In the 1969 case of Carter et al. v. West Feliciana Parish School Board et al., the U.S Supreme Court dealt with issues related to racial segregation in public schools, specifically focusing on "freedom-of-choice" plans as a means of desegregation. The court ruled that such plans were not sufficient if they failed to achieve actual desegregation and eliminate racially identifiable schools. In this particular case, black students constituted more than two-thirds of total enrollment but attended separate schools under a freedom-of-choice plan implemented by the school district in Louisiana's West Feliciana Parish. The Supreme Court held that federal courts have an affirmative duty to ensure compliance with Brown v. Board of Education and must order immediate implementation of effective remedial measures for eliminating segregation where it exists.

In the dissenting opinion for Carter et al. v. West Feliciana Parish School Board et al., Justice Hugo Black argued that the Court was overstepping its authority by imposing a specific timeline on desegregation efforts in public schools, which he believed should be left to local authorities and lower courts to decide. He expressed concern about potential backlash from communities resistant to change and worried that such mandates could lead to more harm than good in achieving racial equality in education. Furthermore, he disagreed with the majority's interpretation of "all deliberate speed" as used in Brown II, arguing it did not imply an immediate end to segregation but rather a careful and measured approach towards integration.