On

Inherency
Milliken effectively reversed Brown V Board – School segregation is increasing and
zero efforts to reverse the trend
ALEXANDER NAZARYAN, senior writer at Newsweek. He was previously on the editorial board of the
New York Daily News, “WHITES ONLY: SCHOOL SEGREGATION IS BACK, FROM BIRMINGHAM TO SAN
FRANCISCO”, May 2nd 2017, http://www.newsweek.com/race-schools-592637

More recently, Clemon has found himself in another surreal situation. This past winter, he was
in court to argue Stout v.
Jefferson County once again, this time because a middle-class Birmingham suburb called Gardendale wants to
leave the Jefferson County school system. Gardendale, which is mostly white, says race has nothing to
do with its push for secession: It simply wants to control its schools. Clemon is skeptical. “The intent is to
create a local school system where they will have control over who comes in and that they will minimize
the number of blacks who come in,” he told me in his raspy, slightly mischievous baritone. Local control has become a
popular rallying cry in municipalities across the nation—including liberal states like New York and California—that
want to form their own school districts. They all have their reasons, and the reasons all sound reasonable, but Clemon
believes he knows what motivates Gardendale and at least some of its counterparts around the country, which is schools that
share a single feature that mild suburbanites, with their secret yearnings, will not name. But Clemon, who faced off against Bull Connor and his
water cannons and his dogs, will: “No
blacks.”The Mason-Dixon Line in South Boston The most remarkable thing about
school integration in the United States is how rare it is, and has always been. The Supreme Court struck down
separate but equal schooling with 1954’s Brown v. Board of Education ruling, but it fell to federal judges of the 1960s
and early ’70s to enforce that decision with orders like Stout v. Jefferson. Such court orders were frequently unpopular; when the
opponents of integration lost in the courts, they took to the streets. The resistance reached its apex in 1974, when the blue-collar Irish of South
Boston resisted the yellow school buses that had come to symbolize integration; they were as feared and loathed by the populace as the tanks
of an invading army. Yet the buses came and went, in Boston and elsewhere. By 1988, widely acknowledged to be the high point of
school integration in the U.S., nearly half of all black children attended a majority-white school. An achievement gap
that once appeared to be intractable suddenly seemed like something that could be closed in a generation or two.Since then, however,
the gains of Brown v. Board have been almost entirely reversed. Last year, a report by the Government
Accountability Office found “a large increase in schools that are the most isolated by poverty and race.”
Between 2000 and 2014, the number of schools the report deemed H/PBH—that is, “high poverty and comprised of mostly
Black or Hispanic students”—more than doubled, from 7,009 to 15,089.An even more astonishing statistic appeared in a
Century Foundation report, published three months earlier, about schools that used socioeconomic status, or class, instead of race as a means
to integrate schools. (There are fewer legal and social barriers to socioeconomic integration, but the result is effectively the same.) The Century
Foundation concluded that only about “8 percent of all public school students currently attend school districts or charter schools that use
socioeconomic status as a factor in student assignment.” The report’s tone was hopeful, because while the number of districts around country
that consciously practiced class integration was a paltry 91 out of more than 13,000, that’s more than double what it was in 2007. Conscious
attempts at integration are rare today because the same court that struck down separate-but-equal promptly struck down
the best remedy for it. In 1974, 20 years after Brown v. Board , the Supreme Court ruled in Milliken v. Bradley that integration
could not take place across district lines, so that Detroit, where the case was brought, was prevented from integrating by
exchanging its kids with white and wealthy Bloomfield Hills. In 1986, in 1991 and again in 1992, an increasingly conservative Supreme Court said
it wanted desegregation orders lifted once certain conditions were met. The Supreme Court’s most severe blow since Milliken came
in 2007, in the Parents Involved in Community Schools v. Seattle School District No. 1 case, in which it prohibited the use of “explicit racial
classifications” in school admissions. Wrote Chief Justice John Roberts Jr., "The way to stop discrimination on the basis of race is to stop
discriminating on the basis of race." By conflating integration with discrimination, Roberts effectively reversed Brown v. Board.
Solvency
 Plan Solves
The Milliken case has hampered any hope of dissolving a ‘separate but equal’
mentality
James Ryan, Dean of Education at Harvard, 6-4-2014, "Brown at 60 and Milliken at 40,"
https://www.gse.harvard.edu/news/ed/14/06/brown-60-milliken-40, James Ryan is the dean of the Ed
School. Before coming to Harvard, he taught at the University of Virginia as a professor of law and a
research professor of civil liberties and human rights. In 2011, he wrote Five Miles Away, A World Apart:
One City, Two Schools, and the Story of Educational Opportunity in Modern America.

The Milliken decision effectively ended any hope that the educational fortunes of urban and suburban
schools, students, and parents would be bound together through school desegregation. Additional
attempts to bind the fate of urban and suburban students have similarly failed, leaving the two worlds of urban
and suburban education largely separate. Our country continues to live in the shadow of Milliken. Most African
American and Latino students attend urban schools. The higher the percentage of minorities in an urban
school, on average, the higher the percentage of poor students. And students who attend high-poverty
schools generally score lower on standardized tests, are less likely to graduate, and are less likely to go
to college. School finance reform, the remedy sought by urban districts and activists in the post-Milliken era, has made less difference than
one would have hoped and has done little to bring most urban schools up to par with suburban ones. Brown asserted that separate is
inherently unequal. One might quarrel with the term inherently. But even if separate is not inherently unequal, it quite often results in
inequalities, especially where separation occurs along lines of socioeconomic status, race, and political power. Milliken thus
both
limited the reach of Brown and confirmed the wisdom of its premise — that we are unlikely to see truly
equal educational opportunities as long as we continue to separate the advantaged from the
disadvantaged and educate them in separate school systems.

The next supreme court case is key – a ruling for desegregation is critical to American
economy and reforming society
Myron Orfield, Professor of Law and the Director of the Institute for Metropolitan Opportunity at the
University of Minnesota, “Milliken, Meredith, and Metropolitan Segregation”, 62 UCLA L. Rev. 364
(2015), http://www.uclalawreview.org/pdf/62-2-3.pdf

Had Milliken been decided more consistently with historical local government law and the Court’s four most recent
desegregation decisions, and had it not ignored the clear factual findings of housing discrimination and that single
district remedies would increase white flight, U.S. schools would be more integrated and our racial
achievement gaps would almost certainly be narrower. In addition, metropolitan neighborhoods would
be both more integrated and more racially stable. Race relations and the housing markets of many
central cities and fully developed suburbs of America would be stronger. This stability would have
encouraged urban and older suburban redevelopment rather than the decline and blight that almost always occur when
neighborhoods resegregate and become majority nonwhite. American prosperity might have been greater and more fully shared. And
American democracy might have been more vibrant and hopeful. Richard Nixon resigned a disgraced president because
of the cover-up of political burglaries. His ethical lapses disillusioned a generation of Americans. Yet, an arguably even greater disservice was
his appointment of justices who, in the service of a divisive political vision, distorted the law and ignored clear factual findings in order to stop
the rapid progress toward equality that had begun under Brown584 and Title VI of the CivilRights Act of 1964.585 Should Justice Kennedy be
replaced with someone more like Chief Justice Roberts, the
Supreme Court would likely sustain a pattern of racial
apartheid more severe and unyielding than it allowed under Plessy v. Ferguson. 586 For all its perfidy, Plessy
did not forbid integration; it simply did not require it. Moreover, Plessy was decided in an America where the suburbs were
nascent and whites and nonwhites by and large still shared the same local governments and local tax base. Today in most parts of
metropolitan America, affluent
whites and poor blacks live in different jurisdictions, with predominantly white
school districts endowed with far more local tax resources. Because the Court in San Antonio v. Rodriquez587 declared
the federal courts were powerless to equalize state school finance,588 nonwhites will not only be stranded in segregated cities and school
districts but in jurisdictions, unless the state has chosen to intervene, without the local tax resources to either exercise meaningful “local
control” or to be “separate but equal.”589 The
next Supreme Court decision on school desegregation will be
another version of Meredith. Will the Supreme Court look at the evidence and allow locally elected officials
the discretion to create stable integration plans that improve student achievement and help integrate
neighborhoods? Or will it continue to limit the authority of elected officials to integrate schools, forcing
local, state, and federal governments to helplessly watch now-integrated neighborhoods resegregate?
There is a clear scholarly consensus that integration is beneficial to individuals and communities, and that
segregation destroys the lives of individuals and prospects of neighborhoods. Segregation hurts regions,
the American economy, and the cohesiveness and fairness of American democracy. It is hard to accept that
a court-imposed return to the school segregation levels of the past can be consistent with equal
protection under the law in the twenty-first century.

Court ruling for a school desegregation remedy is key – only the courts create societal
change through deliberation and precedent that spills-over to effect racial injustices in
prisons, police, and healthcare – Education policy is blueprint for these reforms
Danielle R. Holley-Walker, Associate Professor of Law, University of South Carolina School of Law. “A
New Era for Desegreg”, Georgia State University Law Review, Vol. 28 [2011], Iss. 2, Art. 4 1-1-2012,
http://scholarcommons.sc.edu/cgi/viewcontent.cgi?article=1913&context=law_facpub

As Professor Michelle Adams argues in a recent article, the

topic of school desegregation is central to the broader
dialogue about the value of racial integration.227 Professor Adams argues that the goal of racial integration is under
attack.228 For some conservatives, such as Chief Justice Roberts, promoting racial equality in K-12 schools
means preventing reverse racial discrimination.229 For many progressives and African Americans, the
issue of race and schools is tied to the question of black identity and black achievement.230 These observers
challenge the assertion that quality schools are equivalent to racially integrated schools and argue that we should begin to focus on creating
high-quality schools regardless of their racial makeup.231 Professor Adams then argues that there is a need to embrace
“radical integration” as a “forward-looking, aspirational view of equality.”232 It is difficult to think of many
examples where racial integration is being advocated for in this manner. Traditional desegregation cases provide an
opportunity for plaintiffs to make these types of aspirational arguments for racial equality and to see court
orders that both acknowledge the history of racial discrimination and provide a blueprint and resources
for racially integrated education in the twenty-first century. In the Walthall County desegregation case, the federal government
argued for a vision of equality that includes integrated schools and classrooms.233 Professor Adams also advocates for the radical
integration approach as a way to “highlight[] the deep interdependence between segregation and the
maintenance of white supremacy. Within this paradigm, racial segregation is understood as a
multifaceted and selfsustaining generator of inequality.”234 We see this theory at work in the Little Rock
desegregation case. In the school district’s Motion to Enforce the 1989 Settlement Agreement, the school district
recounted the recent history of both residential and inter-district school segregation in Pulaski
County.235 The school district is able to focus on the importance of ending racial isolation, not for the
goal of diversity, but instead to address structural inequality. Furthermore, there has not been
significant empirical evidence that racially and socioeconomically isolated schools are able to provide
high-quality education for students in those schools.236 Although desegregation decrees remain in only a small number of
school districts, plaintiffs may use these cases as an opportunity to highlight racial isolation and the
importance of racial integration as a value. 3. Litigation as a Dialogic Tool Why is litigation a useful method for
public debate on whether racial integration is an important value in our public schools? Litigation
provides a unique opportunity to have a public dialogue on the issue of racial integration. Litigation
also provides an opportunity to marshal and debate empirical evidence on the role of race in public
education. PICS is an example of litigation providing an opportunity for a broad public dialogue on race in public schools. The party
briefs and amicus briefs provided ample empirical evidence about whether avoiding racial isolation may
be a compelling government reason for employing race-conscious remedies.237 In the Supreme Court opinion, the
Justices engage in a debate about the meaning and legacy of Brown. 238 This became a key point of disagreement for the Justices in PICS. 239
For Chief Justice Roberts, the desegregation cases, beginning with Brown, represent the importance of colorblindness:240 Before Brown,
schoolchildren were told where they could and could not go to school based on the color of their skin. . . . For schools that never segregated on
the basis of race, such as Seattle, or that have removed the vestiges of past segregation, such as Jefferson County, the way “to achieve a system
of determining admission to the public schools on a nonracial basis” is to stop assigning students on a racial basis. The way to stop
discrimination on the basis of race is to stop discriminating on the basis of race.241 Justice Stevens wrote a separate dissent focusing on the
legacy of Brown. Justice Stevens argued that Chief Justice Roberts’ interpretation of Brown was devoid of context and history: There is a cruel
irony in THE CHIEF JUSTICE’s reliance on our decision in Brown . . . . THE CHIEF JUSTICE fails to note that it was only black schoolchildren who
were so ordered [that they could not go to school with white children]; indeed, the history books do not tell stories of white children struggling
to attend black schools . . . . THE CHIEF JUSTICE rejects the conclusion that the racial classifications at issue here should be viewed differently
than others, because they do not impose burdens on one race alone and do not stigmatize or exclude.242 The remaining desegregation
cases and their outcome will provide an important opportunity to recapture the legacy of Brown and
to engage in a public discourse about the continuing racial inequality in our public schools. There are also
significant limits to litigation, and many of these challenges have been demonstrated in the history of the desegregation cases. Traditional
school desegregation cases occupy a special place in the history of American litigation.243 Scholars have
identified desegregation cases as the paradigmatic example of structural reform litigation and public
law litigation. According to Professor Owen Fiss: Adjudication is the social process that enables judges to give meaning to
public values. Structural reform . . . is one type of adjudication, distinguished by the constitutional character of the public
values and, even more important, by the fact that it involves an encounter between the judiciary and the state bureaucracies. The judge
tries to give meaning to our constitutional values in the operation of these organizations . . . . As a genre of
constitutional litigation, structural reform has its roots in the Warren Court era of the 1950s and 1960s and the extraordinary effort to translate
the rule of Brown v. Board of Education into practice.244 As
structural reform litigation, the school desegregation cases
led the way for other types of lawsuits to reform social institutions, such as prisons, mental health
facilities, housing authorities, and police departments.245 The role of desegregation cases as a
paradigm of structural reform litigation means that the legacy of these cases has broader
implications.246 Is the desegregation docket in the federal district courts seen as a failure? Some have argued that the litigation strategy
failed.247 Others have argued that court-supervised desegregation was successful for a short time from the late 1960s to mid-1970s and then
began to suffer a series of setbacks that have led to the current climate of resegregation.248 A
new era of desegregation may
redefine the landscape of structural reform litigation by demonstrating the resilience of this form of
adjudication. These cases lay dormant for decades, but because of the process of adjudication,
specifically the remedy of the injunction, the cases remain a powerful tool for social transformation and racial
justice. The school desegregation cases were a blueprint for many of the other major structural reform
litigation movements, including prison reform and reform of mental health institutions. IV. CONCLUSION The
final chapter of the desegregation cases is now being written. This final chapter is an important
moment for both education reform and racial justice. The remaining desegregation cases are a means
to help address the lingering effects of past discrimination and to refocus our education reform on
equality as a core value.
Race-Conscious inter-district remedies can be diverse and tailored to individual areas
– solves their general inter-district remedy fails arguments
Kevin G. WeIner University of Colorado, Boulder, “K-12 Race-Conscious Student Assignment Policies:
Law, Social Science, and Diversity”, Review of Educational Research Fall 2006, Vol. 76, No. 3, pp. 349-
382

