Milliken v. Bradley

In Brown v. Board of Education, 347 U.S. 483 (1954), the United States Supreme Court held that racial segregation in public schools violated the Equal Protection Clause and was unconstitutional. In the wake of Brown, courts were faced with creating remedies for offending school districts. Verda Bradley, on behalf of her children, and others (plaintiffs) sued Michigan governor William Milliken (defendant), alleging that the Detroit public-school system was unconstitutionally segregated. The district court ruled that the Detroit schools were unconstitutionally segregated and that a combination of federal, state, and local policies had established a pattern of residential segregation in the Detroit metropolitan area. The court ordered the Detroit Board of Education and 53 neighboring suburban school districts to submit desegregation plans that addressed the entire three-county Detroit metropolitan area and included busing students from surrounding school districts to achieve desegregation. The school districts appealed to the United States Court of Appeals for the Sixth Circuit. The Sixth Circuit agreed that a comprehensive metropolitan-area plan was required to remedy segregation in the Detroit school district and that ordering such a remedy was within the court’s equitable powers. The United States Supreme Court granted certiorari.