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Meredith v. Jefferson County

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Affirmative action
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Affirmative action
Affirmative action by state
Affirmative action and anti-discrimination laws
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Civil Rights Act of 1866
Civil Rights Act of 1964
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Supreme Court of the United States
Meredith v. Jefferson County Board of Education
Reference: 05-915
Issue: Affirmative action
Term: 2006
Important Dates
Argued: December 4, 2006
Decided: June 28, 2007
Outcome
Sixth Circuit Court of Appeals reversed and remanded
Vote
8-0 to reverse and remand
Majority
Chief Justice John G. RobertsAntonin ScaliaAnthony KennedyClarence ThomasSamuel Alito
Concurring
Kennedy
Thomas
Dissenting
John Paul StevensDavid SouterRuth Bader GinsburgStephen Breyer


Meredith v. Jefferson County is a case decided by the United States Supreme Court in 2007 that rejected the notion that racial balancing of demographics in public schools was a compelling state interest. The court found the county's enrollment plan unconstitutional under the Fourteenth Amendment of the United States Constitution.[1]

Background

Until 2000, Jefferson County Public Schools in Kentucky had been integrated by court order. After release from the order, the school system maintained a policy that promoted racial integration by allowing no school to have an enrollment of black students less than 15 percent or greater than 50 percent of its student population. Students were allowed a choice of schools, but since not every school could accommodate every applicant, enrollment choices were sometimes made on the basis of race.[1]

The Supreme Court's decisions in Gratz v. Bollinger and Grutter v. Bollinger allowed for race-based classifications directed towards compelling government interests and narrowly tailored to those interests. In these cases, the Supreme Court had found that promoting diversity in the student body provided certain educational benefits that made it a compelling government interest. The court stipulated, however that such policies should be narrowly tailored and provide individualized consideration for the applicants.[2][3]

Crystal Meredith and other parents sued the school system, claiming that the plan's use of racial classification violated the student's rights to equal protection under the Fourteenth Amendment. The United States District Court for the Western District of Kentucky found that the school system had a compelling interest in promoting student diversity, citing the Supreme Court's ruling in Grutter v. Bollinger. The court upheld the use of percentage guidelines for racial diversity, and found that the students whose transfers were rejected were not unduly harmed by the rejection. The plaintiffs appealed to the United States Court of Appeals for the 6th Circuit, which affirmed the lower court's decision. The plaintiffs further appealed to the Supreme Court, which agreed to hear the case.[1][4]

Parents Involved in Community Schools v. Seattle School Dist. No. 1

See also: Parents Involved in Community Schools v. Seattle School Dist. No. 1

A similar case, Parents Involved in Community Schools v. Seattle School Dist. No. 1, was heard alongside Meredith v. Jefferson County. The Seattle School District implemented a series of tiebreakers to determine admissions when too many students applied to the same high school. Part of the consideration for the tiebreaker was the race of the student. The plaintiffs argued that the system violated the Equal Protection Clause of the Fourteenth Amendment, as well as the Civil Rights Act of 1964 and Washington state law. The Supreme Court agreed to hear the case on June 5, 2006.[5]

Decision

Chief Justice John Roberts
Chief Justice John Roberts

On June 28, 2007, in a 5-4 decision, the Supreme Court declared the enrollment plan unconstitutional under the Equal Protection Clause of the Fourteenth Amendment. The majority found that the plan did not provide individualized consideration for students; instead, the plan separated students into two groups, black and other. The court found that the enrollment plan did not meet the standard for constitutional consideration of race. The court held that the plan was targeted towards demographic goals rather than educational interests. The majority opinion was delivered by Chief Justice John Roberts and joined by Justices Antonin Scalia, Clarence Thomas, Anthony Kennedy, and Samuel Alito.[1][6]

Roberts wrote the following in the majority opinion:[1]

"The way to stop discrimination on the basis of race is to stop discriminating on the basis of race."[7]
—Chief Justice John Roberts

Justice Stephen Breyer dissented, joined by Justices John Paul Stevens, David Souter, and Ruth Bader Ginsburg. The dissent argued that the majority opinion ignored the context of the case and that, "it announces legal rules that will obstruct efforts by state and local governments to deal effectively with the growing resegregation of public schools, it threatens to substitute for present calm a disruptive round of race-related litigation, and it undermines Brown’s promise of integrated primary and secondary education that local communities have sought to make a reality."[8]

See also

External links

Footnotes