The Resegregation of Public Schools

Andy Frey and Michael Wilson

Last sLiiiiiner. the Supreme Court declared voluntary student assignment plans to racially
integmtc the public schools in Louisville,Kentucky, and Seattle,Washington,unconstitutional
by a 5-4 majority.This was a landmark ruling for public school integration and civil rights;
the Parans Involved in Community Schools v. Scatik School District No. 1 (2007) ruling is likely
to atFect districts that use nice-conscious criteria for assigning students to schools. School
personnel and citizens committed to racially integrated schools need to understand this
complex decision so they can determine whether their current policy is within the legal
precedent.The case is difficult to interpret because the justices'opinions were extremely
polarized, and although Justice Kennedy agreed with the majority decision, he agreed
with the majority opinion only tn part. To participate and provide leadership in school
integration policy development, school social workers need to recognize how divided the
conservative and liberal factions were in this decision and why the Louisville and Seattle
plans failed to pass the strict scrutiny standard according to the majority ofjustices. In this
article, the trend toward resegregated schools is summarized, the recent Supreme Court
decision is analyzed, and the implications for school social workers are discussed.

KEY wtiRDS: diversity; integration; policy; student assignment

R
ecently, the Supreme Court struck
down voluntary student assignment
plans in Louisville, Kentucky, and
Seattle, Washington, thereby continuing and
extending the trend toward resegregation in
the public schools. Parents înuoli'ed in Community
Schools V. Seattle School District No. 1 { 2005) and
Meredith. Custodial Parent and Next Friend of
McDonald r. Jefferson County Board of Edwation
(2005) were heard together by the Supreme
Court. In Parents Involved in Community Schools
V. Seattle School District No. Í (2007), hereafter
referred to as Parents Involved, both districts
voluntarily preserved the freedom of parents
to choose which school their children attended
while maintaining an integrated school system,
and both relied on the racial classification of
individual students to assign them to a particular
school. In addition, petitioners in both cases
contended that assigning students to schools
solely on the basis of race was a violation of
the Fourteenth Amendment (that is, the Equal
Protection Clause) and the Civil Rights Act of
1964.The Louisville and Seattle districts argued
that educational and intangible social benefits
(for example, socialization and good citizen-
ship) are derived from an educationally diverse
learning environment and that, because racial
diversity was their primary interest, promot-
ing that interest using race-conscious criteria
alone was necessary and justified. On June 28,
2007, Chief Justice Roberts delivered the fmal
affirming opinion, asserting that diversity is not
a "compelling interest" and that, even if it were,
the Louisville and Seattle plans were not "nar-
rowly tailored" to meet this interest.
Not only did the ruling continue and extend
the trend toward school resegregation in public
schools, it also illustrated the deep divisions be-
tween the liberal and conservative factions of the
newly configured Supreme Court and applied
pressure on school districts that rely on race-
conscious criteria to assign students to schools
to revisit their plans so that they fit within the
context of this precedent. All districts that use
race-conscious means to diversify' their schools
should revisit their policy in light of the Parents
Involved decision. We believe that this occasion
provides a unique opportunity for school social
workers to become involved in, if not lead, such
efforts. To participate or provide leadership on
integration policy development, practitioners
will need to understand the history of integra-
tion issues, the details of the Parents hwolved
decision,and the implications of this decision for
school districts. Armed with this information.

