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Meredith v. Jefferson County Board of Education

Parents Involved in Community Schools v. Seattle School District No. 1
Seal of the United States Supreme Court.svg
Argued December 4, 2006
Decided June 28, 2007
Full case name Parents Involved in Community Schools, Petitioner v. Seattle School District No. 1, et al.; Crystal D. Meredith, Custodial Parent and Next Friend of Joshua Ryan McDonald v. Jefferson County Board of Education, et al.
Citations 551 U.S. 701 (more)
127 S. Ct. 2738; 75 U.S.L.W. 4577; 20 Fla. L. Weekly Fed. S 490
Prior history Certiorari to the United States courts of appeals for the Ninth and Sixth Circuits.
Holding
The student assignment plan of Seattle Public Schools and Jefferson County Public Schools does not meet the narrowly tailored and compelling interest requirements for a race-based assignment plan because it is used only to achieve "racial balance." Public schools may not use race as the sole determining factor for assigning students to schools. Race-conscious objectives to achieve diverse school environment may be acceptable.
Court membership
Case opinions
Majority Roberts (parts I, II, III–A, III–C), joined by Scalia, Kennedy, Thomas, Alito
Concurrence Roberts (parts III–B, IV), joined by Scalia, Thomas, Alito
Concurrence Thomas
Concurrence Kennedy
Dissent Stevens
Dissent Breyer, joined by Stevens, Souter, Ginsburg
Laws applied
U.S. Const. amend. XIV

Parents Involved in Community Schools v. Seattle School District No. 1, 551 U.S. 701 (2007), also known as the "PICS" case, is a United States Supreme Court case. At issue were voluntary school desegregation/integration efforts in Seattle, Washington and Louisville, Kentucky. Both school districts voluntarily used individualized racial classifications to achieve diversity and/or avoid racial isolation through student assignment. The Court recognized that seeking diversity and avoiding racial isolation are compelling state interests. However, the Court struck down both school districts' assignment plans, finding that the plans were not sufficiently "narrowly tailored"; a legal term that essentially suggests that the means or method being employed (in this case, a student assignment plan based on individualized racial classifications) is closely and narrowly tied to the ends (the stated goals of achieving diversity and/or avoiding racial isolation).

The Parents Involved decision was a "split decision"—the Court broke 4–1–4 on key aspects of the case, with Justice Kennedy writing the swing vote opinion. Kennedy agreed with four Justices (Roberts, Scalia, Thomas, and Alito) that the programs used by Seattle and Louisville did not pass constitutional muster (because the districts failed to demonstrate that their plans were sufficiently narrowly tailored); but Kennedy also found, along with four Justices (Breyer, Stevens, Souter, and Ginsburg), that compelling interests exist in avoiding racial isolation and promoting diversity. With respect to avoiding racial isolation, Kennedy wrote that, "[a] compelling interest exists in avoiding racial isolation, an interest that a school district, in its discretion and expertise, may choose to pursue." He went on to say that, "[w]hat the government is not permitted to do, absent a showing of necessity not made here, is to classify every student on the basis of race and to assign each of them to schools based on that classification."

None of the nine Supreme Court Justices disputed that, as Justice Kennedy put it, the case was "argued on the assumption...that the discrimination in question did not result from de jure [i.e. state-sponsored] actions." This made the case different from Brown v. Board of Education. All of the dissenting Justices acknowledged that "the Constitution does not impose a duty to desegregate upon districts," if the districts have not practiced racial discrimination. However, the dissenters argued that the Constitution permits such desegregation, even though it does not require it.


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