Between the landmark Brown v. Board of Education decision in 1954 and Supreme Court decisions in 1991 and 1992, civil rights laws and policies, especially those affecting schools, have undergone dramatic transformations and fluctuations. After the elegantly straightforward but unprecedented principles propounded in Brown, which have not been seriously challenged in their application to schools, the Court entered what might be called the conceptual swamp of remedy. In a series of major school desegregation decisions during the 1970s, the Supreme Court grappled with a host of complex legal issues involving the definition of desegregation, the nature of remedies, the obligations of school districts, and the remedial powers of the lower courts. The period was marked by divided Supreme Court panels; conflict among numerous lower courts; intense debate among political groups, legal scholars, and social scientists; and heated controversy—and sometimes violence—in affected communities. These battles and disputes were not over the basic principles of Brown but over how school segregation should be remedied. In view of the difficult and often emotional questions involved, it is not surprising that the evolution of school desegregation law has followed a tortuous and convoluted path. Given the basic constitutional principle of nonracial classifications promulgated by Brown and related cases, there was little indication that the principle would be turned on its head in 1968 by Green v. New Kent County and the concept of affirmative integration and, even more explicitly, by the 1971 decision in Swann v. Charlotte-Mecklenburg Board of Education, which fostered policies of racial balance and racial quotas—in effect, a race-conscious policy of forced integration. In 1973 many people were surprised, if not shocked, when the Supreme Court applied the Swann concepts of mandatory busing and racial balance to northern school systems, most of which never had the statemandated “dual” school systems of the South (Keyes v. Denver). Then, when mandatory busing appeared likely to become commonplace and permanent throughout the country, the 1974 decision in Milliken v. Bradley severely restricted remedies by excluding the white suburbs surrounding the predominantly black Detroit schools.