 The work of legal theorist Derrick Bell was key in bringing a CLS approach to the topic of race. Bell developed a series of interpretive arguments focused on the reforms won by civil rights cases to show that the successes were generally contained to those that did not threaten white entitlement (Bell 1987). Corporate elites used the mandate for diversity, for example, as a means to create a diverse managerial class more effective at controlling the broad multi-racial low-paid workforce. When establishing racism required evidence of intentional attitudes or conscious conspiracies, it was all but impossible to redress cross generational wealth disparities based on race or the structural forms of anti-black racism so deeply embedded in such institutions as education, the justice system, health care, housing, and the local, state and national organizations intended to serve democratic representation. Thus, civil rights reforms left racism “firmly entrenched,” as Bell put it (1987, 4). Forced to work with liberal concepts, progressive civil rights legislation ended up providing cover for the continuation of racial divides in housing, wage scales, and education while the criminal justice system has become even more lethal to Black and Brown populations.