Sheff v. O’Neill

Facts

The plaintiffs were eighteen schoolchildren, including African-American, Latino, and white students, primarily residing in Hartford. In the 1991-92 school year, 92.4% of Hartford public school students were minorities, while the statewide minority enrollment was only 25.7%. Fourteen of Hartford’s twenty-five elementary schools had white student enrollment below 2%. The surrounding twenty-one suburban towns had significantly lower minority percentages, with only seven exceeding 10% minority enrollment. The trial court found that this concentration resulted primarily from a 1909 state statute (§ 10-240) making town boundaries coterminous with school district boundaries, combined with the requirement that students attend school in their residential district (§ 10-184). The state had not intentionally created this segregation, and Connecticut had no history of de jure segregation except for a brief period in 1868. Despite state efforts to address the problem through various voluntary programs and funding mechanisms, racial and ethnic isolation in Hartford schools continued to worsen. The trial court also found that poverty, rather than race or ethnicity, was the principal cause of lower educational achievement, and that Hartford students received a minimally adequate education with resources comparable to or exceeding those of suburban districts.