Race-Conscious Student Assignment Policies The litigation of voluntarily adopted race-conscious student
assignment policies (RCSAPs) began only a decade ago. Most early RCSAPs resembled the type at issue in
Tuttle (1999), one of the first cases, where the federal appellate court struck down a student assignment policy
from Arlington County, Virginia. That policy used a weighted lottery to decide admissions for a popular,
oversubscribed altemative kindergarten school. The weighting formula included race as well as English-language ability and
low-income status, designed to add students classified in groups that had been underrepresented at the
school. The more recent RCSAP policies, including the ones in Seattle and Louisville, turn to race only as
a tiebreaker within choice-based systems. For instance, the Seattle policy, which applies only to its high schools, sets
up a sequential series of four tiebreakers that kick in if a school is oversubscribed. Establishing the RCSAP was part of a larger
plan to create unique, themed high schools and to make transfers easier. Approximately half of the schools were oversubscribed, thus
implicating the tiebreaker system. Students with a sibling attending the chosen school receive first priority for admission. Next, the
race-
based tiebreaker kicks in if the school enrollment differs by more than 15% from the overall racial
composition of the school district. In 2001-2002, the race-based tiebreaker was applied to three of the high schools. It is important
to note that this system can enhance admissions chances for Whites (as happened at one of the three schools) or non-Whites (as happened at
two). The Seattle policy also has what it calls a "thermostat," which turns the racial tiebreaker off immediately whenever the school's
enrollment comes within the 15%, plus or minus variance. The third tiebreaker gives priority to students who live closer to the school. And the
fourth tiebreaker, which is virtually never used, is a simple lottery. The
Louisville system, which applies at all grade levels after
kindergarten, is
fairly complex. Various categories of schools each have their own admissions rules. But
Louisville's race-conscious elements resemble Seattle's in most important ways. The RCSAP was
combined with an enhancement in parental choice and a focus on magnet schools. It allows for a broad range of
student enrollment diversity (15% to 50% African American, reflecting the overall district population),
focusing on avoiding extreme segregation rather than on racial balancing. Local residence (distance) and
parental choice are the key criteria, accounting for the vast majority of enrollment decisions. The litigation in
Louisville concerned mainly some back-to-basics (called "traditional") schools that were oversubscribed. Applicants to these traditional schools
are sorted into four separate lists at each grade level: female White, female African American, male White, and male African American. Each list
is randomly ordered. Subject to the school district's final approval, each
school's principal generally follows a process
whereby he or she starts at the top of each list, drawing candidates and trying to stay within the 15% to
50% racial guidelines, which are applied at the school (not the grade) level.

Integration key to understanding and challenging racial assumptions – builds empathy

for others
Wells et al 16
2/9/16 AMY STUART WELLS, LAUREN FOX, AND DIANA CORDOVA-COBO. Amy Stuart Wells is professor
of sociology and education and director of the Center for Understanding Race and Education (CURE) at
Teachers College, Columbia University. Lauren Fox is an advanced doctoral student in sociology and
education at Teachers College and a research associate at CURE. Diana Cordova-Cobo is a doctoral
student in sociology and education at Teachers College and a research assistant for CURE and for the
Public Good. “How Racially Diverse Schools and Classrooms Can Benefit All Students”
https://tcf.org/content/report/how-racially-diverse-schools-and-classrooms-can-benefit-all-students/

Increased Intercultural and Cross-Racial Knowledge, Understanding, and Empathy: In addition to the robust
social science evidence on the positive relationship between student body diversity and academic outcomes, there is a similarly
impressive body of research supporting the correlation between campus and classroom diversity and an
enhanced ability of students to exhibit interracial understanding, empathy, and an ability to live with
and learn from people of diverse backgrounds. The amicus brief filed by Brown and other elite universities in the Fisher II case
highlights that “diversity encourages students to question their assumptions, to understand that wisdom
may be found in unexpected voices, and to gain an appreciation of the complexity of today’s world.”26
Other research includes analyses of how racially diverse educational settings are effective in reducing prejudice, by
promoting greater contact between students of different races—both informally and in classroom
settings—and by encouraging relationships and friendships across group lines.27 The takeaway for policy makers
in the K–12 education context is that there is extensive and solid evidence that intergroup contact and cross-racial
interaction improves interracial attitudes toward an entire group and reduces prejudice and the implicit
biases discussed above.28 Indeed, as we discuss below, research on these issues in K–12 education with similar
findings was, at one time, far more central to policy debates in elementary and secondary education.
Better Preparation for Employment in the Global Economy Throughout the recent briefs in the Fisher II case, and building on an already rich
body of social science evidence amassed for this and prior affirmative action cases, university officials and business leaders argue that
diverse college campuses and classrooms prepare students for life, work, and leadership in a more
global economy by fostering leaders who are creative, collaborative, and able to navigate deftly in
dynamic, multicultural environments.29 A brief filed by nearly half of the Fortune 100 companies, including Apple, Johnson &
Johnson, and Starbucks, argued that to succeed in a global economy, they must hire highly trained employees of
all races, religions, cultures, and economic backgrounds. They noted that it is also critical that “all of their university-
trained employees” enter the workforce with experience in sharing ideas, experiences, viewpoints, and approaches with diverse groups of
people. In fact, such cross-cultural skills are a “business and economic imperative,” given that they must operate in national and global
economies that are increasingly diverse.A workforce trained in a diverse environment is critical to their business
success. Such college graduates, companies argue, provide more creative approaches to problem-solving by integrating different
perspectives and moving beyond linear, conventional thinking. Employees are: better equipped to understand a wider
variety of consumer needs, including needs specific to particular groups, and thus to develop products
and services that appeal to a variety of consumers and to market those offerings in appealing ways; they
are better able to work productively with business partners, employees, and clients in the United States and around the world; and they are
likely to generate a more positive work environment by decreasing incidents of discrimination and stereotyping.30 Diverse educational
environments also enhance students’ leadership skills, among other skills that are helpful when working
in racially, ethnically, and culturally diverse workplaces. A longitudinal study found that the more often first-year college
students are exposed to diverse educational settings, the greater their “gains in leadership skills, psychological well-being, intellectual
engagement, and intercultural effectiveness.”31 Indeed, the APA brief argues, in addition to obvious academic pursuits, colleges and
universities also prepare students to be effective economic and political leaders on local, national, and global levels. “Effective leadership
begins with prejudice reduction.”32 Increased “Democratic Outcomes,” including Engagement in Political Issues
and Participation in Democratic Processes: And finally, students’ experiences in diverse classrooms can
provide the kind of cross-cultural dialogue that prepares them for citizenship in a multifaceted society.33
Students develop improved civic attitudes toward democratic participation, civic behaviors such as
participating in community activities, and intentions to participate in civic activities resulting from
diverse learning experiences. One meta-analysis synthesized twenty-seven studies on the effects of diversity on civic engagement
and concluded that college diversity experiences are, in fact, positively related to increased civic engagement.
Federal desegregation efforts key to break down racism in society
Wells et al 16
2/9/16 AMY STUART WELLS, LAUREN FOX, AND DIANA CORDOVA-COBO. Amy Stuart Wells is professor
of sociology and education and director of the Center for Understanding Race and Education (CURE) at
Teachers College, Columbia University. Lauren Fox is an advanced doctoral student in sociology and
education at Teachers College and a research associate at CURE. Diana Cordova-Cobo is a doctoral
student in sociology and education at Teachers College and a research assistant for CURE and for the
Public Good. “How Racially Diverse Schools and Classrooms Can Benefit All Students”
https://tcf.org/content/report/how-racially-diverse-schools-and-classrooms-can-benefit-all-students/

A growing number of parents, university officials, and employers want our elementary and secondary
schools to better prepare students for our increasingly racially and ethnically diverse society and the
global economy. But for reasons we cannot explain, the demands of this large segment of Americans have yet to resonate with most of
our federal, state, or local policymakers. Instead, over the past forty years, these policy makers have completely
ignored issues of racial segregation while focusing almost exclusively on high-stakes accountability, even as our schools
have become increasingly segregated and unequal. This report argues that, as our K–12 student population becomes more
racially and ethnically diverse, the time is right for our political leaders to pay more attention to the evidence,
intuition, and common sense that supports the importance of racially and ethnically diverse educational
settings to prepare the next generation. It highlights in particular the large body of research that demonstrates the important
educational benefits—cognitive, social, and emotional—for all students who interact with classmates from different backgrounds, cultures, and
orientations to the world. This research legitimizes the intuition of millions of Americans who recognize that, as
the nation becomes more racially and ethnically complex, our schools should reflect that diversity and
tap into the benefits of these more diverse schools to better educate all our students for the twenty-first
century. The advocates of racially integrated schools understand that much of the recent racial tension and unrest in this
nation—from Ferguson to Baltimore to Staten Island—may well have been avoided if more children had
attended schools that taught them to address implicit biases related to racial, ethnic, and cultural
differences. This report supports this argument beyond any reasonable doubt. Why the Emphasis on the Educational Benefits of Diversity
Now? The call for more attention to intense racial segregation in our nation’s schools and communities is
coming from parents, educators, and employers who are realigning their priorities and understandings
in light of our increasingly global economy and the rapid changes in our nation’s demographics and
migration patterns.1 For the first time, the K–12 student population in the United States is less than 50 percent white, non-Hispanic.
Meanwhile, in many of our major metropolitan areas, we see large-scale migration patterns, as more black, Hispanic, and Asian families move
to the suburbs and more whites return to “gentrifying” urban neighborhoods. In both contexts, de facto diverse communities are forming, if
only temporarily, before patterns of racial segregation re-emerge.2 These recent developments suggest we
are at a critical moment
in history—at a juncture between a future of more racial unrest and a future of racial healing when our
society can become less divided and more equal. It is also clear from our history that absent strong
leadership at the federal, state, and local level to sustain diverse neighborhoods and schools, it is likely we
will recreate high levels of racial segregation in both urban and suburban contexts.3 In this report, we review
the research and reasons why, in the field of education in particular, policy makers should listen to the growing demand for more diverse public
schools. Drawing on the research from both higher education and K–12 education, we demonstrate that there are important educational
benefits to learning in environments with peers who grew up on the other side of the racial divide in this country. Indeed, in recent years, most
of this research on the “educational benefits of diversity” has been conducted in colleges and universities and then put forth as powerful
evidence to support affirmative action in higher education. This year, as the U.S. Supreme Court considers affirmative action once again in the
Fisher v. University of Texas4 case (Fisher II), it is an important moment to consider how those arguments translate into the K–12 educational
context. In fact, researchers, policy makers, and educators in K–12 were, once upon a time, much more focused on the problem of racial
segregation than they have been in recent decades. This shift in focus is due in large part, we argue, to the changing policy context in
elementary and secondary education over the last several decades—away from school desegregation policy and toward a focus on outcomes
and accountability in racially, ethnically, and socioeconomically segregated settings. In fact, the emphasis in K–12 education on narrow student
achievement measures has moved the entire field away from examining cultural issues related to race, ethnicity, and the social and emotional
development of children.5 Given the demographic and attitudinal changes discussed above, now is the time to refocus the K–12 agenda on
issues of racial, ethnic, and socioeconomic integration and the educational benefits that accrue from students learning from each other in
diverse schools and classrooms. We use the term racial “integration” and not “desegregation” to convey that we mean something more than
merely moving students to balance racial enrollments. When we discuss the research evidence on the educational benefits of diversity, we are
talking about a more meaningful form of racial and ethnic integration, leading to greater mutual respect, understanding, and empathy across
racial lines.6 This report provides an overview of the forces within the K–12 educational system—demographic, educational, and political—that
could help move our public school system into the twenty-first century on issues of racial/ethnic diversity and the educational benefits of
teaching and learning in diverse schools and classrooms. While we do not deny the many factors working against the creation and sustainability
of more diverse schools and classrooms, we believe that K–12 researchers, policy makers, and parents should pay more attention to the
arguments put forth in higher education court cases regarding the educational benefits to all students. Furthermore, we argue that there
already exists a body of research in K–12 education that similarly supports an argument in favor of the educational benefits of diversity, but
that unlike the higher education research, it has been largely ignored in recent years. In
light of recent events of racial profiling,
police shootings, campus unrest, and the rise of a movement that sadly seeks to remind us of the self-
evident fact that “Black Lives Matter,” such interracial respect, understanding, and empathy is what we
should all strive for in our increasingly diverse society. There is no institution better suited to touch the
lives of millions of members of the next generation than our public schools. This report will give voice to the
millions who can envision this future for K–12 education and help us get there.

The plan mandates the Overturning of Milliken—this undoes precedents cited in later
cases
Powell 2016 Professor of Law at the University of Louisville, JD from NYU. Powell,
Cedric Merlin. “Milliken, ‘Neutral Principles,’ and Post-Racial Determinism.” Legal
Studies Research Paper Series 2016.2.
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2657194.

