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Brown v. Board of Education

    Brief Fact Summary. After ruling school segregation unconstitutional in Brown v. Board of Education, 347 U.S. 483 (1954) (Brown I), local school boards sought judicial guidance as to the appropriate remedy for the segregation.

    Synopsis of Rule of Law. Federal courts may sit in equity to enforce judgments of the Supreme Court of the United States (Supreme Court).

    Facts. After Brown I, some of the defendant school districts met the ruling with great resistance. While some school districts readily adopted plans to desegregate their school systems, others sought guidance from the Supreme Court on the appropriate remedy for school segregation.

    Issue. What is the appropriate judicial remedy for the damages caused by school segregation?

    Held. Cases remanded to federal district courts for equitable resolution.
    Chief Justice Earl Warren (J. Warren) stated that local school districts were to come into compliance with Brown I at the earliest possible date. J. Warren also notes that the steps toward compliance would vary depending on the circumstances present in various local school systems.
    Because of the variety of local problems, the Supreme Court remanded the individual cases to the district courts in which the suits were filed, asking that the district courts apply principles of equity to guide individual districts into compliance with the tenets of Brown I. Equitable remedies were appropriate because of the traditional flexibility of such remedies and because of the ability of equity to reconcile the personal stakes of the plaintiffs with the public interest in the elimination of obstacles to the implementation of Brown I.

    Discussion. Apart from the delay gained by asking for clarification of the principles of Brown I, the respondents in Brown II were asking for clear goals and guidelines for reaching compliance with Brown I. The Supreme Court disappointed them by not only not providing concrete guidelines, but also requiring the district courts to sit in equity over their compliance process – that is, asking that the judicial review of the school districts’ policies maximize its flexibility.


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