In the case of McDaniel v. Barresi, the U.S. Supreme Court ruled in favor of a school board's decision to reassign students among schools in order to eliminate racial segregation. The DeKalb County School System had previously been operating under a "freedom-of-choice" plan which allowed parents to choose where their children would attend school; however, this resulted in continued de facto segregation as white and black students largely attended separate schools. In response, Superintendent McDaniel reassigned some students based on race to achieve integration, but was sued by several parents who argued that this violated the Equal Protection Clause of the Fourteenth Amendment. The Supreme Court disagreed with these claims and upheld McDaniel's actions as constitutional because they were aimed at dismantling a dual system rooted in racial discrimination.

In the dissenting opinion for McDaniel v. Barresi, Justice Hugo Black argued that the court's decision was a departure from previous rulings which held that states were only required to eliminate laws mandating racial segregation in schools, not actively integrate them. He contended that by ordering school boards to take affirmative action towards integration, the Court had overstepped its bounds and infringed upon state rights. Furthermore, he expressed concern about federal courts becoming too involved in local school affairs and making decisions better left to education professionals. He also questioned whether such forced integration would actually achieve desired social outcomes or simply lead to further tension and conflict.