In the 1972 case of Keyes et al. v. School District No. 1, Denver, Colorado et al., the U.S Supreme Court ruled that deliberate racial segregation policies implemented by a school district were unconstitutional and violated the Fourteenth Amendment's Equal Protection Clause. The lawsuit was initiated by parents of African American and Hispanic students who argued that their children were being deliberately segregated in separate schools within Denver's Park Hill neighborhood through manipulative student assignment practices and discriminatory construction of new schools. The court held that if it could be proven that such segregative actions had been taken intentionally in one part of a school system, then it would be assumed they had occurred across all parts unless evidence suggested otherwise - this marked an important shift from previous rulings where plaintiffs needed to prove intentional segregation for each individual school.

In the dissenting opinion for Keyes et al. v. School District No. 1, Denver, Colorado et al., Justice Powell argued that the majority's decision to impose a system-wide remedy was inappropriate given that intentional segregation had only been proven in some parts of the school district and not others. He contended that there was no evidence showing an explicit policy of racial discrimination by the school board across all schools in Denver; instead, he believed any racial imbalance could be attributed to demographic factors such as housing patterns rather than deliberate segregation efforts by authorities. Therefore, according to him, it would have been more appropriate for remedies to be limited only to those areas where de jure segregation was found.