Equal Educational Opportunity

The promise of racially integrated public schools, mandated by the Brown v. Board of Education decision of the Supreme Court in 1954 and the Civil Rights Act of 1964, spawned decades of civil rights activism and court-ordered desegregation plans. By the mid-1980s, significant racial integration had been achieved across the U.S.; however, demographic data indicate that since then the public schools have become less integrated over the last fifteen years resulting in "resegregation." Minority students are less likely to attend school with white students than in the past and a larger percentage of the school-aged population is poor. In an effort to retain and ensure integrated schools, districts have developed their own voluntary plans; however, the Supreme Court decision in June 2007 that struck down plans in Seattle, Washington and Louisville, Kentucky are forcing schools across the country to re-evaluate their efforts. Similar rulings are expected over the next several decades from a more conservative Supreme Court. School districts are looking for alternative criterions for school assignment other than race. Some school districts have successfully used socioeconomic status as a factor to integrate their schools, and are offering families new educational options.

Keywords Amicus Curiae; Brown v. Board of Education; Charter Schools; Civil Rights; Desegregation / Segregation / Resegregation; Equal Protection Clause; Equal Educational Opportunity; Fourteenth Amendment of the U.S. Constitution; Integration; Magnet Schools; Resegregation; Strict Scrutiny; Unitary Status; Vouchers

Education & the Law > Equal Educational Opportunity

Overview

This article discusses equal opportunity in education in the United States. One of the most contentious and seemingly irresolvable problems in American public education is the provision of equal educational opportunity. Racial integration of the public schools, once a primary strategy of achieving racial equality in our society, has been diminished over the last decade as school district desegregation plans are being challenged in the courts. This paper covers some of these cases, including the Supreme Court decision in June 2007 that struck down two school district's voluntary desegregation plans and how school districts are now re-evaluating their programs and seeking new ways to achieve diversity. Some districts are attempting to integrate students of different socioeconomic rather than racial backgrounds. Others are using non-coercive offerings such as vouchers and charter or magnet schools to appeal to students and parents seeking alternative means to a quality education.

The Legal History of Equal Educational Opportunity

The legal basis for all of the equal education litigation is the equal protection clause of the 14th Amendment. This clause dictates that the laws of a state, not the Federal government, must treat an individual in the same manner as others in similar conditions and circumstances. "The equal protection clause is not intended to provide "equality" among individuals or classes but only "equal application" of the laws. The result, therefore, of a law is not relevant so long as there is no discrimination in its application. By denying states the ability to discriminate, the equal protection clause of the Constitution is crucial to the protection of civil rights" (Legal Information Institute, 2007).

The Supreme Court decision of Brown v. Board of Education of 1954 is recognized as the seminal case that opened the door to racial desegregation in schools. Volumes have been written about this important case that promised integration and equal educational opportunities, and ushered in a thirty year period of subsequent legislation, federal court decisions, and civil unrest. For the most part, the fallout of school integration occurred during the 1960s and 1970s after passage of the Civil Rights Act of 1965. On the whole, integration goals were achieved. Ironically, a little noticed accomplishment was that the South, long the most resistant and most segregated region, "… remained for a third of a century the nation's most integrated" (Orfield, 2007, p. 14).

Support for forced integration began waning during the 1980s. Court orders for desegregation plans expired, and, for the most part, school district integration strategies became voluntary. Orfield notes that "five of the last seven Presidents actively opposed urban desegregation and the last significant federal aid for desegregation was repealed 26 years ago in 1981" (2007, p. 8). The past ten years have seen a new era of court decisions, a tremendous influx of Hispanics into the school system, and major societal shifts including the fruition of the white flight to the suburbs.

Brown v. the Board of Education & the Civil Rights Act of 1964

A series of Supreme Court decisions and legislation drove the integration of U.S. public schools for thirty years beginning with Oliver L. Brown et.al. v. the Board of Education of Topeka (KS) et.al. The 1954 landmark U.S. Supreme Court decision disallowed racial segregation of schools, and in 1955, after a second hearing, the Court ordered desegregation to proceed with "all deliberate speed."

It was not, however, until after the passage of the Civil Rights Act of 1964 that aggressive desegregation and integration began to occur throughout the country. The law prohibited discrimination in public places, and outlawed discrimination in employment and education. Now, the executive branch of the federal government was empowered to enforce integration.

