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PICS v. Seattle School Dist. No. 1

Citation: 72 P.3d 151Docket: 72712-1

Court: Washington Supreme Court; June 26, 2003; Washington; State Supreme Court

Narrative Opinion Summary

The Washington Supreme Court examined whether the Seattle School District's 'open choice' assignment plan violates RCW 49.60.400, which prohibits race-cognizant actions by the state. The plan aims to prevent de facto school segregation resulting from racially segregated housing patterns by allowing student choice and using race as a tie-breaker in oversubscribed schools. Parents Involved in Community Schools (PICS) challenged the legality of the plan, arguing it contravenes state and federal laws. Initially, the United States District Court for the Western District of Washington upheld the School District's plan. However, the Ninth Circuit reversed this decision, raising questions about the interpretation of Initiative 200 (I-200), which mirrors California's Proposition 209. The Washington Supreme Court clarified that I-200 does not prohibit all race-conscious actions, permitting race-neutral programs that do not favor less qualified candidates based on race. The court remanded the case, affirming the legality of the School District's approach, which supports educational diversity without breaching RCW 49.60.400. This decision emphasizes the importance of promoting integrated schooling environments to fulfill the state's constitutional mandate for providing equitable education to all students.

Legal Issues Addressed

Affirmative Action and RCW 49.60.400

Application: Affirmative action initiatives that result in the selection of less qualified candidates over more qualified ones are impermissible under RCW 49.60.400.

Reasoning: Specifically, affirmative action that favors less qualified candidates over more qualified ones is impermissible.

Educational Policy and De Facto Segregation

Application: The court affirmed the authority of school districts to adopt measures addressing de facto segregation to ensure diverse and integrated educational environments.

Reasoning: The School District, facing challenges from racially segregated housing patterns, adopted a plan that allows student choice while promoting racial diversity in schools.

Interpretation of Initiative 200 (I-200)

Application: The court held that Initiative 200 should be interpreted in a manner that does not prohibit race-neutral measures aimed at promoting diversity, while avoiding favoritism based on race.

Reasoning: The court seeks clarity on the implications of I-200, including its relationship to state and federal law, the relevance of California's Proposition 209, and whether I-200's language is clear or ambiguous.

Legality of Racially Neutral Programs

Application: The Seattle School District's open choice plan, which uses a racially neutral approach to promote diversity, is lawful under RCW 49.60.400 as it does not constitute discrimination or preferential treatment.

Reasoning: However, racially neutral programs, such as Seattle School District No. 1's open choice plan, are lawful.

Race-Cognizant Actions under RCW 49.60.400

Application: The court determined that not all race-cognizant actions by state entities are prohibited by RCW 49.60.400. Specifically, certain actions that do not favor less qualified candidates over more qualified ones may be permissible.

Reasoning: The court concluded that while some race-cognizant actions are prohibited, not all are disallowed.