Milliken v. Bradley is the great counterfactual of desegregation. If the Supreme Court had upheld Detroit's metropolitan-wide busing remedy in 1974, would courts have been able to successfully integrate students across district lines or would that have prompted even greater white flight and stronger political backlash? Milliken then raises fundamental questions about judicial policymaking and can be viewed as either a betrayal of Brown v. Board of Education or a prudent recognition of the limits of judicial power. Milliken's causes, development, and consequences are the subject of Joyce Baugh's engaging history. And implicitly, the effects of Milliken, which they single out for blame, are the subject of Erica Frankenberg and Gary Orfield's provocative edited volume.

The Detroit School Busing Case will surely be considered the definitive treatment of Milliken. Eleanor Wolf's Trial and Error (1981) offered a careful critique of the social science evidence relied on by the trial judge, Stephen Roth. But Baugh offers a more comprehensive history, helpfully situating the case within broader political and social changes. Using a range of sources including court records, papers of Supreme Court justices, contemporaneous journalism, and her own interviews with case participants, she presents an analysis of the case that will be of interest to students of Civil Rights, urban politics, and American political development. She first covers the history of Jim Crow and the “Great Migration” of southern blacks to the North in the early and mid-twentieth century, recounting how it transformed the urban landscape of industrial midwestern cities. Due to private preferences and publicly sanctioned redlining, block busting, steering, and restrictive covenants, this migration created large patterns of residential segregation.

The core of Baugh's book focuses on how the legal dispute over desegregation developed in Detroit and made its way through the courts. In the 1960s, proponents of integration battled with supporters of community-controlled schools. A mild integration plan, passed in 1969, sparked outrage in Detroit and in the state capital, leading voters to recall the plan's supporters on the school board and the state legislature to restructure the school board and rescind the plan. As a result, the NAACP sued the state and the school district.

Despite the case's labyrinthine complexities, Baugh deftly navigates through its development and the transformation of Judge Roth. Like many judges in major desegregation cases, Roth, who was considered a conservative Democrat, seemed an unlikely candidate for issuing the nation's most aggressive and far-reaching remedial decree. But after two years and being ordered by the Sixth Circuit to reach broader questions of segregation, he ruled that de jure segregation had occurred in Detroit and, more importantly, that he could not order a Detroit-only remedy.

At this point, Baugh could have done more to emphasize just how strange the case had become. Because the school district and the plaintiffs both desired a metropolitan-wide remedy, the litigation was, for all meaningful purposes, collusive. As well, Roth refused to allow the suburban school districts to present evidence rebutting the plaintiff's testimony, even though he was compelling them to participate in the remedy. Roth himself, as Wolfe showed in Trial and Error, misunderstood some of the basic findings of the Coleman Report. Regardless of how well intentioned, judicial restructuring of an entire metropolitan area's educational system based on misunderstood evidence seems like a rather odd way of making public policy.

Before the metropolitan-wide remedy could take effect, the Supreme Court intervened. Nicely nesting the case in its broader political and legal context, Baugh shows how the 5–4 split decision was not as reflective of emerging divisions on the Court as it might appear. Instead, the divisions were already there, and the Court had barely been able to mask them in superficially unanimous decisions such as Swann v. Charlotte-Mecklenberg.

Baugh concludes with an analysis of the effects of the Supreme Court's decision. This part of The Detroit School Busing Case is the least compelling. While admitting that “it is difficult to determine with precision the impact of Milliken,” the author nevertheless contends that “it is widely accepted that the decision has had a major effect in hindering efforts to desegregate urban schools and to provide a quality education for students of color” (p. 194). Her own analysis, however, raises questions about whether Milliken really changed the trajectory of desegregation.

With George Wallace winning in the Michigan Democratic presidential primary in 1972, Congress forbidding busing by statute, and Boston experiencing antibusing riots, with substantial majorities of both black and white parents opposing busing, it is hard to see how remedies such as Judge Roth's would have had much of a future even if the Court had upheld them. As Donald Horowitz, Gerald Rosenberg, Shep Melnick, and other judicial policymaking scholars have shown, courts face substantial internal and external constraints when trying to shape public policy and their remedies; when actually implemented, both often fail to achieve their goals and generate damaging unintended consequences. Milliken also did not prevent courts from ordering substantial remedies and, in fact, shifted the focus of courts to compensatory educational programs, including those approved in Milliken II and most dramatically in Missouri v. Jenkins. But more importantly, it is not clear that Milliken directly led to substantial segregation or “resegregation” across metropolitan areas, the subject of Frankenberg and Orfield's volume.

