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Jenkins v. State of Mo.

Citations: 593 F. Supp. 1485; 20 Educ. L. Rep. 852; 1984 U.S. Dist. LEXIS 23563Docket: 77-0420-CV-W-4

Court: District Court, W.D. Missouri; September 17, 1984; Federal District Court

Narrative Opinion Summary

In Jenkins v. State of Missouri, plaintiffs alleged that state agencies and the Kansas City Missouri School District (KCMSD) contributed to racial segregation in schools. The KCMSD, initially aligned with plaintiffs, filed a cross-claim against the state, accusing it of failing to dismantle a dual school system. Jurisdiction was based on federal civil rights statutes, including 42 U.S.C. sections 1983 and 2000d, and the 14th Amendment. The court ruled against the State of Missouri and in favor of the KCMSD's cross-claim, recognizing the state's historical role in maintaining segregated schools. However, claims against HUD for housing discrimination under Title VI and VIII were dismissed, with the court finding no constitutional violations. The court underscored Missouri's obligation to transition to a nondiscriminatory school system, rejecting the state's defense of natural demographic changes. A plan to remedy segregation was ordered, emphasizing the collaboration between the KCMSD and the State Board of Education. The ruling mandates that the state bear much of the financial burden for implementing desegregation measures, with a focus on ensuring equitable education across the district.

Legal Issues Addressed

Cross-Claims in Civil Rights Actions

Application: The KCMSD filed a cross-claim against the State of Missouri, asserting that the state failed to dismantle remnants of its dual school system.

Reasoning: The KCMSD cross-claims against Missouri, asserting that the state has not taken necessary steps to dismantle its historical dual school system and has instead contributed to ongoing segregation.

Federal Housing Discrimination Claims under Title VI and VIII

Application: The court found that HUD's actions in Kansas City did not violate plaintiffs’ rights under Title VI and VIII, despite claims related to housing segregation.

Reasoning: The court determined that HUD acted reasonably and responsively...asserting that ceasing funding would harm low-income individuals and that the actions did not violate plaintiffs' Fifth Amendment rights.

Jurisdiction under Federal Civil Rights Statutes

Application: Jurisdiction was established under statutes such as 42 U.S.C. sections 1983 and 2000d, enabling the plaintiffs to seek declaratory and injunctive relief against the defendants.

Reasoning: Jurisdiction was established under various federal statutes, including 42 U.S.C. sections 1983 and 2000d, and the 14th Amendment of the U.S. Constitution.

Remedial Plans for Desegregation

Application: The court ordered the KCMSD and the State Board of Education to develop a plan to create a unitary school system, focusing on schools with over 90% Black enrollment.

Reasoning: The Court emphasizes that the KCMSD Board of Education and the State Board of Education should develop a plan to create a unitary school system within KCMSD, focusing on schools with over 90% Black enrollment.

State Liability for Private Discrimination

Application: The court found that while the State of Missouri fostered an environment that legitimized private discrimination, this does not automatically invoke state liability.

Reasoning: The plaintiffs aim to hold the State of Missouri liable for discriminatory practices conducted by private entities such as real estate brokers, banks, and insurance companies, which are licensed and regulated by the state.

Termination of Segregated School Systems under the 14th Amendment

Application: The Kansas City Missouri School District (KCMSD) and the State of Missouri were found to have failed in their constitutional duty to dismantle the dual school system established prior to the Brown v. Board of Education decision.

Reasoning: The Court has determined that the Kansas City, Missouri School District (KCMSD) and the State of Missouri have failed to fulfill their constitutional obligations regarding public education, leading to the persistence of a dual school system.