Missouri v. Jenkins

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Following is the case brief for Missouri v. Jenkins, 515 U.S. 70 (1995)

Case Summary of Missouri v. Jenkins:

  • The State of Missouri and Kansas City students had been involved in an 18-year-long litigation regarding school segregation in the Kansas City, Missouri, School District.
  • In this particular case, the State challenged two of the remedial measures ordered by the District Court:  (i) State funding of salary increases for employees of the school district, and (ii) State funding of quality education programs.
  • The District Court and the Eighth Circuit Court of Appeals upheld the court order for the State to fund those measures.
  • The U.S. Supreme Court, however, reversed those orders.  It held that both orders exceeded the District Court’s authority, as they went beyond the nature and scope of the school district’s initial constitutional violation.

Missouri v. Jenkins Case Brief

Statement of the Facts:

This case involves an 18-year long litigation regarding school segregation in the Kansas City, Missouri, School District (KCMSD).  Back in 1977, the Federal District Court presided over a seven-month trial between a class of present and future students of the KCMSD as plaintiffs, and the State of Missouri and the KCMSD as defendants.  The District Court found, at the end of trial, that the State and the KSCMSD operated a segregated school system and had failed to eliminate the vestiges of Missouri’s prior discrimination in the schools.

As a result, the District Court began to order remedial measures.  Over the years, it ordered a range of quality education programs, grants to schools, magnet schools, and capital improvement plans.  The State funded all of those measures by court order.  Relevant to the present case, the District Court ordered the State to pay for (i) salary increases to teachers and other employees in the KCMSD, and (ii) the continuation of remedial quality education programs.  Importantly, the District Court did not order the State to bus children from other school districts because the court did not find any interdistrict segregation violations.

Procedural History:

  • The State challenged the District Court’s order.  It argued that the State should not fund the teacher salary increase, and it should no longer fund the quality education programs because it has achieved partial unitary status, under Freeman v. Pitts, 503 U.S. 467 (1992).  The District Court rejected the challenge.
  • The Eighth Circuit Court of Appeals affirmed.  The Court of Appeals held that the salary increase was to avoid “white flight,” and that the quality education programs have yet to eliminate the vestiges of segregation.
  • The U.S. Supreme Court granted certiorari to consider the salary and quality education program issues.

Issue and Holding:

  1. Did the District Court exceed its constitutional authority by ordering salary increases of instructional and non-instructional employees of the KCMSD?  Yes.
  2. Did a lack of rising test scores prove that the State had not achieved partial unitary status with regard to the quality education programs under Freeman v. Pitts?  No.

Judgment:

The judgment of the Eighth Circuit Court of Appeals is reversed.

Rule of Law or Legal Principle Applied:

A federal court’s power to remediate school segregation is bounded by the nature and scope of the initial constitutional violation.  The goals of court remediation of school segregation is to restore victims of discrimination to the position they would have been in but for the discrimination, and to eventually restore school control to the state and local authorities.

Reasoning:

Under Freeman v. Pitts, three factors inform a court’s discretion on continuing a decree to remediate school discrimination:  (i) whether compliance exists with those parts of the decree where federal intervention is to be withdrawn; (ii) whether judicial control is necessary to achieve compliance with other parts of the school system; and (iii) whether the district has shown a good-faith adherence to the decree.

In this case, the order for salary increases exceeded the court’s authority because it created a “magnet district” which is an interdistrict solution to an intradistrict problem.  The notion of “white flight” does not justify the court going beyond its authority here.  With regard to the quality education programs, student test scores are not the appropriate way to measure whether a previously segregated school district has achieved partial unitary status.  The correct measure is through the three-part analysis in Freeman.  Many of the goals of the quality education programs have been attained, and there is an interest in having the court hand back over control to the State and local authorities.

Concurring and Dissenting Opinions:

Concurring Opinion (O’Connor):

A federal court does not have unlimited freedom to impose any and all remedies upon a constitutional violator.  While courts must intervene to stop harmful segregation in schools, its power is bounded by the nature and scope of the constitutional violation.

Concurring Opinion (Thomas):

Anything that is predominantly black is not necessarily inferior.  It is not clear that Missouri’s enforced segregation up until 1954 is why there are predominantly black schools in the KCMSD 30 years later.  The District Court should have made more findings to determine whether the KCMSD’s student population was a result of vestiges of past discrimination.

Dissenting Opinion (Souter):

The majority addressed a foundational issue in this matter that the parties did not expect to be covered in the Court’s limited grant of certiorari.  It is, therefore, unfair to announce a foundational holding regarding Freeman v. Pitts without giving the parties the chance to fully brief that issue.  The Court’s failure to give notice about what it would adjudicate threatens the credibility of the Court.

Significance:

This final iteration of the Missouri v. Jenkins cases (this case is deemed Missouri v. Jenkins III) marks the end of the Court’s involvement in the 18-year-long litigation.  It also marks the Court’s departure from broad, aggressive federal court remedies to provide equal education opportunities in public schools.  This case clearly reveals a Court majority attempting to place parameters around what was once a relatively broad view of a federal court’s ability to cure the ills of past racial discrimination.

Student Resources:

https://supreme.justia.com/cases/federal/us/515/70/case.html

https://www.oyez.org/cases/1994/93-1823

https://www.jstor.org/stable/2967250?seq=1#page_scan_tab_contents