Subsequent Rulings

In the thirty years after Brown, there was a stream of significant Supreme Court cases that advanced desegregation in the nation's schools. In order to meet racial integration goals, students in some areas had to be bused from their neighborhoods to more distant schools in their districts. The Swann v. Charlotte-Mecklenberg Board of Education decision of 1971 ruled that busing was constitutional.

Norwood v. Harrison (1973) ruled that States could not avoid the mandates of Brown by providing financial aid to private schools that discriminate based on race. This was followed by Keyes v. School District No. 1. Denver, Colorado which said that schools outside of the South which engaged in actual practice (de facto) segregation were as subject to the mandates of Brown as the schools in the South that were segregated by law (de jure).

The issues started to become more ambiguous in the mid-1970s as the courts began to draw lines defining how far civil rights actions could go. Milliken v. Bradley (1974) was significant in that it said that federal courts could impost inter-district desegregation remedies on a city and its suburbs without proving that school district boundaries were drawn with the intention to discriminate. The decision emphasized local control of schools and essentially exempted suburbs from participating in integration.

Although the case pertained to higher education, Bakke v. Regents of the University of California impacted affirmative action planning across all strata of education and employment. The ruling held that setting racial quotas is unconstitutional, but did not rule out race-based admissions completely. It provoked a debate about setting goals for diversity in education that was not resolved until the Supreme Court ruled in 2003 (Gratz v. Bollinger and Grutter v. Bollinger) that limited race-based admission may be justified.

Supreme Court decisions made in the early 1990s marked the demise of court-ordered desegregation plans. In the Board of Education of Oklahoma City v. Dowell (1991), a divided Supreme Court determined "that school official needed only to establish that they were operating with the Equal Protection Clause and that it was 'unlikely [they] would return to [their] former ways." (Daniel, 2005, p. 63).

Freeman v. Pitts (1992) followed on this trend when a Georgia school system sought final release "from judicial supervision of its desegregation efforts." The Court ruled that release from judicial rulings can be incremental; i.e., a school district can be released from the portions of its plan that have been met and must be held to the remaining criteria until "unitary status" is achieved. (Daniel, 2005, p. 63).

The last case in this sequence was Missouri v. Jenkins (1995) which pertained to local control of the schools. The Supreme Court ruled as unconstitutional prescribed remedies set by a federal district court that were deemed to go beyond its power. This and the three previous cases all mark the period of the disappearance of court-ordered desegregation plans. They made it evident that the plans were meant as temporary fixes to resolve a problem; once school districts were found "unitary," judicial oversight would end.

Parents Involved in Community Schools v. Seattle School District

Parents Involved in Community Schools v. Seattle School District. (2007) is a turning point in Supreme Court decisions. The ruling overturned lower court decisions that upheld the voluntary desegregation plans of the Louisville (Jefferson County), Kentucky and Seattle, Washington school districts. The impact of the decision remains to be seen, but experts recommend using other variables than race to achieve diversity in schools

Jefferson County Public Schools (Louisville, Kentucky) operated an integrated schools system as a result of a 1975 Federal court decree. When released from the decree twenty-five years later, the school district decided to continue to ensure integration by using its own voluntary integration guidelines, which were written in 2000 ("Is the Jefferson County Plan," 2007, p. 9). These guidelines specified that each elementary school was to be at least fifteen-percent and no more than fifty-percent black. As a result of this policy, the Jefferson County school district had one the most racially balanced school systems in the U.S.

In Louisville, a white mother brought suit against the school district, claiming that, because of this policy, her son was unable to attend the elementary school closest to their home, which, she said, violated her son's rights under the Equal Protection Clause of the Fourteenth Amendment. The case was decided in the Federal District Court for the Western District of Kentucky in 2004 by Judge John G. Heyburn, who ruled that the Jefferson County Board of Education plan was constitutional. He was guided in his opinion by the recently decided Supreme Court cases of Grutter v. Bollinger and Gratz v. Bollinger (2003) which upheld "race-conscious admissions policies at the University of Michigan Law School and University of Michigan, College of Literature, Science and the Arts" ("Is the Jefferson," 2007, p. 9). The judge's decision drew on strict scrutiny standard that has typically been applied by the Supreme Court in discrimination cases, which holds that "racial classifications must further a compelling governmental interest and must be narrowly tailored to meet that interest" ("Is the Jefferson," 2007, p. 10).

