This Article follows the case of Northcross v. Board of Education of the Memphis City Schools from its origins through a period of slow but peaceful desegregation in the 1960s and into the more confrontational busing debates of the early 1970s. The Memphis school desegregation is typical of desegregation during this period in many ways. The familiar themes of initial resistance, reluctant and token desegregation, contentious busing, and White flight all appear in the Memphis narrative. However, Memphis is unique in the degree to which racially-identifiable school systems survived the desegregation litigation. Unlike in Nashville, Tennessee and Charlotte, North Carolina, the city schools were never consolidated with the neighboring county district, leaving two public school systems--one largely White, the other largely Black--in a single metropolitan area. Further, the private schools in Memphis, some of which were created to accommodate the massive White flight of the mid-1970s, succeeded to an extraordinary degree in providing an affordable permanent alternative to the city schools. By 1990, Memphis's private schools were found to be the most segregated in the nation. Despite its tortuous history and its continued effect on the nation's 21st largest school district, no scholar has yet fully examined the Northcross case in its historical context. This Article seeks to begin filling that void.
In addition to providing insight into how Brown impacted Memphis, this detailed case study provides guidance for both civic groups seeking to litigate for social change and for civic leaders seeking to move communities toward embracing diversity in education. For the civic groups, Memphis provides a cautionary tale riddled with examples of litigation's limits in substantially altering entrenched social structures. For civic leaders, Memphis illustrates how hope and progressive judicial policies are easily thwarted by unwelcoming communities and leaders. As school districts across the country seek to embrace diversity voluntarily without running afoul of the new constitutional landscape announced in Parents Involved in Community Schools v. Seattle School District, the Memphis case study is a model for what may happen when large segments of a community abandon a school district. Finally, the current inequities in school quality among the schools in the Memphis metropolitan area suggest that the courts' focus on a school's racial makeup to the exclusion of its educational quality may have been a failed strategy. Ultimately, though, this is a story about how a single community dealt with decades of Supreme Court mandates in the wake of Brown and ultimately avoided offering more than a handful of students an education in a diverse environment.
Institution: University of Memphis
Citation: 26 Law & Ineq. 261 (Summer 2008)