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
- Whether Proposition I violated the Fourteenth Amendment by restricting state-court desegregation remedies to the scope required under federal equal-protection doctrine.
- Whether a state that previously provided broader state constitutional protections and remedies against segregation is federally barred from later limiting those remedies.
- 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.