Parents Involved in Community Schools: The

Educational Manifestation of Seattles Segregated

History

Ben Lennon
HSTAA 260

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On June 28th, 2007, the U.S. Supreme Court handed its decision down in Parents
Involved in Community Schools (PICS) v. Seattle School District No. 1 and in a moment ended
the last vestiges of an over four-decade effort to integrate Seattle schools. Starting in 1963 with a
voluntary transfer program, the district had tried multiple ways to rectify the de facto segregation
that was the result of a long legacy of housing segregation in Seattle. After instituting a
mandatory bussing program in 1977 and its eventual death in 1997, the district had turned to
schools assignments in a weak effort to integrate schools. Students could apply to go to any high
school in the district, and a system of tiebreakers was instituted when some schools got too many
applicants. The first tiebreaker was the grandfather system, which favored students with a
sibling already at the school. The second tiebreaker was the one considered by the court, and it
assigned students based on a racial classification, in an effort to maintain a relative racial balance
across the district. The Court held racial balance alone could not be the goal, and thus declared
the use of a racial tiebreaker in school assignment was unconstitutional under the Equal
Protection Clause of the 14th amendment
One major difference that separates Seattle from other school districts around the country,
especially ones instituting integration plans, is that Seattle never had mandated school
segregation. Likewise, it never had state-enforced housing segregation. This leads to an
important question: how did the district representing one of the countrys most progressive cities
and without any prior mandated school segregation end up needing a method for integrating
schools in the first place? In this paper I will examine the long history of housing, and thus
school, segregation in Seattle, and argue that the tiebreaker was the result of a legacy of housing
discrimination dating back to 1924, when the first racial restriction was written into a group of
housing deeds in North Seattle, codifying that "Said tract shall not be sold, leased or rented to

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any person or persons other than of the Caucasian race nor shall any person or persons other than
of the caucasian race use or occupy said tract (Seattle Civil Rights and Labor History Project
(SCRLHP), 2006). This legacy and the subsequent expansion of racially restrictive housing
covenants, supported at times by the federal government, led to a system of de facto segregation
in Seattle schools based on its neighborhood schools policy. The issue garnered a lot of attention
in the 1960s with the nationwide Civil Rights movement, and culminated in a mandated bussing
program in 1977 that, after almost a decade of failed integration programs, achieved its goals
within 3 years. However, by the time of the PICS decision even this program had ended and the
districts integration efforts were weak, affecting very few students. Today Seattle schools still
face the issue of de facto segregation, and to get at the root of this, we must examine the sociallyenforced legacy of housing segregation that throughout the twentieth century kept Seattles
neighborhoods and schools segregated. This history spans many eras that can be demarcated by a
series of court cases, federal laws, and district integration efforts. To begin this long history, we
have to look at the first racially restrictive housing covenant, which was created in 1924.

Corrigan v. Buckley and Seattles Early Housing Segregation

While the effects of Seattles housing segregation still affect us today, the legal history of
it spans the four decades from the early 1920s to the Civil Rights Act of 1968 that outlawed
housing discrimination. In 1924 the Goodwin Company sold land from part of the companys
development in North Seattle. The deeds to the land included the following clause: "Said tract
shall not be sold, leased or rented to any person or persons other than of the Caucasian race nor
shall any person or persons other than of the Caucasian race use or occupy said tract (SCRLHP,
2006). This made it very clear that the neighborhood was for white people only, and this was the

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first known covenant of its kind (Silva 2009). It started an era of these covenants that excluded
nonwhite people from owning or living in most of North Seattle and various other
neighborhoods. The one exception was made for domestic servants, as long as they were
working for white bosses (SCRLHP, 2006). Different iterations of this covenant would focus
more on who they excluded instead of included. This can be seen the deed for a Sandpoint
House, written in 1929: No person or persons of Asiatic, African or Negro blood, lineage, or
extraction shall be permitted to occupy a portion of said property, or any building thereon; except
domestic servants may actually and in good faith be employed by white occupants of such
premises (SCRLHP, 2006). These covenants all said the same thing in many different ways:
these were neighborhoods for whites, and there were other neighborhoods for everyone else.
What helped these covenants grow was the Supreme Court case Corrigan v. Buckley,
decided on May 24th, 1926. The Court dismissed an appeal from the defendant Irene Corrigan,
who had tried to sell her land to Helen Curtis, who was a person of the negro race (Justice
Sanford, 1926). John Buckley, the plaintiff in the case, sued to stop the sale, arguing that it
violated the covenant in the deed which restricted landowners from selling to any person of the
negro race or blood (Justice Sanford, 1926). Buckley successfully got an injunction against the
sale, which Corrigan and Curtis appealed. The appeal went all the way up to the Supreme Court,
who argued that they did not have jurisdiction because it was a sale between individuals. Thus,
the Court could not rule on the case, and therefore they denied the appeal (Justice Sanford,
1926). This was a huge moment for white landowners across the country who wanted to keep
their neighborhood white, as now they had permission to do so from the federal government. In
Seattle, this kicked off twenty-five years in which hundreds of covenants would be written (Silva
2009). This decision also blurred the lines between de jure and de facto segregation. While it

