Milliken v. Bradley Case Brief

Why is the case important?

The schools of the city of Detroit, Michigan were racially imbalanced in the eyes of the District Court. The court’s remedy was to redraw lines of neighboring suburban school districts to achieve racial balance within the city’s schools.

Facts of the case

A suit charging that the Detroit, Michigan public school system was racially segregated as a result of official policies was filed against Governor Milliken. After reviewing the case and concluding the system was segregated, a district court ordered the adoption of a desegregation plan that encompassed eighty-five outlying school districts. The lower court found that Detroit-only plans were inadequate. The U.S. Court of Appeals for the Sixth Circuit affirmed the metropolitan plan. This case was decided together with Allen Park Public Schools v. Bradley and Grosse Pointe Public School System v. Bradley.

Question

May District Courts redraw the boundaries of integrated school districts to achieve integration in a segregated district?

Answer

“Not without an interdistrict violation or effect.
Chief Justice Warren Burger (J. Burger), writing for the majority, notes that there are many practical difficulties in the proposed plan. It is unclear what the status of currently elected school officials would be in the new super district

  • how taxes would be levied and distributed and who should make curriculum decisions.
    The scope of the remedy is determined by the nature and scope of the constitutional violation. In the present case, the discriminatory acts of a single district must be a substantial cause of interdistrict segregation. Thus, if district lines were drawn on the basis of race, or if discriminatory acts of one district caused segregation in another, an interdistrict remedy may be in order. However, this is not the case here.”

    Conclusion

    The United States Supreme Court stated that a federal remedial power could be exercised only on the basis of a constitutional violation and the nature of the violation would determine the scope of the remedy. The court further found that before the boundaries of separate and autonomous school districts could be set aside by imposing a cross-district remedy, it must first be shown that there had been a constitutional violation within one district that produces a significant segregative effect in another district. Specifically, it must be shown that racially discriminatory acts of the state or local school districts, or of a single school district, have been a substantial cause of interdistrict segregation.

    • Case Brief: 1974
    • Petitioner: William G. Milliken, Governor of Michigan et al.
    • Respondent: Ronald Bradley et al.
    • Decided by: Burger Court

    Citation: 433 US 267 (1977)
    Argued: Mar 22, 1977
    Decided: Jun 27, 1977