Milliken v. Bradley is a seminal decision in the Court’s race and school desegregation jurisprudence because it
marks, for the first time, an intent requirement that will serve to significantly narrow any substantive race-
conscious remedies for decades to come. In the absence of clearly identifiable district-wide
discrimination, remedies stop at the district line. “Since the ‘scope of the remedy is determined by the nature and extent of
the constitutional violation,’ there can be no interdistrict remedy in the absence of an interdistrict violation and interdistrict effect.”9 Just two
years later, in Washington v. Davis, 10 this intepnt requirement was expanded to include any race-conscious
remedy initiated by the state. Thus, racially disproportionate impact is constitutionally irrelevant in the absence of discriminatory
intent. Indeed, Milliken is the doctrinal antecedent of the Roberts Court’s post-racial determinism.11 These
decisions lead directly to the most recent school case, Parents Involved, 12 and all of the race decisions of the
Roberts Court. The Milliken decision sets the stage for the Roberts Court’s post-racial constitutionalism in
Parents Involved by advancing the de jure-de facto distinction as a normative principle under the Fourteenth
Amendment. In Parents Involved, Milliken is cited for the proposition that “the Constitution is not
violated by racial imbalance in the schools without more.”13 In the absence of a clearly identifiable interdistrict violation,
integration stops at the district line. Specifically, race-based remedial approaches are presumptively
unconstitutional without a finding of intentional segregation by the state itself. Without something more than
mere disproportionality, the result in any race case before the Court will be resolved against the interests of
African-Americans and other people of color. Post-racial determinism references the Court’s outcome driven doctrinal posture:
“Structural and systemic inequality is inevitable: in the absence of identifiable discrimination (de jure), there is nothing to remedy so any use of
race taints the political process.”14 Thus, on some level, the Court actually rationalizes the extant systemic inequality inherent in dual school
systems.
The court’s ruling in Milliken makes desegregation impossible—only the AFF solves
Chemerinsky 2016 Dean and Distinguished Professor of Law at UC Irvine, JD from
Harvard Law. Chemerinsky, Erwin. “Fifty Years of Constitutional Law: What's Changed.”
Utah Law Review 2016.5 (2016): 689-708.
From 1964 to 1988, by every measure, American public schools were less racially segregated. Since
1988, every year American
public schools have become more racially segregated.162 And according to UCLA professor Gary Orfield, they're
becoming more racially segregated at an accelerating rate.' 63 And I think Supreme Court decisions are largely
responsible for this. I point to Milliken v. Bradley,164 in 1977 that said that there cannot be interdistrict
remedies for school segregation.' 65 Students generally cannot be taken from suburbs and moved to city
schools, or from cities and moved to suburban schools. The result is, very little in the way of meaningful
school desegregation can be achieved. In most major cities, the school systems are 80% or 90% more
minority students.166 Unless students can be brought across district lines, desegregation cannot be
achieved. In Oklahoma City v. Dowell,167 in 1991, the Supreme Court said once a school system has achieved so-called unitary status,
federal court desegregation orders must end even when it's going to mean the resegregation of the schools.'6 8 And most recently in 2007, in
Parents Involved in Community Schools v. Seattle School District No. 1,169 the Supreme Court said that school systems cannot on their own use
race as a factor of assigning students into their schools to achieve diversity and desegregation.170 These cases-Milliken, Oklahoma City v.
Dowell, Parents Involved all are responsible for what has increasingly become separate and unequal schools.,'7 So that's why I say that
generally, there has been a greater commitment to equality by the Supreme Court, but it's been much less evident with regard to race.
 A2: Circumvention
Louisville proves inter-district remedies work and aren’t circumvented – but not
solvency for states CP because courts struck it down
ALANA SEMUELS, Staff writer at The Atlantic, “The City That Believed in Desegregation”, March 27th
2015, https://www.theatlantic.com/business/archive/2015/03/the-city-that-believed-in-
desegregation/388532/

The Louisville plan wasn’t popular at first. Thousands of protesters rallied against busing at the district’s schools, protesting and
vandalizing police cars until the governor called in the Kentucky National Guard to supervise buses for the first few days. But something
strange happened as the integration plan continued. Many of the residents' fears failed to materialize, and after a few years
the protests ceased. It’s as though “people are amazed to discover that people from another race or ethnic
group are actually pretty similar to them,” said Gary Orfield, the co-director of the Civil Rights Project at UCLA, who has worked
with the city for decades on the plan (and is Myron Orfield’s brother). “There’s a tremendous deflation of protests when
almost all the stereotypes people hold aren’t true.” Orfield remembers the vitriol in Louisville in 1975, when the unions and
white population alike vehemently protested the court order—at one point, a bishop supportive of the integration was spat on as he came out
of church. But Orfield also remembers how, five years after the plan began and the judge ceased active supervision of the court order, the
region’s leaders “decided what he had done was a good idea and they had a banquet for him.” Not everyone felt this way—Jefferson County
saw a drop-off in enrollment after the integration, but it later leveled off. Much has changed in the decades since the bussing plan began.
Surveys done back in the 1970s indicated that 98 percent of suburban residents opposed the plan. But in
a 2011 survey, 89 percent of parents in Jefferson County said they thought that the school district’s
guidelines should “ensure that students learn with students from different races and economic backgrounds.”
About 87 percent of parents asked said they were satisfied with the quality of their child’s education. By 2006, after a frustrated
parent fought the busing plan all the way to the Supreme Court, many in Louisville preferred integration
to the alternative. The case was named for Crystal Meredith, who had moved to Louisville in 2002 and was
required to send her son to a school 10 miles away since the school near her home was full. She and other parents
argued that the plan violated their children’s Fourteenth Amendment right to equal protection under the law.
Their case was merged with Parents Involved, a similar case from Seattle. When a bitterly divided Supreme Court
struck down Jefferson County’s integration plan, students and parents spoke openly about how they
disagreed with the decision. One graduate of Jefferson County Public Schools wrote an impassioned op-ed in the local paper,
suggesting that among those who opposed integration, there was “no talk of society as a collective group, no concern for others, no
consideration of communal benefit.” He recounted an experience he'd had at college in Virginia, where peers chanted racist slogans and carried
around Confederate flags during an “Old South” fraternity party—a display that horrified him, he said, in part because he had been exposed to
diversity in Louisville.

Status quo options available to the states post Seattle decision will fail
Derek W. Black, Associate Professor of Law, Howard University School of Law “The Uncertain Future of
School Desegregation and the Importance of Goodwill, Good Sense, and a Misguided Decision”, Catholic
University Law Review, 2008
http://scholarship.law.edu/cgi/viewcontent.cgi?article=1065&context=lawreview

On its face, Justice Kennedy's

opinion purports to provide school districts with options other than those
chosen by Seattle and Louisville to achieve desegregation, but in reality, these options are unlikely to
yield much, if any, desegregation. He asserts that schools, rather than using race to individually 206 classify students,
can desegregate by using race in a general way. He suggests that "strategic site selection of new schools;
drawing attendance zones with general recognition of the demographics of neighborhoods; allocating
resources for special programs; recruiting students and faculty in a targeted fashion; and tracking
enrollments, performance, and other statistics by race" could be appropriate methods. 2 0 7 He, however,
ignores the problems associated with these methods. Unfortunately, various data and examples reveal that
desegregating schools is far from that simple or easy. Justice Breyer sums up our past experience, writing
in dissent: "Nothing in the extensive history of desegregation efforts over the past 50 years gives the
districts, or this Court, any reason to believe that [these] method[s can] accomplish" desegregation. 20 8
In reviewing all the evidence in the record, amicus briefs, and legal history, there is not a single "example or model ... of a
desegregation plan that is likely to achieve [the schools'] objectives and also makes less use of race-
conscious criteria than [their] plans. 20 9 For instance, "as to 'strategic site selection,' Seattle has built one new high school in the last 44
years (and that specialized school serves only 300 students). 2 1 ° Seattle's experience is not unique, but rather common in most school
districts. 2 1 Thus, although theoretically an option, site selection is generally an unavailable tool. Simply
redrawing attendance zones is an available option to schools districts, but the efficacy of redrawing zones is
low. Most school districts have segregated schools largely because they have segregated residential
neighborhoods, 21 2 not because the attendance zones themselves segregate students. Thus, shifting
attendance zone lines would produce minimal effects and result in most students still attending segregated schools in their
segregated neighborhoods. It is true that a single school could draw students from various neighborhoods by
using multiple attendance zones.213 However, logistics would pose significant problems because poor
minority neighborhoods are often spatially distanced from white and more affluent neighborhoods.214
Consequently, this type of attendance zone drawing would require both busing and the mandatory
assignment of students to schools other than those in their neighborhoods. Putting issues of race
entirely aside, those two issues alone-busing and mandatory non-neighborhood schools-have provoked
some of the fiercest resistance seen in regard to school desegregation. 2 1 5 To put it mildly, "decisions
about where to assign students and how best to adjust attendance boundaries are often political and
sensitive ones, and encouraging racial diversity can be but one of many goals that school officials keep in
mind as they balance competing interests. For purposes of this Article, it suffices to say that Justice Kennedy's
other 217 suggestions are likewise ineffective means of desegregation. Tracking data, recruiting students
and teachers, and offering special programs require nothing of parents and very little of school districts.
Rather, they simply leave the future of desegregation to what is the equivalent of a pure laissez-faire
market, which in the past has permitted (if not tacitly encouraged), increased segregation.2 18 In short,
Justice Kennedy's suggestion that schools can use general policies that simply consider race
underestimates reality.

No private school white flight

Gary Orfield, Distinguished Research Professor of Education, Law, Political Science and Urban Planning
at the University of California, Los Angeles., “SCHOOLS MORE SEPARATE: CONSEQUENCES OF A DECADE
OF RESEGREGATION”, July 2001,
http://la.utexas.edu/users/hcleaver/330T/330TPEEOrfieldSchoolsMoreSeparate.pdf

Also contraryto popular belief, there has been no significant growth in the percent of U.S. students in private
schools since the desegregation era began --in fact, the proportion is lower than a half century ago. If
desegregation produced gains for private schools, a return to segregated neighborhood schools would
logically produce a decline in private education. That has not happened even while desegregation has
been reduced or eliminated in many areas, and the nation’s schools have become more segregated. In
1960, before any significant desegregation, 19.2% of kindergarten students, 14.9% of elementary students and
10.1% of high school students were in private schools. 21 In 1998, the share of kindergarten students in
private schools had dropped by 4.4%, the share of elementary students in private schools was down by
5.8%, and the private share of high school students had dropped by 1.0%.22 There were, of course, communities in
the South where “segregation academies” became very important, primarily at the beginning of serious desegregation, but that impact
was not large on a national scale. Private school enrollment has actually increased more in the
resegregation era than in the era of major increases in desegregation. Projections of existing trends suggest that the private share of
students will continue to drop slowly. Much of the change in the proportion of whites in the schools was caused by disparate birth rates,
immigration, and the building of more and more white suburban communities, not by desegregation plans. The U.S. is in the midst of the
largest wave of immigration in its history--the first that is overwhelmingly non-European and non-white. Latino families are much younger and
much larger than white families, a factor that promises a continuing shift in population proportions, exclusive of future immigration. If the
number of white children being born falls, and the number coming to the U.S. from outside is a small minority in a society where population
growth is very strongly linked to immigration, school enrollment can change dramatically without whites fleeing. There
are a good
many examples of communities where substantial desegregation has lasted a quarter century or longer,
and that have actually gained white enrollment while highly desegregated.23 There are also a number of
communities that never experienced significant desegregation which have had drastic loss of white enrollment—communities such as New York
City, Chicago, and Atlanta. In fact, Atlanta avoided busing, partly in the hope of preventing further loss of white enrollment, to no avail. Los
Angeles terminated all but a tiny voluntary transfer program in 1981, with the opponents charging that busing was causing white loss. Yet, in
l998-99, Los
Angeles, free of mandatory busing for almost two decades, had 10.5 percent whites; while
Chicago, where no mandated busing had occurred, had 10.1 percent.

The court’s ruling in Milliken v. Bradley guaranteed white flight to the suburbs and
made it impossible to resolve de facto segregation
Green and Gooden 2016 Assistant Professor of Educational Administration at UT-Austin,
PhD in Educational Leadership and Policy Analysis from UW-Madison AND Professor of
Educational Administration at UT-Austin, PhD in Educational Administration from Ohio
State. Green, Terrance L. and Mark A. Gooden. “The Shaping of Policy: Exploring the
Context, Contradictions, and Contours of Privilege in Milliken v. Bradley, Over 40 Years
Later.” Teachers College Record 118 (2016).
The landmark Brown v. Board of Education of Topeka, Kansas (1954) (Brown I) decision has been positioned as a critical legal juncture in the
fight for educational equity, especially for African American1 children in the 11 southern U.S. states and the District of Columbia (N. R. Jones,
1992). The Supreme Court in Brown I determined that the “separate but equal” doctrine found in Plessy v. Ferguson (1896) was a violation of
the 14th Amendment’s Equal Protection Clause, and thus held that racially segregated schools were inherently unequal and unconstitutional.
For many, Brown I was expected to achieve educational and even social transformation across the United States
(N. R. Jones, 2004; Radelet, 1991). However, over60 years after the Brown I decision, American public schools are still
racially segregated and unequal (Cashin, 2015; Orfield, 2014). Brown v. Board of Education (1955) (often referred to as Brown II)
declared that school desegregation2 be implemented “with all deliberate speed,” but it was Milliken v. Bradley I3 (1974) that
signified the Supreme Court’s retrenchment from Brown’s legacy (Baugh, 2011a; Gooden, 2004; Orfield & Eaton,
1997). In a 5-4 decision, the Supreme Court found it illegal to impose a metropolitan4 (i.e., cross-district)
desegregation remedy between the predominately black Detroit Public School system and 53
surrounding white, suburban districts. The Supreme Court did so despite evidence of de jure segregation
by the Detroit School Board and the state of Michigan (Baugh, 2011a; N. R. Jones, 2004). Yet, without involving
white, suburban districts in school desegregation efforts, it was nearly impossible to achieve meaningful
desegregation in Detroit and other northern cities. Milliken was thus one of the first opportunities to take
Brown’s fight to racially segregated schools in the North, and therefore became an inflection point in the
struggle for school desegregation in the United States. The Milliken decision essentially closed the door on
mandatory metropolitan school desegregation remedies thus leaving in place de facto segregation (Bischoff, 2008;
Clotfelter, 1999; Frankenberg, Lee, & Orfield, 2003; Gooden, 2004; Holme & Finnigan, 2013; Orfield, 2009; Ryan, 2011). This
ruling also
calcified the lines of racial and social class inequities between urban school districts of color and
wealthy, white suburban districts (N. R. Jones, 1992; Siegel-Hawley, 2013). Moreover, the decision failed to directly
challenge residential segregation, which in turn protected white, suburban districts from participating in
metropolitan school desegregation remedies, and ultimately changed the course of school desegregation in the United States (Gooden, 2004;
Orfield, 2014; Radelet, 1991; Riddle, 2000; Ryan, 2011). As a result, Milliken has been described as the most important school desegregation
case since Brown (Hochschild & Scovronick, 2004), yet Milliken is rarely discussed beyond university classrooms or as a footnote to cases that
succeeded Brown.

