Board of Education of Oklahoma City v. Dowell


Significance: The Supreme Court held that federal district courts may end court-supervised busing plans when the “effects of past intentional discrimination” have been removed “as far as practicable” and a local school board has complied with a desegregation order for a “reasonable period of time.”

In 1985 the Oklahoma City school district requested dissolution of a desegregation decree that had been in effect for nineteen years. Approving the request, the district judge observed that the school board had done nothing to promote residential segregation for twenty-five years and that it had bused students in good faith for more than a decade. The court of appeals reversed the judgment because the majority of children in the district continued to attend one-race schools, reflecting demographic residential patterns mostly developed after the decree had gone into effect. By a 5-3 vote, the Court ruled in favor of the district judge's decision. Chief Justice William H. Rehnquist argued that desegregation decrees had never been intended to “operate in perpetuity” and that the tradition of local control over public schools justified the dissolution of court-supervised desegregation plans as long as present residential segregation was a result of private decisions and economic factors rather than official policies. The Court amplified the Dowell decision in Freeman v. Pitts (1992), holding that district judges have discretion to withdraw supervision of school districts once officials have shown good faith compliance with a court-ordered desegregation plan, even if some vestiges of de jure segregation continued.