United States of America v. Flagler County School District et al.

District Court, M.D. Florida·Decided March 4, 2026·No. 3:70-cv-00636·Unknown

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION

UNITED STATES OF AMERICA,

Plaintiff, Case No. 3:70-cv-636-TJC-PDB v.

FLAGLER COUNTY SCHOOL DISTRICT et al.,

Defendants.

ORDER This case is before the Court on the Joint Motion for Unitary Status. (Doc. 114). The Court has considered the Joint Motion, reviewed the historical record, and heard oral argument on January 14, 2026, the record of which is incorporated by reference. (Doc. 119). For the following reasons, the Joint Motion for Unitary Status is due to be granted. I. BACKGROUND On July 10, 1970, the United States filed suit against Flagler County School District, challenging its racially segregated school system.1 On August 7, 1970, this

1 At the same time, the United States filed suit against the Baker, Bradford, Pasco, Seminole, and St. Johns County school districts, docketed together with this matter. The Baker, Pasco, Seminole, and St. Johns matters are now closed. At the hearing, the United States stated that it anticipates movement in the Bradford case within the calendar year. Court approved and ordered a plan to desegregate the District commencing with the 1970–1971 school year, and directed the District to file annual reports on its

desegregation efforts. (Doc. 98-2). On June 5, 1972, this Court issued a Consent Decree and Order, negotiated by the parties, allowing the District to reassign students in grades K–6 to a newly- constructed Bunnell Elementary School, to reassign students in grades 7–12 to a

new high school, Flagler Palm Coast High School, and to close the Flagler Beach School. (Doc. 116-1). On May 7, 1980, the Court removed this action from its active docket, noting that the District retained a “duty to abide by and comply with the Court’s orders,” including its obligation to file annual reports. (Doc. 98-4). Between

1971 and 1988, the District regularly filed annual reports pursuant to the Court’s orders. (Doc. 116, attachments). In January 2018, the United States conducted a site visit, during which it visited each of the District’s schools, including its two public charter schools,

interviewed senior central office staff, and observed a quarterly meeting of the District’s Coalition for Student Success. (Doc. 114 at 2).2 On September 25, 2024, the United States sent the District another request for information about its compliance with the Court’s orders, seeking an update to

2 The Coalition consists of staff, students, community members, and local law enforcement who monitor and recommend amendments to the District’s student discipline policies and practices. the previously provided information, to which the District responded on January 15, 2025. (Id. at 3). At the January 14, 2026 hearing, the United States stated that

the data demonstrated the vestiges of prior de jure segregation were eliminated to the extent practicable in Flagler County Public Schools. II. LEGAL STANDARD The goal of a school desegregation case is to promptly convert a de jure

segregated school system to a system without “white” schools or “black” schools, but just schools. Green v. County Sch. Bd. of New Kent Cnty., Va., 391 U.S. 430, 442 (1968). In determining whether a declaration of unitary status is appropriate, the Court considers: (1) whether the school district has fully and satisfactorily complied

with the Court’s decrees for a reasonable period; (2) whether the vestiges of prior de jure segregation have been “eliminated to the extent practicable”; and (3) “whether the school district has . . . demonstrated a good-faith commitment to the whole of the [C]ourt[’]s decree[s] and to those provisions of the law and the

Constitution that were the predicate for judicial intervention in the first instance.” See Missouri v. Jenkins, 515 U.S. 70, 87–89 (1995) (quoting Freeman v. Pitts, 503 U.S. 467, 491–92, 498 (1992); Bd. of Educ. of Oklahoma City Pub. Sch. v. Dowell, 498 U.S. 237, 249–50 (1991)).

The Supreme Court has identified six areas, commonly known as the “Green factors,” to be addressed when analyzing whether a school district has fulfilled its desegregation duties and eliminated vestiges of the prior dual system to the extent practicable: (1) student assignment; (2) faculty; (3) staff; (4) transportation; (5) extracurricular activities; and (6) facilities. Green, 391 U.S. at 435; see Manning ex

rel. Manning v. Sch. Bd. of Hillsborough Cnty., 244 F.3d 927, 942 (11th Cir. 2001) (“For a district court to determine whether the vestiges of discrimination have been eliminated to the extent practicable, it must examine . . . the so-called Green factors[.]”). Consideration of other indicia, such as “the quality of education being

offered to the white and black student populations” and student discipline, may be appropriate. Freeman, 503 U.S. at 492–93; see Lee v. Etowah Cnty. Bd. of Educ., 963 F.2d 1416, 1426 (11th Cir. 1992). The proper measure of a school district’s progress toward unitary status “is the effectiveness, not the purpose” of its actions.

Dayton Bd. of Educ. v. Brinkman, 443 U.S. 526, 538 (1979); see also Swann v. Charlotte-Mecklenburg Bd. of Educ., 402 U.S. 1, 25 (1971). A school district must demonstrate its “affirmative commitment to comply in good faith with the entirety of a desegregation plan,” and that it has not “acted in bad faith or engaged in

further acts of discrimination since the desegregation plan went into effect.” Freeman, 503 U.S. at 499. To satisfy the faculty and staff factors of the Green test, the ratio of black to white teachers and other staff assigned to each school must be “substantially the

same” in comparison to the school district in its entirety. Singleton v. Jackson Mun. Separate Sch. Dist., 419 F.2d 1211, 1217–18 (5th Cir. 1970), rev’d in part sub nom, Carter v. W. Feliciana Parish Sch. Bd., 396 U.S. 290 (1970). “Substantially the same” has been interpreted as allowing for up to a 15% variation in faculty and staff for each school’s minority staff ratio. See Pitts by Pitts v. Freeman, 887 F.2d

1438, 1447–48 (11th Cir. 1989), rev’d on other grounds, 503 U.S. 467 (1992); see also Belk v. Charlotte-Mecklenburg Bd. of Educ., 269 F.3d 305, 319 (4th Cir. 2001) (approving use of a 15% variance from districtwide proportions for assessing student assignment).

III. ANALYSIS

The following facts are stipulated by the parties. (Doc. 114 at 4). During the 1974–75 school year, the District operated just two schools, enrolling 1,140 students (66.4% white and 33.5% black). (Id.). Bunnell Elementary School served all students in grades K–6, of whom 467 (63.3%) were white and 271 (36.7%) were black. (Id.). Flagler Palm Coast High School served all students in grades 7–12, of

whom 489 (69.7%) were white and 212 (30.2%) were black. (Id.).

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