## Facts

- Mexican-American students and parents sued the Raymondville Independent School District (RISD) and officials, challenging practices affecting K–8 students and district staffing.
- Plaintiffs alleged RISD used ability grouping based on standardized tests and teacher recommendations that produced substantial ethnic separation in classrooms.
- Plaintiffs alleged discriminatory hiring and promotion practices that underrepresented Mexican-Americans among teachers and administrators.
- Plaintiffs alleged RISD failed to provide adequate bilingual education and language remediation for students with limited English proficiency, in violation of federal civil-rights statutes.
- The district court entered judgment for defendants, finding no constitutional or statutory violations, and plaintiffs appealed.

## Issues

1. Whether RISD’s K–8 ability grouping unlawfully discriminated or created impermissible ethnic segregation, especially in light of any prior segregation and whether RISD was unitary.
2. Whether RISD unlawfully discriminated against Mexican-Americans in hiring and promotion of faculty and administrators.
3. Whether RISD’s bilingual/ESL and language-remediation efforts violated Title VI.
4. Whether RISD failed to take “appropriate action” under the EEOA to overcome language barriers, and what standard governs that inquiry.

## Decision

- Affirmed the judgment rejecting the Title VI challenge to RISD’s bilingual/ESL program.
- Reversed and remanded as to ability grouping and employment discrimination because the district court did not make necessary findings on RISD’s history of discrimination and whether it had achieved and maintained a unitary system.
- Adopted a three-part framework for evaluating “appropriate action” under the EEOA and remanded for closer examination of whether RISD’s program was effectively implemented and evaluated.

## Legal Principles

- Ability grouping is not unconstitutional per se, but in a district with a history of unlawful segregation it must be closely examined for disparate impact and segregative effect; such practices may not perpetuate effects of past discrimination absent proof of unitary status maintained for a sufficient period.
- When assessing discriminatory staffing patterns, the proper comparison is to the pool of qualified individuals in the relevant labor market, not the general population.
- In a school system with a history of discrimination, once plaintiffs establish a prima facie pattern or practice in hiring/promotion, the district must rebut with clear and convincing evidence of legitimate, nondiscriminatory reasons.
- Title VI is not violated by a facially neutral, educationally grounded language-remediation program absent proof it denies benefits on prohibited grounds or functions as a pretext for national-origin discrimination.
- EEOA § 1703(f) compliance is evaluated under a three-part test: (1) the program rests on sound educational theory; (2) it is effectively implemented with adequate personnel, materials, and space; and (3) after a reasonable trial period, it is shown through evaluation to be effective in overcoming language barriers or is modified if ineffective.

## Conclusion

The Fifth Circuit affirmed that RISD’s language program, as designed, did not violate Title VI, but required further findings on whether ability grouping and staffing practices were lawful given any prior discrimination and unitary status. It also established the three-part EEOA standard governing whether a district has taken “appropriate action” to remedy language barriers, emphasizing implementation and meaningful evaluation of results.


Castaneda v. Pickard, 648 F.2d 989 (5th Cir. 1981)