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Mississippi was brought to task over its desegregation policies of its university system. Even by the mid-'80s, predominantly single race student populations persisted in both the white and black institutions. The District Court held that the affirmative duty to desegregate in higher education does not require either restricting student choice or the achievement of any racial balance. The lower court held that the current state policies and practices were racially neutral, developed and implemented in good faith, and did not contribute substantially to the racial identifiability of individual institutions. The Court of Appeals affirmed that the state had met its affirmative duty to desegregate.

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