The situation in Seattle was similar to that in Louisville. Complainants in Parents Involved in Community Schools vs. Seattle Schools sued the school district, believing that their children were not accepted into their first choice high schools because they were white. The Seattle schools had never been charged with court-ordered segregation and the district's integration guidelines were wholly voluntary. They were adopted in 1998 to prevent "segregation that was caused by the self-segregation in housing patterns in the area" (Bullock, 2006, p. 9).

Numerous amicus curiae ("friends of the court") briefs were submitted to the Supreme Court including one from Solicitor General Paul D. Clement, who urged the Justices to rule with the belief "… that true use of racial classification to achieve a desired racial balance in public schools is as unconstitutional as racial segregation" (Bullock, 2006). The Court concurred with a 5-4 majority that overturned the ruling of the lower courts, and in the view of many, ignored fifty years of judicial precedent. Writing for the New York Times, in reaction to the decision, Jeffrey Rosen predicted that the central premise of Brown, "that integrated public schools are the most important institution in a pluralistic society," would "not survive the 21st century."

The outcome of the 2007 Seattle case clearly diverged from the University of Michigan Law School decision, which was settled a few short years before in 2003. Sandra Day O'Connor, who cast the swing vote in Grutter v. Bollinger and Gratz v. Bollinger for a 5-4 majority, was influenced by the many amicus curiae briefs that urged the value of racial diversity. However, her written argument that voiced her general opposition to affirmative action plans was one more segue to the court's shift to more restrictive decisions.

The Future of Equal Educational Opportunity

Clearly, the desegregation plans mandated by Brown v. Board of Education and the Civil Rights Act of 1965 are no longer practical. School administrators and civil rights leaders are now embarking on what Arthur Coleman and Scott Palmer titled their article in the Chronicle of Higher Education, "A More Circuitous Path to Racial Diversity." Coleman and Parker argued that educators must accommodate "the hostility of…[the] four most 'conservative' justices to race-conscious policies …" However, the authors did note that there may be promise in Justice Kennedy's dissenting statement that the "decision today should not prevent school districts from continuing the important work of bringing together students of different racial, ethnic, and economic backgrounds" (Coleman, 2007).

The recent decision was not surprising to those who have followed integration trends and perhaps least of all to administrators in the Seattle and Jefferson County school districts. The Seattle school district anticipated the decision and had suspended their program for the five years during which the case was moving through the courts. A New York Times article reported that "school officials cast the ruling as more victory than defeat, saying it would provide guidance for their efforts to promote racial diversity" (Lewin, 2007). Mandatory racial desegregation may no longer be feasible, the article continued, but the Supreme Court did recognize in its decision the benefits of diverse schools. Consequentially, it is probable "… that the decision will lead more districts to consider income as a race-neutral means of achieving school diversity" as is already done in a number of school districts throughout the country (Lewin, 2007).

Further Insights

Education & Racial Equity Data

The most comprehensive current study on racial balance in the schools is available from the UCLA Civil Rights project, an organization that analyzes data, and publishes and asserts recommendations related to civil rights and equal opportunities. Their report written by Gary Orfield and Chungmei Lee, "Historic Reversals, Accelerating Resegregation, and the Need for New Integration Strategies," was released in August 2007. The work is full of data from the National Center for Education Statistics (NCES), an office of the U. S. Department of Education, which they interpret to show the reversal in segregation.

Briefly, their analysis indicates that more students of all races are attending schools with a larger percentage of poor students; that whites are the most segregated of all the races and Asians the least; and that Latinos are the most segregated of the minority groups with "increasing patterns of triple segregation - ethnicity, poverty, and linguistic isolation" (p. 32).

Resegregation

Integration and desegregation, the buzz-words of the 1950s and 1960s, are now replaced by a new one: "Resegregation," which is increasingly used by politicians, civil rights leaders, and researchers to describe a resurgence of racially imbalanced schools. The data indicate that, since the 1980s, students have become increasingly racially isolated. A New York Times study in 2000, "The Lost Promise of School Integration," by Jeffrey Rosen, presented compelling data that showed that between 1989 and 1997, there was a measurable decline, state by state, in the "likelihood that a black student will have classmates who are white …[and] the percentage of a typical black student's classmates [who] are likely to be white."