No circumvention—legislative statutes following up on Court decisions are normal

means
Ostrander 2015 Associate at the Law Offices of Vincent P. Hurley, JD from New England
Law. Ostrander, Rachel R. “School Funding: Inequality in District Funding and the
Disparate Impact on Urban Migrant School Children.” B.Y.U. Education and Law Journal
2015.1 (2015): 271-295.
While there has not been any real change implemented following the constitutional challenges which have been brought in the past, there is
hope in pursuing change through overriding statutory law if the demand were made.70 We can use the model of desegregation
for guidance on how to achieve meaningful change in the school finance structure through legislative action, as we have
herein by close examination of those challenges. In early desegregation era cases, it is important to note that it was not until
statutes were enacted to support the changes mandated by court decisions that meaningful change
was seen in the desegregation effort in the South. This was largely due to the fact that courts played a minimal role in
effecting a lasting policy remedy.71 In Brown, the Court clearly outlawed state-sanctioned racial
segregation in education, but following the decision there was little real world effect without
legislative follow up. Similar to the challenges to funding disparity and the effect on migrant and urban populations, as we will see in
the McDuffy example, the Court was also left to monitor the progress of the mandated changes in the Brown era with little meaningful effect.
In those early desegregation cases, local districts that wanted to eliminate segregation lacked any tools or roadmap for doing so, and were
weak in the face of staunch political opposition. Those remedial rulings allowed school districts to proceed at a sluggish pace in removing firmly
entrenched barriers to educational opportunity for minorities.72 This is mirrored in the school finance litigation case of McDuffy v. Secretary of
Executive Office of Education. Without
a firm push from the courts to see real change through legislative
action, it is unlikely that it will occur absent the crucial statutory law mandating it. If we take a lesson from history, we can see
that courts will continue to be an inadequate means to change the system without legislative follow up to create policies effecting those
changes, even when the right cases are brought.
Advantage One – Desegregation
 Overview
Milliken vs Bradley causes de facto segregation and racism, challenging institutional
racism and segregation ought to be an a priori of the government and its
policymakers. War’s largest proximate cause is such racism and segregation.
Case outweighs…
Case turns…
 UQ
Schools are separate and unequal
Felton 16
5/20/16 Ryan Felton is a contributing writer for Guardian US, based in Detroit. Formerly an investigative
reporter for the Detroit Metro Times, his writing has been published by FiveThirtyEight, Pacific Standard,
In These Times, Jalopnik and Reuters. https://www.theguardian.com/us-news/2016/may/20/detroit-
schools-desegregation-congress-report-civil-rights
When Terrance Green was a student at Detroit public schools starting in the 1980s, he celebrated his experience in the overwhelmingly black
district. “The teachers were outstanding … there was a very strong ethos around racial identity, around civil rights, around celebrating who we
were,” he said. It wasn’t lost on Green, however, that just north of 8 Mile Road – the demarcation line of Detroit and its suburbs – students had
access to a significantly higher amount of resources. “I do remember … 8 Mile being like the psychological barrier, even in the early 80s it was,”
said Green, 33. “I knew there were these suburbs [that] had more amenities, but I don’t think I could articulate that as an elementary school
child.” A fourth-generation Detroiter, Green’s entry into the city’s public school system was only several years removed from a seminal 1974 US
supreme court ruling on school desegregation, Milliken v Bradley, which ended a plan to integrate mostly white suburban schools into Detroit’s
public school system. The city’s population continued to swiftly decline in the years that followed, eroding the school system’s resources in
tandem until the state declared a financial emergency. How do you have meaningful desegregation when you have white flight occurring at
rapid rates? Terrance Green Green, a professor of educational policy and planning at the University of Texas at Austin, pointed to the Milliken
decision as a “death knell” to implementing the supreme court’s 1954 decision in Brown v Board of Education to desegregate school systems.
“How do you have meaningful desegregation when you have white flight occurring at rapid rates, but we can’t involve suburban school districts
where this was occurring?” Green said. “It stopped mandatory desegregation efforts metropolitan-wide.” A
report released this week
by the Government Accountability Office illuminated the extent to which school systems across the US
are, once again, becoming more segregated. The report found that more than 60% of schools with high
levels of poor students were racially segregated, which the report defined as being at least 75% black or
Latino. The study reviewed federal data from 2001 to 2014 and found 16% of all US schools were both
racially segregated and poor, increasing from about 7,000 schools in 2001 to 15,089 by 2013 to 2014.
Observers and advocates for school desegregation said the report should be a “huge warning sign” that
needs to be addressed. “There are many who believe in this country that we are operating on an even playing field,” said Jadine
Johnson, staff attorney at Advancement Project. “I think what this report revealed … is that the legacies of slavery in this country, the legacies
of Jim Crow, are alive and active,” she said. “That did not go away with Brown v Board of Education.” Compared
to other schools,
the GAO report found, segregated schools offered fewer college prep, science, and math classes to take,
and a disproportionate number of students were either held back in ninth grade, suspended, or
expelled. Michigan congressman John Conyers was among several lawmakers who requested the report, which was released on the 62nd
anniversary of Brown v Board of Education. Conyers and Virginia congressman Bobby Scott are pushing legislation that would amend Title VI of
the 1964 Civil Rights Act and restore the rights of parents to file lawsuits against segregated school districts under claims of disparate impacts,
which are based on ascertaining the discriminatory effect of a policy rather than ascertaining a discriminatory intent. The legacies of slavery ...
and Jim Crow are alive and active. That did not go away with Brown v Board of Education Jadine Johnson “This
GAO report confirms
what has long been feared and proves that current barriers against educational equality are eerily
similar to those fought during the civil rights movement,” Conyers said in a statement. “There simply can
be no excuse for allowing educational apartheid in the 21st century.” Johnson said the loss of parents’ ability to file
disparate impact cases was a “huge blow to the civil rights community”. Johnson has assisted in filing several Title VI complaints in recent years
with the federal department of education – complaints that could have been filed in federal court under Conyers’ proposal. “Us having that
right could have potentially … slowed down the school closures crisis that’s happening today,” she said. In Conyers’ home state, the largest
public school system – Detroit – is currently embroiled in a struggle for survival amid bloated class sizes, paltry resources, and large-scale
protests waged by teachers who have faced the prospect of working without pay. Michigan’s governor, Rick Snyder, is pushing a controversial
$715m plan to overhaul the district, which needs a significant influx of cash to move forward with much-needed repairs for dozens of
dilapidated facilities. Only one-third of high school students in Detroit public schools are proficient in reading,
according to Snyder’s office. Green said the Milliken decision is one of the “main culprits” in what has happened to his alma mater. Despite
the supreme court’s 1954 landmark decision that US schools must be desegregated, Detroit’s school
system remained effectively segregated, stemming in part from an accelerated white flight. When the
NAACP legally challenged the state of Michigan in 1970 to end the district’s segregation, at first, the
federal courts agreed something needed to be done: A plan was crafted to bus students in from
suburban districts and was upheld by an appellate court. But the plan was quickly stamped out. In 1974, the
US supreme court in a 5-4 ruling shot down the efforts in Detroit, saying desegregation measures had to remain inside district boundaries. In a
column he co-wrote for the Detroit Free Press, Green argued that “we need advocacy and policies for all schools to be equitable, and racially
and socioeconomically diverse across metro Detroit so that all children can learn to grow up in a diverse nation.” Compared
to
suburban districts, he said, citing the GAO report, segregated schools have less access to courses needed
to exceed in college – and, in some cases, a lower level of teacher experience. Indeed, a plan approved by the
Michigan house to overhaul Detroit schools would allow uncertified teachers to be hired by the district. “So I think there’s also a resource
argument that has to be made [for integration],” he said. The GAO recommended that the US department of education “more routinely
analyze” civil rights data to identify disparities and said the federal justice department could “systematically track key information on open
federal school desegregation cases to which it is a party to better inform its monitoring”. Eve Hill, US deputy assistant attorney general, wrote
in a response letter to the report: “The Department carefully monitors each open desegregation case to which the United States is a party on a
case-by-case basis, recognizing that each case is unique.” The justice department is involved in 178 open desegregation cases, stemming from
court orders that originated in the 1970s and 1980s. Green said the GAO report underscores the spirit of the Brown v Board of Education
decision. “It’s not just about putting white bodies and black bodies together,” he said. “It’s about understanding what they said in 54, that
racially segregated and separate schools are inherently unequal.”
 Segregation Bad
Segregated schools devastate educational benefits –overwhelm any of the costs of
bussing
Nelson, Thurgood Marshall Law School Assistant Professor, 2006 [Eboni, "ARTICLE: Parents Involved &
Meredith: A Prediction Regarding The (Un)Constitutionality of Race-Conscious Student Assignment
Plans," 84 Denv. U.L. Rev. 293]
Historically, the neighborhood school concept, which calls for the assignment of students to schools that are in close proximity to their homes,
has been a preferred method for making school assignment decisions. n84 Many
argue that adherence to neighborhood
schools provide educational benefits ranging from increased parental and community involvement that results in improved
student achievement, n85 to reductions in transportation costs, which provide additional funding for teacher [*307] salaries and educational
programs. n86 These benefits, however, are
greatly outweighed by the detrimental effects that accompany many
neighborhood school decisions: namely, the resegregation of elementary and secondary schools and the
overwhelming challenges that are present in such environments. Following the termination of desegregation decrees
and the return of educational decisions to local control, many school districts returned to the neighborhood school concept when making their
student assignment decisions. n87 Considering the rate of residential segregation in communities throughout the country, it is not surprising that
such decisions have resulted in the resegregation of public schools. n88 "One-third of all African Americans in the United States live under
conditions of intense racial segregation." n89 In 2000, over 230 American urban communities could be described as "hypersegregated" or
"partially segregated." n90 Therefore, in accordance with student assignment policies that assign students to schools based on neighborhood
proximity, schools populated by students living in these areas will also experience high levels of racial segregation, n91 which often brings about
adverse educational consequences. [*308] Research shows that students attending racially segregated schools, which are often
economically segregated as well, n92 encounter tremendous challenges that greatly hinder their educational
achievement. Students attending schools with majority minority student populations are often educated
in "substandard and deteriorating facilities." n93 Their learning environments often suffer from "shortages
of library books, computers, or laboratory equipment." n94 The teachers who educate them are often less
qualified than those teaching at racially and economically diverse schools. n95 This lack of resources leads
to disparities in minority students' academic achievement as measured by standardized tests scores, n96
high school drop-out and graduation rates, n97 college matriculation rates, n98 and post-graduate degrees. n99
Not only are students attending segregated schools forced to overcome educational resources deficiencies, but they are also deprived
of the educational benefits related to interacting with students who possess higher educational
aspirations. Unfortunately, many minority students who live in lower-income, racially segregated
neighborhoods and attend lower performing schools within those neighborhoods have low expectations
regarding academic achievement. In fact, some minority communities suffer from a culture that devalues academic success, n100
which significantly undermines minority students' academic expectations and aspirations. As noted by scholar John Charles Boger: A pupil's
achievement is strongly related to the educational backgrounds and aspirations of the other students in the school . . . . Thus . . . if a minority
pupil from a home without much educational strength is put with schoolmates with strong educational backgrounds, his achievement is likely
to increase. n101 If, in fact, "the
social characteristics of a school's student body are the single most important
school-related factor in predicting minority student achievement," n102 student assignment plans that rely
on poor, racially segregated neighborhoods will only exacerbate the current disparities existing between
minority and non-minority student achievement.
 A2: Can’t Solve
Plan solves – White flight happens because INTRA-district remedies – Inter-district
solves
Susheela Jayapal, JD “School Desegregation and White Flight: The Unconstitutionality of Integration
Maintenance Plans”, University of Chicago Legal Forum Volume 1987 | Issue 1 Article 16,
http://chicagounbound.uchicago.edu/cgi/viewcontent.cgi?article=1026&context=uclf

Moreover, even if increasing black enrollment does have a significant impact on white flight, the first line of
attack ought to be on addressing that correlation, not on accepting and institutionalizing it. There are ways to limit
white flight that do not involve limiting black enrollment. First, metropolitan desegregation plans should be
implemented whenever possible.8 3 Such plans desegregate entire metropolitan areas as opposed to single
districts within a metropolitan area. Thus, these plans would include the suburbs surrounding a city school
district as well as the city district itself. To the extent that school desegregation causes white flight,
metropolitan plans should result in less flight than single district plans. By increasing the area subject
to desegregation, they make it much more difficult for white families to escape desegregation. 4 In
addition, they increase the pool of students available for reassignment, and thus facilitate a greater
degree of integration. If a central city school district is already 90 percent black, a single district plan can accomplish only token
integration. By involving the surrounding white suburbs, a metropolitan plan can achieve a more substantial
degree of integration.

