Pasadena City Board of Education et al. v. Spangler et al.
427 U.S. 424 (1976)
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Rule of Law:
Once a school district has implemented a racially neutral student assignment plan that remedies a prior constitutional violation, a federal court exceeds its authority by requiring annual readjustments of attendance zones to maintain a specific racial balance when subsequent demographic shifts are not the result of the district's segregative actions.
Facts:
- In 1968, the Pasadena Unified School District (PUSD) was alleged to be operating an unconstitutionally segregated school system.
- A federal court found that PUSD's policies were unconstitutional and in 1970 ordered it to implement a desegregation plan.
- The court-approved 'Pasadena Plan' included a requirement that by September 1970, 'there shall be no school in the District... with a majority of any minority students.'
- The PUSD implemented the plan, and in the 1970-1971 school year, no school had a majority-minority student body.
- In the following years, due to normal demographic changes and residential patterns unrelated to any action by the PUSD, some schools once again developed majority-minority student populations.
- By 1974, five of the PUSD's 32 schools had student bodies with a majority of minority students, in literal violation of the 1970 order.
- The school board, successors to the original defendants, sought relief from the court's ongoing 'no majority of any minority' requirement.
Procedural Posture:
- Students and parents sued the Pasadena City Board of Education in the U.S. District Court for the Central District of California, alleging unconstitutional segregation.
- The United States government intervened in the action as a plaintiff.
- In 1970, the District Court found for the plaintiffs and issued an injunction ordering the PUSD to submit a desegregation plan, which had to include a provision that no school would have a majority of any minority students.
- The PUSD complied and implemented the court-approved 'Pasadena Plan' without appealing the 1970 order.
- In 1974, the PUSD (petitioners) filed a motion in the same District Court seeking to modify the 1970 judgment and dissolve the 'no majority of any minority' requirement.
- The District Court denied the PUSD's motion in its entirety.
- The PUSD (appellant) appealed the denial to the U.S. Court of Appeals for the Ninth Circuit, where the plaintiffs and the United States were appellees.
- A divided panel of the Court of Appeals affirmed the District Court's order.
- The PUSD (petitioners) successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a federal district court exceed its remedial authority by requiring a school district to annually readjust its student attendance zones to maintain a specific racial balance, after the district has already implemented a court-approved, racially neutral plan that remedied the initial constitutional violation?
Opinions:
Majority - Justice Rehnquist
Yes. A federal district court exceeds its remedial authority by requiring a school district to annually readjust student attendance zones to maintain a prescribed racial balance after the district has remedied its constitutional violation with a racially neutral plan. The District Court's 1970 order was a remedy for a past constitutional violation, and the implementation of the 'Pasadena Plan' established a racially neutral system of student assignment. Citing Swann v. Board of Education, the Court explained that there is no 'substantive constitutional right to a particular degree of racial balance' and that courts cannot require 'year-by-year adjustments of the racial composition of student bodies once the affirmative duty to desegregate has been accomplished.' Because the demographic shifts that occurred after 1971 were not caused by any segregative actions of the PUSD, the district had no constitutional duty to remedy them. Having implemented a racially neutral attendance pattern, the District Court had fully performed its remedial function and was not entitled to require the PUSD to maintain a specific racial mix in perpetuity.
Dissenting - Justice Marshall
No. The District Court did not abuse its discretion in refusing to modify its order because the PUSD had not yet fully eliminated racial discrimination and achieved a 'unitary' system. The majority's reliance on Swann is misplaced because Swann's prohibition on year-to-year adjustments applies only after the affirmative duty to desegregate has been fully accomplished. In this case, there was evidence that the school board was uncooperative with the desegregation plan and had not yet remedied discrimination in other areas, such as faculty hiring and promotion. A district court possesses broad equitable power to remedy past wrongs, and it should not be compelled to relinquish supervision over one aspect of a remedy (student attendance) until the constitutional violation has been eliminated 'root and branch' from the entire system. Modifying the order prematurely risks allowing the system to become resegregated before the remedy is complete.
Analysis:
This decision significantly clarifies the temporal limits of a federal court's equitable power in school desegregation cases. It establishes that the judicial remedy is aimed at correcting a specific constitutional violation, not at maintaining a perpetual racial balance against neutral demographic forces. The ruling distinguishes between a school district's affirmative duty to dismantle a dual system and a non-existent duty to counteract 'white flight' or other population shifts not caused by official action. This precedent limits the scope of ongoing court supervision, allowing school districts that have successfully implemented a racially neutral plan to regain control over student assignments without the need for annual court-mandated adjustments.