Gary Orfield & Chungmei Lee further documented the trend in their August 2007 report. The scholars reported that the " … country's rapidly growing population of Latino and black students is more segregated than they have been since the 1960s and we are going backward faster in the areas where integration was most far-reaching." (p. 4)

The issue of educational inequality is at heart a socioeconomic one. Those in the lowest economic strata are predominately minorities who tend to live in poor communities where resources are limited. Likewise, many urban centers have are predominately inhabited by minorities, where there are fewer whites to make integration a commonsense possibility. A lack of fulfillment of basic needs gets in the way of learning and even though "a given student who is poor has the same potential as any other student … concentrating poor students together can overwhelm teachers, given the multitude of problems poor students often bring into the classroom … hunger, exposure to violence, or substandard housing" (Feldman, 2005).

Alternative Desegregation Strategies in Selected U.S. Schools

Although the prospects for school integration look bleak, school districts have been experimenting with alternative strategies, many based on socioeconomic status, rather than racial categories. Some have found new ways to attract an integrated student body. Situations vary from city to city, and state to state, so strategies that are effective in one locale may not be suitable for another.

The Wake County school district, which includes Raleigh, North Carolina and its suburbs, is one of the most successfully integrated districts in the country. A point in its favor is that the school district is a county-run system, which makes it easier to integrate urban and suburban areas. Wake County's population is also growing fast and is becoming increasingly diverse.

The district has tried to cap the proportion of low-income students in each of the county's 143 schools at 40 percent (Glater). Wake County has also opened several magnet schools that have met with a great deal of success and attracted national attention. The Washington Gifted and Talented Magnet Elementary School in Raleigh, North Carolina draws applicants from all racial groups and socioeconomic classes, even though it is adjacent to a poor neighborhood. Almost 95% of its nearly 600 students test at or above grade level, "even though 32% of its students receive free and reduce-price lunches" (Hardy).

Not all school districts have been so successful in using magnet schools to achieve diversity. Rosen calls Kansas City's strategy a "field-of-dreams" theory; i.e., if you improve the schools, white students will come. They "… spent nearly $200 million to build a state-of-the-art magnet school. The white students failed to materialize" (Rosen, p. 5). Likewise, a study of Miami-Dade, Florida magnet schools showed a decline in diversity after the district was released from its desegregation order (Davis).

St. Louis, one of the most segregated cities in the country, used an interdistrict transfer program for a number of years. Over 10,000 city students transferred to the suburban schools at state expense, and 1,000 suburban students attended school in the city. City schools did not improve, but many city students have reportedly done well at the suburban schools (Hardy). St. Louis' program ended in a 2009 without having established significant long-term desegregation. In 2013, the majority of Louisiana's public school districts were still under federal oversight, and a plan to issue vouchers to public school students to be applied to private school tuition was met with resistance from the Department of Justice (Federal Oversight Backed, 2013).

San Francisco is unique in that around a third of its school-age population is of Chinese heritage. The city has also lost many middle class families because of the high cost of raising children there. Rather than using race as a factor in placing students, the school district initiated a desegregation plan in 2002-03 based on socioeconomic diversity. "Students apply to the school they want to attend, and the district uses a 'diversity index' for assignment when the school is oversubscribed" (Glater, 2007). The formula has reportedly worked to some extent, but racial integration within the San Francisco schools is far from complete.

Charlotte-Mecklenburg, North Carolina's largest school district has also tried an economic integration plan but has had problems administering it. On the other hand, Cambridge, Massachusetts, a smaller district, has been using socioeconomic status to assign students to its 12 elementary schools since 2002. Students there showed marked progress in reading proficiency (Glater, 2007).

Viewpoints

After release of the decision in the case of "Parents Involved in Community Schools v. Seattle School District," some civil rights leaders and politicians proclaimed the death of racial integration. Some saw it as the end of fifty years of progress in desegregation. On the other hand, others are more optimistic as they realize the need to continue the struggle to ensure equal educational opportunities for all students. Many civil rights leaders, recognizing the trends and the conservative climate, recommend making the best of the alternative educational options that are offered.

Many magnet schools or charter schools, however controversial, are demonstrating higher levels of achievement, and are attractive to families of all racial and socioeconomic strata. A 1998 survey conducted by the Public Agenda, showed that 82 percent of the black parents "said that raising academic standards was more important than achieving more diversity and integration" (Rosen, 2000, p. 5). The academic performance of charter-management organizations-consisting of three or more charter schools-is not better than non-CMO charters. According to a Stanford University Center for Research on Education Outcomes (CREDO) study, charters affiliated with management organizations (CMOs) tend to deliver greater academic gains among poor and minority students than traditional public schools, though performance is predicated on strong, well run programs that are effective beginning in their firest year (Cavanagh, 2013).