The Resegregation of Suburban Schools has much that is of value to students of education. It is hampered, however, by one fundamental problem, its title. The phenomenon it discusses does not seem to resemble what we would normally call resegregation. More accurately, and less alarmingly, the authors are describing demographic change. In fact, many of the contributors, including the coeditors in Chapter 1, often use “demographic change” or “racial transformation,” rather than “resegregation.” Most of the book is devoted to detailed case studies of suburban school districts from seven metropolitan areas: Atlanta, Boston, Chicago, Los Angeles, Minneapolis, San Antonio, and southern Florida. The contributors interviewed leading educational, community, and political elites from each area to determine how their communities were responding to demographic change.

The first two chapters try to establish the importance and existence of resegregation. Chapter 1, “Why Racial Change in the Suburbs Matters,” coauthored by Frankenberg and Orfield, argues that demographic trends in the suburbs, including racial transformation and increasing poverty, have received insufficient attention from scholars and policymakers. Chapter 2, “Understanding School District Transformation,” written by Frankenberg, uses cluster analysis to lay out a useful typology of six different kinds of suburban school districts based on racial and economic characteristics. The suburbs, as she shows, are not monolithic.

Frankenberg also attempts to show that the demographic changes in the suburbs have led to increased segregation. To measure segregation, she uses a dissimilarity index between suburban districts in major metropolitan areas and the percentage of students in 90%–100% minority schools. Both measures are problematic. Her dissimilarity index only reports levels of dissimilarity from 2006–7, but to establish that segregation is increasing, changes over time are necessary. She does note that some areas with the highest levels of dissimilarity in 1990 have experienced decline since then. This is consistent with several studies using more sophisticated measures that have found that segregation has decreased since 1990 (David M. Frankel and Oscar Volij, “Measuring School Segregation,” Journal of Economic Theory 146 [2011]: 1–38; Kori J. Straub and Merideth P. Richards, “From Resegregation to Reintegration: Trends in the Racial/Ethnic Segregation of Metropolitan Public Schools, 1993–2009,” American Educational Research Journal 20 [2013]: 1–35; John Logan, “Resegregation in American Public Schools? Not in the 1990s” [2004], report by the State University of New York, Lewis Mumford Center for Comparative Urban and Regional Research). Frankenberg does show that the percentage of students in all six of her clusters attending 90%–100% minority schools has risen and that the percentage of white students has declined since 2000. But measures of isolation, such as this one, are notoriously sensitive to demographic shifts. The observed changes are largely due to an increase in the number of minority, particularly Hispanic, students, not because white students shifted to more majority-white schools or because white and minority students have separated. As Frankel and Volij show, ethnic groups have actually become “more similarly distributed across schools” over the past two decades but that ethnic diversity “has grown significantly” (p. 16).

The case studies follow the same general pattern, with a discussion of the general features of the school district followed by an analysis of how the district has changed demographically and by the districts' responses to those changes. For those interested in educational politics and policy, these chapters provide useful analyses of a variety of school districts struggling with a range of issues along with racial change, including increased emphasis on high-stakes testing; competing and contradictory local, state, and national mandates; lingering achievement gaps; reduced funding; and growing numbers of lower-income students. Even though the authors all wish that the districts they studied would do more to deal with demographic change, a compelling portrait still emerges of school districts balancing competing pressures and interests. For instance, Elizabeth DeBray and Ain Groom's fascinating study of an unidentified school district in the outer suburbs of Atlanta reveals a district successfully managing significant racial change. Because of collaboration among the school district, Civil Rights groups, and business organizations, the community has largely avoided racial antagonisms. In fact, many of the case studies indicate that economic sorting of students is becoming a more significant issue than race.

The volume concludes with a chapter by Orfield praising the school districts they studied for creating “small positive initiatives” (p. 217), but lamenting that they were not more attuned to “the destructive process of resegregration” (p. 223). He particularly chides “middle-class nonwhite movers to suburbia” for being in “deep denial about the necessity of focusing on issues of race” (p. 228). However, since increasing ethnic diversity is not the same thing as resegregation, this volume can be read as telling a more encouraging story. It is one where school officials, civic leaders, and parents are responding capably, if not perfectly, to their own experiences and to shifting social, political, and economic conditions.

Taken together, both books reveal the significant transformations that have occurred in America's schools over the last 50 years. But they also show the limitations that policymakers face when trying to change them. Baugh's book exposes the institutional and political headwinds confronting those who want to leverage judicial decisions into meaningful educational change. And Orfield's concluding proposals, such as encouraging cooperation among Civil Rights organizations and school districts or merging metropolitan and suburban districts, seem either unhelpfully vague or politically problematic given the edited volume's bleak diagnosis. Fortunately, there are good reasons to think that things are not quite so dire.