Missouri v. Jenkins (Jenkins III)
515 U.S. 70 (1995)
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Rule of Law:
A federal district court's remedial power in a school desegregation case is limited by the nature and scope of the constitutional violation, and therefore a court exceeds its authority by ordering remedies aimed at an interdistrict goal, such as attracting non-minority students from outside the school district, to correct a purely intradistrict violation.
Facts:
- Prior to 1954, the State of Missouri mandated by law that schools be segregated for black and white children.
- Following the Brown v. Board of Education decision, the Kansas City, Missouri, School District (KCMSD) and the State of Missouri failed to take affirmative steps to dismantle this dual school system.
- This failure resulted in a system-wide reduction in student achievement and the persistence of many racially identifiable schools (with over 90% black student populations) within the KCMSD.
- The racial composition of the KCMSD shifted over several decades, becoming predominantly black (approximately 68% by 1984), a change attributed in part to 'white flight' to surrounding suburban school districts and private schools.
- The physical facilities of the KCMSD schools fell into a state of extreme disrepair, with widespread health and safety hazards, described by the District Court as having 'literally rotted'.
Procedural Posture:
- The Kansas City, Missouri, School District (KCMSD) and a class of KCMSD students sued the State of Missouri and other defendants in the U.S. District Court for the Western District of Missouri.
- After trial, the District Court found the State and KCMSD liable for perpetuating a segregated school system within the district (an intradistrict violation).
- The District Court issued a series of extensive and expensive remedial orders, including quality education programs, a capital improvements plan, and the creation of a magnet school system, holding the State and KCMSD jointly liable for the costs.
- Subsequently, the District Court ordered the State to fund salary increases for nearly all KCMSD employees and to continue funding the quality education programs.
- The State of Missouri, as appellant, appealed these specific orders to the U.S. Court of Appeals for the Eighth Circuit.
- The Court of Appeals affirmed the District Court's orders.
- The State of Missouri successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the Court of Appeals' decision.
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Issue:
Does a federal district court exceed its constitutional authority in a school desegregation case by ordering expensive remedial programs, such as salary increases and massive capital improvements, with the primary goal of achieving 'desegregative attractiveness' to attract non-minority students from outside the district, when the underlying constitutional violation was confined to a single school district?
Opinions:
Majority - Chief Justice Rehnquist
Yes. A district court's desegregation remedy must be tailored to the nature and scope of the constitutional violation. The remedy must be designed to restore the victims of discriminatory conduct to the position they would have occupied in the absence of such conduct. Here, the violation was intradistrict, yet the remedy's goals of 'desegregative attractiveness' and 'suburban comparability' were impermissibly interdistrict, as they aimed to attract non-minority students from other school districts. The court cannot devise a remedy to accomplish indirectly what it lacks the authority to mandate directly, such as the interdistrict transfer of students. Similarly, requiring student achievement to rise to national norms is not a proper test for ending judicial supervision, as it is not directly linked to the vestiges of segregation and postpones the return of control to local authorities.
Concurring - Justice O'Connor
Yes. The propriety of 'desegregative attractiveness' as a remedial goal was a central issue properly before the Court. The Court's holding is consistent with precedent like Hills v. Gautreaux, which does not eliminate Milliken I's requirement that a remedy crossing district lines is only permissible upon a showing of a significant interdistrict segregative effect. The lower courts explicitly found no such interdistrict effect in this case. Therefore, the District Court cannot order remedies designed to rectify regional demographic trends, like white flight, that go beyond the scope of the intradistrict constitutional violation.
Concurring - Justice Thomas
Yes. The District Court's remedy was based on the flawed premise that racially isolated schools are inherently inferior and that black students cannot succeed without the presence of white students. This assumption of black inferiority is not a constitutional principle. Furthermore, federal courts have been permitted to exercise virtually unlimited equitable powers in desegregation cases, which tramples on principles of federalism and the separation of powers. Remedies should be narrowly tailored to cure the harm suffered by the actual victims of segregation, not to engage in broad social engineering by indiscriminately benefiting an entire school district.
Dissenting - Justice Souter
No. The Court improperly decides a foundational issue—the validity of the magnet school remedy—that was not granted certiorari and that the respondents were not prepared to argue. The majority misinterprets the lower court's findings; the District Court found that the intradistrict violation did cause an interdistrict effect, namely 'white flight,' which exacerbated segregation within the KCMSD. The Court also misapplies precedent, effectively overruling Hills v. Gautreaux, which permits remedies that have effects beyond a violator's boundaries so long as they do not coerce innocent government entities. The remedy here only burdened the constitutional violators (the State and KCMSD), not the surrounding districts, and was therefore permissible.
Dissenting - Justice Ginsburg
No. The Court's decision to curtail desegregation efforts is premature and disregards the historical context. Given Missouri's long and deep history of state-enforced segregation, which spanned more than two centuries, the seven years of remedial programs ordered by the District Court have been 'evanescent' in comparison. To stop the integration efforts at this stage is an action that is 'at once too swift and too soon'.
Analysis:
This decision significantly curtailed the remedial authority of federal district courts in school desegregation cases. By invalidating 'desegregative attractiveness' as a remedial goal for a purely intradistrict violation, the Court limited the judiciary's power to address demographic changes like 'white flight.' The ruling established a stricter nexus requirement between the constitutional violation and the remedy, signaling a shift toward ending federal court supervision of school districts and restoring local control. It makes it substantially more difficult for courts to order expensive, district-wide capital and programmatic remedies intended to have an integrationist effect beyond the district's borders.
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