## Facts

- After prior proceedings limited relief to the Detroit public school system, the federal district court held hearings to craft a Detroit-only desegregation decree.
- The district court approved a plan that included both student assignment measures and “educational components” aimed at remedying the effects of de jure segregation.
- The educational components included reading programs, in-service teacher training, testing, and counseling, and had been proposed by local school authorities.
- The district court found the components necessary to implement desegregation and ordered the added costs to be shared by the Detroit School Board and the State of Michigan, with the State paying one-half.
- The Sixth Circuit affirmed both the inclusion of the educational components and the state cost-sharing requirement.
- State officials sought Supreme Court review, challenging the remedial scope and the funding order under the Eleventh Amendment.

## Issues

1. Whether a federal court may, as part of a school desegregation decree, order compensatory or remedial educational programs in addition to pupil reassignment to remedy the effects of past de jure segregation.
2. Whether requiring state officials to fund one-half of the additional costs of such programs violates the Eleventh Amendment.

## Decision

- The Supreme Court affirmed the judgment.
- The Court held that a district court may order compensatory or remedial educational programs when supported by the record as necessary to remedy the effects of de jure segregation.
- The Court held that requiring the State to pay one-half of the additional costs did not violate the Eleventh Amendment because the relief was prospective and equitable, even if it required state expenditures.
- The Court concluded the district court did not abuse its discretion in approving the programs, particularly given that they were proposed by local school authorities and directed at identified educational harms caused by the dual system.

## Legal Principles

- Desegregation remedies are governed by equitable principles and must be tailored to cure the constitutional violation identified in the record.
- Federal courts may address more than student assignment when needed to eliminate the effects of de jure segregation, including ordering compensatory educational components.
- A desegregation decree may include programmatic remedies within the violating district without exceeding the scope of the proven violation.
- The Eleventh Amendment does not bar prospective equitable relief against state officials that requires state spending when the expenditures are part of enforcing constitutional compliance.

## Conclusion

The Court upheld a Detroit-only desegregregation decree that included compensatory educational programs and required Michigan to share their costs, ruling that such measures can be necessary to remedy the effects of de jure segregation and that prospective equitable funding obligations are not barred by the Eleventh Amendment.


Milliken v. Bradley, 433 U.S. 267 (1977)