Los Angeles Branch NAACP v. Los Angeles Unified School District

The Los Angeles Branch NAACP (NAACP) (plaintiff) filed a federal class action lawsuit against the Los Angeles Unified School District (LAUSD) and others (defendants), alleging violations of the United States Constitution through the intentional, de jure segregation of Los Angeles public schools. The defendants moved for summary judgment, contending that Crawford v. Board of Education, 113 Cal. App. 3d 633 (1980), aff’d, 458 U.S. 527 (1982), operated as res judicata to the NAACP’s suit. Crawford was a class action alleging unlawful segregation in Los Angeles public schools based on events occurring on or before May 2, 1969. The Crawford trial judge determined that both de facto and de jure segregation existed in the Los Angeles school system. On appeal, the California Supreme Court held that the California Constitution required LAUSD to mitigate segregation, whether it was de facto or de jure. After a desegregation plan involving mandatory student reassignment and busing was proposed, California residents amended the state constitution to forbid those measures unless necessary to remedy a federal constitutional violation. A California trial court held that reassignment and busing were required, because Crawford had established de jure segregation. An appellate court reversed, concluding that de jure segregation had not been established, given recent Supreme Court decisions requiring a showing of specific, discriminatory intent. The California Supreme Court declined to review, and a revised desegregation plan—involving no mandatory reassignment or busing—was established. The Crawford plaintiffs did not appeal the revised plan. In the NAACP case, the district court denied the defendants’ motion for summary judgment. The Ninth Circuit agreed to hear the defendants’ interlocutory appeal.