Crawford v. Board of Education of the City of Los Angeles
Crawford v. Board of Education of the City of Los Angeles (1982) involved two decades of legal wrangling over the desegregation of Los Angeles schools, including several rounds through California’s state courts and a trip to the U.S. Supreme Court. The case began in August 1963, when the American Civil Liberties Union (ACLU), representing a group of minority students, brought a class action suit against the Los Angeles City Board of Education seeking to desegregate two high schools, one predominantly African American and the other mostly White. The dispute was later expanded to include the entire district.
An Extended Conflict
After initially filing suit in 1963, the plaintiffs spent nearly five years trying to persuade the board to desegregate its schools. In 1968, litigation replaced negotiations. A trial court found that the board substantially engaged in de jure segregation in violation of the state and federal Constitutions, and in 1970, the court ordered the board to prepare a desegregation plan for immediate use. The board sought further review, which did not come until 1975.
While awaiting the appeal, the Supreme Court made it clear that for the purpose of the federal Constitution, courts could order remedies only in de jure segregation effected by state action. When the appeal finally came through, the court reversed in favor of the board. However, a year later, the Supreme Court of California, in turn, reversed in favor of the plaintiffs, affirming the order calling on the board to desegregate its schools (Crawford v. Board of Education of the City of Los Angeles, 1976).
At the next stage in the controversy, the school board submitted a mostly voluntary plan for desegregating the schools that a trial court declared ineffective in July 1977. The court ordered the board to submit a new plan within 90 days. The new plan called for mandatory student reassignment and busing to be implemented in the fall of 1978. Yet, before the plan could be implemented, a group called Bustop, composed of White parents, challenged the mandatory busing part of the plan. Ultimately, the Supreme Court denied the group’s request for a stay (Bustop, Inc. v. Board of Education of the City of Los Angeles, 1978). In denying the stay, the Court discussed the difference between the California and federal constitutions, noting that when state courts interpret their own constitutions, they may impose more rigorous restrictions on local school boards than would be permitted under the federal counterpart.
On remand, the opponents of mandatory busing relied on the distinction in the Supreme Court’s opinion. To this end, the state legislature placed a constitutional amendment, Proposition 1, on the November 1979 ballot that declared school boards had no obligation or responsibility to exceed the guarantees of the Equal Protection Clause of the Fourteenth Amendment with regard to student school assignment or pupil transportation. Once the amendment passed, the school board immediately invoked Proposition 1, seeking a judicial order to end all mandatory student reassignment and busing.
A Final Challenge
In July 1980, a state trial court rejected the board’s request, calling for a new mandatory busing plan in relying on the de jure segregation finding 10 years earlier. An intermediate appellate court decided that the trial court, not the school board, had the responsibility for overseeing the desegregation plan. After the Supreme Court of California refused to review the case, the school board submitted a completely voluntary plan for desegregating the schools that led the trial court, in late 1981, to end its jurisdiction over Crawford. Even so, the dispute did not end there, because the viability of the state constitutional amendment had yet to be resolved.
The question that came before the Supreme Court in Crawford was whether Proposition 1 violated the Equal Protection Clause of the Fourteenth Amendment. The Court upheld the constitutionality of the amendment based on four main points. First, the Court ruled that because the proposition did not involve a racial classification, it was constitutional. Second, the Court pointed out that an attempt to repeal or modify desegregation or antidiscrimination laws as in Crawford did not involve a presumptively invalid classification based on race. Third, the justices agreed that the state courts correctly decided that the amendment was not based on a discriminatory purpose. Fourth, the Court concluded that the Fourteenth Amendment does not prohibit states from backing away from its dictates once they have completed actions that exceeded its dictates.
Darlene Y. Bruner
- Bustop, Inc. v. Board of Education of the City of Los Angeles, 439 U.S. 1382, 184 (1978).
- Crawford v. Board of Education of the City of Los Angeles, 130 Cal. Rptr. 724 (Cal. 1976), 170 Cal. Rptr. 495 (Cal Ct. App. 1980), 458 U.S. 527 (1982).