In Swann v. Charlotte-Mecklenburg Board of Education the Supreme Court suggested, by negative implication, that a court supervising the desegregation of a school district can require school officials to eliminate resegregation caused solely by natural demographic changes if school officials have not yet achieved a unitary system. The Court's holding in Pasadena City Board of Education v. Spangler, however, demonstrates that the Court did not intend this negative implication. Under Spangler, once school officials have eliminated state-imposed segregation from student assignment, the supervising court cannot require school officials to redraw attendance zones to eliminate non-state imposed resegregation even though the school district's transition from a dual to a unitary system is incomplete. Although Spangler is constitutionally justifiable, the decision is unsound because it did not require school officials to prove that the resegregation was not state-imposed.
Ellen Bowman Welsch, Case Comment: Desegregating a Demographically Changing School District--Pasadena City Board of Education v. Spangler, 1 SEATTLE U. L. REV. 212 (1977).