## Facts

- Detroit parents and students sued Michigan state officials and Detroit officials, alleging that official actions had created and maintained unconstitutional racial segregation in Detroit public schools.
- The federal district court found de jure segregation within the Detroit school system attributable to the Detroit Board of Education and, through state control, to Michigan.
- The district court first required desegregation plans confined to Detroit, then concluded Detroit-only plans were inadequate.
- The district court ordered a multi-district remedy covering Detroit and numerous surrounding suburban districts in a three-county area, including an interim busing plan.
- The court of appeals largely affirmed and accepted a metropolitan remedy as necessary to desegregate Detroit.
- State officials sought Supreme Court review of the propriety of imposing a cross-district remedy without findings of constitutional violations in the suburban districts.

## Issues

1. Whether a federal court may impose a multi-district desegregation plan crossing school-district boundaries without findings that outlying districts committed constitutional violations or that actions in one district caused segregation in another.
2. Whether the scope of a desegregation remedy may extend beyond the geographic limits of the proven de jure segregation.

## Decision

- The Supreme Court reversed, holding that the metropolitan, multi-district remedy was unauthorized on the record presented.
- A cross-district remedy requires proof of an interdistrict constitutional violation—discriminatory acts that were a substantial cause of segregation across district lines.
- Because there was no showing of significant constitutional violations by the suburban districts and no proof of interdistrict effects, the district court’s plan exceeded permissible remedial authority.
- The Court reiterated that the Constitution does not require racial balance for its own sake; the judicial task is to remedy state-imposed segregation.
- The Court emphasized the significance of maintaining separate, locally controlled school districts absent a constitutional basis to restructure them.

## Legal Principles

- The permissible scope of equitable relief in school desegregation is limited by the nature and extent of the constitutional violation proven.
- School-district boundaries may not be displaced for remedial purposes absent a showing that discriminatory state or local actions caused interdistrict segregation.
- Racial imbalance alone is not a constitutional violation; liability turns on de jure segregation attributable to governmental action.
- Federal courts may not order consolidation, cross-district busing, or other metropolitan reorganization to achieve regional racial balance without a demonstrated causal connection between an interdistrict violation and the proposed remedy.
- Respect for local control and state educational governance constrains federal remedial orders unless necessary to cure a proven constitutional wrong.

## Conclusion

The Court held that a metropolitan desegregation plan could not be imposed to remedy Detroit’s de jure segregation without proof that suburban districts (or state actions affecting them) caused or contributed to segregation across district lines, limiting desegregation remedies to the geographic reach of the constitutional violation shown.


Milliken v. Bradley, 418 U.S. 717 (1974)