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

Brief Fact Summary.

Parents of school children sued the Seattle School Districts after their children were assigned to particular schools based on racial classifications to achieve integration in the school system.

Synopsis of Rule of Law.

School districts cannot assign students to different schools based on race to achieve integration unless narrowly-tailored standards are used to promote diversity.

Facts.

Seattle School District No. 1 (Seattle) assigned students to particular schools based on their race in order to maintain a predetermined racial composition. Parents Involved in Community Schools (PICS) whose children were denied admission to particular schools sued Seattle on the basis of equal protection violations. The district court and court of appeals upheld the constitutionality of the racial assignments.

Issue.

Whether school districts that do not have a history of discrimination can assign students to different schools based on race to achieve integration?

Held.

No. Reversed.

Dissent.

(Stevens, J.) The majority opinion misinterpreted the Brown v. Board of Education, 347 U.S. 483 (1954) decision.

(Breyer, J.) School authorities should be allowed to bring about desegregation through whatever means they see appropriate without interference from the courts. Judges are not as competent as schools in determining what efforts best benefit students.

Concurrence.

(Kennedy, J.) The school districts did not meet the burden of proof under strict scrutiny that required narrowly tailored policies that serve a compelling government interest.

(Thomas, J.) Diverse classrooms do not increase student performance because studies show that historically black colleges and universities promote African American student success as well.

Discussion.

The use of racial classifications must be narrowly tailored to reach a compelling governmental interest. Compelling interests include resolving past discrimination and promoting diversity within the student body. The assignments of students in Seattle does not satisfy a compelling governmental interest because discrimination has not previously existed within the Seattle School District and there is no evidence showing that Seattle’s actions worked towards a specific diversity goal that benefitted the students.