How De Facto Segregation Survives

Malik Miah

The Containment:
Detroit, the Supreme Court, and the Battle for Racial Justice in the North
By Michelle Adams
Farrar, Straus & Giroux, 2025, 528 pages, $35 hardcover.

MICHELLE ADAMS IS a professor at the University of Michigan Law School, who grew up in Detroit. Her new book The Containment explains the continuing effect of Milliken v. Bradley and its prohibition of a metropolitan Detroit cross-district desegregation order.

The Supreme Court made that decision in 1974, more than 50 years ago. The decision made clear that Jim Crow-type legal segregation in the North was still very much alive.

A similar and violent struggle happened in a Boston desegregation battle during the same period. I was directly involved in that fight in 1974-75.

Boston schools had many more white students than Detroit. Whites, mostly working class, opposed using buses to integrate their schools.

Professor Adams’ book about Detroit’s fight for school equality in the 1970s is very much relevant to Trump’s ongoing attacks on Diversity, Equity and Inclusion (DEI) and removal of Black stories from “American” history and institutions.

Twenty years after the Court’s 1954 landmark Brown v. Board of Education rejection of “separate but [un]equal” doctrine in the South was overturned, desegregation in 1974 was less advanced in northern and western states. Why?

The federal government had directly intervened in the South, including with force, to integrate schools and change other laws such as interstate busing and sitting at public counters.

It took mass civil disobedience and public peaceful protests, but the civil rights movement led to major legislation passed by Congress and signed into law by President Johnson. But in the North that government intervention rarely happened, because on paper states like Michigan opposed legal segregation.

Instead, white communities fought integration by other means — through violence and claiming defense of “neighborhood schools,” knowing that residential segregation kept African Americans out of their communities.

They opposed so-called “forced busing” — even though buses have been used for decades to transport children to public and private schools.

Direct Experience

I know this historical record firsthand as I grew up in Detroit in the 1950s and 1960s. My father was an auto worker (immigrant from Bangladesh), employed by Ford in Sterling Heights, a city where Blacks and minorities could not live in the 1960s.

Inside Detroit, exclusionary residential policy, as Adams explains, kept Black workers out of certain areas. Housing segregation was the norm in the suburbs and the city.

Like all families, my parents (mother was an African American, born in Detroit) sought the best education available.

I was fortunate to attend Cass Technical High School, a citywide selective admissions public school that prepares students for higher education. Its high academic standards also attracted white students from the suburbs.

To go to Cass, I rode a city bus for free.

Turning Back the Clock

Some opponents of integration in Detroit and Michigan claimed to be for a “colorblind” society (as we hear from white supremacists today), while denying African Americans equal education or the ability to buy property in their neighborhoods.

If somehow a Black family bought a home, they were met by organized white attacks, and if that failed, whites would go to other white conclaves, in other faraway suburbs.

To this day there remains a major resources gap between mostly Black and white schools, making the battle for the desegregation of Detroit and other big city schools very much relevant.

President Donald Trump and his MAGA white supremacist allies seek to overturn all vestiges of the civil rights revolution and turn back the clock — not necessarily to legal segregation as it existed for most of the country’s 300-year history, but to the type of segregation that the North practiced.

This book tells an important story for all of us seeking justice and freedom.

Black Nationalism versus Integrationism

Adams explains that the central question debated in the 1960s and 1970s was how to move forward toward equal and quality education and community control in a city with a majority Black public school population.

Black nationalists who followed the ideology of Malcolm X (assassinated in 1965) demanded Black control of the schools with full resources. Malcolm’s followers were staunch supporters of Black Power and Black control in the community.

The prominent leader in Detroit in the 1960s was Albert Cleage, a minister and promoter of Black Christian Nationalism. He was also a founder of the Freedom Now Party that ran candidates for office.

The other side of the debate was the civil rights organization, the NAACP, which advocated full desegregation.

The NAACP led the fight in Detroit as it did around the country for integration. Its primary weapon was taking legal action based on the 14th Amendment, which stated that every citizen has the right to equal protection under the law.

Adams explains that Black Nationalists represented a minority viewpoint, even after the 1967 “race riots” where police caused 43 fatalities. Some 7000 National Guard and army troops were sent to Detroit. Armored vehicles rolled down the streets of the Black community.

That social rebellion was followed in 1968, after Martin Luther King, Jr. was assassinated in Memphis, sparking more rebellions across the country.

A special commission set up by President Johnson later that year, the Kerner Commission, concluded that “white racism” was responsible for the violence and said the United States is a divided country, one for whites and one for Blacks.

