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

In the mid-1950s, the [ National Association for the Advancement of Colored People] defined desegregation as the personal right of a qualified applicant to be admitted on the same basis as any other applicant. The problem was individual, not institutional; it concerned particular state universities, not university systems; the Negro public colleges did not fit the legal equation at all.

Preer, 1982, p. 141

In 1990, the Supreme Court ruled in the Women's Equity Action League v. Cavazos ( 906 F.2d 743) litigation that although Congress could elect to provide for a private right of action under Title VI against the federal government, it had not proposed or passed such a provision. This ruling ended twenty years of federal monitoring of desegregation compliance. Additionally, the Women's Equity Action League ruling resulted in the dismissal of the Adams v. Richardson suit ( 356 F.Supp. 92 [ 1973]) seeking federal enforcement of higher education desegregation. However, the Women's Equity Action League ruling did not dismiss the federal mandate issued in Title VI of the Civil Rights Act of 1964 that "no person in the United States shall, on the ground of race, color, or national origin, be excluded from participation in, or be denied the benefits of, or be sub

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