Pasadena City Board of Education v. Spangler
"Pasadena City Board of Education v. Spangler" is a significant Supreme Court case that emerged from a lawsuit filed in 1968 by students and parents against the Pasadena Unified School District in California, claiming that the district's schools were segregated due to official actions. In a ruling made in 1970, a federal district court found in favor of the plaintiffs, mandating the district to create a plan to address racial imbalances in its schools and stipulating that no school should have a majority of minority students. Over time, the school district requested changes to this ruling, arguing that demographic shifts had resulted in new racial imbalances, despite having ceased racially segregative practices.
The district court denied this request, a decision later upheld by the Ninth Circuit Court of Appeals. However, when the case reached the Supreme Court, the majority opinion, led by Justice William H. Rehnquist, determined that the district court had overstepped its authority by maintaining the majority-minority requirement, asserting that there was insufficient evidence that the district's policies caused the demographic changes. Meanwhile, dissenting justices expressed concern over limiting federal courts' discretion to combat segregation. This case ultimately reflects the complexities and challenges of addressing both de jure and de facto segregation in public schools and the evolving judicial interpretation of federal authority in such matters.
Pasadena City Board of Education v. Spangler
In 1968, several students and their parents filed suit against the Pasadena Unified School District in California, alleging that the district’s schools were segregated as a result of official action on the part of the district. In 1970, the federal district court found for these plaintiffs, concluding that the district had engaged in segregation and ordering the district to adopt a plan to cure the racial imbalances in its schools. The federal court’s order provided that no school was to have a majority of minority students. The district thereafter presented the court with a plan to eliminate segregation in the Pasadena schools; the court approved the plan, and the district subsequently implemented it.
Approximately four years later, the Pasadena Unified School District asked the district court to modify its original order and eliminate the requirement that no school have a majority of minority students. The district contended that though it had abandoned its racially segregative practices, changing racial demographics had created new racial imbalances in the district’s schools. The federal district court refused to modify its original order, however, and the Ninth Circuit Court of Appeals upheld the district court’s ruling.
Reviewing this decision, Justice William H. Rehnquist, joined by five other justices, concluded that the district court had abused its authority in refusing to remove the requirement that no district school have a majority of minority students. According to the Supreme Court, there had been no showing that changes in the racial mix of the Pasadena schools had been caused by the school district’s policies. Since the school district had implemented a racially neutral attendance policy, the federal district court was not entitled to require a continual reshuffling of attendance zones to maintain an optimal racial mix. Justices Thurgood Marshall and William Brennan dissented from this holding, emphasizing the breadth of discretion normally allotted to federal district courts to remedy school segregation once a constitutional violation had been shown.
The majority’s decision signaled that the broad discretion with which the Court previously had seemed to have invested federal district courts was not without limits. It had been widely thought that once officially sanctioned or de jure segregation had been shown, a federal court had great latitude in eliminating not only such de jure segregation but also de facto segregation— that is, segregation not necessarily tied to official conduct. The majority’s decision in this case, however, signified otherwise.
Bibliography
Imber, Michael. Education Law. 5th ed. London: Routledge, 2014. eBook Collection (EBSCOhost). Web. 12 May. 2015.
Kemerer, Frank R., and Peter Sansom. California School Law. Stanford: Stanford Law Books, 2013. eBook Collection (EBSCOhost). Web. 12 May 2015.
Rossum, Ralph A., and G. Alan Tarr. American Constitutional Law, Volume II : The Bill of Rights and Subsequent Amendments. New York: Westview, 2013. eBook Collection (EBSCOhost). Web. 12 May 2015.
Roth, Evan J. “Supreme Quotes.” Maine Bar Journal 28.4 (2013): 215. Publisher Provided Full Text Searching File. Web. 12 May 2015.
“School Desegregation.” The Supreme Court : A to Z. Jost, Kenneth, ed. London: Routledge, 2013. eBook Collection (EBSCOhost). Web. 12 May 2015.
Welsch, Ellen Bowman. “Case Comment: Desegregating a Demographically Changing School District—Pasadena City Board of Education v. Spangler.” Seattle University Law Review 1.1 (1977): 212. Publisher Provided Full Text Searching File. Web. 12 May 2015.