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Monroe v. Board of Commissioners

Monroe v. Board of Commissioners (1968) involved the adequacy of the city of Jackson, Tennessee's, plan to desegregate its public schools in the wake of Brown v. Board of Education of Topeka. Monroe is another one of the cases in which the Supreme Court reviewed the efforts of school boards, finding that it developed and administered a plan that allowed it to remain segregated. The Court remanded Monroe for modifications to create a unitary school system.

Facts of the Case

A state law from 1954 required racially segregated schools in Tennessee. The city had eight elementary schools, three junior high schools, and two senior high schools. Five elementary schools, two junior high schools, and one senior high school were for Whites. After Brown, the state adopted a pupil placement law. Basically, the law allowed current students to stay put and gave local school boards the authority to approve pupil placement and transfer requests. Under this plan, no White students enrolled in African American schools, and only seven African American students applied for enrollment in the White schools.

In 1962, the Sixth Circuit ruled that the placement plan was inadequate when it came to dismantling a segregated school system. After the plaintiffs filed action in the district court in 1963, a plan with court-ordered modifications was adopted. Elementary students living within attendance zones were automatically assigned to schools in zones that had geographic or neutral boundaries; however, the plan also included a free transfer provision. Citing evidence that the African American schools had remained one-race schools and that only 118 African American students attended White schools, the court held that the plan had been administered in a racially discriminatory manner.

The board also filed its plan for desegregating the junior high schools. In 1964, all three junior high schools retained their traditional racial identities. The faculties of the schools were also segregated. Despite parental protests that the board had gerrymandered school attendance zones, the district court ruled for the board. The court further held that a feeder system recommended by expert witnesses did not have to be adopted. The court of appeals affirmed the decision but remanded for further proceedings on the issue of faculty desegregation.

The Court's Ruling

The Supreme Court granted certiorari and rendered its decision on the same day as the decision in Green v. County School Board of New Kent County. Reviewing the evidence and the holding in Green, the Supreme Court concluded that the Jackson schools had remained one-race schools. After three years, Merry Junior High School was still a one-race school, for example. White students who had been assigned to Merry Junior High School transferred elsewhere. There were only seven African American students in the mainly White Tigrett Junior High School. The only exception was the Jackson School, where there were a substantial number of African American students. The same pattern was maintained in the elementary schools in the district.

The free transfer plan had not allowed the board to meet its affirmative duty to create a unitary school system “in which racial discrimination would be eliminated root and branch,” the Supreme Court ruled. Until the district court intervened, the board had administered the plan in a discriminatory manner, the court said, and this resulted in a lengthy delay in the desegregation of the schools. Furthermore, the court asserted that no plan can have racial segregation as its consequence. The Court made no bones about the fact that the board had administered a plan that allowed it to remain comfortable and unchanged with regard to racial segregation.

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