Because housing patterns tend to be segregated, integrating the schools is complicated, and may be near impossible. "Many of the nation's largest urban districts now have so few white students that any large-scale effort at racial balance would be impractical" (Lewin, 2007). Assigning students on the basis of income rather than race may be practical, but, as has been shown in San Francisco, may not be fully successful. Richard Kahlenberg, a senior fellow at the Century Foundation still encourages school districts to pursue it: "not only do you get a fair amount of racial integration that's legally bullet-proof, but the research shows that for individual students, it's more closely aligned with achievement, with higher test scores, than racial integration." (Lewin, 2007).

Nebraska State Senator Ernie Chambers received some national attention in 2006 for his proposal to rezone the Omaha, Nebraska schools into three districts along racial lines. Surprisingly this was coming from a 69-year-old African-American, who himself had attended segregated schools. He told the American School Board Journal that "… you can have single-race schools and still have a quality education. Don't try to make schools do what society won't. Since we'll always have segregated neighborhoods, we'll have segregated schools." He believes that the public schools have never been integrated. Times have changed. "I'm not interested in segregation or integration. I'm interested in quality education" ("Five Questions," 2006).

Terms & Concepts

Amicus Curiae: Literally means "friends of the court" and refers to parties that are invited by a court to speak to the issue of litigation, usually by submitting briefs, in which they may have an interest, but are not directly involved.

Charter Schools: Publicly funded schools that are freed of some of some restrictions of other public schools in exchange for other forms of accountability. Charter schools are intended to provide educational alternatives. In some cities, most notably New York City, admission is highly competitive as families flee underperforming schools.

Equal Protection Clause: The Equal Protection clause is the last clause of the first section of the Fourteenth Amendment of the U.S. Constitution. It states that "… All persons born or naturalized in the United States, and subject to the jurisdiction thereof, are citizens of the United States and of the state wherein they reside. No state shall make or enforce any law which shall abridge the privileges or immunities of citizens of the United States; nor shall any state deprive any person of life, liberty, or property, without due process of law; nor deny to any person within its jurisdiction the equal protection of the laws."

In other words, Federal law prohibits states from denying any person within its jurisdiction the equal protection of law. A violation would occur, for example, if a state prohibited an individual from entering into an employment contract because he or she was a member of a particular race.

Magnet Schools: Schools that are administered within a public school system, exist outside of zoned school boundaries, and generally provide more direct funding for students. Magnet schools sprang up in the 1980s and 1990s as a way to attract students to voluntarily attend a school, without busing or other coerced integration, and thus increase the diversity of the school. A magnet school frequently offers alternative modes of instruction and specialized programs, and most foster high levels of parental involvement.

Resegregation: : Describes the trend of de facto desegregation in U.S. schools.

Strict Scrutiny: The principal used by the Supreme Court in reviewing civil rights cases, first used in "… Korematsu v. United States (1944), where it found all racial classifications to be immediately suspect" and subject to "the most rigid scrutiny

Unitary Status: "Unitary status," or "unity," describe the achievement of the racial integration goals that are part of a court-ordered desegregation plan.

Vouchers: Direct financial support for parents who wish to have more choice in where to educate their children. Parents may choose to educate their children in private schools or a public school of their choice.

Bibliography

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Bernstein, M. (2007). Our kids need a diversity lesson. Will the court allow it? School Administrator, 64 , 55. Retrieved September 20, 2007 from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=24545138&site=ehost-live

Bullock, L. (2006, August 31). Bush administration turns its back on school integration. New York Amsterdam News, 97 , 33-41. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=22559069&site=ehost-live

Cavanagh, S. (2013). Charters' success or failure set early. Education Week, 32, 12-13. Retrieved December 15, 2013, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=85375075&site=ehost-live

Coleman, A. L. & Palmer, S. R. (2007, July 13). A more circuitous path to racial diversity. Chronicle of Higher Education, 53 , p. B10-53. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=25848149&site=ehost-live

Daniel, P. (2005, January). The not so strange path of desegregation in America's public schools. Negro Educational Review, 56 , 57-66. Retrieved September 20, 2007 from EBSCO online database, Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=16473173&site=ehost-live

Davis, M. (2007). Magnet schools and diversity. Education Week, 26 , 9. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=23653860&site=ehost-live

Federal oversight backed for Lousiana voucher plan. (2013). Education Week, 33, 5. Retrieved December 15, 2013, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=92862556&site=ehost-live

Feldman, J. (2005). Integrated public education is still worth fighting for. Human Rights: Journal of the Section of Individual Rights & Responsibilities, 32 , 13-14. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=19875571&site=ehost-live

Five questions…for Ernie Chambers on the Omaha controversy. (2006). American School Board Journal, 193 , 11. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=23041370&site=ehost-live

Glater, J. D. & Finder, A. (2007, July 15). Diversity plans based on income leave some schools segregated. New York Times, 24.

