The case of the School Board of City of Richmond, Virginia v. State Board of Education of Virginia in 1972 revolved around a dispute over school desegregation plans. The Supreme Court ruled that federal courts have the authority to order busing as a means to achieve racial integration in public schools. This decision was based on previous rulings which held that segregation is unconstitutional and all deliberate speed should be used to eliminate it. In this particular case, the court found that local authorities had not acted with sufficient urgency or effectiveness in eliminating segregation from their schools and thus intervention by federal courts was necessary and appropriate.

In the dissenting opinion for the School Board of City of Richmond, Virginia v. State Board of Education case in 1972, Justice William O. Douglas argued that the majority's decision was a step backward in achieving racial equality and integration within schools. He contended that by allowing state authorities to maintain racially segregated school districts under their "freedom-of-choice" plans, they were effectively perpetuating systemic racism and inequality within education systems. Furthermore, he criticized this approach as it placed an unfair burden on black students who had to actively choose integrated schooling rather than having it be a given right. In his view, true desegregation would only occur when states took proactive measures towards integrating schools rather than leaving it up to individual choice which could easily be influenced by societal pressures or biases.