The Broken Promise of Brown

This was the background to the 1970s desegregation battle in Detroit, culminating in the 1974 Supreme Court that would strike a major blow to Brown.

Some called that decision a slow walk back to the infamous Plessey v. Ferguson 1896 decision that codified the white supremacist concept of “separate but [un]equal,” enabling legal segregation in various forms nationwide.

Michelle Adams asks:

“What does Brown v. Board of Education mean? Did Brown just ban the kind of ‘dual’ school systems that were once ubiquitous in the South: overtly racially segregated schools for whites and Blacks? Or did Brown stand for the proposition that, given the myriad harms of segregation, Americans of different races should be educated together rather than apart, even if it meant assigning students on the basis of race to accomplish that goal?” (Prologue)

The key word is in the title of her book, “Containment.” What does that mean?

Black people before the Civil War (1861-65), both those partially free in the North and those living in slavery, were seen as inferior human species. In the North and West, they lived under codes or laws that restricted their ability to live and be educated.

Michigan, however, was a proud anti-slavery state. It became an official state in 1830. But whites generally, including liberals, saw Blacks as less than them, no matter their education or abilities. The United States was a caste-based system — whites at the top, Blacks at the bottom.

Containment Reality

Detroit schools were segregated, although not by laws like those in the Jim Crow South that openly said “Whites only.” Instead, Michigan passed special real estate codes and land-ownership laws, and drew city and county lines to contain the Black communities.

Detroit, like virtually everywhere in the United States, operated on a neighborhood school model. And since Detroit’s neighborhoods were highly segregated in 1970— 99% white in some areas and 95% Black in others — its schools were, too.

Adams writes of the longstanding policy of containment: a system of government and private actions that kept the city’s Black residents confined (contained) to a handful of neighborhoods in Detroit and out of the suburbs altogether.

Methods of containment included racially restrictive covenants in housing deeds (no sales to Black people allowed), redlining (mortgages for Black home buyers only in certain areas), as well as segregated public housing and real estate associations.

I’ve seen similar covenants in home deeds in Sonoma County, California where I live, although none can be legally enforced.

White Flight

Adam also writes about “white flight” to the suburbs and their public schools. She says less about white flight to private and parochial schools — which often happened in Detroit and other northern cities before white families could afford to live in the suburbs.

She notes that white flight from Detroit began in the 1950s as Blacks from the South (The “Great Migrations”) continued moving to the city for auto and other jobs. The predominantly white city run by white politicians began to change its racial composition.

Detroit’s population in 1950 was 1.8 million. After deindustrialization, it has finally stabilized at just over 600,000.

Black Detroiters did not have that option to leave containment, since housing segregation in the suburbs essentially excluded Black home ownership. Black realtors were excluded from white realtors’ associations and never saw their property listings.

The Federal Housing Administration, set up in 1934, used redlining for home insurance, thus excluding Blacks from cheaper government-backed loans.

White Detroiters, middle income or working class, did not approve of Blacks moving into their neighborhoods and began to leave, even though all seats of political power were in white hands.

1970 Desegregation Lawsuit

The Containment follows the lawsuit filed in 1970 by the NAACP to integrate Detroit’s schools. The civil rights group eventually found an unlikely ally: the Citizens Committee for Better Education (CCBE).

The CCBE represented the already shrinking white population of the northern part of the city, an area bordered by the road known as Eight Mile. Adams refers to Eight Mile as the fence or wall between Detroit and suburbs.

The CCBE originally entered the case as an opponent of the NAACP. In time, however, CCBE became a partner of sorts, because its members — mostly working-class white families — began arguing to federal judge Stephen J. Roth that it was unfair to place the burden of integration exclusively on those white Detroiters who could not afford to move north of Eight Mile, while shielding their wealthier white neighbors in the suburbs.

Roth, a conservative Democrat and former state attorney general, ultimately saw the logic of the argument.

In June 1972, Judge Roth ordered a broad integration plan, which included such prosperous suburbs as Grosse Pointe and Bloomfield Hills in the same “metropolitan” school district as Detroit.

That is, he established a system of cross-district busing — quickly called “forced busing” by opponents— as the only way to desegregate quickly. New buses were bought to start the following school year.

Court’s Role in the Reversal

George Wallace, the segregationist Alabama governor, had ridden an antibusing platform to a smashing victory in the May 16, 1972 Michigan Democratic presidential primary.

Republican President Richard Nixon, running for re-election, had demanded “an immediate halt to all new busing orders by federal courts,” and his campaign responded to Roth’s ruling with a TV ad declaring: “President Nixon believes busing is wrong. And he intends to do something about it.”