CCC Code: 1532-8759/09 Ï3.00 02009 National Association of Sociai Workers 79

school social workers will be well positioned to v. Charlotte-Mechlenhurg Board of Education (1971)
initiate efforts to ensure that their district s stu-ruling ordered the use of transportation/busing,
dent assignment pohcy is aligned with the new thereby prohibiting school districts from argu-
criteria outlined by this country's highest court ing that their lack of integration is the result
and to develop a plan that best meets the needs of housing patterns, over which they have no
of all children-—-one that includes the pursuit of control.
diversity when that is an important goal. The Supreme Court's trend of promoting
school integration was reversed with Millikai
SCHOOL RESEGREGATION V. Bradley (1974), in which the Supreme Court
In 1954, the same Supreme Court, which up- released districts from having to integrate schools
held the "separate but equal doctrine" just 58 that were segregated as a result of housing pat-
years earlier, struck down the Plcssy v. Fcrgtison terns (that is, de facto segregation). A further
(1896) decision as unconstitutional in its Brown shift toward resegregation was witnessed in the
f. Board of Education /(1954) decision.The court early 1990s, when the Supreme Court ruled in
ruled that separate educational facilities were three separate cases that federal district courts
inherently unequal, prohibiting de jure (based could declare a school system "unitary," a label
on laws} racial segregation in the public schools. that validated a district's efïorts to integrate,
As justice Warren (affirming) pointed out: determining that it had done all that was fea-
sible to eliminate the consequences of prior
In these days, it is doubtful that any child may discrimination. Many school districts,including
reasonably be expected to succeed in life if he those that had been court ordered to integrate
is denied the opportunity of an education. Such as well as those that had not, viewed this as the
an opportunity, where the stace has undertaken end ot their obligation to integrate the public
to provide It, is a TI^M which must be made schools (NAACP Legal Defense and Education
available to all on cqu;!] terms, (p. 493) Fund, 2008).
The Parents /ííi'ti/r'c¡/decision extents the trend
In 1955, another decision, based on Bronm v. toward resegregation by definmg for the first
Board of Education (1954), mandated immediate time the legal parameters governing voluntary
dissolution of all racial segregation in public school integration. Although school integra-
schools (Bt-ini'ii r. Board of' Education ll, 1955). tion adversaries have interpreted the decision
The decision was ambiguous and left timelines as forbidding the use of race-conscious criteria
for desegregation up to school districts' discre- to promote school integration, the decision is
tion. With the Brown v. Board of Education U far more nuanced. For school social workers
(1955) decision, the Supreme Court delegated to participate in and lead school integration
desegregation to district courts, with orders that efforts, they must understand the legal standard
it occur "with all deliberate speed." governing the issue and the deeply divided posi-
After nearly a decade passed without sig- tion of the current Supreme Court regarding
nificant efforts to integrate the public schools. this standard.
Congress passed the Civil Rights Act of 1964,
which mandated the end of racial discrimination PARENTS INVOLVED: AN ANALYSIS OF
in all federally supported programs (NAACP THE COURT'S DECISION
Legal Defense and Education Fund, 2008). In The Parents Involved decision provided a ba-
the late 1960s and early 1970s, many school rometer for what policies and strategies are
districts were forced to integrate. For example, legally defensible with regard to the use of
in Green v. County School Board of New Kent race-conscious criteria to promote integration in
County (196H), the district was required to public schools. Although the barometer will not
eliminate all segregation in every aspect—from be fully tested until future lawsuits are filed and
students, faculty, and staffing patterns to after- heard, the details of the complex Parents Involved
school activities and transportation.The Swann decision are instructive.This section summarizes

