Rachel D. Godsil, Linda R. Tropp, and Kim Forde-Mazrui
We deal here with the right of all of our children,
whatever their race, to an equal start in life and to an
equal opportunity to reach their full potential as citizens.
–Justice Thurgood Marshall, dissenting, Milliken v. Bradley (1974), p.783.
Introduction
Justice Thurgood Marshall was convinced that, for all children to be “our” children, it would require people to engage meaningfully across racial lines and other lines of difference. In his dissent in Milliken v. Bradley, he lamented:
Those children who have been denied that right in the past deserve better than to see fences thrown up to deny them that right in the future. Our Nation, I fear, will be ill-served by the Court’s refusal to remedy separate and unequal education, for unless our children begin to learn together, there is little hope that our people will ever learn to live together. (Milliken, 1974, p.783)
The vision of our children—where all children in this country would have the freedom to thrive and reach their potential regardless of racial background—still feels far away in 2024, seventy years after Brown and fifty years after Milliken.
Our goal in this commentary is to share research from the social sciences and legal scholarship that supports Justice Marshall’s conviction that genuine cross-group engagement is a critical step for people across race (and other group-based identities) to hold each other in a shared circle of concern and do the work that will create equal opportunities for all to reach their full potential. We describe the mixed legacy of school integration efforts after Brown to achieve the cross-racial community that Marshall envisioned. We also explain and endorse Michelle Adams’ conception of “radical integration” as a goal for fulfilling Marshall’s aspiration. Finally, we highlight empirical research supporting the notion that integrating schools, under conditions of inclusion, cooperation, and respect, would facilitate the kinds of cross-racial understandings and relationships to which Marshall aspired.
I. Brown’s Mixed Legacy and Adams’ Vision of “Radical Integration”
We are mindful that our support for integration is contested. Indeed, legal scholarship focusing on interracial contact has been fraught in light of the complex trajectory of Brown and its implementation. Most powerfully and iconically argued by Derrick Bell (1976) beginning in the mid-1970s, shortly after Milliken, the question of whether educational integration genuinely serves the interests of students of color continues to be explored (e.g., Huq, 2021; Johnson, 1993). Relatedly, the harms of gentrification have drawn attention to the issue of whether residential integration benefits people of color or whether, instead, communities of color are better served by equitable—rather than integrated—access to resources and by in-group solidarity (e.g., Johnson, 2019).
Michelle Adams (2006) named the inadequacy and limitations associated with the traditional integration approach while setting forth an alternative: radical integration. She argues that the original challenges to segregation were focused on the eradication of white supremacy and that the goal of integration without that structural underpinning is deeply inadequate. The inadequacy is manifested in how integration came to be interpreted: “[i]ntegration today is synonymous with ‘assimilation,’” the process whereby “a minority group gradually adopts the customs and attitudes of the prevailing culture.” (Adams, 2006, p. 264). When integration is understood as “assimilation,” it is accompanied by an unacceptable identity sacrifice as well as a failure to address related structural inequities (Adams, 2006). Adams’ “radical integration” would recognize the need for authentic chosen identity formation and expression, rather than the felt need to assimilate into a dominant culture; moreover, “radical integration” would demand actual and tangible enfranchisement in social, economic, and political domains of American life (Adams, 2006). The social science evidence to which we refer in the paragraphs that follow is useful for considering whether Adams’ perspective on radical integration is possible and what steps are necessary to work toward this articulation of Marshall’s original vision.
During the time that Brown and Milliken were decided, white ethnics in the U.S.—like Irish, Polish, and Italian Americans—were being absorbed more firmly into the broader category of “white” Americans as the federal government subsidized their move to the suburbs (Godsil & Waldeck, 2021). Though not without encountering resistance and varied forms of exclusion and discrimination along the way with each generation, these groups became more assimilated into a dominant vision of whiteness while losing aspects of their distinct ethnic heritages and cultural identities. This transition became a form of “racial agency” for those who were seeking white spaces, and it was achieved with direct support from the federal government, along with state and local governments through zoning and other land use policies (Godsil & Waldeck, 2021). This agency and financial prosperity made available to white families were denied to Black families (Rothstein, 2017). The divide between “white” people and “people of color” became more stark, as did residential segregation.
