Crawford v. Los Angeles Board of Educ. - 458 U.S. 527 (1982)
U.S. Supreme Court
Crawford v. Los Angeles Board of Educ., 458 U.S. 527 (1982)
Crawford v. Board of Education of City of Los Angeles
Argued March 22, 1982
Decided June 30, 1982
458 U.S. 527
In a California state court action seeking desegregation of the schools in the Los Angeles Unified School District (District), the trial court, in 1970, found de jure segregation in violation of both the State and Federal Constitutions and ordered the District to prepare a desegregation plan. The California Supreme Court affirmed, but based its decision solely upon the Equal Protection Clause of the State Constitution, which bars de facto as well as de jure segregation. On remand, the trial court approved a desegregation plan that included substantial mandatory pupil reassignment and busing. While the trial court was considering alternative new plans in 1979, the voters of California ratified an amendment (Proposition I) to the State Constitution which provides that state courts shall not order mandatory pupil assignment or transportation unless a federal court "would be permitted under federal decisional law" to do so to remedy a violation of the Equal Protection Clause of the Fourteenth Amendment to the Federal Constitution. The trial court denied the District's request to halt all mandatory reassignment and busing, holding that Proposition I was not applicable in light of the court's 1970 finding of de jure segregation in violation of the Fourteenth Amendment. The court then ordered implementation of a revised plan that again included substantial mandatory pupil reassignment and busing. The California Court of Appeal reversed, concluding that the trial court's 1970 findings of fact would not support the conclusion that the District had violated the Federal Constitution through intentional segregation. The Court of Appeal also held that Proposition I was constitutional under the Fourteenth Amendment, and barred that part of the plan requiring mandatory student reassignment and busing.
Held: Proposition I does not violate the Fourteenth Amendment. Pp. 458 U. S. 535-545.
(a) This Court's decisions will not support the contention that, once a State chooses to do "more" than the Fourteenth Amendment requires, it may never recede. Such an interpretation of that Amendment would be destructive of a State's democratic processes and of its ability to experiment in dealing with the problems of a heterogeneous population. Proposition I does not embody, expressly or implicitly, a racial classification.
The simple repeal or modification of desegregation or antidiscrimination laws, without more, does not embody a presumptively invalid racial classification. Pp. 458 U. S. 535-540.
(b) Proposition I cannot be characterized as something more than a mere repeal. Hunter v. Erickson, 393 U. S. 385, distinguished. The State Constitution still places upon school boards a greater duty to desegregate than does the Fourteenth Amendment. Nor does Proposition I allocate governmental or judicial power on the basis of a discriminatory principle. A "dual court system" -- one for the racial majority and one for the racial minority -- is not established simply because civil rights remedies are different from those available in other areas. It was constitutional for the people of the State to determine that the Fourteenth Amendment's standard was more appropriate for California courts to apply in desegregation cases than the standard repealed by Proposition I. Pp. 458 U. S. 540-542.
(c) Even if it could be assumed that Proposition I had a disproportionate adverse effect on racial minorities, there is no reason to differ with the state appellate court's conclusion that Proposition I in fact was not enacted with a discriminatory purpose. The purposes of the Proposition -- chief among them the educational benefits of neighborhood schooling -- are legitimate, nondiscriminatory objectives, and the state court characterized the claim of discriminatory intent on the part of millions of voters as but "pure speculation." Pp. 458 U. S. 543-545.
113 Cal.App.3d 633, 170 Cal.Rptr. 495, affirmed.
POWELL, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, BLACKMUN, REHNQUIST, STEVENS, and O'CONNOR, JJ., joined. BLACKMUN, J., filed a concurring opinion, in which BRENNAN, J., joined,post, p. 458 U. S. 545. MARSHALL, J., filed a dissenting opinion,post, p. 458 U. S. 547.