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Parents Involved v. Seattle School District

(2007)

Supreme Court of the United States - 551 U.S. 701

tl;dr:

Elementary school districts may not use affirmative action.

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ICRAIssue, Conclusion, Rule, Analysis for Parents Involved v. Seattle School District

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Facts & HoldingParents Involved v. Seattle School District case brief facts & holding

Facts:The school districts in this case voluntarily adopted student assignment...

Holding:SeattleOperates 10 schools, incoming 9th graders rank however many schools...

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Parents Involved v. Seattle School District | Case Brief DeepDive
Majority opinion, author: Chief Justice Roberts
Level 1
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The case involves two school districts that used race to maintain a predetermined racial balance, which was found to violate the Equal Protection Clause of the Fourteenth Amendment. The use of race in school assignments was challenged by Parents Involved in Community Schools, alleging a violation of the Equal Protection Clause of the Fourteenth Amendment, Title VI of the Civil Rights Act of 1964, and the Washington Civil Rights Act. The District Court erred in finding that the school district's use of the racial tiebreaker was constitutional and narrowly tailored to serve a compelling government interest. The en banc court later affirmed the District Court's determination that Seattle's plan was narrowly tailored to serve a compelling government interest. However, the use of individual racial classifications in the assignment plans must be narrowly tailored to achieve a compelling government interest. The interest in diversity in higher education is recognized as compelling for strict scrutiny, but the use of race in the present cases is not part of a broader effort to achieve diversity. The plans rely on racial classifications in a non-individualized, mechanical way, without providing for a meaningful individualized review of applicants. The plans have a limited notion of diversity and do not consider the full range of diversity in the community. Prior to the Grutter case, courts of appeals rejected attempts to implement race-based assignment plans in primary and secondary schools. However, after the Grutter case, some courts found that race-based assignments were permissible at the elementary and secondary level, largely relying on that case.

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Opinion (Concurrence), author: Justice Thomas
Level 1
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Justice Thomas agrees with The Chief Justice that race-based student-assignment programs are unconstitutional and do not serve a compelling state interest. He distinguishes segregation from racial imbalance in public schooling and emphasizes that race-based remedial measures may only be required in cases of state-enforced racial separation. The dissent's argument for a compelling interest in the race-based student-assignment plans is flawed, as the records do not demonstrate that either school board's plan is supported by an interest in remedying past discrimination. The dissent's claim that racially balanced schools improve educational outcomes for black children is questionable, as there is no evidence that integration is necessary for black achievement. The dissent's argument that forced racial mixing is necessary for improved educational results for black children is also flawed. The Constitution forbids preferring members of any one group based solely on race or ethnic origin, as it constitutes discrimination for its own sake. The dissent's argument that racial balancing is necessary to teach children to engage in cooperation among Americans of all races is not a compelling interest, as it is too sweeping and not uniquely relevant to schools.

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Opinion (Concurrence), author: Justice Kennedy
Level 1
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The legal case discusses the unconstitutionality of state-mandated racial classifications in two school districts, Louisville and Seattle, which aimed to promote diversity but risked entrenching prejudices and violating the law. The Supreme Court allows race-conscious methods to promote diversity in schools, but individual students cannot be assigned to schools based on their race unless it is a last resort to achieve a compelling interest. The government must prove that racial classifications are narrowly tailored measures that further compelling governmental interests when subjected to strict scrutiny. The Jefferson County Board of Education fails to meet this threshold mandate, as the district's use of individual racial classifications lacks clarity and precision, and the explanations for how and when it employs these classifications are broad and imprecise. The lack of clarity and precision in the district's use of racial classifications is further highlighted in McFarland v. Jefferson Cty. Public Schools. Judicial deference to legislative or executive pronouncements of necessity is not acceptable in equal protection analysis. The Court has criticized the dissent's assumptions that race-based classifications are permitted by existing precedents and that they cause no harm or anger of the type the Constitution prevents. The Court has found that the dissent's general conclusions have no principled limit and would result in the broad acceptance of governmental racial classifications in areas beyond schooling.

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Dissenting opinion, author: Justice Stevens
Level 1
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Justice Stevens criticizes the Chief Justice's reliance on Brown v. Board of Education and accuses him of rewriting history. The Chief Justice rejects the argument that racial classifications should be treated differently and argues that strict adherence to different levels of scrutiny confuses the message of Brown v. Board of Education. The Court's misuse of the three-tiered approach to equal protection analysis confirms this view. An example is given of a state law requiring racial integration in schools that was upheld by the Supreme Judicial Court of Massachusetts.

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Dissenting opinion, author: Justice Breyer
Level 1
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This legal case allows school authorities to use race-conscious criteria to achieve racial balance in schools, even if not required by the Constitution. The use of such criteria is justified as a special administrative remedy required by history to promote racial integration in primary and secondary schools. The plans must meet strict scrutiny and be tailored to the need for racial integration. The dissenting opinion argues that the decision lacks sufficient consideration of the law and may establish legal rules that impede resolving the ongoing problem of re-segregation in public schools. The Supreme Court recognizes the importance of racially diverse education in promoting cross-racial understanding and breaking down stereotypes. Justice Thomas disagrees with the idea that school districts can have compelling interests in integrating public schools, but he believes that the use of race-conscious criteria in the plans passes the "tailoring" test.

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