Decades after the de jure actions to create white spaces, the generational consequences of residential segregation are enormous and include material benefits (such as inherited wealth and access to economic opportunities) as well as differences in racial status. The conventional presumption is that white families earned their heightened wealth and economic advancement solely of their own volition (see Kinder & Sanders, 1996); although persistence and hard work no doubt played a role in the growing prosperity of many white families, conferral of the original federal benefit to white families—the subsidization of housing in the suburbs—is often ignored. And when such historical conditions remain unacknowledged, the more challenging it is for white people to recognize how race has shaped their own and others’ experiences, or to challenge the belief that meritocratic systems determine life outcomes (Knowles & Lowery, 2012).
Not surprisingly, then, a powerful barrier to addressing and dismantling racial status hierarchies is whites’ disbelief or skepticism that such hierarchies even exist (Knowles et al., 2014; Wilkins & Kaiser, 2014). Further differences in the perspectives of white people and people of color can grow from different reference points in assessing progress: white people in the United States tend to perceive more racial progress than people of color and are far more apt to anchor their assessment of racial progress in how far the U.S. has come relative to the past (Brodish et al., 2008). Additional scholarship has linked these perceptual differences about racial progress to white Americans’ attitudes toward affirmative action (DeBell, 2017) as well as their decisions about how best to combat racial inequality (Kraus et al., 2019).
We are now in an era in which the Supreme Court has prevented the use of race in higher education admissions (SFFA v. Harvard, 2023) and states are enacting laws to prevent efforts to promote diversity, equity, and inclusion and to teach about the history of race and racism in the United States. At the local level, new school systems have been breaking off from larger school districts, “seceding” so that “their” tax dollars go to teach “their” children, instead of treating “all” children as our own (Taylor, Frankenberg, Siegel-Hawley, 2019). The phenomenon has been led by predominantly white schools and has increased racial segregation. The research suggests two distinct reasons for the hostility that many white people are expressing in response to efforts explicitly designed to inform the public about our nation’s history and to increase access to opportunities for people of color. The first is that those with higher status—like white people in the United States—fear losing that status, particularly when demographic shifts suggest they will not be in the numerical majority for much longer (Craig & Richeson, 2014). For many white people in the U.S., the prospect of losing status can trigger efforts to preserve their own privileged position (Knowles et al., 2014; Tropp & Barlow, 2018). A second reason is the fear of being left out, or being left behind, in a changing world—a motivation that is distinct from the desire to maintain privilege (see Barsa et al., 2022 for a review). This fear is rooted in the fundamental human need to belong (see Baumeister & Leary, 1995), such that people are highly attuned to what may be perceived as signals of potential exclusion or rejection (Plaut et al. 2011).
II. The Promise of Intergroup Contact Through Structured Integration
For those who may be activated by the fear of exclusion or rejection, the pursuit of meaningful contact with people from other groups and backgrounds can serve as a powerful counterforce. Cross-group interaction normalizes the experience of diversity in society (Jones & Dovidio, 2018) and offers a way to expand our vision of the “we” to include people of varying racial and other group identities (Dovidio et al., 2009). We recognize that, at first glance, this description appears to do little to challenge the status quo, thereby maintaining hierarchies of power and privilege as they currently stand. However, our aim is quite the opposite, seeking instead to identify how realistically to support the conditions that are required for Adams’ radical integration to be achieved.
Along with other scholars, we contend that intergroup contact—that is, meaningful contact and engagement between members of different groups—can lead to a recognition of our shared humanity and transform how people in diverse societies relate to each other. A robust body of research supports that greater contact between groups can reduce prejudice and promote more positive intergroup attitudes. Such effects are especially likely to emerge when people from different groups interact with each other as equals while engaging in cooperative, interdependent activities toward the pursuit of common goals (Pettigrew & Tropp, 2006). The intergroup contact research literature offers converging evidence across a range of studies, including experimental, longitudinal, and meta-analytic research (see Pettigrew & Tropp, 2011). Importantly, studies indicate that prejudice reduction typically generalizes beyond the specific group members who interact with one another, and greater levels of contact at a societal level can motivate broader attitude change (Christ et al., 2014). Beyond fostering positive attitudes between groups, intergroup contact carries the potential to encourage people—and particularly members of historically advantaged groups—to reappraise the position of their own group (Verkuyten, Voci, & Pettigrew, 2022) and to become more supportive of and involved in efforts to promote social change (Hässler et al., 2020; Tropp & Barlow, 2018).
