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Washington v. Seattle School District No. 1

    Citation. 458 U.S. 457, 102 S. Ct. 3187, 73 L. Ed. 2d 896, 1982 U.S. 151.

    Brief Fact Summary. The Seattle School Board mandated busing to expand racial integration in its schools. A majority of statewide voters thereupon passed an initiative terminating the policy of mandatory busing.

    Synopsis of Rule of Law. Although the political majority may restructure the political process to hinder everyone from seeking to obtain benefits from the government, it may not place special burdens on racial minorities within the political process.


    Facts. In 1978, the Seattle School Board voluntarily adopted a plan of mandatory busing to expand racial integration in its schools. In response, opponents of the plan passed a statewide initiative (“Initiative 350”) designed to terminate the policy of mandatory busing. Thereupon, the Seattle School Board sued, challenging the constitutionality of the statewide initiative.

    Issue. Was the statewide initiative adopted by the citizens of Washington, overriding the Seattle School Board’s policy of mandatory busing, a violation of the Fourteenth Amendment of the United States Constitution (Constitution)?

    Held. Yes.
    Justice Harry Blackmun (J. Blackmun) stated that despite its facial neutrality, there is little doubt that Initiative 350 was enacted for racially motivated reasons. Desegregation of the public schools has the effect primarily of benefiting minority children and was designed for that reason. Before the adoption of the initiative, the power to determine, which programs were best for the school district – including those involving desegregation – rested entirely with the school board. After the passage of Initiative 350, discretion for all matters except one – those involving integration – were left to the school board’s complete discretion.

    Dissent. Justice Lewis Powell (J. Powell) argued that the States are under no constitutional duty to adopt integration programs in their schools. No one questions whether the school district itself could have changed its mind and cancelled the integration program without violating the United States Constitution (Constitution). This opinion would suggest that the States’ have less authority. Until this decision, no one would have questioned the authority of a State to abolish a school board altogether or to require that school board policies conform to any lawful State policy.

    Discussion. This case illustrates how governing bodies, by making certain political decisions, can subject themselves to constitutional restraints in areas where they otherwise would have been free from them.


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