What were the issues in the case of Lau v. Nichols?

Answer 1

Lau v. Nichols, 414 US 563 (1974)

As a result of the US Supreme Court case Lee v. Johnson,404 US 1215 (1971), the California State school system was ordered to integrate non-English-speaking Chinese students into regular schools to correct patterns of de jure (legal) segregation. Brown v. Board of Education, (1954), was intended to protect the constitutional rights of all students, regardless of race or national origin.

Despite the state's mandated integration policy, the San Francisco Unified School District (SFUSD) failed to provide sufficient English language instruction to approximately 1,800 of its 2,856 Chinese-American students. Lau v. Nichols, (1974) was a class action suit brought against the SFUSD, seeking relief on the grounds that the District was guilty of violating the students' Fourteenth Amendment right to Equal Protection.

The federal District Court refused to order SFUSD to accommodate the children's educational needs, and the Circuit Court affirmed this ruling, alleging that neither the Constitution nor the Civil Rights Act of 1964 was being violated, reasoning that "[e]very student brings to the starting line of his educational career different advantages and disadvantages caused in part by social, economic and cultural background, created and continued completely apart from any contribution of the school system..."

US Supreme Court Decision

Justice William O. Douglas delivered the unanimous opinion of the Court, which held in Lau's and the other Chinese-speaking students' favor.

According to the Court, the SFUSD was a public school system bound by the rules of the California Educational Code, which stated in § 71 "English shall be the basic language of instruction in all schools," but permits the individual school districts to determine when bilingual instruction is appropriate. This section all states that, "the policy of the state is to insure the mastery of English by all pupils in the schools."

The California Educational Code also provides (§ 8573) that no student may receive a diploma or graduate who has not met the standards of proficiency in English, and (§ 12101, Supplement 1973) requires children ages 6-16 to receive "compulsory full-time education."

Under the state-imposed standards, simply providing the students with the same facilities, teachers and supplies is inadequate to meet their educational needs.

The Court further determined that, although applicable, there was no need to explicate the protection of the Fourteenth Amendment, because § 601 of the Civil Rights Act of 1964 (42 USC § 2000d), which bans discrimination on the basis of "race, color or national origin...in any program or activity receiving Federal financial assistance," was sufficient to ensure all students receive the educational services needed to meet the state's goals.

The San Francisco Unified School District was contractually bound to comply with Title VI of the Civil Rights Act of 1964 and all requirements imposed by the HEW (Department of Health, Education and Welfare; educational policy is now handled by the United States Department of Education), as well as California's educational statutes.

In conclusion, Justice Douglas wrote, "Simple justice requires that public funds, to which all taxpayers of all races contribute, not be spent in any fashion which encourages, entrenches, subsidizes, or results in racial discrimination."

The decision of the Court of Appeals was reversed, and the case remanded for proper relief.