The Crawford v. Board of Education case in 1981 involved the Los Angeles school district and its attempts to desegregate schools through busing students. The Supreme Court ruled that California's Proposition I, which limited court-ordered school desegregation plans unless intentional segregation was proven, did not violate the Equal Protection Clause of the Fourteenth Amendment. This decision effectively allowed states to repeal or limit laws requiring student reassignment for racial balance unless there was a finding of deliberate racial discrimination by those states. It marked a significant shift from previous rulings where more aggressive measures were endorsed to combat de facto segregation in public schools.

In the dissenting opinion for Crawford et al. v. Board of Education of the City of Los Angeles et al., Justice Thurgood Marshall, joined by Justice Brennan, disagreed with the majority's decision to allow California to amend its constitution in a way that limited court-ordered busing as a remedy for school segregation. They argued that this amendment was discriminatory and violated equal protection under law because it specifically targeted racial desegregation efforts while leaving other types of student transportation untouched. The justices also criticized the majority's interpretation of Brown v. Board of Education, stating that they believed it required not just an end to de jure segregation but also affirmative steps towards integration where past discrimination had occurred - something which limiting busing would prevent.