Northern officials achieved segregation through surface-neutral tools like attendance-zone gerrymandering

Evidence

Some Northern districts did pursue blatantly segregationist policies. In Dayton, Ohio, for example, African American teachers were forbidden to teach white students. But in most cases, Northern school officials had contrived to promote racial segregation through undramatic and, on the surface, race-neutral policy choices. In Denver, for example, the school board gerrymandered school attendance zones to maintain racially homogeneous schools and set up mobile classrooms at black schools rather than transfer the overflow of students to underutilized white schools. — G. Alan Tarr, Judicial Process and Judicial…, 3018

Categorization

• XREF: Denver’s gerrymandered zones and unequal portable classrooms are the evidentiary core of the Keyes de jure finding, connecting doctrine to concrete facts. — connects to: Gerrymandering converts transient majorities into durable control without added votes — Daryl Levinson and Benjamin I. Sachs, Political Entrenchment and Public Law, 89; Entrenched incumbents resist redistricting even as the same tools oppress others — Daryl Levinson and Benjamin I. Sachs, Political Entrenchment and Public Law, 89