Prof. Myron Orfield's UCLA Law Review Article Cited by Chief Justice Natalie Hudson '82 in Minnesota Supreme Court Case Cruz-Guzman vs. State of Minnesota 

In a landmark state civil rights decision, the Minnesota Supreme Court has decided that if racial segregation causes educational inadequacy, it is sufficient to establish a violation of the state constitution. Its deliberations relied in part on University of Minnesota Law School research.

In Cruz-Guzman v. State of Minnesota, several parents seek the racial desegregation of Minnesota K-12 schools, arguing that existing segregation violates the state constitution's Education Clause. The case has been ongoing for eight years and was previously heard by the state Supreme Court in 2018, where the parents prevailed in establishing the justiciability of their claims. The case has led to years of negotiations between state representatives and plaintiffs, attempting to find a settlement plan. Those negotiations relied heavily on research by the Law School's Institute on Metropolitan Opportunity.

In 2023, the case returned to the Supreme Court. In a decision released on Dec. 13, the state Supreme Court agreed with the parents on several core issues, particularly that de facto segregation may violate the state constitution without having been caused by state policy. The court also held that the parental plaintiffs must show that de facto racial segregation was a "substantial factor" in causing student's inadequate education. Chief Justice Hudson wrote in dissent, arguing that the court should adopt a stricter standard in which de facto racial segregation is forbidden by the state constitution regardless of its effect on educational adequacy.

Professor Myron Orfield submitted an amicus brief in the case, arguing that violations of the state Education Clause should require neither a showing of intent nor causation by state policy. The court ultimately agreed on both counts. In addition, Professor Orfield's article Milliken, Meredith, and Metropolitan Segregation, 62 UCLA L. Rev. 364, 430–31 (2015), was cited by Chief Justice Hudson '82.

Myron Orfield

Myron Orfield

Earl R. Larson Professor of Civil Rights and Civil Liberties Law
Director, Institute on Metropolitan Opportunity