## Facts

- Black students, citizens, and taxpayers sued federal education officials responsible for administering federal education funds and enforcing Title VI’s nondiscrimination conditions.
- Plaintiffs alleged the agency had identified segregated public education systems receiving federal funds yet continued funding without timely use of Title VI enforcement tools.
- After discovery, the case was resolved on cross-motions for summary judgment in federal district court.
- The district court found prolonged agency inaction inconsistent with Title VI and entered declaratory and injunctive relief requiring enforcement actions and progress reporting.
- The injunction addressed both public higher education systems in multiple states and numerous primary and secondary school districts alleged to be noncompliant.
- Federal officials appealed, challenging reviewability, the scope of any enforceable duty to act, and the specificity of the court-ordered deadlines and tasks.

## Issues

1. Whether systemic agency inaction in enforcing Title VI conditions on federal education funding is judicially reviewable, or instead committed to unreviewable agency discretion.
2. Whether Title VI requires an agency to move beyond voluntary compliance efforts and initiate formal enforcement measures within a reasonable time when noncompliance persists.
3. Whether a detailed injunction directing enforcement steps, targets, and timetables impermissibly intrudes on agency discretion, particularly regarding higher education desegregation.

## Decision

- The D.C. Circuit (en banc, per curiam) largely affirmed the injunction compelling Title VI enforcement, while modifying aspects concerning higher education.
- The court agreed the agency’s performance had fallen below what Title VI required and that continued funding of known segregated systems without meaningful enforcement was unlawful.
- The court held Title VI enforcement obligations are judicially enforceable when the record shows a broad failure to carry out statutory responsibilities, not merely isolated non-enforcement choices.
- The court approved court-ordered timetables and specific steps as an appropriate response to systemic default, while preserving room for administrative judgment.
- For higher education, the court adjusted the district court’s directives to allow greater flexibility in developing and implementing statewide compliance plans, while still requiring concrete progress.

## Legal Principles

- Title VI’s funding condition (no discrimination in federally assisted programs) and its enforcement provision (agency “authorizes and directs” enforcement by regulation) can create enforceable duties for administering agencies.
- Reliance on voluntary compliance cannot justify indefinite delay; when voluntary measures fail within a reasonable period, the agency must proceed to formal enforcement mechanisms authorized by statute and regulation.
- Systemic failure to implement a statutory enforcement scheme may be reviewed and remedied through declaratory and injunctive relief, notwithstanding general deference to agency enforcement discretion.
- Courts may order structured, time-bound enforcement actions to correct sustained administrative nonperformance, while leaving agencies discretion over technical and policy choices, especially in complex areas such as higher education desegregation.

## Conclusion

The D.C. Circuit held that persistent, program-wide failure to enforce Title VI against known segregated recipients of federal education funds is subject to judicial correction, and it largely upheld an injunction requiring timely enforcement action while tempering the remedy to preserve agency latitude in higher education compliance planning.


Adams v. Richardson, 480 F.2d 1159 (D.C. Cir. 1973) (en banc)