legal reasoning, step by step
- The Court looked at the lower court's core holding that 'interposition' — a state's claimed power to block federal authority — is not a real constitutional doctrine, and that acting on it is illegal defiance of the Constitution.
- Louisiana's main argument for a stay was that the state had exclusive control over public education and could use that control to resist desegregation orders through interposition.
- The Court treated this argument as already resolved by its earlier decision in Cooper v. Aaron, which held that state and local officials cannot nullify federal desegregation rulings through evasive or defiant state action.
- Applying that precedent, the Court found Louisiana's exclusive-control argument, and its other objections, without merit.
- Because none of the state's arguments cast doubt on the lower court's ruling, the Court concluded there was no basis to pause the injunction while further proceedings continued.
Doctrinal impact
Cases affected by this decision
Reaffirms Cooper v. Aaron (358 U.S. 1)
Relied on to reject Louisiana's claim that it could resist federal desegregation orders.