In Dowell et al. v. Board of Education of Oklahoma City Public Schools et al., the U.S Supreme Court was tasked with deciding whether a school district that had previously been segregated could be declared "unitary" and thus, no longer under court supervision to desegregate its schools. The case began in 1961 when an African American student sued the Oklahoma City School District for operating a racially segregated school system, which violated the Equal Protection Clause of the Fourteenth Amendment. By 1972, after implementing various desegregation plans, it appeared that segregation had been eliminated root and branch from the district's schools; however, by 1985 racial imbalance reemerged due to demographic changes within neighborhoods served by these schools. The plaintiffs argued this constituted de facto segregation while defendants claimed they were not responsible for housing patterns causing such imbalances. In its decision issued in 1991 (not 1969), The Supreme Court ruled in favor of allowing federal courts to release school districts from their jurisdiction once they have complied fully with desegregation orders and demonstrated good faith efforts over time towards becoming unitary systems - even if some level of racial imbalance persists as long as it is not caused by discriminatory intent on part of school authorities.

In the dissenting opinion for Dowell v. Board of Education, it was argued that the court's decision to end federal oversight of desegregation in Oklahoma City Public Schools was premature and potentially harmful. The dissenters believed that there were still significant racial disparities within the school district, indicating a need for continued supervision to ensure equal educational opportunities for all students. They expressed concern that without ongoing federal intervention, progress towards integration could be reversed or stalled. Furthermore, they disagreed with the majority's interpretation of "unitary status," arguing instead that this should not simply mean an absence of current discriminatory practices but also require evidence of sustained commitment to preventing future discrimination.