Parents Involved in Community Schools v. Seattle School District No. 1

Citation. 555 U.S. 701 (2007)

Brief Fact Summary.

The school districts in Seattle voluntarily adopted student assignment plans that rely upon race to determine which public schools certain children may attend, so that the racial balance at the school falls within a predetermined range based on the racial composition of the school district as a whole. Parents of students denied assignment to particular schools under these plans solely because of their race and brought suit, arguing that allocating children to different public schools on the basis of race violated the Fourteenth Amendment guarantee of equal protection.

Synopsis of Rule of Law.

When the government distributes burdens or benefits on the basis of individual racial classifications, that action is reviewed under strict scrutiny. To satisfy this standard of review, a party must demonstrate that the use of individual racial classifications in a plan is “narrowly tailored” to achieve a “compelling” government interest.

Facts.

The school districts in Seattle voluntarily adopted student assignment plans that rely upon race to determine which public schools certain children may attend, so that the racial balance at the school falls within a predetermined range based on the racial composition of the school district as a whole. The Seattle school district classified children as white or non-white. Seattle has never operated legally segregated schools and most white students live in the northern part of Seattle while most students of other racial backgrounds live in the southern part. This plan had inevitably allocated both white and non-white students to school districts they and their parents did not want. Parents of students denied assignment to particular schools under these plans solely because of their race and brought suit, arguing that allocating children to different public schools on the basis of race violated the Fourteenth Amendment guarantee of equal protection.

Issue.

May a public school that had not operated legally segregated schools or has been found to be unitary choose to classify students by race and rely upon that classification in making school assignments?

Held.

No. Before Brown, schoolchildren were told where they could and could not go to school based on the color of their skin. The school districts here have not carried the heavy burden of demonstrating that the Court should allow this once again. For schools that never segregated on the basis of race, the Seattle school districts must achieve a system of determining admission to the public schools on a nonracial basis and stop assigning students on a racial basis.

Dissent.

Justice Stevens and Breyer

Justice Stevens: The majority in stating that “before Brown, schoolchildren were told where they could and could not go to school based on the color of their skin” fails to note that it was only back schoolchildren who were so ordered. No history tells white children struggling to attend black schools.

Justice Breyer: A longstanding legal authority tells that the Equal Protection Clause permits local school boards to use race-conscious criteria to achieve positive race-related goals. The context in our case in one in which school districts seek to advance or to maintain racial integration in schools, which shall be deemed as race-conscious. Moreover, the school districts’ interest in eliminating school-by-school racial isolation and increasing racial mixture characterizes individual student’s school experience.

Concurrence.

Justice Thomas

Contrary to the dissent’s arguments, resegregation is not happening in Seattle nor is there clear evidence that racially balanced schools have improved educational outcomes for black children. Moreover, the dissent’s approach confers on judges to power to say what sorts of discrimination are benign and which are evil. To defer to one’s preferred result, however, is not to defer at all. Our Constitution is color-blind and any race-based decisionmaking is unconstitutional.

Discussion.

In the present cases, race is not considered as part of a broader effort to achieve “exposure to widely diverse people, cultures, ideas, and viewpoints.” Instead, race, for some students, is determinative standing alone. The plans adopted by the school districts do not provide a meaningful individualized review of applicants but rely solely on racial classifications in a “non-individualized, mechanical” way. The districts provided no evidence that the level of racial diversity necessary to achieve the asserted educational benefits happens to coincide with the racial demographics of each school district; rather, they simply assume that the racial breakdown entails educational benefits. The districts have also failed to demonstrate that they considered alternatives to explicit racial classifications to achieve their stated goals.