80 Children &Si:hools VOLUME 31, NUMBER Z APRIL 1009

the history of the Louisville and Seattle student
assignment plans that led to the lawsuits,reviews
the legal standard governing voluntary school
integration, and analyzes the Supreme Court's
highly divided decision.
History of the Assignment Plans in
Louisville and Seattle
Justice Breyers dissenting opinion provides a
summary of the districts' integration efforts. In
Louisville, as with the rest of the country, the
courts ordered school desegregation after the
Brown u Board of Education U (1955) decision. In
1973, a federal court found that Jefferson County,
Kentucky, operated and maintained a segregated
school system. The student assignment plan
implemented in 1975 was revised in 19%, and
the one at issue in Meredith, Custodial Parent and
Next Friend of McDonald v.jefferson County Board
of Education (2U05) was adopted in 2001. The
1996 integration plan included racial guidelines
requiring all schools to maintain students bodies
of between 15 percent and 50 percent of African
American students {"black" and "other" were
the only distinctions).The decree forcing the
Louisville schools to desegregate was dissolved
in 1999, when a U.S. district judge ruled that the
schools were doing everything in their power to
desegregate.To prevent resegregation,thejudge
permitted the district to use race as a deciding
factor when reviewing transfer requests. At the
time the desegregation order was lifted, it was
widely understood that Jefferson C-ounty hous-
ing was largely segregated along racial lines and
that the assignment of all (district) students to
neighborhood schools would result in resegrega-
tion (Egelko, 2007).
Currently, approximately 34 percent of Jef-
ferson County Public Schools'nearly U)0,()00
students are African American, with the vast
majority of the remaining students being
white. Decisions to assign students to schools,
including between-school transfers, were based
on parental choice, availability, and the racial
guidelines. At the elementary level, students
were assigned to a "resides" school on the ba-
sis of their address. Resides schools were then
grouped into "clusters." Elementary students
were assigned to a school in one of two ways.
FRF.V AND W I L S O N / The Reseprgation of Publie Schools
Parents of kindergarteners, first graders, and
new students to the district indicated a hrst
and second preference for schools within their
cluster. If a school had exceeded the racial
guidelines, a student whose race would further
the "imbalance" would not be admitted.When
petitioner Crystal Meredith moved into the
school district in August 2002. she attempted to
enroll her kindergarten-age son in the nearest
elementary school.The school was full,and her
son was assigned to another school, which was
10 miles from their home. Meredith attempted
to transfer her son to another elementary
school, which was one mile from their house,
but was denied. Despite space being available,
the district stated that the transfer would have
adversely affected the racial balance of the
school from which Meredith was attempting
to transfer her son.
Seatde Public Schools adopted their district-
wide integration plan in 1998.The district served
45,000 students during the 2006-07 school
year. At present, 41 percent of Seattle Public
Schools' children are white; the remaining stu-
dents represent a variety of racial groups. The
district's plan stated that if a school s enrollment
of white/nonwhite students was not within 10
percentage points of the district's overall racial
balance (for the white/nonwhite ratio only),the
school was "oversubscribed." It is important to
note that the district had never been declared
legally segregated (that is. no desegregation
was ever ordered). Seattle's plan also balanced
parental choice, availability, and racial guidelines.
The Seattle plan permitted ninth graders to
rank high schools (unlimited number) in order
of preference. If more children listed a school as
their first choice than the school could accom-
modate, the district used a series of tiebreakers
to determine which students would be selected
given the allotted slots. The first tiebreaker in
the series was sibling status; siblings of students
already enrolled in the school were admitted.The
second tiebreaker depended on the needs within
the school to maintain racial diversity and the
race of the individual student. As a result, more
nonwhite students who chose one of the three
most popular schools in the district received
their top choice than did white students.
81