In line with this scholarship from the field of psychology, subsequent research inside and outside of legal academia suggests that racial integration constitutes a powerful means to important social justice ends. Consider, for example, policing and education. The relationship between police reform and residential integration is based on the current correlation of residential segregation with police violence (Bell, 2020). Monica Bell (2020) argues that residential segregation both contributes to and is a consequence of harmful forms of policing. This conclusion is based in part on a study of cities with over 100,000 residents. That study found that the most powerful differentiating variable between cities with higher levels of substantiated claims of police brutality was the level of racial segregation of Black residents (Smith & Holmes, 2014). In the context of educational reform, the social science literature relied upon by legal academics (including one of the authors of this commentary) argues for a research-based focus on educational integration as a means to improving education for all students (e.g., Johnson, 2019; Godsil, 2019; Orfield, 2015). Integrated educational and residential settings provide promising opportunities for sustained and meaningful intergroup contact (Godsil, 2019) that can prepare people to live and thrive in a multiracial society (Tropp & Saxena, 2018), and can, in turn, lead to political action to reduce injustice through further integration of society and its institutions (Godsil, Forde-Mazrui, & Tropp, in press).
Conclusion
Justice Marshall articulated the vision of a society in which we see all children as “our” children, such that we care about the welfare of all children, rather than constricting our circle of concern to include only those from our own racial backgrounds. The ideal of integration articulated by the Court in Brown and in the powerful dissents in Milliken continues to be an imperative for this country to move beyond the devastating forms of polarization and hoarding of opportunities and resources that endanger our democracy.
Rachel D. Godsil (rg861@law.rutgers.edu) is Professor of Law at Rutgers Law School, Co-Founder of Perception Institute, and a PRRAC Board member.
Linda R. Tropp (tropp@umass.edu) is Professor of Social Psychology and Faculty Associate in Public Policy at the University of Massachusetts Amherst, and an NCSD Research Advisory Panel member.
Kim Forde-Mazrui (kfm@law.virginia.edu) is Professor of Law at the University of Virginia School of Law.
References
Adams, M. (2006). Radical integration. California Law Review, 94(2), 261-311.
Barsa, M., Dehrone, T. A., Khedari, V., Landry, A., Pasek, M. H., Phillips, T., Ramsey, J., & Tropp, L. R., (2022). Renewing American Democracy: Navigating A Changing Nation. Beyond Conflict. Retrieved from: https://beyondconflictint.org/wp-content/uploads/2022/05/Renewing-American-Democracy-Navigating-A-Changing-Nation-Beyond-Conflict.pdf
Baumeister, R. F., & Leary, M. R. (1995). The need to belong: Desire for interpersonal attachments as a fundamental human motivation. Psychological Bulletin, 117(3), 497–529.
Bell, D. A. (1976). Serving two masters: Integration ideals and client interests in school desegregation litigation. Yale Law Journal, 85(4), 470-516.
Bell, M. C. (2020). Anti-segregation policing. New York University Law Review, 95(3), 650-765.
Brodish, A. B., Brazy, P. C., & Devine, P. G. (2008). More eyes on the prize: Variability in white Americans’ perceptions of progress toward racial equality. Personality and Social Psychology Bulletin, 34(4), 513–527.
Christ, O., Schmid, K., Lolliot, S., Swart, H., Stolle, D., Tausch, N., … & Hewstone, M. (2014). Contextual effect of positive intergroup contact on outgroup prejudice. Proceedings of the National Academy of Sciences, 111(11), 3996-4000.
Craig, M. A., & Richeson, J. A. (2014). On the precipice of a “majority-minority” America: Perceived status threat from the racial demographic shift affects white Americans’ political ideology. Psychological Science, 25(6), 1189-1197.
Dovidio, J. F., Gaertner, S. L., & Saguy, T. (2009). Commonality and the complexity of “we”: Social attitudes and social change. Personality and Social Psychology Review, 13(1), 3-20.
DeBell, M. (2017). Polarized opinions on racial progress and inequality: Measurement and application to affirmative action preferences. Political Psychology, 38(3), 481-498.
Godsil, R. D. (2019). Rigor and relationships: The positive case for integration in schools and neighborhoods. Cardozo Law Review, 40(3), 1287-1326.
Godsil, R. D., Forde-Mazrui, K., & Tropp, L. R. (2024). Overcoming identity-based hierarchies: Understanding psychological barriers and motivating social justice through intergroup contact. In R. Hollander-Blumoff (Ed.), Research Handbook on Law and Psychology. Edward Elgar Publishing.
