## Facts

- A California trial court in 1970 found the Los Angeles Unified School District had engaged in unconstitutional segregation and ordered development of a desegregation plan.
- The California Supreme Court affirmed desegregation obligations on state constitutional equal-protection grounds, interpreting the state constitution to bar both de jure and de facto segregation.
- On remand, the trial court approved a plan that included substantial mandatory student reassignment and transportation.
- In 1979, California voters adopted Proposition I, a state constitutional amendment limiting state-court authority to order mandatory reassignment or busing to circumstances in which such relief would be permitted under federal equal-protection law.
- After Proposition I, the trial court continued to require largely mandatory reassignment and busing, treating the amendment as inapplicable given the earlier findings.
- The California Court of Appeal reversed, concluding the prior findings did not establish intentional segregation violating the Federal Constitution and holding Proposition I consistent with the Fourteenth Amendment.
- The U.S. Supreme Court granted review.

## Issues

1. Whether Proposition I violated the Fourteenth Amendment by restricting state-court desegregation remedies to the scope required under federal equal-protection doctrine.
2. Whether a state that previously provided broader state constitutional protections and remedies against segregation is federally barred from later limiting those remedies.
3. Whether Proposition I created an unconstitutional racial classification or was enacted with discriminatory purpose and effect.

## Decision

- The Court affirmed the California Court of Appeal and upheld Proposition I.
- The Court held that a state may provide protections beyond federal equal-protection requirements and later reduce them, without violating the Fourteenth Amendment.
- The Court found Proposition I facially neutral and not a racial classification.
- The Court found no sufficient showing that Proposition I was adopted with discriminatory purpose or effect under federal equal-protection standards.
- The Court rejected reliance on political-process restructuring precedents, treating Proposition I as a general limitation aligning state remedies with federal remedial limits.

## Legal Principles

- The Equal Protection Clause does not prevent a state from withdrawing or narrowing state-law remedies that exceed federal constitutional minimums, standing alone.
- Repeal or modification of desegregation or antidiscrimination measures is not presumptively invalid absent a racial classification or proven discriminatory purpose and effect.
- Facially neutral state action violates equal protection only upon an adequate showing of discriminatory intent (and resulting unconstitutional operation).
- A state may limit state-court remedial authority for school desegregation to remedies that would be available for a proven federal equal-protection violation.

## Conclusion

The Court held that California could restrict state-court-ordered mandatory reassignment and busing to the limits permitted under federal equal-protection doctrine, because the amendment did not classify by race and was not shown to have been enacted with discriminatory purpose or unconstitutional effect.


Crawford v. Bd. of Educ. of L.A., 458 U.S. 527 (1982)