In the context of public education, the
Fourteenth Amendment implies that equal
educational opportunities should exist fi)r
all children, irrespective of race.
The Legal Standard Governing Voluntary
School Integration
Tiie Equal Protection Clause of the Fourteenth
Amendment to the United States Constitution
provides that "no state shall... deny to any per-
son within its jurisdiction the equal protection
of the laws" (U.S. Constitution, Section l).The
clause attempts to legislate the firm principal
within the constitution that "all men are cre-
ated equal." In the context of public education,
the Fourteenth Amendment implies that equal
educational opportunities should exist for all
children, irrespective of race. "Strict scrutiny,"
the legal standard governing voluntary sciiool
integration, is relevant when a government
entity considers race; two criteria must be met
regarding this legal standard. First, the racial
classification must serve a "compelling interest";
in short, the government body must provide a
sound reason why race-conscious measures are
needed. Second, the racial classification must
be "narrowly tailored" to further that interest
(NAACP Legal Defense and Education Fund,
2008); to meet this criterion, the use of race-
conscious means must be minimally intrusive,
clear, and consistently applied.
The Court's Decision
The court's decision should be understood from
three perspectives: those of the conservative
faction, the liberal faction, and the majority
opinion—in which Justice Kennedy agreed
with the conservative faction's decision but only
agreed with their opinion in part.
Conservative Faction. President Bush's two
new appointees (Justice Alito and Chief Justice
Roberts), along with well-known conservative
Justices Scalia and Thomas, rejected the school
districts' guidelines for diversity, asserting that
diversity was not a "compelling interest" and
that, even if it were., the plans before them were
not "narrowly tailored" to meet this interest.
82
They explained their position by stating that
the guidehnes were not tied to any pedagogic
threshold of diversity needed to obtain the
desired educational and social benefits sought.
In addition. Chief Justice Roberts stated,
"Government action dividing people by race
is inherently suspect because such classifications
promote notions of racial inferiority and lead
to a politics of racial hostility" (p. 5). In this
context. Chief Justice Roberts went on to state,
"Simply because the school district may seek
a worthy goal does not mean they are free to
discriminate on the basis of race to achieve it,
or that the racial classifications should be sub-
ject to less exacting scrutiny" (p. 36). Roberts
explained that
the school districts have not carried their heavy
burden of showing that the interest they seek
to achieve justifies che extreme means they
have chosen: discriminating among individual
students based on race by relying upon racial
classifications in making school assignments.
(p. 2, syllabus)
Roberts concluded with this highly publi-
cized quotation: "The way to stop discrimina-
tion on the basis of race is to stop discriminating
on the basis of race" (p. 41).
Extending Chief Justice Roberts' opinion
related to the compelling interest criterion.
Justice Thomas offered a separate concurring
opinion, which advocated for a "colorblind"
view of the Constitution; emphasizing his ap-
proach, he stated, "As a general rule, all race-
based government decision making—regardless
of context—is unconstitutional" (p. 6).
Liberal Faction. The dissenting opinion, sup-
ported in full by four justices, concluded that
diversity in public education is a conipelling
government interest and that the plans under
review were narrowly tailored. Furthermore,
the dissenting opinion stated that the court
had approved of narrowly tailored plans no less
race-conscious than Louisville's and Seattle's and
understood that the Constitution allowed local
communities to adopt desegregation plans on a
voluntary basis. These four justices accused the
plurality of paying
Children & Schools VOLUME Î I . NtiMBER i APRÍI, 2009
 inadequate attention to this law, to past opin-
ions' rationales, their language, and the context
in which they arise. As a result, it reverses
course and reaches the wrong conclusion. In
doing so, it distorts precedent, it misapplies the
relevant constitutional principles,it announces
legal rules that will obstruct efforts by state
and local governments to deal effectively with
the growing desegregation of public schooLs,
it threatens to substitute for present calm a
disruptive round of race-related litigation, and
it undermines Brown's promise of integrated
primary and secondary education that local
communities have sought to make a reality.
This cannot be justified in the name ot the
Equal Puîtection Clause, (p. 2)
The dissenters were adamant that, beyond the
mininuim requirements of ßroiw, the court had
permitted tremendous latitude with respect to
how local communities achieved integration.
In this respect, they believed that the majority
held the districts to too rigorous of a "strict
scrutiny" standard.
The dissent also declared that the plans were
narrowly tailored. The dissent argued that the
purpose of the Fourteenth Amendment is not
to prohibit race-conscious criteria from ever
being used (as a color-blind constitution would
indicate) but, rather, to limit their use for keeping
the races apart, justice Breyer stated,
I can fmd no case in which this Court has fol-
lowed Justici." Thomas' "colorblind" approach.
And 1 have found no case that otherwise
repudiated this constiturional asymmetry be-
tween that which seeks to exclude and that
which seeks to include members of minority
races, (p. 29)
Breyer went on to say that equating Topeka
Kansas in the 1950s and Louisville and Seattle
m the modern day was a distortion ot history.
While acknowledging that there is a price to
pay for race-based labeling in these cities, he
stated that "that cost does not approach, in
degree or in kind, the terrible harms ot slavery,
the resulting caste system, and 8Ü years of legal
racial segregation" (p. (S7).
FREY AND W I L S O N / The Resegregamn of Public Schools
In an ominous conclusion. Justice Breyer
asserted in no uncertain terms that both the
Louisville and the Seattle desegregation plans