Inter-district remedies work

Theoharis 15
10/23/15 George Theoharis is a professor and a chair in the School of Education at Syracuse University.
‘Forced busing’ didn’t fail. Desegregation is the best way to improve our schools.”
https://www.washingtonpost.com/posteverything/wp/2015/10/23/forced-busing-didnt-fail-
desegregation-is-the-best-way-to-improve-our-schools/?utm_term=.ff5dba0db627
Two miles from my office in Syracuse, N.Y., Westside Academy Middle School has been in need of repairs for decades. Located in one of the
nation’s poorest census tracts, 85 percent of its students are black or Latino, and 86 percent are poor enough to qualify for free or reduced-
price lunches. The 400 students have limited creative outlets, with no orchestra or band and just two music teachers. Ten miles away,
Wellwood Middle School, in a suburban district, offers students a stately auditorium and well-equipped technology rooms. There, 88 percent of
the students are white and only 10 percent qualify for free or reduced-price lunch. The 700 students have at least five music teachers, band,
orchestra, choir, musical theater and dozens of other clubs and activities. Fifty percent of Wellwood’s eighth graders passed the state math
assessment. At Westwood, none did. The disparate student outcomes are no surprise. Since the Reagan administration’s “A Nation at Risk”
report pronounced that schools across the country were failing, every president has touted a new plan to close the racial academic
achievement gap: President Obama installed Race to the Top; George W. Bush had No Child Left Behind; and Clinton pushed Goals 2000. The
nation has commissioned studies, held conferences and engaged in endless public lamentation over how to get poor students and children of
color to achieve at the level of wealthy white students — as if how to close this opportunity gap was a mystery. But we forget that we’ve done
it before. Racial achievement gaps were narrowest at the height of school integration. U.S.
schools have become more
segregated since 1990, and students in major metropolitan areas have been most severely divided by
race and income, according to the University of California at Los Angeles’s Civil Rights Project. Racially homogenous
neighborhoods that resulted from historic housing practices such as red-lining have driven school
segregation. The problem is worst in the Northeast — the region that, in many ways, never desegregated — where students face some of
the largest academic achievement gaps: in Connecticut, Maryland, Massachusetts and the District of Columbia. More than 60 years
after Brown v. Board of Education, federal education policies still implicitly accept the myth of “separate
but equal,” by attempting to improve student outcomes without integrating schools. Policymakers have
tried creating national standards, encouraging charter schools, implementing high-stakes teacher
evaluations and tying testing to school sanctions and funding. These efforts sought to make separate
schools better but not less segregated. Ending achievement and opportunity gaps requires implementing a variety of
desegregation methods – busing, magnet schools, or merging school districts, for instance – to create a more just public education system that
successfully educates all children. Public radio’s “This American Life” reminded us of this reality in a two-part report this summer, called “The
Problem We All Live With.” The program noted that, despite
declarations that busing to desegregate schools failed in
the 1970s and 1980s, that era actually saw significant improvement in educational equity. When the National
Assessment of Educational Progress began in the early 1970s, there was a 53-point gap in reading scores between black and white 17-year-olds.
That chasm narrowed to 20 points by 1988. During that
time, every region of the country except the Northeast saw
steady gains in school integration. In the South in 1968, 78 percent of black children attended schools
with almost exclusively minority students; by 1988, only 24 percent did. In the West during that period,
the figure declined from 51 percent to 29 percent. But since 1988, when education policy shifted away
from desegregation efforts, the reading test score gap has grown — to 26 points in 2012 — with segregated
schooling increasing in every region of the country. Research has shown that integration is a critical
factor in narrowing the achievement gap. In a 2010 research review, Harvard University’s Susan Eaton noted that racial
segregation in schools has such a severe impact on the test score-gap that it outweighs the positive effects of a higher family income for
minority students. Further, a 2010 study of students’ improvements in math found that the level of integration was the only school
characteristic (vs. safety and community commitment to math) that significantly affected students’ learning growth. In an analysis of the
landmark 1966 “Coleman Report,” researchers Geoffrey Borman and Maritza Dowling determined that both the racial and socioeconomic
makeups of a school are 1¾-times more important in determining a student’s educational outcomes than the student’s own race, ethnicity or
social class. But we
continue to think about segregation as a problem of the past, ignoring its growing
presence in schools today. Desegregating schools has become a political third rail, even though it is an essential solution to one of our
nation’s most persistent problems. This month, Education Secretary Arne Duncan announced he would step down in December and his deputy,
John King, would replace him. King, during his tenure as New York state’s education commissioner, visited both school districts mentioned
above to advance the national Race to the Top agenda, but he never acknowledged the increasing school segregation apparent in the region. In
1989, Syracuse city schools were about 60 percent white, and just 20 percent of black and Latino students attended predominately minority
schools. Today, the district is 28 percent white, while 55 percent of Latino students and 75 percent of black students attend predominately
minority schools. Racial
and economic segregation affects schools in various ways. Federal and state policies
that impose sanctions on poor-performing schools — state takeovers and forced replacement of school
leaders, for example — often make matters worse. For example, Westside Academy , the Syracuse middle school where no
students passed the state eighth-grade math assessment, has has had multiple principals and saw 44-percent teacher turnover in the 2012-
2013 school year. About a decade ago, the elementary schools that feed into Westside Academy and Wellwood Middle School adopted the
same math curriculum program, touted as one of the best standards-based elementary programs available. As is typical, both districts struggled
to implement the new curriculum initially. But a decade later, the schools in Wellwood’s district are still using it, with teachers becoming more
skilled and comfortable with the new way to teach math. The schools in Westside’s district, however, changed their math program at least two
more times, leaving teachers, students, and families in a constant state of churn and undoubtedly affecting student learning and test scores. In
this era of accountability, this instability is not forced upon white, upper-middle class families. While
much has been said about
the failure of busing, it’s time to move beyond this myth. In one of the most famous examples of court-ordered
desegregation, Boston began busing students between white and black neighborhoods in 1974, sparking
violent white protests and boycotts by white students. White families fled to the suburbs. Supporting
neighborhood schools and opposing school bus rides became rhetoric to fight desegregation without
overtly racist language. But as black activists in Boston noted at the time, “It’s not the bus, it’s us.” Before the court order,
nearly 90 percent of high school students rode a bus to school without protest. Today, most children get
on a school bus to attend a segregated school. Busing ended because of a combination of white protest, media that
overemphasized resistance, and the lack of systematic collection to judge the impact of desegregation. So we need to be sober about our
history: Busing didn’t fail; the nation’s resolve and commitment to equal and excellent desegregated
schools did.
 Impact Framing
We are only responsible for whether the plan itself is a moral action – the decisions of
other agents are outside your power to determine and focusing on them perpetuates
inaction and sanctions atrocity
Harris, 8 (Alex, J.D. Stanford University, Harvard University Bachelors (magna cum laude), Practicing
Appellate and Constitutional Law at Gibson, Dunn & Crutcher LLP, former Adjunct Analyst at The
Competitive Enterprise Institute, “Philosopher's Corner: The Principle of Intervening Action”,
https://cei.org/blog/philosophers-corner-principle-intervening-action, August 15, 2008, ak.) ***Note ---
PIA = Principle of Intervening Action

Gewirth takes the position that weare solely responsible for the morality of our own actions in two senses. First, only
we are responsible for the acts we commit, even if someone else's action caused us to act as we did. (For example, if a woman's
husband cheated on her and she, upon finding out, grew enraged and killed his lover, she - not he - would bear sole responsibility.) Second, we
are only responsible for our own actions, even if they lead to other actions. Thus, we have a preeminent
duty to never act immorally, even if doing so would preclude others from taking even more immoral
actions. Gewirth contends that never violating the negative rights of another "is an obligation so fundamental
that it cannot be overridden even to prevent evil consequences from befalling some persons." He clarifies with an
example. Imagine that a group of terrorists kidnaps a woman and offers her son a choice: he must torture
his mother or they will blow up a city with a nuclear weapon. Gewirth argues that the son has a primary
duty to not violate the rights of his mother, whereas he is not the actor who is blowing up the city - the
terrorists are the moral agents responsible for that action, not the son. If the son had the choice, he would pick neither. His
duty is to never violate rights; the only way to fulfill this is to not torture his mother. Gewirth argues: "It would be unjustified to violate the
mother's right to life in order to protect the rights to life of the many other residents of the city. For rights
cannot be justifiably
protected by violating another right." PIA is the only consistent, justifiable moral theory of
consequences. First, one should note that only PIA sets a non-arbitrary limit on the string of effects that can
factor into the moral calculation. PIA says that no consequences of other actions can count; the only
other non-arbitrary standard says that all consequences in the chain must count. One cannot claim that I
am responsible for only, say, the first four other actions resulting from my action. One must either
consider only my actions or all resulting actions. Thus, if the destruction of the city by
terrorists actually ended up preventing more rights violations by, say, staving off a Malthusian
population crunch that would result in mass starvation and world war, then the consequentialist
position has to endorse the terrorists' action. Consequentialists have to count every
effect in the chain, even in the absurdly far-off future, to determine whether an action is moral.
This fact, of course, does not by itself constitute a reason to reject consequentialism in favor of PIA, but it does suggest that PIA
is the only
reasonable interpretation of the requirement of non-consequentialism. It also suggests an implausible
feature of consequentialism. I went on to demonstrate how the libertarian principle of self-ownership supports PIA and
why people cannot be responsible for all effects of their actions: Since we are born owning ourselves and
nothing else, controlling our mind and body and no one else's, it makes perfect sense that we should be
responsible for only the actions that we ourselves commit. Some could argue that we should be responsible for the
results of these actions. PIA states that we are. If a person gets a wrecking ball and knocks over a building, which then falls and crushes twenty
people, the person is to some degree responsible for those results. But this is not the case if someone else's action intervenes, because another
moral agent is the more proximate cause of the effects; she has stepped into the line of causation to take the moral responsibility. When
you act upon a rock that you hurl at an enemy's face, you are responsible for the effects of the rock for
two reasons: first, you
are using force upon the rock; secondly, the rock has no agency over the effects it
causes. The rock, by the fact that it has no agency of its own, is merely your tool, an extension of your agency. But neither of these
reasons holds for using non-coercive measures that result in a person's action. As long as one does not
use coercion to compel another to commit a rights-violating action, one has not reduced that other
person's agency. Possessing full agency, the person is morally responsible for the totality of her actions; thus
no one else can assume any portion of that responsibility. You are not responsible for anyone else's
free actions and no one else is responsible for yours. If the son were somehow partially responsible for
the terrorists blowing up the city, that would necessarily diminish, by whatever fraction of responsibility the son assumed,
the terrorists' responsibility for that action. They would not be wholly responsible, because the son had caused their action.
But this must not be the case; the terrorists must be held totally responsible for the destruction of the city.
Consequentialists ask, "Which set of rights-violations do you endorse: the torture of the mother, or the deaths of the millions?" Gewirth
responds that PIA endorses neither. PIA
gives the terrorists complete responsibility for their actions, and
emphatically condemns them, in a way that no other position is capable of. Only PIA is capable of
giving rights their supreme status by proclaiming that they may never be violated for any reason,
including preventing future rights-violations.
Advantage Two – Academic Achievement
 Overview
Currently, students in the US are failing compared to global peers. Racial segregation
is a key factor in this failure. By fixing racial segregation with the overturn of Milliken,
academic achievement grows and our economy grows with it. Without this, our
economy will fail and cause war.
Case outweighs…
Case turns…
 UQ
Segregation promulgates racial achievement gaps
Boschma and Brownstein 16
2/29/16 JANIE BOSCHMA is a former senior associate editor at The Atlantic; AND RONALD BROWNSTEIN
is Atlantic Media's editorial director for strategic partnerships. “The Concentration of Poverty in
American Schools” https://www.theatlantic.com/education/archive/2016/02/concentration-poverty-
american-schools/471414/
In almost all major American cities, most African American and Hispanic students attend public schools where a majority of their classmates
qualify as poor or low-income, a new analysis of federal data shows. This systemic economic and racial isolation looms as a huge obstacle for
efforts to make a quality education available to all American students. Researchers have found that the
single-most powerful
predictor of racial gaps in educational achievement is the extent to which students attend schools
surrounded by other low-income students. Underscoring the breadth of the challenge, the economic segregation of
minority students persists across virtually all types of cities, from fast-growing Sunbelt places like Austin, Denver, Dallas,
and Charlotte to struggling Rust Belt communities like Detroit, Cleveland, and Milwaukee, to the nation’s largest metropolitan centers,
including New York, Los Angeles, Chicago, and Houston. But cities, educators, and researchers are also exploring new ways to abate the
negative impact of concentrated poverty on black and brown students. In about half of the largest 100 cities, most
African American
and Latino students attend schools where at least 75 percent of all students qualify as poor or low-
income under federal guidelines. These stark results emerge from an analysis of data from the National Equity Atlas. The Atlas is a
joint project of PolicyLink and the University of Southern California’s Program for Environmental and Regional Equity, or PERE. Following federal
guidelines, the National Equity Atlas defines low-income students as those eligible for the federal free- and reduced-lunch program. That
includes students with incomes up to $44,863 for a family of four, or 185 percent of the federal poverty line. (Students from families with
incomes up to the 130 percent of the poverty line, or $31,525 for a family of four, are eligible for free lunch; the remainder can obtain reduced
price lunches.) The
overwhelming isolation of students of color in schools with mostly low-income
classmates threatens to undermine efforts both to improve educational outcomes and to provide a
pipeline of skilled workers for the economy at a time when such students comprise a majority of the
nation’s public school enrollment. Educational reformers are quick to underscore that in individual schools around the country
dedicated teachers and principals have produced impressive results even for students submerged in communities of pervasive poverty. But,
overall, concentrated poverty is tightly correlated with gaps in educational achievement. “It’s the measure
of segregation that is most strongly correlated to the racial achievement gap,” said Sean F. Reardon, a professor at
Stanford University’s graduate school of education and one of the nation’s leading experts on residential and educational segregation. “The
difference in the rate at which black, Hispanic, and white students go to school with poor classmates is
the best predictor of the racial-achievement gap.” The latest figures from the National Center for Educational Statistics show
that nationwide about three-fourths of both African American and Hispanic young people (compared to about one-third of white students)
attend schools where most of their classmates qualify as low income. The analysis expands on that national portrait to examine the extent of
economic isolation at the city level. That assessment points to one overwhelming conclusion: economic isolation and the concentration of
poverty among students of color afflicts not only a few struggling cities, but virtually all cities—including many that have seen the most robust
growth in jobs, incomes and population since the Great Recession. “The difference in the rate at which black, Hispanic, and white students go to
school with poor classmates is the best predictor of the racial-achievement gap.” The economic segregation
facing African
American and Hispanic students represents the convergence of many trends, including the stubbornly
high rates of childhood poverty since the Great Recession; persistent patterns of housing segregation in
many major cities; the increasing economic polarization in many metropolitan areas that has resulted in
more residents living either in affluent or poor neighborhoods, and fewer residing in middle-income
communities; and the general retreat from efforts to promote racial or economic integration in the
schools. Together these factors have left most African American and Hispanic students marooned in
schools where economic struggle is the rule and financial stability—and all the social and educational
benefits that flow from that—is very much the exception. “Kids who spend more than half of their childhood in poverty
have a high-school graduation rate of 68 percent,” said Abigail Langston, a senior associate at PolicyLink, and a public fellow at the American
Council of Learned Societies. “You see how these things compound over time. There
is a link between housing policy,
economic and racial segregation, you see what those do to schools and to people who grow up in those
neighborhoods. There is a vicious feedback loop.” The issue, Reardon said, isn’t “that sitting next to a poor
kid makes you do less well in school.” Rather, he said, “it’s that school poverty turns out to be a good
proxy for the quality of a school. They are in poorer communities, they have less local resources, they
have fewer parents with college degrees, they have fewer two parent families where there are parents
who can come spend time volunteering in the school, they have a harder time attracting the best
teachers. So for a lot of reasons schools serving poor kids tend to have fewer resources, both economic
and social capital resources.” The cumulative effect of these disadvantages has proven overwhelming almost everywhere. Reardon
and his colleagues have studied test scores for students in all of the nation’s roughly 12,000 school districts. And while they have not finished
sorting all of the data, the preliminary results underscore how difficult it is for schools alone to overcome the interlocking challenges created by
the economic segregation of low-income students. “We can look at every poor district in the United States and see if there are any that are
doing reasonably well, where kids are performing at least at the national average,” Reardon says. “And the answer is virtually none. You can
find isolated schools that are doing…better than you would predict. But the weight of socioeconomic disadvantage—or, on the other side of the
scale, of advantage—is really quite big. We don’t have much evidence of places that have been systematically successful when they serve very
large populations of low-income students. It’s a big lift.“ Those daunting findings reinforce the gravity of the economic isolation for students of
color that the data reveal. Among the key findings: Kids of color represent a majority of the student body in 83 of the 100 largest cities. In all
but three of those 83 cities (Honolulu, and Chula Vista and Fremont, in California), at least half of them attend a school where a majority of
their peers are poor or low-income. In 58 of those cities, at least three-fourths of non-white students attend majority low-income schools. Data
is available for African American students in 97 large cities. In 83 of those 97 cities (or 85.6 percent), the majority of African American students
attends schools where most of their classmates qualify as poor or low income. In 54 of those cities, at least 80 percent of black students attend
schools where most of their classmates qualify as poor or low-income. The cities where the very highest shares of African American students
attend mostly low-income schools testify to the breadth of the problem. They include communities from all corners of the country, and range
from weathered Rust Belt communities (like Detroit and Newark) to Sunbelt high-fliers (like Dallas, Houston, and Nashville). In order, the cities
where the most black students attend majority low-income schools include: Detroit; San Bernardino, Calif.; Newark; Milwaukee; Birmingham,
Ala.; Hialeah, Fla.; Boston; Chicago; Philadelphia; New York; Memphis, Tenn.; Baton Rouge, La.; Dallas; North Las Vegas; Stockton, Calif.;
Wichita, Kan.; New Orleans; Tulsa, Okla.; Houston; and Miami. Only in 14 of the 97 cities with available data do less than half of black students
attend majority low-income schools. The cities with the very lowest share of blacks in high-poverty schools include San Jose, Reno, and
Colorado Springs. But most of those 14 have relatively small black student populations. In 11 of those cities, black students represent 11
percent of the student population or less, with the exceptions only of Raleigh, and Virginia Beach and Chesapeake, Virginia. Among Hispanic
students, the picture is noticeably similar. Data is available for them in 96 cities; in 85 (or 88.5 percent), a majority of Hispanic students attend
schools with mostly low-income classmates. In 53, at least 80 percent of Hispanic students attend majority low-income schools. The cities
where the most Hispanic kids attend schools of concentrated poverty also span the spectrum. In order, they include: Detroit; Newark; San
Bernardino, Calif.; Philadelphia; Milwaukee; Boston; Dallas; Irving, Texas; Chicago; Oakland, Calif.; Hialeah, Fla.; North Las Vegas, Nev.; Los
Angeles; Santa Ana, Calif.; Nashville and Memphis, Tenn.; New York; Baton Rouge, La.; Anaheim, Calif.; and Wichita, Kan. Only in 11 of the 96
cities with available data do fewer than half of Hispanic students attend schools where most of their classmates qualify as poor. Those 11 also
have relatively small Latino student populations. Only four of those cities—Colorado Springs; Plano, Texas; Chandler, Arizona; and Henderson,
Nevada—have schools where Latinos represent more than 20 percent of their student body. Even in those four, Latino students represent less
than a third of students. In just four cities do most white students attend schools where at least three-fourths of their classmates qualify as low-
income. In fully 82 of the 96 cities with data for both African American and Hispanic students, at least half of both groups attend majority low-
income schools. In 65 of those 96 cities, at least 70 percent of both black and Hispanic students attend majority low-income schools. In Chicago,
96 percent of both black and Latino students attend majority-poverty schools. In New York City, 96 percent of black and 95 percent of Latino
students attend majority low-income schools. And in Los Angeles, 85 percent of black and 96 percent of Latino students attend schools where a
majority of their peers are poor. The experience for white students, who now represent a minority of the public school student body
nationwide, remains very different. Figures are available for whites in 95 cities. Only in 35 of them (or almost 37 percent) do most white
students attend schools where a majority of their classmates qualify as poor. At least 80 percent of whites attend majority low-income schools
in just six cities (compared to 54 cities for African Americans and 55 for Hispanics). The cities where such large level of whites experience
concentrated poverty are all places confronting long-term economic decline: Detroit; Newark; Hialeah, Fla.; San Bernardino, and Stockton,
Calif.; and Jersey City. That stands in clear contrast to the economic isolation confronting minority students even in many thriving cities. Even
more strikingly, in 49 cities, or over half the total where data is available, fewer than 30 percent of white students attend majority low-income
schools. In just 11 cities do so few African American students attend majority low-income schools; for Hispanics, the number is just seven cities.
The trends in the patterns of schools experiencing the deepest economic isolation—institutions where at least 75
percent of students qualify as poor or low-income—further underscore the stark racial divergence in these findings. In
just four cities do most white students attend schools where at least three-fourths of their classmates
qualify as low-income. But most black students attend schools confronting that level of concentrated
poverty in fully 51 cities; for Hispanics the number is 54. These high levels of concentrated poverty in
schools persist—and have increased overall—even in cities where there has been tremendous growth
since the recession. Many advocates for low-income communities say economic isolation in the schools represents one
of the most complex and consequential barriers to equalizing opportunity. “It seems to be the thing that
everybody points to as the biggest challenge,” said Sarah Treuhaft, PolicyLink’s director of equitable growth initiatives.
 A2: Can’t Solve Ach Gap
Integration key to lower achievement gap
Theocharis 15 (George is a professor in the school of education at Syracuse University; Washington
post. “Forced busing’ didn’t fail. Desegregation is the best way to improve our schools: Racial
achievement gaps were narrowest at the height of school integration”
https://www.washingtonpost.com/posteverything/wp/2015/10/23/forced-busing-didnt-fail-
desegregation-is-the-best-way-to-improve-our-schools/?utm_term=.854d50dcb76e)
Public radio’s “This American Life” reminded us of this reality in a two-part report this summer, called “The Problem We All Live
With.” The program noted that, despite declarations that busing to desegregate schools failed in the 1970s and 1980s, that era
actually saw significant improvement in educational equity. When the National Assessment of Educational Progress began in
the early 1970s, there was a 53-point gap in reading scores between black and white 17-year-olds. That chasm narrowed to 20
points by 1988. During that time, every region of the country except the Northeast saw steady gains in school integration. In the
South in 1968, 78 percent of black children attended schools with almost exclusively minority students; by 1988, only 24
percent did. In the West during that period, the figure declined from 51 percent to 29 percent. But since 1988, when education
policy shifted away from desegregation efforts, the reading test score gap has grown — to 26 points in 2012 — with segregated
schooling increasing in every region of the country. Research has shown that integration is a critical factor in
narrowing the achievement gap. In a 2010 research review, Harvard University’s Susan Eaton noted
that racial segregation in schools has such a severe impact on the test score-gap that it outweighs the
positive effects of a higher family income for minority students. Further, a 2010 study of students’
improvements in math found that the level of integration was the only school characteristic (vs. safety
and community commitment to math) that significantly affected students’ learning growth. In an
analysis of the landmark 1966 “Coleman Report,” researchers Geoffrey Borman and Maritza Dowling
determined that both the racial and socioeconomic makeups of a school are 1¾-times more important
in determining a student’s educational outcomes than the student’s own race, ethnicity or social class.

