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This paper examines the broader context of remembering Milliken in relation to the often celebrated Brown decision, examining how the Milliken decision built an all but impenetrable wall around the suburbs that blocked the flow and exchange of students, resources, and ideas. The decision ended northern commitment to the principles of integration by ruling that social or “de facto” segregation was permissible. The spaces where de facto segregation was most obvious – such as northern suburbs – would not be subject to desegregation orders. Originating in Detroit, a major destination of the Great Migration the decision dictated how desegregation would proceed outside of Dixie, if at all. The courts had done well to help eradicate segregation in the South through federal court orders, even employing military force. But the nation largely understood segregation to be an issue confined to the South. Milliken brought the freedom struggle’s call for integration to the North and the courts shut it down.
Focusing on Brown without comprehending Milliken compounds a collective misunderstanding about the issue. It misses the complexity of Thurgood Marshall, someone our nation tends to honor with effusive praise. Appointed to the High Court by Lyndon Johnson in 1967, the lead counsel for the NAACP when the Brown case was brought to the Court, issued a scathing dissent. He noted that, “After 20 years of small, often difficult steps toward [equal justice under law], the Court today takes a giant step backwards.” By upholding de facto segregation, the Court revived “the same separate and inherently unequal education… afforded in the past.” Milliken erected a legal boundary protecting suburban spaces racialized as White, relegating northern complicity to the margins of history. Continuing to ignore Milliken obfuscates the fundamental re-segregation of our schools today and the choices available to improve education.