Brown v. Board of Education was conceived in a rime of judicial activi
sm and a demographic context that reflected two nations, one white and
one black. Forty years after Brown, the legal climate and the demogra
phic composition of the United States are quite different. The 1990s a
re judicially conservative and the cities in particular are more diver
se demographically. The intersection of a restrained court and fundame
ntal demographic shifts has changed the agenda and raised issues of ho
w to proceed toward the continuing objective of societal integration.
Recent court decisions about unitary status and the return to local co
ntrol have directed attention to the clash between spatial demographic
change and legal intervention. Geography and demography have modified
the effect of Brown and the potential for future judicial interventio
n in school systems. Whatever our ideological perspective, the interse
ction of geography and demography, and individual responses to legal a
ction, clearly have limited the possibilities of change through legal
intervention.