Keyes v. School District No. 1

Keyes v School Board No. 1 marked the first time that the Supreme Court identified discrimination in a state that had never imposed racial segregation by statute. This case also served to reinforce the Court's distinction between de facto and de jure segregation, a position further developed in Milliken v. Bradley (1974). Finally, Keyes established that racially segregative actions in one portion of a school system could render the entire system liable to definition as segregated.

Despite the apparent victory for desegregation seen in Keyes, many schools in the United States remain, essentially, segregated. Majority flight to the suburbs increased throughout the 1970s and 1980s, rendering intrasystem remedies increasingly ineffective. In Milliken v. Bradley, the Court ruled that demographic shifts (such as flight to the suburbs) not caused by state action could not be redressed by judicial action. As such, intersystem desegregation could only occur on a voluntary basis, and has rarely been attempted.