Hardy, L. (2006, September). Separate our students by race and income to meet NCLB? Education Digest, 72 , 12-20. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=22680775&site=ehost-live

Huang, J. (2013). Intergenerational transmission of educational attainment: The role of household assets. Economics of Education Review, 33112-123. Retrieved December 15, 2013, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=86419755&site=ehost-live

Is the Jefferson County Public Schools' desegregation plan unconstitutional? (2007). Supreme Court Debates, 10 , 2-3. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=24945562&site=ehost-live

Legal Information Institute. Cornell University Law School. (2007). Equal protection. Retrieved September 24, 2007, from http://www.law.cornell.edu/wex/index.php/Equal_protection

Lewin, T. (2007, June 29). Across U.S., a new look at school integration efforts. New York Times, A25-A25. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=25904135&site=ehost-live

McDermott, K.A., & Nygreen, K. (2013). Educational new paternalism: Human capital, cultural capital, and the politics of equal opportunity. Peabody Journal of Education (0161956X), 88, 84-97. Retrieved December 15, 2013, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=85221487&site=ehost-live

Orfield, G. & Lee, C. (2007 August). Historic reversals, accelerating resegregation, and the need for new integration strategies. A report of the Civil Rights Project / Proyecto Dechechos Civiles. Los Angeles, California: UCLA. Retrieved September 22, 2007, from http://www.civilrightsproject.ucla.edu/research/deseg/reversals_reseg_need.pdf

Resegregation now. (2007, June 29). [Editorial]. New York Times, A28.

Roberts Rules. (2007). New Republic, 237 , 1-4. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=25803268&site=ehost-live

Rosen, J. (2000, April 2). Bus stop: the lost promise of school integration. New York Times, 1.

Russo, C. (2002). An American perspective on equal educational opportunities. Education & the Law, 14 (1/2), 25-32. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=7066980&site=ehost-live

Supreme Court delivers setback to Brown v. Board progress. (2007). NEA Today, 26 , 15. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=26407645&site=ehost-live

Trotter A. (2006). Diverse views offered on Supreme Court race cases. Education Week, 26 , 31-33. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=22912497&site=ehost-live

Williams, S.M. (2013). Micropolitics and rural school consolidation: The quest for equal educational opportunity in Webster Parish. Peabody Journal of Education (0161956X), 88, 127-138. Retrieved December 15, 2013, from EBSCO Online Database Education Research Complete. http://search.ebscohost.com/login.aspx?direct=true&db=ehh&AN=85221489&site=ehost-live

Suggested Reading

Barnes, A. (2005). The conundrum of segregation's ending: the educational choices. Marquette Law Review, 89 , 33-51. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=16473173&site=ehost-live

Bell, Derrick. (2004). Silent covenants: Brown v. Board of Education and the unfulfilled hopes for racial reform. Oxford, NY: Oxford University Press.

Charne, I. (2005). The Milwaukee cases. Marquette Law Review, 89 , 83-85. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=18922391&site=ehost-live

Frankenberg, E. & Orfield, G. eds. (2007). Lessons in integration: realizing the promise of racial diversity in American schools. Charlottesville: University of Virginia Press.

Tatum, B. D. (2007). Can we talk about race: And other conversations in an era of school resegregation. Boston: Beacon Press.

UCLA. Civil Rights Project. Looking to the future: Voluntary K-12 school integration. Retrieved September 20, 2007, from http://www.civilrightsproject.ucla.edu/resources/manual/manual.pdf

U. S. Supreme Court. Parents involved in Community Schools v. Seattle School District no. 1. et al. Washington, DC: Government Printing Office. Retrieved September 20, 2007, from http://www.supremecourtus.gov/opinions/06pdf/05-908.pdf

Wraga, W. (2006). The Heightened significance of Brown v. Board of Education in our time. Phi Delta Kappan, 87 , 425-428. Retrieved September 20, 2007 from EBSCO Online Database Academic Search Premier. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=19640758&site=ehost-live