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didnt mandate these covenants by law, it gave the covenants and homeowners the full force of
the law.
What further blurred this line was the National Housing Act of 1934. What was on the
surface an effort to protect homeowners through making mortgages more accessible was at the
same time a force that would further segregate the country. What the bill did was divide cities
into different areas and marked which areas were good for investment, where white people lived,
and which ones were risky, where minorities lived (Silva 2009). The Federal Housing
Administration, created by the Housing Act, would then back mortgages in the ideal areas and
discourage mortgages in the risky areas. In Seattle, after a decade of housing covenants that
restricted where minorities could live, the main redlined area was the Central District. This
delineation is clearly seen on a FHA map of Seattle. The Central District, marked to the North by
Madison Street, is outlined in red and labeled Hazardous (FHA, 1936). This was both caused
by the housing restrictions and helped to solidify them, as by preventing minorities in the Central
District to buy house and forcing them to rent, it prevented them from saving up the money
needed to buy a house in other neighborhoods, places where they couldnt buy houses anyway
because of the covenants.
Ultimately, this also created a kind of de facto segregation in the schools. Similar to
districts across the country, the Seattle school district assigned students to schools on the basis
of the neighborhood concept that pupils should attendthe schools nearest their homes (Seattle
School District, 1970). As Seattle neighborhoods were strictly segregated into white
neighborhoods, mainly throughout North Seattle, and nonwhite neighborhoods, in the Central
District and the International District, Seattle school students thus found themselves surrounded
by students that looked exclusively like them. While a Supreme Court decision would overturn

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the legitimacy of the housing covenants, the social enforcement of segregation which had been
fostering this whole time would continue to ensure that Seattle neighborhoods stayed the same.

Shelly v. Kraemer and De Facto Housing Segregation

In 1948 the Supreme Court heard a new case about racial covenants from a family in St.
Louis. While the court ruled that, under the Buckley decision, racial covenants were
constitutional, they focused more on the judicial enforcement of these covenants. While the
covenants themselves were not acts of the State and so not judged on constitutional basis, the
enforcement of these covenants by judicial offices in their official capacities was indeed an act
of the State (Chief Justice Vinson 1948). This being an act of the State is was subject to
Constitutional scrutiny, and the court declared that the enforcement of these covenants by the
state was unconstitutional. While this seemed like a step forward for housing equality, the
decision also made it clear that private enforcement was not a constitutional matter.
This decision shifted the emphasis to social relationships to uphold de facto segregation.
Many different tactics to keep nonwhites from buying homes in white neighborhoods emerged,
including threats of violence against the family and the threat of cutting off utilities (Silva 2009).
There have been multiple documented cases of nonwhite or Jewish families attempting to buy
houses in white neighborhoods about the Kraemer decision only to stop looking after facing
many different threats. Further, believing that allowing minorities to live in white neighborhoods
would bring down property values, realtors enforced a code that kept them from selling houses to
minorities in white neighborhoods (Silva 2009). These were just a few of many different ways
that people kept Seattle segregated, and the effect was clear: In 1960, Black, Indian, Japanese,
Filipino, and Chinese populations were still centered in the Central and International Districts

