BOARD OF EDUCATION OF OKLAHOMA CITY PUBLIC SCHOOLS V. DOWELL 498 U.S. 237 (1991) CASE BRIEF

BOARD OF EDUCATION OF OKLAHOMA CITY PUBLIC SCHOOLS V. DOWELL

498 U.S. 237 (1991)

NATURE OF THE CASE: Petitioner Board of Education of Oklahoma City sought dissolution of a decree entered by the District Court imposing a school desegregation plan.

FACTS: The Board (P) sought dissolution of a decree entered by the District Court for desegregation. The District Court granted relief over the objection of Dowell (D), black students and their parents. The Court of Appeals reversed holding that P would be entitled to relief only upon a clear showing of grievous wrong evoked by new and unforeseen conditions. P appealed that decision. The original action started in 1961 and was taken to end de jure segregation in the public schools. In 1963, the District Court found that P had intentionally segregated and was operating a dual school system segregated by race. The plan to desegregate by neighborhood zoning failed. The District Court then ordered P to adopt the Finger Plan. In 1977, P filed a motion to close the case. The District Court made an order terminating the case. The court concluded that the Finger Plan worked and that substantial compliance had been obtained. The court terminated jurisdiction subject only to final disposition of any case now pending on appeal. In 1984, P had to adopt a Student Reassignment Plan to alleviate demographic changes. In 1985, D motioned to reopen the case contending that the schools had not achieved unitary status and that the 1984 plan was a return to segregation. The District Court concluded that court ordered desegregation must end. The Court of Appeals reversed and the case was remanded to determine if the decree should be lifted or modified. On remand the District Court found that the present segregation was the result of private decision making and economics, that P had maintained its unitary status, and that the neighborhood assignment plan was not designed with discriminatory intent. The District Court concluded that the previous injunction should be vacated and the school district returned to local control. The Court of Appeals again reversed holding that an injunction takes on a life of its own and becomes an edict quite independent of the law it is meant to effectuate. The appeals court then ruled on the case under what it determined to be the proper application of federal law on injunctive remedies. The appeals court then ruled that the decree remained in effect until the school district can show grievous wrong evoked by new and unforeseen conditions and dramatic changes in conditions unforeseen at the time of the decree that impose extreme and unexpectedly oppressive hardships on the obligor. The Supreme Court granted certiorari.

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