Morrilton School District No. 32 et al. v. United States of America

Morrilton School District No. 32 et al. v. United States of America was a school desegregation case that began in 1972. However, aspects of the lengthy litigation were still being contested into the mid-1980s.

The case began in December 1972 when the U.S. Department of Justice filed suit against the State of Arkansas, the Arkansas Department of Education, the members of the state Board of Education, and the school districts of Conway County, as well as the local school board members and superintendents. The federal government charged that, in the process of consolidating the county’s school districts in response to a federal desegregation order, the school officials had in fact purposely created segregated school districts and, in doing so, had violated both the Fourteenth Amendment and the Civil Rights Act of 1964.

The case came to trial in 1973 after the District Court had dismissed the State of Arkansas and the Arkansas Department of Education as defendants while keeping the individual members of the state board as well as the state director of education as parties to the suit. At trial, the court determined that local authorities had segregated students according to race throughout the county’s school district. One of the factors that led to the court’s ruling was the racial makeup of the faculty within the Conway County schools. Indeed, it alone was enough to create a violation of the equal protection clause of the Fourteenth Amendment—two of the all-white districts had no African-American teachers, while one had only two black teachers, and the African-American district had only one white teacher.

Upon appeal in 1979, the Court of Appeals upheld the finding of purposeful segregation. It acknowledged that the Arkansas statutes under which the school district consolidations had been achieved were themselves racially neutral, having no requirement that the newly consolidated districts be constructed along racial lines. However, the Court noted that the pattern of consolidation, operating out of a historic pattern that had made previous districts either black or white, led to this new round of segregation.

At the same time, the Court of Appeals declared, “Interdistrict relief is properly ordered when one district was almost entirely African American and included territory that would have been properly consolidated with the surrounding school districts were it not due to racial considerations.” It also upheld the District Court’s order that the districts be redrawn so that the integration of the high schools in the newly created districts would be ready to begin in August 1979, while the integration of the elementary and junior high schools in the new districts would be ready to take effect beginning in August 1980. The case was appealed to the U.S. Supreme Court, but the request for a writ of certiorari was denied in 1980, leaving the lower court rulings in effect.

The U.S. Supreme Court’s refusal to hear the case ended the substantive discussion. However, new efforts were made to restore the previously dismissed parties to the complaint, as litigation continued well into the 1980s over matters of liability for the costs of consolidation as well as who and what were the appropriate parties to the litigation. These issues were ultimately resolved, but not before they illustrated the residual effects of the decades-long struggle to desegregate the state’s schools.

For additional information:
Morrilton School District No. 32 v. U.S., 606 F.2d 222 (8th Cir. 1979). https://law.justia.com/cases/federal/appellate-courts/F2/606/222/441198/ (accessed January 31, 2020).

United States v. State of Arkansas, 791 F. 2d 1573 (8th Cir. 1986). https://openjurist.org/791/f2d/1573/united-states-v-state-of-arkansas (accessed January 31, 2020).

William H. Pruden III
Ravenscroft School