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(SCRLHP 2006). Though over a decade had passed since the Kraemer decision, the housing
situation in Seattle hadnt changed.
This isnt to imply that minorities in Seattle accepted the situation. As was happening
across the nation, the 50s and 60s saw a time of civil rights activism and protest in Seattle.
Beyond the housing situation, blacks had also been left out of Seattles economic boom and their
unemployment rate was triple that of the city at large (Taylor 1995). Faced with the hardships of
job discrimination, housing restrictions, and school segregation, local civil rights leaders started
to organize, and the numerous groups came together to form the Central Area Civil Rights
Committee that would lead the charge (Taylor 1995). This Committee included elements from
the Seattle Urban League, the Baptist Churches, the Seattle branch of the NAACP, and CORE.
The leaders in these organizations were all local civic and community leaders, yet they had
important national ties, such as the Martin Luther King Jr. as well. In the early 1960s they started
a campaign to get an open housing ordinance passed, which would in their minds finally end the
specter of housing discrimination that haunted them. They turned to the city council to get this
legislation passed, but they were initially ignored (City of Seattle, 1995). This led them to
organize more direct action, and eventually the council put the ordinance up to a city vote. The
campaign quickly turned vicious, as civil rights activists were met with all sorts of violence,
including burned crosses, explosives, and gunfire (Wells 2006). The system of social
enforcement that had upheld segregations for over a decade was not going to be undone that
easily, and indeed it wasnt. The finally vote turned down the housing ordinance by a margin of
over two-to-one (City of Seattle, 1995). White Seattleites who had been protecting their
segregated neighborhoods for years, with or without the help of the federal government, won

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another victory and made it clear that to solve this problem federal intervention would be needed.
However, the protests werent over yet.

The School Boycott and the Fair Housing Act of 1968

A second major aspect of the protest movement was the school segregation. The problem
was very clear: while there was no legal mandate, Seattles schools were very segregated. Black
students made up 9.1% of students in the district and they were concentrated in only a few
schools. Seven elementary schools had an African American population anywhere from 45% to
95%, 80% of black middle schoolers went to two middle schools, and 75% of black high
schoolers went to Garfield, representing 52% of that student body (Clark 2005). The school
board proved to be very resistant to change as they were determined to stick with the
neighborhood school model. As many in the protest movement pointed out, however, this simply
upheld the status quo that had been created through legalized housing discrimination.
The issue swelled in the 1960s with the rise of the Southern Civil Rights movement.
While the district tried to make various concessions, such as a voluntary transfer program, none
of them were satisfactory as they affected few students and did nothing to solve the problem
(Clark 2005, Seattle School District 1970). The same civil rights groups that were leading the
housing effort started also turned their attention to schools, and after discussion, they decided to
threaten a boycott or a similarly dramatic action, with the goal of getting the attention of the
school board and forcing them to act. This culminated into a two day boycott, March 31st and
April 1st in 1966, during which near 3000 students stayed away from Seattle schools and instead
attended Freedom Schools, where they learned about black history and wrote letters to Seattle
School District officials (Clark 2005). While this didnt have an immediate effect, it was a huge

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moment in the school desegregation process and would play a role even a decade later when the
districts bussing system was implemented.
In terms of housing, 1968 saw the passing of the Civil Rights Act of 1968, which
outlawed any form of housing discrimination (Silva 2009). After decades of fighting against
racial covenants, the battle was won, legally. In reality, however, the act had little effect in
Seattle. By 1980 little had changed, and minorities were still centered in the Central District,
though they did now make up a significant portion of the South Seattle Population. They
remained under 10% of the population in North Seattle (SCRLHP 2004). Clearly the social
enforcement forces were still strong, and so the protest movement and the school district had to
figure out a way to circumvent this. The city was segregated and it appeared to be staying that
way, so how would they integrate the schools? This debate raged throughout the 1970s,
culminating in the adoption of a major bussing program in 1977.

Mandated Bussing: The Successes and Failures

Eventually the school board did acknowledge the need to desegregate schools. After
nearly a decade of failed ideas such as voluntary transfer (which affected less than 3% of the
student population) and compensatory education (Clark 2005), the district adopted a bussing plan
in 1977 that would aim to desegregate Seattle schools by the 1979-1980 school year (Seattle
Public Schools 1977). Success would be racially balanced schools, defined as schools where the
white and nonwhite populations fell within 20% of the district average, and indeed, by 1980 the
plan had worked, and only one school (Cleveland, where the minority population was over 20%
more than the district average) was still considered racially imbalanced (Shaw 2008). The plan
affected nearly a quarter of the student population, and, on paper, it worked.

