In particular, the Court held that the school systems were not responsible for desegregation across district lines unless it could be shown that they had each deliberately engaged in a policy of segregation.

The case also did not take into account many sources of segregation in the US, including an ongoing migration of Black people into cities, white flight to the suburbs, and policies and practices that barred non-whites from suburban housing.

[4] Educational segregation was therefore widespread, with informal racial barriers in the form of numerous thinly disguised practices that opposed Black people living in suburbs.

[4] On August 18, 1970, the NAACP filed suit against Michigan state officials, including Governor William Milliken.

The Sixth Circuit Court of Appeals ruled that the "implementation of the April 7 plan was [unconstitutionally] thwarted by State action in the form of the Act of the Legislature of Michigan" and remanded the case for an expedited trial on the merits.

The Court noted that desegregation, "in the sense of dismantling a dual school system," did not require "any particular racial balance in each 'school, grade or classroom.'"

According to Wayne State professor John Mogk, the decision also enabled the white flight that re-entrenched the city's segregation.