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After decades of being the most successfully integrated schools in the United States, the public schools of the South appear to be headed slowly toward resegregation.

The causes of this trend, however, remain unclear. Changes in public school segregation patterns could be caused by any of three general factors: changes in residential patterns; changes in private school enrollment patterns; or changes in public school districts' policies. Changes in these three factors are, in turn, the result of a host of complicated and intertwined factors, including judicial, political, and policy trends, individual attitudes and their changes over time, structural aspects of school systems, demographic trends, labor and housing markets, and economic trends.

In this Article we examine various relationships between residential and school segregation to better understand the increase in school segregation in the South during the 1990s. The relationship between residential and public school segregation is particularly important given the Supreme Court's insistence that states and their public school systems cannot be held responsible for school segregation patterns that result from segregated residential patterns arising from the private choices of individuals. 2 If, then, school resegregation results primarily from increased residential segregation, there may be little recourse in the courts to oppose the resegregation of schools. If, however, resegregation of public schools is not a result of increasing residential segregation, but rather a result of school action (or inaction) in student assignment policies, there may be more leverage in the courts.