were "narrowly tailored" to achieve their
"compelhng" and noble goals. He went on to
state that
until today, this Court understood the Consti-
tution as aftbrding the people, acting through
their elected representatives, treedotn to select
the use of "race-conscious" criteria trom
among their available options. . . .Today the
Court restricts (and some members would
eliminate) that leeway. I fear the consequences
of doing so for the law, for the schools, for
the democratic process, and for America's
efforts to create, out of its diversity, one Na-
tion. .. .To invalidate the plans under review
is to threaten the promise of Brown. The
plurality's position, I fear, would break that
promise. This is a decision that the Court
and the Nation will come to regret. I must
dissent, (p. 63)
Tbe Majority Opinion. Because the court
was deeply divided, Justice Kennedy's opinion
appears to provide direction for Louisville and
Seattle as well as for other districts seeking to
voluntarily diversify their schools. Justice Ken-
nedy rejected the conservative faction's conclu-
sion that diversity is not a "compelling interest"
but concurred with their ascertainment that the
Louisville and Seattle plans were not "narrowly
tailored" to achieve educational and social ben-
efits dependent upon racial diversity, because the
classifications ultimately had minimal effect on
student assignments (for example, race was only
used as a deciding factor in a small number of
cases annually), the districts failed to demonstrate
that race-neutral approaches were attempted, the
districts used racial classifications in a mechanical
fashion, and the procedures for decision mak-
ing were imprecise.Justice Kennedys partially
concurring opinion appears to permit districts
to continue to use race-conscious measures so
long as their measures do not use race to treat
individual students differently "solely on the
basis of a systematic individual typing by race"
{p. 7).
 that Brown provided, concluding that the plans
An example ofa race-neutral strategy is expand student choice, limit the burden that
the use of specialized programs or schools earlier student assignment plans imposed on
to draw a diverse pool of students into children and families, and use race in limited
schoob that would otherwise he attended ways. Second, the dissenting opinion cited con-
siderable social science research documenting
predominantly hy minority students. the positive effects that Brown had for achieving
integrated school systems and how these effects
rMPLICATIONS FOR SCHOOL SOCIAL have deteriorated in the past decade as deseg-
WORK PRACTICE regation orders have been waived. In addition,
The Parents Involved decision will likely affect Frankenberg and Garces (in press) analyzed this
school districts that use race-conscious criteria literature independently and concluded that
for student assignment. Specifically, districts may Justice Thomas's concurring opinion distorted
voluntarily modify, or even abandon, their use of the current knowledge base available to guide
race-conscious criteria to integrate their schools. the Supreme Court.The authors, after reviewing
To participate effectively in district decision the literature, acknowledged that there is not
making related to school integration, school unanimity in social science evidence over the
social workers must be knowledgeable about the past several decades. However, they suggested
Parents /ííM>/i'fí/decision. We recommend that that there is general agreement within this
school social workers in districts that use race- body of knowledge, over many years and across
conscious criteria determine how their district multiple disciphnes, that students of all races
is responding to the recent Supreme Court deci- and ethnicities who attend racially integrated
sion and create a task force to clarify whether schools benefit from the experience. There
the existing policy meets the new standard. is additional, fairly uniform information that
Specifically, the task force should be prepared documents the short- and long-term employ-
to apply the compelling interest and narrow ment and educational consequences for those
tailoring criteria to the districts policy. attending racially segregated schools, which is
often associated with unequal access to resources
With regard to the compelling interest crite-
within these schools.
rion, the task force must know when diversity
is considered an important goal. The majority With regard to the narrow tailoring criterion,
opinion suggests that school districts have a com- the Parents Involved decision resulted in several
pelling interest in diversity when diversifying takeaway points for districts to consider when
the student population is done to compensate revisiting their policy. First, the decision-making
for the consequences of segregation, overcome guidelines should be precise; specifically, the
adverse educational effects resulting from and policy should clearly specify the circumsunces
associated with highly segregated schools, and in which classifications based on race are used.
produce an educational environment that rep- Second, the policy should include race-neutral
licates the "pluralistic society" children will live strategies to promote diversity. Although the
in upon graduation. It would behoove districts defense in the Parents Involved case could not
to incorporate this language in their pohcy. document an instance in which a desegregation
In the event that other school personnel plan achieved diversity using less intrusive race-
have interpreted the Parents Involved decision to conscious criteria, the majority of justices clearly
mean that striving for racially balanced schools believed that race-neutral approaches must be
is unconstitutional, school social workers can used. An example of a race-neutral strategy Is
invoke two important points. First, although the use of specialized programs or schools to
four justices reached this conclusion, the ma- draw a diverse pool of students into schools that
jority of justices did not. ln fact, four justices would otherwise be attended predominantly by
explicitly applauded the Louisville and Seattle minority students. In addition, diversity must
districts' efforts to voluntarily fulfill the promise be broadly defuied.The Supreme Court sent a