Integration lowers achievement gap

Potter & Quick 16 (Halley is a senior fellow at The Century Foundation, where she researches public
policy solutions for addressing educational inequality. Kimberly is a policy associate at The Century
Foundation. “A New Wave of School integration” https://tcf.org/content/report/a-new-wave-of-school-
integration/)
Sharkey concludes that “the parent’s environment during [her own] childhood may be more important than the
child’s own environment.” He calculates that “living in poor neighborhoods over two consecutive generations
reduces children’s cognitive skills by roughly eight or nine points … roughly equivalent to missing two to four years
of schooling” (Sharkey 2013, pp. 129-131).

Integrating disadvantaged black students into schools where more privileged students predominate
can narrow the black-white achievement gap. Evidence is especially impressive for long term outcomes
for adolescents and young adults who have attended integrated schools (e.g., Guryan, 2001; Johnson,
2011). But the conventional wisdom of contemporary education policy notwithstanding, there is no
evidence that segregated schools with poorly performing students can be “turned around” while
remaining racially isolated. Claims that some schools, charter schools in particular, “beat the odds”
founder upon close examination. Such schools are structurally selective on non-observables, at least,
and frequently have high attrition rates (Rothstein, 2004, pp. 61-84). In some small districts, or in areas
of larger districts where ghetto and middle class neighborhoods adjoin, school integration can be
accomplished by devices such as magnet schools, controlled choice, and attendance zone
manipulations. But for African American students living in the ghettos of large cities, far distant from
middle class suburbs, the racial isolation of their schools cannot be remedied without undoing the racial
isolation of the neighborhoods in which they are located.

Racial and socioeconomic integration = educational opportunity deprived from

minority children
Brisport 13 (Neda N. is an attorney/Baha’I Faith activist, National Lawyers Guild Review. “Racism &
Power: The inaccessibility of opportunity In The Educational System in The United States” pg. 18

Opportunity leads to success and success often leads to power. However, gaining power requires that
you be a part of a certain select alliance, one whose doors are only open to the current power holders-
the majority race. This is not to say that being born white automatically affords a person power, but that
there are certain privileges, advantages and opportunities which open the doors to attaining power. In
an effort to prevent those who are unwelcome-the minority races-from attaining a seat at the power
table, the majority purposefully denies them the initial opportunity through the educational system. The
imposition of various obstacles-insufficient funding for education, scarcity of human and material
resources, and the absence of programs geared towards success in certain poverty-ridden minority
areas-are ways of reducing competition for scarce resources and preventing minority populations from
sharing power. The fact that African-American children in impoverished neighborhoods are not receiving
the same education as white children in more affluent neighborhoods is not an accident-it is purposeful
and deliberate. This article will take us through the history of the education system in the United States
as well as the litigation and legislation surrounding education to provide a clear understanding of how
far we have come in the advancement of equal educational opportunity. We will find that in order to get
to where we need to be, we must completely restructure our current system on all levels and
redistribute our attention in order to ensure that all children in the United States have open doors to
proper education, opportunity, success and ultimately to power.
 A2: Can’t Solve for Econ
The impact of educational achievement gaps in the U.S. is the economic equivalent of
a permeant recession
Edelman 10 (Marian is President of the Children’s Defense Fund and its Action Council. “The Huge
Economic Impact of the Achievement Gap” http://www.huffingtonpost.com/marian-wright-
edelman/the-huge-economic-impact_b_317280.html)

What is the price we pay for schools that aren’t doing their job for children in America? Who pays it?
McKinsey reported two kinds of costs―one price paid for by the individual students we leave behind
and another price paid by our country. For individual children faced with unequal educational
opportunities, McKinsey found that “avoidable shortfalls in academic achievement impose heavy and
often tragic consequences, via lower earnings, poorer health and higher rates of incarceration.” They
also discovered that, sadly, it is possible to predict which children are being singled out to bear this
burden before they have even finished elementary school. For many students, poor achievement as
early as fourth grade appears to predict future chances of graduating from high school or college and of
low lifetime earnings. But some children are at greater risk than others before they even enter their first
classroom—especially children who are Black, Latino or poor.

McKinsey’s research showed “on average, Black and Latino students are roughly two to three years of
learning behind White students of the same age.” The income achievement gap was just as glaring with
poor children: “roughly two years of learning behind the average better-off student of the same age.”
They were also able to make comparisons between groups by both race and income. Not surprisingly,
they found the intersection of race and poverty was the most dangerous of all: “Poor White students
tend toward lower achievement than rich White students. Whites, meanwhile, significantly outperform
Blacks and Latinos at each income level . . . [and] low-income Black students suffer from the largest
achievement gap of any cohort.” Measured in years again, “the average non-poor White student is
about three and a half years ahead in learning compared to the average poor Black student.”

It’s almost possible to imagine those gaps as wasted time—time so many children can never get back.
And productivity the whole country cannot get back. McKinsey estimated what our nation’s GDP might
look like if we had closed these achievement gaps between 1983 and 1998, the fifteen years after the
government report, “A Nation at Risk,” first alerted us to the serious problems facing children in our
schools. They found that the 2008 GDP would have been $310 billion to $525 billion higher if we had
closed the racial achievement gap, and $400 billion to $670 billion higher if we had closed the income
achievement gap. McKinsey also found that there continues to be a gap between students in America
and their peers in other countries and notes the 2008 U.S. GDP could have been $1.3-$2.3 trillion higher
if had we had closed the international educational achievement gap between students in America and
those in top-performing countries like Finland and Korea. McKinsey concluded that the combined
impact of the educational achievement gaps in the United States is the “economic equivalent of a
permanent, deep recession.”

The educated workforce is critical to the economy – public education is crucial

Norman R. Augustine et al, National Academies Committee on Prospering in the Global Economy of
the 21st Century Chair, 2006 [Augustine is also the retired Lockheed Martin Chairman and CEO, report
written by the National Academies (The National Academy of Sciences, The National Academy of
Engineering, The Institute of Medicine, and The National Research Council) Committee on Prospering in
the Global Economy of the 21st Century, “Rising Above The Gathering Storm”]

The most effective way for the United States to meet the challenges of a flatter world would be to draw
heavily and quickly on its investments in human capital. We need people who have been prepared for
the kinds of knowledge-intensive occupations in which the nation must excel. Yet the United States has
for a number of decades fallen short in making the kinds of investments that will be essential in a global
economy. An educated, innovative, motivated workforce—human capital—is the most precious
resource of any country in this new, flat world. Yet there is widespread concern about our K–12 science
and mathematics education system, the foundation of that human capital in today’s global economy.

Education is key to competitiveness-innovation, market growth and employment.

