Cisneros v. Corpus Christi School District

The Case

Geography is a big factor in understanding the Cisneros case. The Corpus Christi Independent School District encompassed the metropolitan area of Corpus Christi, Texas. The Mexican American and Black population of the district was concentrated in a narrow area that makes up the middle part of the district, known as the Mexican “corridor.” The southern part of the district was almost exclusively a White residential area. Marked residential segregation thus existed. When the school board imposed neighborhood school zones in these residentially segregated neighborhoods, this resulted in Mexican American and White children being substantially separated in the public schools.

In 1968, José Cisneros and twenty-five other Mexican American parents filed suit against the Corpus Christi Independent School District, charging operation of a dual school system at all levels on a de facto basis. The attorney for the plaintiffs, James de Anda, was a well-regarded Mexican American civil rights lawyer. De Anda argued that Mexican Americans were an identifiable minority group and had been illegally segregated by state action because of the school district plan. The school district maintained that since there was no state law requiring segregation, there was no dual school system. Further, the school board said it did not take any action that fostered segregation with that objective in mind.

The school board did not deny that severe racial and ethnic separation existed in the Corpus Christi public schools. It submitted that this separation was not the result of school board actions and policies, however, but rather of housing patterns, geographic fluctuations, and other social and economic factors prevalent in the city. There was no discriminatory motive or purpose on its part, the board said.

The Rulings

The Brown v. Board of Education decision in 1954 arose in the context of segregation by state law, often termed classical or historical de jure segregation. Brown prohibits segregation in public schools as a result of state action. It requires the making of two distinct factual determinations to support a finding of unlawful segregation. First, a denial of equal educational opportunity, in terms of racial or ethnic segregation, must be found to exist. Second, this segregation must result from state action. In the Brown case, because state laws were involved, the plaintiffs could demonstrate “state action” as required for purposes of the Fourteenth Amendment. In Cisneros, no laws of the state were involved in the discrimination. However, the Court of Appeals decided to include actions of public school authorities as being within the ambit of “state action.”

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