Children & Schoob VOLUME H . NuMBfiR i APRIL 1009

clear message in Parents Involved that diversity
concerns more than race alone. Although race
may be one indicator, others such as socioeco-
nomic status, parental education, and academic
achievement should be included in the defini-
tion of diversity. Finally, the court made clear
that a narrowly tailored plan does not assign
students to schools on the basis of individual
classifications. If diversity is an important goal,
assignment plans should rely on global indicators versed the direction of school policies regarding
of diversity within geographical boundaries (for
example, zip codes) to assign individual student
to schools.
School social workers can also provide leader- and whether or not that is even a worthy goal,
ship by examining district assignment plans that
appear to be consistent with the Parents Involved Court. Although the recent Supreme Court
decision. For example, about 40 U.S. school
districts, with some 2.5 million students, are
known to use socioeconomic status as a factor
in student assignment (Kahlenberg, 2006); in
some situations, socioeconomic status can be
an effective proxy for race. For example. Wake
County Public Schools serves a diverse student
body of approximately 120,000 in Raleigh,
North Carolina (U.S. Department of Educa-
tion, 2004). Their plan dictates that no school
in the district should have more that 40 percent
of students eligible for free or reduced-price
lunch or more than 25 percent of its students
performing below grade level. Wake County's
plan has received considerable support recently
among scholars as one that does indeed raise
achievement scores of all students (Kahlenberg,
2006); Wake County's lower income and mi-
nority students are subsequently outperforming
students of similar groups in North Carolina's
other major urban school districts (Kahlen-
berg, 2006). In Louisville, the revised Jefferson
County Public School student assignment plan
consists of geographical boundaries that were
determined on the basis of minority status,
household income.and parental education.The
district has identified two areas on the basis ot Fninkcnbcrji, E.. & Garces, L. M. (in press). The usv
these criteria, and their goal is to have between
15 percent and 50 percent of students from ar-
eas defined by a high percentage of minorities,
relatively low household incomes, and parents
with lower educational attainment levels.Thus,
it has broadened its definition of diversitv and
no longer assigns students to schools solely on
the basis of race.
CONCLUSION
With the cases of Louisville and Seattle deter-
mined by the Supreme Court, the future of
school integration in this country still remains
uncertain. Fifty-four years after the historic
Browti V. Board of Education I (1954) decision re-
race and segregation, we are again at a historic
crossroads. Whether children will receive an
education that includes those of different races,
are questions that deeply divide the Supreme
decision striking down the student assignment
plans designed to integrate the public schools
in Louisville and Seattle appears likely to result
in increased educational resegregation. it does
not forbid school districts seeking diversity to
pursue it using race-conscious means.
Although debate over the best plan to educate
our children in a diverse school environment
while combating natural racial boundaries con-
tinues within the court system and individual
districts, it is important for school social workers
to stay current on this issue and participate or
provide leadership within their districts. Arnied
with the most current information related to
integration efforts, school social workers can
ensure that their school districts follow the new
criteria outlined by this country's highest court
and assist their districts in developing a plan that
is legally defensible and meets the needs of all
children within our educational system, ffi
REFERENCES
lirowii V. Board of Education 1.347 US. 483 (1954).
Brown v.Uoard of Eduf/itioii 11,349 U.S. 294 (1955).
Civil Rights Act of 1964. 42 U.S.C. §¡971 ec seq. (IWS).
Egelko, B. (20(17,June 29). 5-4 decision disrupts schools'
integntion plans: Ruling condemns nict'-ha^ed
enrollment and says districts must seek alternatives.
San í-fíjncisciy ChroiiicU: p. A 2 1 .
of social science evidence in Parents hivolwd AntS
Merfdith: Implicitions for researchers jnd scluiolü.
University n/ Liniisvillc IJUI' Review.
Green v. County School Board of New Kent C~oiinty,
3')1 U.S. 43(1,435 {l")f,IS).
berg;. R. D. (2ll(lf)). Helping chihlrai nioivJroin
d sclmols lo good imes [SecuriK and Opportunity
gfiidii Report). New York: Century Foundation.