Gates in 2k7 (Bill Gates, Chairman and former CEO of Microsoft, Founder of the Bill and Melinda
Gates Foundation, “How to Keep America Competitive”, Washington Post, February 24, 2007,
http://www.washingtonpost.com/wp-dyn/content/article/2007/02/23/AR2007022301697.html)

For centuries people assumed that economic growth resulted from the interplay between capital and
labor. Today we know that these elements are outweighed by a single critical factor: innovation.
Innovation is the source of U.S. economic leadership and the foundation for our competitiveness in the
global economy. Government investment in research, strong intellectual property laws and efficient
capital markets are among the reasons that America has for decades been best at transforming new
ideas into successful businesses. . The most important factor is our workforce Scientists and engineers
trained in U.S. universities -- the world's best -- have pioneered key technologies such as the
microprocessor, creating industries and generating millions of high-paying jobs. But our status as the
world's center for new ideas cannot be taken for granted. Other governments are waking up to the vital
role innovation plays in competitiveness. This is not to say that the growing economic importance of
countries such as China and India is bad. On the contrary, the world benefits as more people acquire the
skills needed to foster innovation. But if we are to remain competitive, we need a workforce that
consists of the world's brightest minds. Two steps are critical. First, we must demand strong schools so
that young Americans enter the workforce with the math, science and problem-solving skills they need
to succeed in the knowledge economy. We must also make it easier for foreign-born scientists and
engineers to work for U.S. companies. Education has always been the gateway to a better life in this
country, and our primary and secondary schools were long considered the world's best. But on an
international math test in 2003, U.S. high school students ranked 24th out of 29 industrialized nations
surveyed. To remain competitive in the global economy, we must build on the success of such schools
and commit to an ambitious national agenda for education. Government and businesses can both play a
role. Companies must advocate for strong education policies and work with schools to foster interest in
science and mathematics and to provide an education that is relevant to the needs of business.
Government must work with educators to reform schools and improve educational excellence. During
the past 30 years, U.S. innovation has been the catalyst for the digital information revolution. If the
United States is to remain a global economic leader, we must foster an environment that enables a new
generation to dream up innovations, regardless of where they were born. Talent in this country is not
the problem -- the issue is political will.
 A2: Econ Resilient
US economy vulnerable – decreases can trigger collapse
Hughes 16 (Robert, Senior Research Fellow @ American Institute for Economic Research, 3/22, "An
Economy, Growing But Vulnerable," https://www.aier.org/blog/economy-growing-vulnerable)

The economic outlook is modestly upbeat, but rife with risks. As we approach the seventh anniversary of the end of the
worst recession since the Great Depression, the economy has made substantial progress. There are reasons to believe that
later this year businesses could feel more confidence in hiring and making other investments. But obstacles remain. First,
let’s look at the economy right now. On the positive side, the labor market has made substantial progress recovering from the severe job losses
in 2008 and 2009. The unemployment rate is below 5 percent, and net job creation has averaged over 200,000 per month for the past five
years. In addition, employers are trying to fill more than 5.5 million open positions across the country. Despite the progress, gains in hourly
earnings remain modest. On the negative side, the U.S. dollar has appreciated against most currencies, making our exports more
expensive and imports cheaper, both of which are bad for U.S. manufacturers, though cheaper imports generally benefit consumers by keeping
prices low. An additional drag is that economic growth in many countries around the world remains subpar,
further depressing demand for U.S. exports. The collapse in commodity prices, particularly energy, is a double-edged sword for the overall
economy. Lower energy prices are helpful to consumers and some industries (think, transportation and shipping), but have hurt the domestic
energy production industry. With that basic backdrop, the policy makers at the Federal Reserve have begun raising short-term interest rates.
Signals from the Federal Open Market Committee (FOMC, the group responsible for setting monetary policy) suggest further rate increases will
come, though at an extremely slow pace given the shaky economic backdrop and benign outlook for inflation. How do these trends translate to
an outlook for the second half of 2016? Overall, not too badly. The
U.S. economy is still driven by the consumer. The
slowly improving labor market, combined with lower energy prices and improved household balance
sheets, provide a solid foundation for consumers to continue spending. A reasonably healthy consumer combined
with low interest rates should help support activity in the housing market, particularly as the important spring and summer selling season
approaches. If consumers do push ahead with spending and home purchases, that will likely give confidence
to businesses to continue hiring and boost investment, sustaining a virtuous cycle to keep the economy
growing. That’s the optimistic outlook, and in our view, the likely path. However, any number of things could turn
the virtuous cycle into a vicious cycle. The latest reading from our Business Cycle Conditions model suggests a note of caution.
The Leaders Index – our compilation of economic indicators that help forecast the health of the economy –
had a value of 50 (on a scale of 0 to 100) in the latest month, exactly neutral. Generally, persistent readings below 50 would
indicate an increased probability of recession in the next 6 to 12 months. So, according to our model, while we don’t expect a
recession in the immediate future, the economy is somewhat vulnerable. There are a number of factors that could
make an impact in such a state of vulnerability. For instance, the Fed could raise rates too quickly. Consumers could lose
confidence and slow spending, or businesses could lose confidence and slow or stop hiring, or cut back
on investment. We could be faced with an unforeseen geopolitical event. If one or some combination of these occur, it
could tip our model and the economy into a new recession. There is always some ebb and flow to economic activity,
and when those ebbs and flows happen while overall growth is modest, the risk of a recession can rise. The economy
becomes more vulnerable, policy decisions become more important, and the potential impact of some
shock to the system becomes magnified.

The US economy is in a late stage of the business cycle – the economy is vulnerable
and policy mistake can push the economy into recession.
Blitz 16 (5/5, Josh Zumbrun, a national economics correspondent for The Wall Street Journal in
Washington, D.C. He joined the Journal in 2014 and has covered the U.S. economy since 2008. He
previously worked as a Federal Reserve reporter for Bloomberg News, a Washington Correspondent for
Forbes Magazine and a metro and style reporter for the Washington Post, interviewing Steven Blitz,
chief economist of ITG Investment Research and has more than three decades of experience around
Wall Street and economic forecasting, including a stint as a derivatives market strategist at Salomon
Brothers. He was also global head of fixed income for Lazard Asset Management and at Data Resources
Inc., the predecessor to the economic forecasting firm IHS Global Insight., “Q&A: Why a Cautious
Economic Forecaster Thinks There’s a 60% Chance of Recession in the Next Year”,
http://blogs.wsj.com/economics/2016/05/05/qa-why-a-cautious-economic-forecaster-thinks-theres-a-
60-chance-of-recession-in-the-next-year/)

the economy is nearing a point where policy mistakes can kick it into
My 60% probability really means to convey a sense that

recession. A lot of data appear to be more middle or end-of-cycle in their behavior. This means to me
that the economy is more susceptible to a policy mistake. The Federal Reserve really needs to be careful and more recent statements from [Chairwoman Janet]
Yellen suggest they are. The U.S. economy doesn’t drift into recession — expansions in the U.S. end with a bang not

with a whimper. There was a time when it could have been labor strikes. Today, it could be any 10 random events we could all list. Being
random means, of course, you can’t forecast them. What we can say is that with the economy at a later stage in its cycle, it is more

vulnerable to surprise. If no negative surprise occurs, the economy keeps growing. Q. What are some of these
late-cycle phenomena? Understand the Fed tightening began after QE3 ended, and the forward market started pricing an aggressive forward trajectory for Fed policy, aggressive for this economy. Media
focuses on the funds rate, but forward pricing matters most. Forwards determine the Treasury yields against which mortgages, corporate borrowing, and dividends are priced. As an increasingly aggressive Fed policy tack was
priced in, capital markets reacted as they always do once the Fed starts in this direction—the 2s/10s yield curve flattened, equity markets weakened, and economic growth began to decelerate, which continued into the first

quarter. Today, inventories are high in a number of industries, notably autos. Home buying is up and a source of growth, but given increased income
and employment and low mortgage rates, housing should be doing better. There are many reasons why it isn’t, including demographics, but I want to add the dichotomy between good topline employment data and growth in

. In this
consumer spending, including homes. Historically, the array of industries adding positions was broad enough such that the time-honored relationship between employment and spending growth worked

cycle, employment growth has instead been markedly strongest where income is lowest. Right now, goods-side
employment growth is flat—construction is up but only offsetting reductions in mining and manufacturing. On the service side, temporary
employment is slowing down, often an early signal of a slowing economy. Indeed, outside of restaurant, retail, and healthcare workers, the pace of hiring has been slowing for three- to six-
months.

Another recession would rapidly spiral into economic collapse – fiscal and monetary
solutions are tapped out.
Hilsenrath and Timiraos 15 – Jon Hilsenrath, Nick Timiraos, Wall Street Journal, 2015 (“U.S. Lacks
Ammo for Next Economic Crisis,” WSJ, August 17th, http://www.wsj.com/articles/u-s-lacks-ammo-for-
next-economic-crisis-1439865442)

As the U.S. economic expansion ages and clouds gather overseas, policy makers worry about recession.
Their concern isn’t that a downturn is imminent but whether they will have firepower to fight back
when one does arrive. Money has been Washington’s primary weapon in the decades since British economist John
Maynard Keynes proposed aggressive government spending to battle the Great Depression. The U.S.

generally injects cash into the economy through interest-rate cuts, tax cuts or ramped-up federal
spending. Those tools could be hard to employ when the next dip comes: Interest rates are near zero,
and fiscal stimulus plans could be hampered by high levels of government debt and the prospect of
growing budget deficits to cover entitlement spending on retired baby boomers. Few economists believe the U.S. is near recession. The economy
seems to have regained its footing after a first-quarter stumble, and Federal Reserve officials are considering whether to raise short-term interest rates for the first time in nearly a decade to

ensure the economy doesn’t overheat. Even so, looming threats are a reminder that the slow-growing global economy is just a
shock away from peril. Japan’s economy contracted in the second quarter and Europe recorded lackluster growth. China’s slowdown, meanwhile, appears more severe than
global policy makers initially realized and a currency devaluation there might spur trade frictions. With the U.S. expansion entering its seventh year,

policy makers are planning how to respond to the next downturn, which history shows is inevitable. The
 The world economy is like an ocean
current expansion is now 16 months longer than the average since World War II, and none has lasted longer than a decade. “

liner without lifeboats,” economists at HSBC Bank wrote in a recent research note. In the next downturn, former Fed Chairman Ben Bernanke said in an interview, the
tools of government will be “more limited than usual, but they’re not zero by any means.” The Fed, for example, could experiment with negative
interest rates. A recession also could force Congress and the White House to bridge Washington’s partisan divide to strike a deal that pairs short-run stimulus with long-run plans to reduce the
deficit. ‘Live question’ “This is a very live question,” said Douglas Elmendorf, the recently departed director of the Congressional Budget Office. “Policy makers are thinking about their backup,
backup plans.” The Fed’s strategy of keeping interest rates low well into an expansion is intended to help avoid a relapse into recession. Fed Chairwoman Janet Yellen has described low rates

Federal fiscal
as insurance against another downturn. That is another reason officials intend to move slowly once they begin nudging up rates. Worries stretch to the White House. “

policy will be a more important tool in addressing future business cycles because monetary policy may
be more frequently constrained,” Jason Furman, the chairman of the White House Council of Economic Advisers, said in an interview. “That’s a big
change in the way the economics profession sees the world.” The U.S. over the past quarter century regularly turned to the Fed to provide
stimulus when the economy stumbled. In the most recent recession, short-term interest rates were pushed to near zero, then the

central bank embarked on massive—and controversial—bond-buying programs to drive down long-term interest
rates. The Fed also promised to keep short-term interest rates low for an extended period. The tactics were meant to make it easier for households to pay off debts, encourage new
borrowing and promote risk-taking; officials hoped that would push investment and consumer spending higher. The next downturn could further expand Fed bondholdings, but with the

central bank’s balance sheet already exceeding $4 trillion, there are limits to how much more the Fed can buy. Mr. Bernanke said he was struck by
how central banks in Europe recently pushed short-term interest rates into negative territory, essentially charging banks for depositing cash rather than lending it to businesses and
households. The Swiss National Bank, for example, charges commercial banks 0.75% interest for money they park, an incentive to lend it elsewhere. Economic theory suggests negative rates
prompt businesses and households to hoard cash—essentially, stuff it in a mattress. “It does look like rates can go more negative than conventional wisdom has held,” Mr. Bernanke said.

Others, including Sen. Bob Corker (R.,Tenn.), see only the Fed’s limits. “They have, like, zero juice left,” he said.

New decline causes depression - overwhelms the defense

Isidore 11 (Financial Correspondent-CNN Money, 8/10,
http://money.cnn.com/2011/08/10/news/economy/double_dip_recession_economy/index.htm

Another recession could be even worse than the last one for a few reasons. For starters, the economy is more
vulnerable than it was in 2007 when the Great Recession began. In fact, the economy would enter the new
recession much weaker than the start of any other downturn since the end of World War II. Unemployment
currently stands at 9.1%. In November 2007, the month before the start of the Great Recession, it was just 4.7%.
And the large number of Americans who have stopped looking for work in the last few years has left the
percentage of the population with a job at a 28-year low. Various parts of the economy also have yet to recover
from the last recession and would be at serious risk of lasting damage in a new downturn. Home values continue
to lose ground and are projected to continue their fall. While manufacturing has had a nice rebound in the last
two years, industrial production is still 18% below pre-recession levels. There are nearly 900 banks on the FDIC's
list of troubled institutions, the highest number since 1993. Only 76 banks were at risk as the Great Recession
took hold. But what has economists particularly worried is that the tools generally used to try to jumpstart an
economy teetering on the edge of recession aren't available this time around. "The reason we didn't go into a
depression three years ago is the policy response by Congress and the Fed," said Dan Seiver, a finance professor
at San Diego State University. "We won't see that this time." Three times between 2008 and 2010, Congress
approved massive spending or temporary tax cuts to try to stimulate the economy. But fresh from the bruising
debt ceiling battle and credit rating downgrade, and with elections looming, the federal government has shown
little inclination to move in that direction. So this new recession would likely have virtually no policy effort to
counteract it.
 Impact D
Competitiveness prevents global great power wars
Elbridge Colby 14, the Robert M. Gates fellow at the Center for a New American Security; and Paul
Lettow, was senior director for strategic planning on the U.S. National Security Council staff from 2007
to 2009, 7/3/14, “Have We Hit Peak America?,”
http://www.foreignpolicy.com/articles/2014/07/03/have_we_hit_peak_america

Many foreign-policy experts seem to believe that retaining American primacy is largely a matter of will --
of how America chooses to exert its power abroad. Even President Obama, more often accused of being
a prophet of decline than a booster of America's future, recently asserted that the United States "has
rarely been stronger relative to the rest of the world." The question, he continued, is "not whether
America will lead, but how we will lead."

But will is unavailing without strength. If the United States wants the international system to continue
to reflect its interests and values -- a system, for example, in which the global commons are protected,
trade is broad-based and extensive, and armed conflicts among great nations are curtailed -- it needs to
sustain not just resolve, but relative power. That, in turn, will require acknowledging the uncomfortable
truth that global power and wealth are shifting at an unprecedented pace, with profound implications.
Moreover, many of the challenges America faces are exacerbated by vulnerabilities that are largely self-
created, chief among them fiscal policy. Much more quickly and comprehensively than is understood,
those vulnerabilities are reducing America's freedom of action and its ability to influence others.

