In 1972 the American Civil Liberties Union represented a group of plaintiffs, many members of the Atlanta chapter of the National Welfare Rights Organization, in a suit that demanded the adoption of a metropolitan school integration plan that would have functionally consolidated the school systems of the city of Atlanta and Fulton and surrounding counties. The US Supreme Court’s decision in Milliken v. Bradley, which overruled the Michigan Supreme Court and declared that suburban school districts could not be compelled to join in a similar metropolitan desegregation plan for Detroit, essentially rendered Armour v. Nix moot. You can and most definitely should read about Armour within the long and contentious context of school desegregation in Atlanta in Tomiko Brown-Nagin’s outstanding book The Courage to Dissent.
I’d like to focus a bit on how the defendants in Armour invoked the differentiation of metropolitan space as a foundation of freedom and liberty. In a 1973 motion asking for dismissal, the defendant school systems invoked an understanding of federalism worthy of junior high social studies, in which
the far greater worth of strong city and county government really lies in keeping that ultimate reality of all political life, “the power to decide,” as close to the people as possible in as many areas affecting their daily lives as possible.
What the Armour plaintiffs pointed out was that one person’s or community’s power to decide to maintain a political division between their school district and neighboring ones severely impinged on others’ power to realize integrated and quality education for their children. This observation was glaringly obvious, even in a cultural context where local control carried the ideological weight for segregation. The defendants were compelled to admit that
In education, as elsewhere, of course, the price (if it can be called a price) of keeping government close to the people is lack of uniformity. When the power to decide is in the hands of the many rather than the few, it is to be expected that decisions will differ….
Needless to say, county to county and city to city diversities of this sort permeate local governmental activities generally. The differences are accepted as an inherent consequence of the very existence of local government (the power to decide obviously being inclusive of the power to differ). Nor have these diversities ever been thought of as posing problems under the “equal protection clause” of the Fourteenth Amendment.
This blithe dismissal of the consequences of political fragmentation as the outcome of decisions the residents of different localities made represents an opportunistic application of public choice theory to rationalize deep spatial inequalities (a subject I’ve addressed here), but it also signals a particular historical turning point for American racism toward the strategic embrace of color-blindness. Just as public choice as a theory evolved in dialogue with changing spatial practices in suburbanizing America, the invocation of individual choice to explain away glaring racial inequities was an ideological maneuver rooted in the metropolitanization of America and the adaptation of white supremacy to a new spatial form and a mode of expression characterized by privilege more than oppression.
Indeed, one of the most effective rhetorical maneuvers of color-blind racism–placing the burden of proof on claimants of racism–was in full effect in the defendants’ motion:
The fact that there is a concentration of black citizens in Atlanta, New York, Chicago, Detroit, Los Angeles, and virtually all other major urban centers of the United States is generally known. Yet there seems to be little if any agreement as to the reasons for this demographic pattern. We think it unlikely that any precise, all-inclusive answer, will ever be arrived at to replace the present speculation.
Since there was absolutely no way to ever reach the conclusion that racism accounted for this admittedly severe deviation from random population distribution, then courts supporting metropolitan desegregation would be engaging with social engineering that, for dubious benefits, risked not the particular prerogatives of the region’s white suburbanites but liberty itself:
plaintiffs would deprive the State and its citizens of a long established political liberty (i.e. the right to establish and maintain autonomous city and county governments for the control of public education, police power, and the numerous other functions and services in which local governments have traditionally been engaged)….
One of the difficulties I have as a historian with much of the sociological literature on color-blind racism is that, for all its sophistication in identifying rhetorical constructions and their usefulness in particular social contexts, that literature tends to assume a sweeping change in the dominant ideological expression of white supremacy without exploring how that change took place–i.e., after the Civil Rights movement, it was no longer socially acceptable to invoke biological racial difference as a justification for white supremacy, necessitating subtler ideological constructs. But if ideologies are in one sense interpretive frames through which one makes sense of the world, they are also strategies for getting what one wants. Ideologies don’t work in the abstract; they can reproduce and spread only to the extent that they work in repeated iterations of similar circumstances. In this case, what the defendant school systems in the counties around Atlanta and their nearly all-white constituencies wanted was to avoid integration, and they could get it by invoking local control, exercised through their county school systems, as a pillar of Americanism while simultaneously playing dumb about why the metro area’s black residents overwhelmingly lived in Atlanta.
One of the things that Armour helps us to understand, then, is that shifts to color-blind expressions of white racism quite literally took place–that is, they took the kinds of places, and the kinds of material and social privileges and interests organized by place, that suburbanization created across the nation after World War II.