The Containment & the Future of Schools

Last year, author and University of Michigan professor Michelle Adams released her groundbreaking book, The Containment: Detroit, the Supreme Court, and the Battle for Brown v. Board of Education (2023). In it, Adams tells the story of how the landmark case Bradley v. Milliken came to be.

For those unfamiliar with Bradley v. Milliken (1974), it is helpful to review the broader history of school segregation and desegregation in the United States first. In 1954, the U.S. Supreme Court ruled in Brown v. Board of Education that “separate but equal” schools were unconstitutional. This decision compelled school districts across the country to begin integrating their schools “with all deliberate speed” (Warren, 1954). However, the implementation of Brown proved to be far from straightforward. Across the South, districts developed busing plans to transport Black students across municipal boundaries to attend predominantly white schools.

Interestingly, scholars have since noted that, despite fierce resistance, the South often made more progress toward integration than many Northern states (Orfield, 2009). This was due, in part, to the North’s characterization of segregation as de facto—a matter of individual preference—rather than de jure or legally sanctioned segregation. Adams’s The Containment challenges this narrative. She demonstrates that racial segregation in Northern cities, like that in the South, was not merely accidental but the product of intentional policies and practices at the federal, state, and local levels.

Adams highlights how organizations such as the NAACP worked tirelessly to expose how housing covenants, redlining, and discriminatory lending practices produced residential segregation—laying the groundwork for racially segregated schools through neighborhood-based school assignment policies (Rothstein, 2017). Through vivid storytelling, Adams recounts the efforts of numerous individuals who fought for school integration and traces how their advocacy influenced key figures, including Judge Stephen J. Roth, who presided over the Bradley v. Milliken case.

Importantly, Adams also explores the complexity of the integration debate. She acknowledges that the push for integration was not universally supported—not only by white opponents but also by some Black advocates, such as Robert L. Gill (often misattributed as “Clegg”), who feared that integration might undermine Black community institutions and autonomy (Bell, 1976).

However, Milliken v. Bradley (1974) did not end with the efforts of civil rights advocates. Adams details how white parents and suburban communities—such as those in Pontiac, Michigan—mobilized to resist busing and school integration. The election of President Richard Nixon and his subsequent Supreme Court appointments shifted judicial attitudes toward desegregation. These political and judicial changes became, as Adams describes, “hinge points” that culminated in the Milliken decision, which overturned Judge Roth’s metropolitan integration plan. The Supreme Court ruled that busing Black and white students across Detroit’s city-suburban boundary was unconstitutional unless it could be proven that suburban districts had intentionally contributed to segregation. This decision effectively limited busing as a remedy for racial segregation and set a precedent that continues to shape educational inequities today.

Adams argues that the Milliken decision has had profound and lasting consequences—contributing to the reality that American schools today are more segregated than at any point since the 1960s (Reardon & Owens, 2014).

During our team’s visit with Professor Adams, we had the opportunity to hear her expand upon the story of this landmark case and its enduring impact on contemporary education. At EDquity, we believe that providing equitable education for all students is essential not only for their individual success but for the moral and civic health of our nation. We share Adams’s conviction that school integration is vital—not only because of its academic benefits but because it strengthens the social fabric of our democracy.

Adams references numerous studies, including the Kentucky Study (Foster & Jefferies, 2021), which show that access to diverse learning environments improves student outcomes and long-term achievement. Yet beyond measurable outcomes, integration fosters social cohesion—a sense of shared destiny that sustains a pluralistic democracy. As Dr. Martin Luther King Jr. once reminded us, our nation’s future depends on our ability to live out its moral promise:

“When Black boys and white boys walk together as brothers, when Black girls and white girls walk together as sisters, then we shall overcome.”

We believe that true solidarity—and the fulfillment of America’s democratic ideals—begins in our schools.

Adams, M. (2023). The Containment: Detroit, the Supreme Court, and the Battle for Brown v. Board of Education. Pantheon Books.

Bell, D. (1976). Serving Two Masters: Integration Ideals and Client Interests in School Desegregation Litigation. Yale Law Journal, 85(4), 470–516.

Foster, M., & Jefferies, C. (2021). The Kentucky Study: Diversity and Educational Equity in Public Schools. University of Kentucky Press.

Orfield, G. (2009). Reviving the Goal of an Integrated Society: A 21st Century Challenge. UCLA Civil Rights Project.

Reardon, S. F., & Owens, A. (2014). 60 Years After Brown: Trends and Consequences of School Segregation. Annual Review of Sociology, 40, 199–218.

Rothstein, R. (2017). The Color of Law: A Forgotten History of How Our Government Segregated America. Liveright Publishing.

Warren, E. (1954). Brown v. Board of Education, 347 U.S. 483.