Preserving America's international position will require it to restore its economic vitality and make
policy choices now that pay dividends for decades to come. America has to prioritize and to act.
Fortunately, the United States still enjoys greater freedom to determine its future than any other major
power, in part because many of its problems are within its ability to address. But this process of renewal
must begin with analyzing America's competitive position and understanding the gravity of the situation
Americans face.

Economic decline causes nuclear conflict

Mathew J. Burrows (counselor in the National Intelligence Council (NIC), PhD in European History from
Cambridge University) and Jennifer Harris (a member of the NIC’s Long Range Analysis Unit) April
2009 “Revisiting the Future: Geopolitical Effects of the Financial Crisis”
http://www.twq.com/09april/docs/09apr_Burrows.pdf

Of course, the report encompasses more than economics and indeed believes the future is likely to be
the result of a number of intersecting and interlocking forces. With so many possible permutations of
outcomes, each with ample opportunity for unintended consequences, there is a growing sense of
insecurity. Even so, history may be more instructive than ever. While we continue to believe that the
Great Depression is not likely to be repeated, the lessons to be drawn from that period include the
harmful effects on fledgling democracies and multiethnic societies (think Central Europe in 1920s and
1930s) and on the sustainability of multilateral institutions (think League of Nations in the same period).
There is no reason to think that this would not be true in the twenty-first as much as in the twentieth
century. For that reason, the ways in which the potential for greater conflict could grow would seem to
be even more apt in a constantly volatile economic environment as they would be if change would be
steadier. In surveying those risks, the report stressed the likelihood that terrorism and nonproliferation
will remain priorities even as resource issues move up on the international agenda. Terrorism’s appeal
will decline if economic growth continues in the Middle East and youth unemployment is reduced. For
those terrorist groups that remain active in 2025, however, the diffusion of technologies and scientific
knowledge will place some of the world’s most dangerous capabilities within their reach. Terrorist
groups in 2025 will likely be a combination of descendants of long established groupsinheriting
organizational structures, command and control processes, and training procedures necessary to
conduct sophisticated attacksand newly emergent collections of the angry and disenfranchised that
become self-radicalized, particularly in the absence of economic outlets that would become narrower in
an economic downturn. The most dangerous casualty of any economically-induced drawdown of U.S.
military presence would almost certainly be the Middle East. Although Iran’s acquisition of nuclear
weapons is not inevitable, worries about a nuclear-armed Iran could lead states in the region to develop
new security arrangements with external powers, acquire additional weapons, and consider pursuing
their own nuclear ambitions. It is not clear that the type of stable deterrent relationship that existed
between the great powers for most of the Cold War would emerge naturally in the Middle East with a
nuclear Iran. Episodes of low intensity conflict and terrorism taking place under a nuclear umbrella could
lead to an unintended escalation and broader conflict if clear red lines between those states involved
are not well established. The close proximity of potential nuclear rivals combined with underdeveloped
surveillance capabilities and mobile dual-capable Iranian missile systems also will produce inherent
difficulties in achieving reliable indications and warning of an impending nuclear attack. The lack of
strategic depth in neighboring states like Israel, short warning and missile flight times, and uncertainty
of Iranian intentions may place more focus on preemption rather than defense, potentially leading to
escalating crises Types of conflict that the world continues to experience, such as over resources, could
reemerge, particularly if protectionism grows and there is a resort to neo-mercantilist practices.
Perceptions of renewed energy scarcity will drive countries to take actions to assure their future access
to energy supplies. In the worst case, this could result in interstate conflicts if government leaders deem
assured access to energy resources, for example, to be essential for maintaining domestic stability and
the survival of their regime. Even actions short of war, however, will have important geopolitical
implications. Maritime security concerns are providing a rationale for naval buildups and modernization
efforts, such as China’s and India’s development of blue water naval capabilities. If the fiscal stimulus
focus for these countries indeed turns inward, one of the most obvious funding targets may be military.
Buildup of regional naval capabilities could lead to increased tensions, rivalries, and counterbalancing
moves, but it also will create opportunities for multinational cooperation in protecting critical sea lanes.
With water also becoming scarcer in Asia and the Middle East, cooperation to manage changing water
resources is likely to be increasingly difficult both within and between states in a more dog-eat-dog
world.

Global economic crisis causes nuclear war

Cesare Merlini 11, nonresident senior fellow at the Center on the United States and Europe and
chairman of the Board of Trustees of the Italian Institute for International Affairs, May 2011, “A Post-
Secular World?”, Survival, Vol. 53, No. 2
Two neatly opposed scenarios for the future of the world order illustrate the range of possibilities, albeit at the risk of oversimplification. The first scenario entails the premature crumbling of the post-

Westphalian system. One or more of the acute tensions apparent today evolves into an open and traditional conflict between
states, perhaps even involving the use of nuclear weapons. The crisis might be triggered by a collapse of the global
economic and financial system, the vulnerability of which we have just experienced, and the prospect of a second Great Depression, with
consequences for peace and democracy similar to those of the first. Whatever the trigger, the unlimited exercise of
national sovereignty, exclusive self-interest and rejection of outside interference would self-interest and rejection of outside interference
would likely be amplified, emptying, perhaps entirely, the half-full glass of multilateralism, including the UN and the European Union. Many of the more likely conflicts,
such as between Israel and Iran or India and Pakistan, have potential religious dimensions. Short of war, tensions such as those related to immigration might become unbearable. Familiar issues

of creed and identity could be exacerbated. One way or another, the secular rational approach would be sidestepped by a
return to theocratic absolutes, competing or converging with secular absolutes such as unbridled nationalism.

Economic Downturn causes lashout and great power war

Dennis M. Foster, 12-19-2016, Dennis M. Foster is professor of international studies and political
science at the Virginia Military Institute. "Would President Trump Go To War To Divert Attention From
Problems At Home?," Washington Post, https://www.washingtonpost.com/news/monkey-
cage/wp/2016/12/19/yes-trump-might-well-go-to-war-to-divert-attention-from-problems-at-
home/?utm_term=.a9165a23751e

If the U.S. economy tanks, should we expect Donald Trump to engage in a diversionary war? Since the age of
Machiavelli, analysts have expected world leaders to launch international conflicts to deflect popular attention
away from problems at home. By stirring up feelings of patriotism, leaders might escape the political
costs of scandal, unpopularity — or a poorly performing economy. One often-cited example of
diversionary war in modern times is Argentina’s 1982 invasion of the Falklands, which several (though
not all) political scientists attribute to the junta’s desire to divert the people’s attention from a
disastrous economy. In a 2014 article, Jonathan Keller and I argued that whether U.S. presidents engage in
diversionary conflicts depends in part on their psychological traits — how they frame the world,
process information and develop plans of action. Certain traits predispose leaders to more belligerent
behavior. Do words translate into foreign policy action? One way to identify these traits is content analyses of leaders’ rhetoric. The more
leaders use certain types of verbal constructs, the more likely they are to possess traits that lead them to use military force. For one,
conceptually simplistic leaders view the world in “black and white” terms; they develop unsophisticated
solutions to problems and are largely insensitive to risks. Similarly, distrustful leaders tend to exaggerate
threats and rely on aggression to deal with threats. Distrustful leaders typically favor military action and
are confident in their ability to wield it effectively. Thus, when faced with politically damaging problems
that are hard to solve — such as a faltering economy — leaders who are both distrustful and simplistic
are less likely to put together complex, direct responses. Instead, they develop simplistic but risky
“solutions” that divert popular attention from the problem, utilizing the tools with which they are most
comfortable and confident (military force). Based on our analysis of the rhetoric of previous U.S. presidents, we found that
presidents whose language appeared more simplistic and distrustful, such as Harry Truman, Dwight Eisenhower and George W. Bush, were
more likely to use force abroad in times of rising inflation and unemployment. By contrast, John F. Kennedy and Bill Clinton, whose rhetoric
pegged them as more complex and trusting, were less likely to do so. What about Donald Trump? Since Donald Trump’s election, many
commentators have expressed concern about how he will react to new challenges and whether he might make quick recourse to military
action. For example, the Guardian’s George Monbiot has argued that political realities will stymie Trump’s agenda, especially his promises
regarding the economy. Then, rather than risk disappointing his base, Trump might try to rally public opinion to his side via military action. I
sampled Trump’s campaign rhetoric, analyzing 71,446 words across 24 events from January 2015 to
December 2016. Using a program for measuring leadership traits in rhetoric, I estimated what Trump’s
words may tell us about his level of distrust and conceptual complexity. The graph below shows Trump’s level of
distrust compared to previous presidents. These results are startling. Nearly 35 percent of Trump’s references to
outside groups paint them as harmful to himself, his allies and friends, and causes that are important
to him — a percentage almost twice the previous high. The data suggest that Americans have elected a leader who, if his
campaign rhetoric is any indication, will be historically unparalleled among modern presidents in his active suspicion of those unlike himself and
his inner circle, and those who disagree with his goals. As a candidate, Trump also scored second-lowest among presidents in conceptual
complexity. Compared to earlier presidents, he used more words and phrases that indicate less willingness to see multiple dimensions or
ambiguities in the decision-making environment. These include words and phrases like “absolutely,” “greatest” and “without a doubt.” A
possible implication for military action I took these data on Trump and plugged them into the statistical
model that we developed to predict major uses of force by the United States from 1953 to 2000. For a
president of average distrust and conceptual complexity, an economic downturn only weakly predicts an
increase in the use of force. But the model would predict that a president with Trump’s numbers
would respond to even a minor economic downturn with an increase in the use of force. For example,
were the misery index (aggregate inflation and unemployment) equal to 12 — about where it stood in
October 2011 — the model predicts a president with Trump’s psychological traits would initiate more
than one major conflict per quarter.

Weak growth causes nuclear war---turns every impact

Kemp 10 – Geoffrey Kemp, Director of Regional Strategic Programs at The Nixon Center, served in the
White House under Ronald Reagan, special assistant to the president for national security affairs and
senior director for Near East and South Asian affairs on the National Security Council Staff, Former
Director, Middle East Arms Control Project at the Carnegie Endowment for International Peace, 2010,
The East Moves West: India, China, and Asia’s Growing Presence in the Middle East, p. 233-234

The second scenario, called Mayhem and Chaos, is the opposite of the first scenario; everything that can
go wrong does go wrong. The world economic situation weakens rather than strengthens, and India,
China, and Japan suffer a major reduction in their growth rates, further weakening the global economy.
As a result, energy demand falls and the price of fossil fuels plummets, leading to a financial crisis for the
energy-producing states, which are forced to cut back dramatically on expansion programs and social
welfare. That in turn leads to political unrest: and nurtures different radical groups, including, but not
limited to, Islamic extremists. The internal stability of some countries is challenged, and there are more
“failed states.” Most serious is the collapse of the democratic government in Pakistan and its takeover
by Muslim extremists, who then take possession of a large number of nuclear weapons. The danger of
war between India and Pakistan increases significantly. Iran, always worried about an extremist
Pakistan, expands and weaponizes its nuclear program. That further enhances nuclear proliferation in
the Middle East, with Saudi Arabia, Turkey, and Egypt joining Israel and Iran as nuclear states. Under
these circumstances, the potential for nuclear terrorism increases, and the possibility of a nuclear
terrorist attack in either the Western world or in the oil-producing states may lead to a further
devastating collapse of the world economic market, with a tsunami-like impact on stability. In this
scenario, major disruptions can be expected, with dire consequences for two-thirds of the planet’s
population.
Nuclear war
Friedberg and Schoenfeld 8
[Aaron, Prof. Politics. And IR @ Princeton’s Woodrow Wilson School and Visiting Scholar @ Witherspoon
Institute, and Gabriel, Senior Editor of Commentary and Wall Street Journal, “The Dangers of a
Diminished America”, 10-28, http://online.wsj.com/article/SB122455074012352571.html]

Then there are the dolorous consequences of a potential collapse of the world's financial architecture.
For decades now, Americans have enjoyed the advantages of being at the center of that system. The
worldwide use of the dollar, and the stability of our economy, among other things, made it easier for us
to run huge budget deficits, as we counted on foreigners to pick up the tab by buying dollar-
denominated assets as a safe haven. Will this be possible in the future? Meanwhile, traditional foreign-
policy challenges are multiplying. The threat from al Qaeda and Islamic terrorist affiliates has not been
extinguished. Iran and North Korea are continuing on their bellicose paths, while Pakistan and
Afghanistan are progressing smartly down the road to chaos. Russia's new militancy and China's
seemingly relentless rise also give cause for concern. If America now tries to pull back from the world
stage, it will leave a dangerous power vacuum. The stabilizing effects of our presence in Asia, our
continuing commitment to Europe, and our position as defender of last resort for Middle East energy
sources and supply lines could all be placed at risk. In such a scenario there are shades of the 1930s,
when global trade and finance ground nearly to a halt, the peaceful democracies failed to cooperate,
and aggressive powers led by the remorseless fanatics who rose up on the crest of economic disaster
exploited their divisions. Today we run the risk that rogue states may choose to become ever more
reckless with their nuclear toys, just at our moment of maximum vulnerability. The aftershocks of the
financial crisis will almost certainly rock our principal strategic competitors even harder than they will
rock us. The dramatic free fall of the Russian stock market has demonstrated the fragility of a state
whose economic performance hinges on high oil prices, now driven down by the global slowdown. China
is perhaps even more fragile, its economic growth depending heavily on foreign investment and access
to foreign markets. Both will now be constricted, inflicting economic pain and perhaps even sparking
unrest in a country where political legitimacy rests on progress in the long march to prosperity. None of
this is good news if the authoritarian leaders of these countries seek to divert attention from internal
travails with external adventures.

Econ collapse causes global nuclear war

Michael Mandelbaum, Professor and Director of the American Foreign Policy Program, Johns Hopkins
University, The frugal superpower: America’s global leadership in a cash-strapped era, 2010, p.105-6

It is the dominance of peace, democracy, and free markets, supplemented and bolstered by the
reassurance that the United States supplies, that have made the twenty-first century a peaceful period –
so far. But their domination, and the global peace they underpin, are not necessarily destined to last
forever; and the recent turmoil in the global economy does raise the possibility that their era of
dominance will turn out to be a short one. The severe global economic downturn that the financial
collapse of September 15, 2008 catalyzed threatens not only the American role in helping to maintain
peace in the world but also the foundations of the stable twenty-first-century global security order
itself. The international economic and security systems are not, after all, hermetically sealed off one
from the other. To the contrary, each affects the other, and in the 1930s economics had a profound –
and profoundly malignant – effect on politics. The crisis of the global economy led to the outbreak of the
bloodiest episode in the history of international security, World War II, by bringing to power in Germany
and Japan the brutal governments that started that dreadful conflict.