## Facts

- A class action challenged de jure segregation in the DeKalb County, Georgia, School System (DCSS).
- In 1969, a federal district court entered a consent order adopting a neighborhood school attendance plan (with a minor modification) and retained jurisdiction to supervise dismantling segregation.
- Compliance was assessed using the six Green factors: student assignments, transportation, physical facilities, extracurricular activities, faculty, and staff/resource-related measures.
- Over time, DCSS experienced substantial demographic changes affecting racial composition of schools independent of DCSS policies.
- In 1986, DCSS moved for a declaration of “unitary” status and dismissal of the case.

## Issues

1. Whether a district court supervising a desegregation decree may withdraw judicial supervision in stages by terminating oversight in operational areas where compliance has been achieved while retaining jurisdiction over remaining noncompliant areas.
2. Whether demographic change may be considered in determining that racial imbalance in student assignments is not a vestige of prior de jure segregation requiring further remedial measures.
3. Whether the court of appeals erred by requiring unitary status across all Green factors simultaneously for a sustained period before any supervision could be lifted.

## Decision

- The Supreme Court reversed the Eleventh Circuit and upheld the district court’s authority to end supervision incrementally.
- The Court held a district court may declare a school system unitary in discrete Green-factor areas and terminate supervision as to those areas while retaining jurisdiction over others.
- The Court approved considering whether racial imbalance in student assignments is attributable to independent demographic forces rather than to the prior constitutional violation.
- The Court concluded the district court did not abuse its discretion in finding DCSS unitary in student assignments, transportation, physical facilities, and extracurricular activities, while continuing oversight over faculty and resource allocation/quality of education.

## Legal Principles

- Federal court control over local school systems is remedial and temporary; once vestiges of de jure segregation are eliminated to the extent practicable, authority should return to local officials.
- Unitary status is not an all-or-nothing determination; courts may tailor relief and terminate portions of a decree when compliance is achieved in particular operational areas.
- The central inquiry for continued remedies is causation: whether current racial conditions are traceable to the prior de jure violation; racial imbalance alone does not establish a constitutional violation.
- Demographic shifts and private choices can sever the causal connection between past de jure segregation and present racial imbalance, limiting any obligation to impose further race-based corrective measures.
- District courts have broad equitable discretion in managing desegregation decrees; appellate review is deferential absent abuse of discretion.

## Conclusion

The Court held that desegregation supervision may be withdrawn incrementally as compliance is achieved in specific Green-factor areas and that demographic change may justify declining to impose further remedies for racial imbalance not traceable to past de jure segregation, reaffirming district court discretion and the goal of restoring local control once practicable compliance is reached.


Freeman v. Pitts, 503 U.S. 467 (1992)