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However, keeping in line with Seattles history, social forces swelled against the bussing
plan. On the surface the anti-bussing movement was about choice and freedom, but these were
coded words that suggested something much deeper: underlying racial tensions that had fueled
housing segregation for decades (Pochop 2014, 200). The forms of resistance were many, one of
the major ones being CiVIC, Citizens for Voluntary Integration Committee, who argued that
integration by any means shouldnt be mandatory, but voluntary (Pochop, 203). Largely white,
CiVIC was very delicate with their rhetoric so that they wouldnt appear racist. Their focus then
was on choice and democracy, and they often conflated political rights with their supposed
property rights (Veninga 2005 106). These parents argued that their taxes went to their
neighborhood school and that they had the right to go there. As one parent said, let racial
balance be made by choice, not by government force (Veninga 2005, 106). This one sentence
shows the connection between the anti-bussing movement and the decades of social enforcement
that came before it. The statement completely overlooks the different ways that racial balance
by choice was prevented by all kinds of homeowners. Whether it was restrictive covenants,
realtor codes, or violence, this choice had never been an option because homeowners, similar to
the ones protesting the bussing campaign, had done everything they could to prevent it from
being a choice. However, now that they were forced with government action, they tried to argue
that they should have a choice that nonwhite Seattleites had been prevented from having for
decades. In other words, the legacy of social enforcement of de facto segregation lived on.
The types of protests were varied, and these efforts combined with lackluster results
would eventually lead to the downfall of the bussing campaign. One of the strongest efforts
against the Seattle Plan, as the integration plan was called, was Initiative 350 which aimed to
deny schools boards the ability to assign a student to a school that wasnt one of the two closest

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to the student (Veninga 2005, 99). I-350 would in fact pass statewide, with lots of support from
predominantly white North and West Seattle, but it would later be struck down by the Supreme
Court (Veninga 2005, 99). Another form of protest was the school equivalent of white flight, or
white parents pulling their students out of Seattle Public Schools and enrolling them into either
private schools or nearby district. Over 1500 students didnt show up for school in 1978
(Veninga 2005, 100), and by 1980 white enrollment had dropped by 28% (Shaw 2008). Beyond
these protests, academic achievement didnt improve, and while the school district was less
segregated, the schools themselves saw the rise of student self-segregation (Shaw 2008). These
forces led the district to reduce busing in 1989 and eventually do away with it in 1997. This left
the districts last policy, which was the racial tiebreaker.
Compared to the busing, the tiebreaker was a very modest policy. Whereas busing had
affected twelve thousands students, the tiebreaker ended up involving less than three hundred
students and had a very minimal effect on the make-up of the district (Shaw 2008). When
challenged by a parent who wanted their kid to enroll in an academy at Ballard High School, the
Supreme Court ended up ruling that simple racial balance isnt compelling enough to justify the
use of race as a tiebreaker (Justice Roberts, 2007), and with that the districts decades of
integration efforts finally came to a halt. While they are not out of the question for the future,
currently the segregation of schools continues, a devastating reflection of decades of de facto and
socially enforced housing segregation.
Conclusion
Today Seattle schools, while not as segregated as they were sixty or seventy years ago,
remain a reflection of the segregated legacy of Seattle. Two schools have white populations that
are over 20% higher than the district average, African Americans are concentrated in the five

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South Seattle schools, and Asian Americans are also largely concentrated in the South end
(Office of the Superintendent of Public Instruction, 2013). This is a reflection of the city itself,
where minorities are still largely centered in the Central District (SCRLHP 2004). There is no
public discussion about how to integrate our schools, and year by year the status quo continues.
While Seattle has slowly become more integrated (North Seattle has gone from 99% white to
75% white (SCRLHP 2005)), it seems that nowhere in the city is the racial makeup
representative of the whole picture. While this legacy doesnt have a specific starting point, it is
easy to point out the first restrictive covenant which was written in 1924. For the next ninetyplus years, a system of social enforcement, realtor practices, and at least for a while federal
policies helped to uphold this de facto segregation, and it continues today. While federal policies
dont explicitly enforce segregation today, even in this century realtors unofficially use practices
like steering (in which they generally steer white people away from minority communities),
using language like questionable ethnic mix and saying things like its primarily an ethnic
neighborhood and I wouldnt send you there (Leeuw, 2006). This inherently has been driven by
social enforcement, as any other enforcement has either stopped or been stopped by the
government.
The fact that the underlying factor here is social enforcement is telling of a city that
claims a liberal persona. To be fair, Seattle is in many ways a progressive city, especially when
compared to the rest of the country. Seattle is after all the driver of the national discussion on
minimum wage, and it tends to push Washington to be on the forefront of progressive issues such
as gun control or marriage equality. However, when it comes to racial issues Seattle falls into the
same issues as the rest of the country. Try as it might, it cannot escape the race issues that our
country has and refuses to acknowledge. To some, especially in the Central District, these issues

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are apparent. To some, especially in the North end, these issues dont seem real. But the legacy
of social enforcement of de facto segregation cannot be denied, and to truly be a progressive city
it is a legacy that Seattle must confront.

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