Milliken v. Bradley facts for kids
Quick facts for kids Milliken v. Bradley |
|
|---|---|
|
|
| Argued February 27, 1974 Decided July 25, 1974 |
|
| Full case name | Milliken, Governor of Michigan, et al. v. Bradley, et al. |
| Citations | 418 U.S. 717 (more)
94 S. Ct. 3112; 41 L. Ed. 2d 1069; 1974 U.S. LEXIS 94
|
| Prior history | Bradley v. Milliken, 433 F.2d 897 (6th Cir. 1970); 438 F.2d 945 (6th Cir. 1971); 338 F. Supp. 582 (E.D. Mich. 1971); 345 F. Supp. 914 (E.D. Mich. 1972); affirmed, 484 F.2d 215 (6th Cir. 1973); cert. granted, 414 U.S. 1038 (1973). |
| Subsequent history | On remand, Bradley v. Milliken, 402 F. Supp. 1096 (E.D. Mich. 1975); affirmed and remanded, 540 F.2d 229 (6th Cir. 1976); cert. granted, 429 U.S. 958 (1976); affirmed, 433 U.S. 267 (1977). |
| Holding | |
| The Court held that "[w]ith no showing of significant violation by the 53 outlying school districts and no evidence of any interdistrict violation or effect," the district court's remedy was "wholly impermissible" and not justified by Brown v. Board of Education (1954). | |
| Court membership | |
| Case opinions | |
| Majority | Burger, joined by Stewart, Blackmun, Powell, Rehnquist |
| Concurrence | Stewart |
| Dissent | Douglas |
| Dissent | White, joined by Douglas, Brennan, Marshall |
| Dissent | Marshall, joined by Douglas, Brennan, White |
| Laws applied | |
| U.S. Const. amend. XIV | |
Milliken v. Bradley was an important case decided by the Supreme Court of the United States in 1974. It was about how to make public schools fair for all students, especially after the famous Brown v. Board of Education decision in 1954.
This case looked at plans to end segregation in schools in Detroit, Michigan. Segregation means keeping different groups of people apart. The question was whether students could be bused across different school district lines to create more diverse schools.
The Supreme Court's decision made it clearer when segregation was allowed. It said that segregation was okay if it wasn't caused by a specific rule or action from a school district. This is called de facto segregation (meaning "by fact" or "by circumstance"). However, if segregation was caused by a deliberate policy, it was called de jure segregation (meaning "by law"). The Court ruled that school systems were only responsible for ending segregation within their own district. They were not responsible for desegregating schools across different districts unless it was proven that those districts had intentionally caused segregation.
Contents
School Segregation in the U.S.
Why Schools Were Segregated
The Brown v. Board of Education case in 1954 said that separate schools for different races were not equal. This ruling aimed to end segregation. However, putting this decision into practice was very difficult.
Many things made schools stay segregated. For example, many Black families moved to cities, while many white families moved to the suburbs. Also, some rules and practices made it hard for non-white people to live in certain suburban areas. This led to many city schools having mostly Black students, and suburban schools having mostly white students.
Detroit's Segregation Story
Detroit is a city in the United States that has a history of being very segregated. During a time called the Great Migration, many Black people moved to Detroit. When they arrived, they were often not allowed to live in white neighborhoods.
This separation was enforced in several ways:
- Economic discrimination: Some areas were marked as "risky" for loans, making it hard for Black families to buy homes there. This practice was called redlining.
- Property rules: Some property deeds had rules that prevented non-white people from buying homes.
- Violence: Sometimes, homes were damaged or people were attacked to keep neighborhoods separated.
Over time, some of these unfair rules in Detroit began to change. This happened as more people became aware of the Civil Rights Movement. Also, as more Black people gained the right to vote, their power in the city grew. These changes allowed Black families to move into more neighborhoods within the city. However, in the suburbs around Detroit, many segregating practices continued.
By the mid-1970s, more than two-thirds of the students in Detroit's city schools were Black.
The Court Case Begins
On August 18, 1970, a group called the NAACP (National Association for the Advancement of Colored People) sued officials in Michigan, including Governor William Milliken. The trial started on April 6, 1971.
The NAACP argued that even though schools in Detroit were not officially segregated by law, the city and the state had put policies in place that actually increased racial separation in schools. They also said that unfair housing practices, like redlining, were directly connected to school segregation.
A judge named Stephen John Roth first heard the case. He ruled that the state and school districts were responsible for the segregation. He ordered a plan to desegregate schools across the entire metropolitan area, which included many different school districts.
The state officials who were sued then appealed this decision to the Supreme Court. The Supreme Court agreed to hear the case on February 27, 1974.
The Supreme Court's Decision
The Supreme Court overturned the lower courts' decision in a 5-to-4 vote. This meant they disagreed with the plan to desegregate schools across different districts.
The Court decided that school districts did not have to desegregate across their boundary lines unless it was proven that those lines were drawn with the specific goal of separating races. So, if school district lines seemed to cause segregation but weren't drawn with racist intent, they were not illegal.
The Court explained that there was "no showing of significant violation" by the 53 school districts outside Detroit. Also, there was "no evidence of any interdistrict violation or effect." This meant the lower court's plan to mix students from different districts was "wholly impermissible." The Court said this plan was not supported by the Brown v. Board of Education ruling.
The Supreme Court also said that ending segregation did not mean every school, grade, or classroom had to have a specific racial balance. They agreed that the Constitutional rights of Black students in Detroit's city schools had been violated. However, they ruled that the suburban districts and the State of Michigan were not responsible for the segregation that resulted across district lines.
The Court also stressed that local communities should have control over their own schools.
What the Judges Who Disagreed Said
Four justices disagreed with the Supreme Court's decision. Here's what some of them said:
Justice Thurgood Marshall wrote that:
School district lines, even if drawn innocently, will be seen as fences separating races. This happens when white parents move their children from Detroit city schools to the suburbs to keep them in all-white schools.
Justice Douglas wrote that:
Today's decision... means that there is no violation of the Equal Protection Clause, even if schools are separated by race and if the Black schools are not only 'separate' but 'inferior.'... Michigan, through different ways, has created Black school districts and white school districts over the years. The job of fairness is to create one system for the affected area when the State washes its hands of its own creations.
How the Case Changed Things
The Supreme Court's decision meant that Detroit's city school district had to spread its smaller number of white students more evenly within its own boundaries. However, it also allowed many white families to move out of the city to the suburbs. This movement, often called white flight, made the city's schools even more segregated.
As a result, the Detroit Public Schools became even more heavily Black over the next two decades. By 1987, about 90% of the students in Detroit's public schools were Black.
This ruling helped set a pattern across the United States. City schools often had mostly Black students, while the surrounding suburban schools had mostly white students.
