The Quest to Define Collegiate Desegregation: Black Colleges, Title VI Compliance, and Post-Adams Litigation

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The Quest to Define Collegiate Desegregation: Black Colleges, Title VI Compliance, and Post-Adams Litigation, by M. Christopher Brown, II. Westport, CT: Berlin & Garvey, 1999. 167 pp. $29.95, cloth. Reviewed by Jessica E. Stephens, Eastern Kentucky University, and J. John Harris III, University of Kentucky

The year 1999 marked the 45th anniversary of the U.S. Supreme Court's decision in Brown v. Board of Education of Topeka, Kansas (1954), the decision that shattered the foundation of Plessy v. Ferguson (1896). Brown ranks among the most significant rulings in the history of the Court and it continues to exert far-reaching effects on the lives of all citizens of this nation. In its declaration that segregation had deprived minority children of equal educational opportunities in violation of their right to equal protection under the Fourteenth Amendment, this epochal decision accomplished more than the recognition that education is perhaps the most important function of state and local governments. However, people of African descent have discovered that the new dawn promised by Brown was eclipsed with prolonged darkness and little light. Indeed, it formed the cornerstone for all subsequent legal developments ensuring the rights of disenfranchised groups, whether classified by race, country of national origin, or language.

As assistant professor of higher education at the University of Illinois at UrbanaChampaign, author Brown advocates ceasing the practice of viewing desegregation in terms of race and enrollment. As he maintains, desegregation should instead be viewed in terms of access, equal outcomes, and freedom of choice in attempting to discuss how these concepts may be used when designing and implementing policies that comply with Title VI or the construction of unitary systems of higher education. In this book, written for higher education faculty, administrators, and policymakers, Brown outlines and elucidates the statutory and legal bases of desegregation in the higher education context. He further chronicles and describes its historical development, and analyzes the history of compliance and enforcement litigation in the aftermath of Adams v. Richardson (1973). The work also explores how the evolution of legal desegregation standards has impacted recent litigation in such states as Alabama, Louisiana, Mississippi, and Tennessee. As Brown asserts, "There is a lack of clarity regarding the definition of desegregation and a criteria for compliance" (p. 52). He suggests as well that the field of higher education continues to exist without a well-articulated, clearly defined meaning of what a truly desegregated state system of higher education is, although seemingly dismantling dual educational structures.

The book contains six chapters, a foreword, an introduction, and an afterword. In Chapter 1, "Black Colleges and Desegregation," Brown addresses the history of higher education through its attendant court cases and demonstrates that segregation still permeates the very fabric of higher education based on laws and public policy that essentially merged or closed many Black colleges. In Chapter 2, "The Unfinished Quest for Compliance," he provides a history of African American education incident to various land grant initiatives emanating out of the 1862 Morrill Act and culminating with the 1890 version of the Act, the latter of which specifically addresses the delivery of land grant services through Black colleges. In this chapter, additional attention is directed toward the Adams case, in which 19 southern and border states' colleges and universities were still distinctively identifiable as Black institutions and White institutions.

In Chapter 3, "Desegregation Litigation Reborn," Brown examines the proposition that de jure segregation continues to exist in the four states (Louisiana, Mississippi, Alabama, and Tennessee) on which his analysis is focused. …