 Efforts to combat de facto segregation have been limited by US jurisprudence since the Brown decision. Although the Supreme Court previously allowed plans to integrate schools within a particular school district (see Swann v. Charlotte-Mecklenburg Board of Education, 1970), in Milliken v. Bradley (1974) the Court struck down an inter-district busing plan that moved students across district lines to desegregate the Detroit city and surrounding suburban schools. This limitation on legal remedies for de facto segregation has significantly hampered integration efforts given that most school districts in the US are not racially diverse. More recently, the US Supreme Court further curtailed integration efforts within the small number of districts that are racially diverse. In its Parents Involved in Community Schools v. Seattle School District decision (2006), the Court prohibited districts from explicitly using individual students’ race as a factor in school assignment plans, thereby condoning only race-neutral integration plans in what many regarded as the Court’s final retreat from redressing de facto segregation (e.g., Rebell 2009; Ryan 2007).