Smith, et al. v. Palestine-Wheatley Sch. Dist, et al., No. 13-1816 (8th Cir. 2014)
Annotate this CaseIn 1989, Wheatley plaintiffs filed suit against the District alleging on-going violations of the Voting Rights Act, 42 U.S.C. 1971 et seq., and the Fourteenth Amendment. In 1990, the district court confirmed a settlement between the parties. In 2012, the District filed a motion to modify or terminate the settlement decree, seeking an order permitting the District to relocate the middle school grades from the Wheatley campus to the Palestine campus. The district court granted the motion and the Wheatley plaintiffs appealed. The court concluded that the district court properly applied the standards for modifying a consent decree when changed circumstances have caused it to be unjust under Rufo v. Inmates of the Suffolk County Jail. In this case, the district court did not abuse its discretion in approving the modification, which was directly related to the evidence of changed circumstances the District presented. Further, it is apparent from the face of the consent decree that many of its eleven contractual commitments were premised on continued use of two school campuses and, therefore, these provisions were effectively terminated. Other provisions in the decree do not require functioning schools in both communities. The district court did not intend that its order terminate the entire consent decree, and the court so construed its order. Accordingly, the court affirmed the district court's order.
Court Description: Civil case - School Desegregation. The district court did not err in applying the standards set out in Rufo v. Inmates of Suffolk County Jail, 502 U.S. 367 (1992) to the defendant school district's motion to modify or terminate the consent decree governing the desegregation of the district; nor did the court abuse its discretion in modifying the decree as the district established changed circumstances warranting the modification of the decree and the proposed modification - transfer of middle school grades to a new campus - was suitably tailored to the changed circumstances; under the circumstances, the court is confident that the district court did not intend that is Order would terminate the entire consent decree, and the court would so construe its order.
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