Missouri v. Jenkins
Encyclopedia
Missouri v. Jenkins, 515 U.S. 70
(1995), is a case decided by the United States Supreme Court
. On June 12, 1995 the Court, in a 5-4 decision, overturned a District Court ruling that required the state of Missouri
to correct de facto racial inequality in schools by funding salary increases and remedial education programs.
as restricting only de jure
segregation
, and referred to Milliken v. Bradley
and other precedents as applying only to intra-district desegregation. The Supreme Court argued that the lower courts had exceeded their authority in ordering measures such as across-the-board state-funded salary increases in order to fund continued quality education programs which could not be sustained by local government.
The Court looked to Board of Ed. of Oklahoma City Public Schools v. Dowell
for the decisive question of "'whether the [constitutional violator] ha[s] complied in good faith with the desegregation decree since it was entered, and whether the vestiges of past discrimination ha[ve] been eliminated to the extent practicable.'"
According to The Living Constitution, 3rd Revised Ediiton 1995, (Saul K. Padover, Revised by Jacob W. Landynski) the other issue involved was whether a federal court could order a local government to raise taxes above the state statute amount to cover the cost of removing the "vestiges of discrimination". The Supreme Court ruled that while direct imposition of taxes is indeed beyond judicial authority, it would be permissible for the district court to order the school district to levy the same tax. The Court said: "Authorizing and directing local government institutions to devise and implement remedies not only protects the function of these institutions but, to the extent possible, also places the responsibility for solutions to the problems of segregation upon those themselves who have created the problem."
The Court also said: To hold otherwise would fail to take account of the obligations of local governments, under the Supremacy Clause, to fulfill the requirements that the Constitution imposes upon them.
(KCMSD) sued the state of Missouri
, federal agencies, and suburban districts around Kansas City on behalf of the district's students. The District Court then instead named the school district as a defendant. The courts held that the state of Missouri was liable for segregated schools within the boundaries of KCMSD. Originally the school district wanted a "metropolitan plan," which would have included bus transfers to even out the racial inequalities of inner-city and suburban schools. However, over the 18 year span of the case, the court ordered remedies focused instead on improving educational facilities and programs.
In 1985, the district court
then ordered the legal remedy
of educational improvement programs, school facility repairs, and magnet schools, which were thought to be the best way to attract white suburban students back into city schools. In 1987, the district courts ordered mandatory salary assistance, arguing that in order to end segregation in the schools the district needed higher-paid, quality teachers, and in 1993 the district court ordered the state to pay for salary increases for teaching and non-teaching personnel.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1995), is a case decided by the United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
. On June 12, 1995 the Court, in a 5-4 decision, overturned a District Court ruling that required the state of Missouri
Missouri
Missouri is a US state located in the Midwestern United States, bordered by Iowa, Illinois, Kentucky, Tennessee, Arkansas, Oklahoma, Kansas and Nebraska. With a 2010 population of 5,988,927, Missouri is the 18th most populous state in the nation and the fifth most populous in the Midwest. It...
to correct de facto racial inequality in schools by funding salary increases and remedial education programs.
Ruling
The Supreme Court majority interpreted Brown v. Board of EducationBrown v. Board of Education
Brown v. Board of Education of Topeka, 347 U.S. 483 , was a landmark decision of the United States Supreme Court that declared state laws establishing separate public schools for black and white students unconstitutional. The decision overturned the Plessy v. Ferguson decision of 1896 which...
as restricting only de jure
De jure
De jure is an expression that means "concerning law", as contrasted with de facto, which means "concerning fact".De jure = 'Legally', De facto = 'In fact'....
segregation
Racial segregation
Racial segregation is the separation of humans into racial groups in daily life. It may apply to activities such as eating in a restaurant, drinking from a water fountain, using a public toilet, attending school, going to the movies, or in the rental or purchase of a home...
, and referred to Milliken v. Bradley
Milliken v. Bradley
Milliken v. Bradley, 418 U.S. 717 , was a significant United States Supreme Court case dealing with the planned desegregation busing of public school students across district lines among 53 school districts in metropolitan Detroit. It concerned the plans to integrate public schools in the United...
and other precedents as applying only to intra-district desegregation. The Supreme Court argued that the lower courts had exceeded their authority in ordering measures such as across-the-board state-funded salary increases in order to fund continued quality education programs which could not be sustained by local government.
The Court looked to Board of Ed. of Oklahoma City Public Schools v. Dowell
Board of Ed. of Oklahoma City Public Schools v. Dowell
Board of Education of Oklahoma City Public Schools v. Dowell, 498 U.S. 237 , United States Supreme Court case "hasten[ing] the end of federal court desegregation orders." The Court held that a federal desegregation order should be ended even though it meant that that schools would become...
for the decisive question of "'whether the [constitutional violator] ha[s] complied in good faith with the desegregation decree since it was entered, and whether the vestiges of past discrimination ha[ve] been eliminated to the extent practicable.'"
According to The Living Constitution, 3rd Revised Ediiton 1995, (Saul K. Padover, Revised by Jacob W. Landynski) the other issue involved was whether a federal court could order a local government to raise taxes above the state statute amount to cover the cost of removing the "vestiges of discrimination". The Supreme Court ruled that while direct imposition of taxes is indeed beyond judicial authority, it would be permissible for the district court to order the school district to levy the same tax. The Court said: "Authorizing and directing local government institutions to devise and implement remedies not only protects the function of these institutions but, to the extent possible, also places the responsibility for solutions to the problems of segregation upon those themselves who have created the problem."
The Court also said: To hold otherwise would fail to take account of the obligations of local governments, under the Supremacy Clause, to fulfill the requirements that the Constitution imposes upon them.
History
The case began in 1977 when the Kansas City, Missouri School DistrictKansas City, Missouri School District
Kansas City, Missouri School District, or KCMSD is a school district headquartered at 1211 McGee Street in Downtown Kansas City, Missouri.- Boundaries:The school district primarily serves residents within Kansas City....
(KCMSD) sued the state of Missouri
Missouri
Missouri is a US state located in the Midwestern United States, bordered by Iowa, Illinois, Kentucky, Tennessee, Arkansas, Oklahoma, Kansas and Nebraska. With a 2010 population of 5,988,927, Missouri is the 18th most populous state in the nation and the fifth most populous in the Midwest. It...
, federal agencies, and suburban districts around Kansas City on behalf of the district's students. The District Court then instead named the school district as a defendant. The courts held that the state of Missouri was liable for segregated schools within the boundaries of KCMSD. Originally the school district wanted a "metropolitan plan," which would have included bus transfers to even out the racial inequalities of inner-city and suburban schools. However, over the 18 year span of the case, the court ordered remedies focused instead on improving educational facilities and programs.
In 1985, the district court
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
then ordered the legal remedy
Legal remedy
A legal remedy is the means with which a court of law, usually in the exercise of civil law jurisdiction, enforces a right, imposes a penalty, or makes some other court order to impose its will....
of educational improvement programs, school facility repairs, and magnet schools, which were thought to be the best way to attract white suburban students back into city schools. In 1987, the district courts ordered mandatory salary assistance, arguing that in order to end segregation in the schools the district needed higher-paid, quality teachers, and in 1993 the district court ordered the state to pay for salary increases for teaching and non-teaching personnel.
See also
- List of United States Supreme Court cases, volume 515
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court