Godsil, R. D., & Waldeck, S. E. (2021). The new tipping point: Disruptive politics and habituating equality, Emory Law Journal, 70, 1507-1533.
Hässler, T., Ullrich, J., Bernardino, M., Shnabel, N., Van Laar, C., Valdenegro, D., Sebben, S., Tropp, L. R., Visintin, E. P., González, R., Ditlmann, R. K., Abrams, D., Selvanathan, H. P., Brankovic, M., Wright, S., von Zimmerman, J., Pasek, M., Aydin, A. L., Zezelj,I . . . Ugarte, L. M. (2020). A large-scale test of the link between intergroup contact and support for social change. Nature Human Behavior, 4, 380-386.
Huq, A. Z. (2021). As Brown has waned. University of Chicago Law Review, 88(7), 1659-1676.
Johnson, A. M. (1993). Bid Whist, Tonk, and United States v. Fordice: Why integrationism fails African-Americans again. California Law Review, 81(6), 1401-1470.
Johnson, O. (2019). Choice and gentrification. In I. Ellen and J. Steil (Eds.), The dream revisited: Contemporary debates about housing, segregation, and opportunity (pp. 329-330). Columbia University Press.
Jones, J. M., & Dovidio, J. F. (2018). Change, challenge, and prospects for a diversity paradigm in social psychology. Social Issues and Policy Review, 12(1), 7-56.
Kinder, D. R., & Sanders, L. M. (1996). Divided by color: Racial politics and democratic ideals. University of Chicago Press.
Knowles, E. D., & Lowery, B. S. (2012). Meritocracy, self-concerns, and whites’ denial of racial inequity. Self and Identity, 11(2), 202–222.
Knowles, E. D., Lowery, B. S., Chow, R. M., & Unzueta, M. M. (2014). Deny, distance, or dismantle? How White Americans manage a privileged identity. Psychological Science, 9(6), 594-609. https://doi.org/10.1177/1745691614554658
Kraus, M. W., Onyeador, I. N., Daumeyer, N. M., Rucker, J. M., & Richeson, J. A. (2019). The misperception of racial economic equality. Perspectives on Psychological Science, 14(6), 899-921. https://doi.org/10.1177/1745691619863049
Milliken v. Bradley, 418 U.S. 717 (1974) (Marshall, J., dissenting).
Orfield, M. (2015). Milliken, Meredith, and metropolitan segregation. UCLA Law Review, 62(2), 363-462.
Pettigrew, T. F., & Tropp, L. R. (2006). A meta-analytic test of intergroup contact theory. Journal of Personality and Social Psychology, 90(5), 751–783.
Pettigrew, T. F., & Tropp, L. R. (2011). When groups meet: The dynamics of intergroup contact. Psychology Press.
Plaut, V. C., Garnett, F. G., Buffardi, L. E., & Sanchez-Burks, J. (2011). “What about me?”: Perceptions of exclusion and whites’ reactions to multiculturalism. Journal of Personality and Social Psychology, 101(2), 337-353.
Rothstein, R. (2017). The color of law: A forgotten history of how our government segregated America. Liveright.
Smith, B. W., & Holmes, M. D. (2014). Police use of excessive force in minority communities: A test of the minority threat, place, and community accountability hypotheses. Social Problems, 61(1), 83-104.
Students for Fair Admissions, Inc. v. President & Fellows of Harvard College, 143 S. Ct. 2141 (2023).
Taylor, K., Frankenberg, E., & Siegel-Hawley, G. (2019). Racial segregation in the Southern schools, school districts, and counties where districts have seceded. AERA Open, 5(3), 1-16.
Tropp, L. R., & Barlow, F. K. (2018). Making advantaged racial groups care about inequality: Intergroup contact as a route to psychological investment. Current Directions in Psychological Science, 27(3), 194–199.
Tropp, L. R., & Saxena, S. (2018). Re-weaving the social fabric through integrated schools: How intergroup contact prepares youth to thrive in a multiracial society. National Coalition on School Diversity. Retrieved from: https://school-diversity.org/wp-content/uploads/2018/05/NCSD_Brief13.pdf
Verkuyten, M., Voci, A., & Pettigrew, T. F. (2022). Deprovincialization: Its importance for plural societies. Social Issues and Policy Review, 16(1), 289–309.
Wilkins, C. L., & Kaiser, C. R. (2014). Racial progress as threat to the status hierarchy: Implications for perceptions of anti-White bias. Psychological science, 25(2), 439-446.
