Keyes v. Denver School District No. 1
Keyes v. Denver School District No. 1 is a significant court case involving school desegregation in the United States. The case arose when a federal district judge determined that the Denver school officials had implemented policies that encouraged segregation in the Park Hill section of the city. While the judge ordered a desegregation plan for this specific area, he concluded that there was insufficient evidence to support a citywide plan, as there was no proof of intentional segregation in other neighborhoods. The case highlighted the judicial principle that if deliberate segregation is found in any significant part of a school district, the burden shifts to the school officials to demonstrate that such segregation is not present elsewhere due to official policies. In a landmark decision, the Supreme Court upheld the idea that school officials had an affirmative duty to desegregate the entire system if segregation was proven in certain areas. This ruling led to the implementation of busing plans, aiming to address segregation in urban districts, although later cases, such as Milliken v. Bradley, limited the scope of such measures. Overall, Keyes v. Denver School District No. 1 represents a critical moment in the ongoing struggle for educational equality and the complexities surrounding desegregation efforts in American schools.
Keyes v. Denver School District No. 1
Date: June 21, 1973
Citation: 413 U.S. 189
Issue: School integration and busing
Significance: In its first school desegregation case involving a major city outside the South, the Supreme Court held that a district-wide busing plan was an appropriate remedy for a situation in which official policies had encouraged the establishment of racially segregated schools in any section within the district.
A federal district judge ordered a desegregation plan for the Park Hill section of Denver, Colorado, after he concluded that school officials had adopted policies promoting and encouraging segregation of the schools in that section. The judge did not require a citywide desegregation plan because of a lack of proof that other neighborhood schools were segregated as a result of intentional policy.
Speaking for a 7-1 majority, Justice William J. Brennan, Jr., held that a finding of deliberate segregation in one significant portion of a district is sufficient to shift the burden to school officials to prove that segregation elsewhere in the district is not also a result of official policy. School officials could avoid the imposition of a desegregation plan for the entire district only if they could prove that the district had not promoted segregation in some places through its choices of school construction sites, its drawing of attendance zones, and its pursuance of other such policies. Without such evidence, said Brennan, the school board had “an affirmative duty to desegregate the entire system, ’root and branch.’” Rejecting the arguments of two justices, the majority endorsed the continuing validity of the de jure/de facto distinction in school desegregation cases. The case was sent back to the district court, which adopted a system-wide busing plan.
The controversial Keyes decision allowed an expansion of court-ordered busing plans into many urban districts that were primarily segregated on a de facto basis. In Milliken v. Bradley (1974), however, the Court decided not to extend the reasoning of Keyes to a large urban region that was divided into many school districts.