FREY AND W Í L S O N / The Resígregation of Public Schools

McR-dith, Custodial Parent Jiid Next Friend of ONLINE eBOOK ANNUAL
Mi-i>onald v.Jeflersoti County Board of Education.
(2(ll).S).(t5-yi5 (Sixth Circuit Court of'Appeals). SUBSCRIPTION NOW AVAILABLE
Millikenv Bradley, 418, U.S. 717,740-741 (1974).
NAACM' Leg;il Defense and Education Fund. (200H). Still TO NASW MEMBERS ONLY!
ltvkii{í¡ h' the future: l'oluiiiiiry K-12 school intt'^ration:
Á numial for parents, educaiors, & advocates. New York:
Author.
I'arents Involved in Community Schools v. Seattle Encyclopedia
School ! )istri<. t No. 1, (201)5). 05-0908 (Ninth of Social Work
Circuit Court of Appeals).
Parents Involved in Community Schools V.Seattle
School District No. I. (2O07). 127 U.S. 273R.
Plessy V. Ferguson. 163 U.S. 537 (18%).
Swann v. Charlotte-Mecklenhurg board of Education,
402 U.S. I (]<)71}.
U.S. Constitution. Ainendinent XIV. Section 1.
US. Department of Education. (20(14). .4(hiei'ing diuersity:
Racc-iinitml aUcnuuives in Amerkim education.
Retrieved November 12. 200«. from http;//
www. ed.gov/about/ofilcfs/Üst/ocr/cdÜte-
i:aceneutralreport2.htnil

Andy Frey, PhD, is associate professor, Kent School of Social

Work, University ofLomsvitie,, Patterson Hall, Lmisville. KY
40292; e-tnail: ajfreyOÎ(a)JouisviUe.cdu. Michael Wilson,
MSSH^ is hclhwionil .<ptridlist, Colorado Sprinj^s Harrison
District 2 .Schools. (Aflorado Springs.

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86 Children &Sehools VOLUME 31, NUMBER Z APRIL 2009