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Hobson v. Hansen
Hobson v. Hansen is the earliest documented case to undertake the issue of a public school's engagement in the discriminatory practice of tracking, which served to foster segregation. The case findings led to the reform of education for African American and poor students in the Washington, D.C., school system and advanced educational reform in the area of equal educational opportunity for others, such as children with disabilities. This entry presents a contextual framework for the case, provides a description of the problematic four-track system, and offers a summary of the case.
Prior to the U.S. Supreme Court's May 1954 decision in Brown v. Board of Education, the organizational structure in place in the Washington, D.C., school system consisted of two divisions under the administration of one superintendent and governed by one board of education: Division I schools for White students and Division II schools for African American students. Although the Board of Education adopted policies to integrate the district in September 1954, its action also introduced optional attendance zones and exempted White students from the neighborhood attendance policy that would have placed them in unequal, predominantly African American schools. Additionally, the policy also continued the race-based teacher-assignment system in effect prior to 1954. Dr. Carl Hansen was the administrator for Division I elementary schools and the administrator for districtwide curriculum, which gave him the responsibility for a committee of secondary school educators and lay leaders in the design and implementation of the district's four-track system of curriculum.
The tracking system challenged in Hobson v. Hansen placed students in one of four educational programs: honors, college preparatory, general, and basic. Criteria for all four tracks included aptitude tests even though African American children were not part of the norm population for the tests. Faculty reviewed aptitude tests, achievement tests, reading levels (looking for students two or more levels above grade), previous academic performance, students' interest, parental consent, physical and emotional stamina, and teacher recom mendations as criteria to determine a student's placement in the honors track. Criteria for the college preparatory track were the same as the honors track with the exception that students were required to read at or above grade level. Any student, excluding students who met the criteria for the basic track, could choose placement in the general track, which offered the same curriculum that was in place prior to the new tracking system. Faculty determined student placement in the basic track using a three-pronged review process: aptitude test scores of 75 or lower, achievement test scores three or more levels below grade level in reading and mathematics, and teacher recommendation. Although students started basic track programs as early as first grade, the majority of the children initiated their programs in fourth grade, with African American students comprising the greatest percentage of students. The district designed the basic curriculum for children with mental retardation, and despite the existence of cross-tracking among other tracks, basic track placements were usually permanent. Hansen first implemented the track system in the high schools in September 1956 and expanded it to junior high and elementary schools in 1959.
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