Meanwhile, the state of Michigan appealed Roth’s order to the Supreme Court in a case called Milliken v. Bradley. (Milliken was the moderate Republican governor of Michigan. Bradley, represented by the NAACP, was a Black parent.)

What was called de facto segregation was actually de jure, the NAACP charged. In Jim Crow North, as Adams explains, residential segregation included laws preventing Black and Latino property ownerships in suburbs and even in parts of the city.

By 1974, Nixon had placed four new justices on the Supreme Court, who formed the core of the 5-to-4 majority that voted that July to overturn Roth’s metropolitan desegregation plan on the grounds that the Constitution compelled states to remedy only de jure, not de facto, segregation.

(Roth himself died of a heart attack at 66, just before the Supreme Court’s decision was announced.)

The U.S. Supreme Court has generally been the most conservative and reactionary institution of government. At moments it reacts to outside social pressures (e.g. civil rights and abortion rights) movements and approves change. But it can just as readily erode those changes.

In her summary, Adams writes that the court’s opinion was “grounded in white innocence. There was no acknowledgment of how Blacks were locked in specific Detroit neighborhoods and mostly Black schools, and then into an ever-expanding urban core that was hermetically sealed off from the suburbs.”

Author’s Background

Michelle Adams, born in 1963, did not attend Detroit public schools. Her better-off parents decided to send her to a private school (Roeper), in the white suburb of Bloomfield Hills where she, a Black girl, wouldn’t have been able to live in or attend public schools.

Her private school was run by Annemarie and George Roeper, liberal immigrants who fled Nazi Germany in 1938. She rode a bus every day to attend school.

Her father was a prominent Black lawyer, still rare, who moved his family to Palmer Woods, an historic community within Detroit that was made up of auto executives and other wealthy white residents.

She explains that her parents hired a white intermediary to buy the home and then transfer the property’s deed. No white realtor would sell the house if he knew the family was Black. Previous Black purchases in the city’s all-white areas had led racist mobs to attack the families.

Adams started private school at age four and never attended a Detroit public school. After graduating, she went to Brown University.

Her own history is relevant, as it shows how Black parents in Detroit, who could send their kids away from poor quality segregated Black inner-city schools, did so. The battle for integration is fundamentally about getting a decent and quality education.

Blacks in Detroit lived in a form of apartheid — worse schools, worse equipment, underpaid staff, and few chances to succeed. Most Black families favored integration, believing it would change their children’s financial futures.

Legacy of Failure

After the Supreme Court rejected District Judge Roth’s plan of metropolitan busing, a subsequent, much more modest plan by Roth’s successor, another federal judge, attempted to address segregation within Detroit. It affected just 10% of the students in the city’s school system and left many schools untouched. Adams observes that in this period, there was more successful court-ordered integration in the public schools of the South. Municipalities there tended to include the suburbs, while in the North suburban towns were often legally separate from the cities they abutted.

In the end, as Adams puts it, “Milliken was where the promise of Brown ended.” (Epilogue) In 2006 Chief Justice John Roberts put the court’s final nail in Brown with his ahistorical and false claim: “The way to stop discrimination on the basis of race is to stop discriminating on the basis of race.”

But as Martin Luther King had explained in the 1960s, it is not enough to change the laws to end segregation without affirmative action plans to allow African Americans to catch up.

Full Speed Backward

The current Roberts court later overturned affirmative action programs in higher education. Trump seeks a total ban with his attacks on “reverse discrimination” and campaign against “wokism” in the corporate world.

Race and racism are at the heart of the so-called “American experiment” and “exceptionalism.” It is hypocritical to suggest otherwise, as Roberts and his majority have done for the past two decades — gutting voting rights, affirmative action and abortion rights, and giving the imperial presidency of Donald Trump expanded impunity.

In conclusion, Adams recognizes that there is a long history in the Black community, including in Detroit, of some hostility to integration, given the reality of racist white backlash.

There are other ways to achieve Black self-sufficiency. One way is to achieve Black excellence in all matters, including in education. This does not necessarily require the presence of whites. It requires self-determination with real resources and powers as Black nationalists have argued.

More Black elected officials — including mayors (Coleman Young was Detroit’s first Black mayor in 1974), president (Barack Obama the first Black president in 2008) and Black representation in the corporate world and on Wall Street — haven’t changed anything yet.

The Containment shows how race and racism remain central to white attitudes and capitalist state rule.

Here is a short update on the state of the Detroit public schools today.

July-August 2026, ATC 237