Lexplug logoLexplug

Washington v. Seattle School District No. 1

Supreme Court of the United States
458 U.S. 457 (1982)
ELI5:

Rule of Law:

A state law violates the Equal Protection Clause of the Fourteenth Amendment if it reallocates governmental decision-making power in a way that places special burdens on the ability of racial minorities to achieve beneficial legislation through the political process.


Facts:

  • Due to segregated housing patterns, Seattle School District No. 1 had racially imbalanced schools.
  • In March 1978, the Seattle School Board voluntarily enacted the 'Seattle Plan,' which used mandatory student reassignments and busing to desegregate the district's schools.
  • A citizens' group called the Citizens for Voluntary Integration Committee (CiVIC), which opposed the Seattle Plan, drafted a statewide measure called Initiative 350.
  • Initiative 350 prohibited school boards from requiring any student to attend a school other than the one nearest or next nearest to their home, effectively banning mandatory busing for desegregation.
  • The initiative provided broad exceptions, allowing mandatory busing for many non-racial reasons, such as special education, overcrowding, or safety hazards.
  • In November 1978, Washington voters passed Initiative 350, with supporters having assured voters that it would only affect busing for desegregation.

Procedural Posture:

  • The Seattle, Tacoma, and Pasco School Districts sued the State of Washington in the United States District Court for the Western District of Washington.
  • The District Court found Initiative 350 unconstitutional and issued a permanent injunction against its implementation.
  • The State of Washington appealed to the United States Court of Appeals for the Ninth Circuit.
  • A divided panel of the Ninth Circuit affirmed the District Court's judgment, holding that the initiative created a suspect racial classification and unconstitutionally restructured the political process.
  • The State of Washington appealed to the Supreme Court of the United States, which noted probable jurisdiction.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a state law, enacted via a statewide initiative, that prohibits local school boards from requiring student busing for racial integration purposes, while permitting it for most other educational purposes, violate the Equal Protection Clause of the Fourteenth Amendment?


Opinions:

Majority - Justice Blackmun

Yes, the state law violates the Equal Protection Clause. A state may not use the racial nature of an issue to define the governmental decision-making structure in a way that imposes substantial and unique burdens on racial minorities. While facially neutral, Initiative 350 was enacted 'because of' its adverse effects on busing for integration, thereby addressing a racial issue. Before the initiative, local school boards had the authority to make student assignment decisions; afterwards, authority over desegregative busing was removed from local boards and placed at the state level. This reallocation of power disadvantages those seeking to enact integration policies, forcing them to lobby a remote, statewide body, while those seeking student assignments for non-racial reasons can still work with their local school boards. Citing Hunter v. Erickson, the Court found this non-neutral restructuring of the political process impermissibly burdens minority interests.


Dissenting - Justice Powell

No, the state law does not violate the Equal Protection Clause. States have plenary authority over public education and are free to structure their governmental decision-making processes as they see fit, including deciding whether policies are set at the state or local level. Initiative 350 is a racially neutral neighborhood school policy that the state's sovereign, the people, have every right to adopt. It does not alter the political process in a discriminatory way as in Hunter; it is simply a policy choice. Since local school districts are creatures of the state, the state retains the ultimate authority to pre-empt local policies. The initiative does not place a special burden on minorities; it merely reflects the outcome of a normal democratic political process in which there are winners and losers.



Analysis:

This decision significantly reinforces and expands the 'political process' doctrine from Hunter v. Erickson. It establishes that a state action can violate equal protection not just by discriminating directly, but by restructuring the political process to make it harder for minorities to achieve their goals. The ruling prevents the majority from using its power to move the goalposts for racial issues, ensuring that minorities can seek favorable legislation at the same level of government as other interest groups. This case stands for the principle that the structure of government decision-making cannot be selectively altered to disadvantage racial minorities.

🤖 Gunnerbot:
Query Washington v. Seattle School District No. 1 (1982) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.
Locked
Subscribe to Lexplug to chat with the Gunnerbot about this case.

Unlock the full brief for Washington v. Seattle School District No. 1