In the 1969 case of Carter et al. v. West Feliciana Parish School Board et al., the U.S Supreme Court ruled in favor of African American students and parents who challenged a "freedom-of-choice" plan implemented by a Louisiana school district that was designed to maintain racial segregation in public schools. The plaintiffs argued that this plan violated their Fourteenth Amendment rights, which guarantee equal protection under the law. The court agreed with them, stating that such plans were unconstitutional if they failed to eliminate segregation "root and branch." This ruling reaffirmed previous decisions mandating desegregation in public education and clarified that any attempts to circumvent these mandates through ostensibly race-neutral policies would not be tolerated.

In the dissenting opinion for Carter et al. v. West Feliciana Parish School Board et al., Justice Hugo Black argued that the court's decision to allow federal judges to oversee and enforce desegregation plans was a misinterpretation of the Constitution, which he believed did not grant such powers to federal courts. He contended that this ruling would lead to an overreach of judicial authority into local school affairs, disrupting their operations and undermining local control over education policy. Furthermore, he expressed concern about potential conflicts between different branches of government as well as between state and federal authorities due to this decision. Ultimately, Justice Black disagreed with his colleagues' interpretation of constitutional law in relation to desegregation enforcement.