Tuesday, November 12, 2013
One of the reasons why integration is a powerful tool for improving educational outcomes is that it creates equal access to resources. In a racially and socio-economically stratified education system, the stubborn reality is that the "haves" will almost always out compete the "have-nots" for the best teachers and the "haves" will resist equity policies that interfere with their ability to out compete. These realities are what make the new study from the Department of Education's Institute for Educational Science on teacher transfers so interesting. It was able to answer the question of "what if we could get the best teachers to teach in the neediest schools." Prior programs have be relatively ineffective in getting high quality teachers to transfer or seek jobs in high need districts. Some studies have found that the cost of incentivizing teachers was prohibitively high.
This new study overcomes the incentive problem and founds impressive results. A pilot program in 10 districts across 7 states identified "[t]he highest-performing teachers in each district—those who ranked in roughly the top 20 percent within their subject and grade span in terms of raising student achievement year after year (an approach known as value added)," and offered them "$20,000, paid in installments over a two-year period, if they transferred into and remained in designated schools that had low average test scores."
The major findings from the study were:
• The transfer incentive successfully attracted high value-added teachers to fill targeted vacancies. Almost 9 out of 10 targeted vacancies (88 percent) were filled by the high-performing teachers who had been identified as candidates eligible for the transfer intervention. To achieve those results, a large pool of high-performing teachers was identified (1,514) relative to the number of vacancies filled (81). The majority of candidates did not attend an information session (68 percent) or complete an online application to participate in the transfer intervention (78 percent).
• The transfer incentive had a positive impact on test scores (math and reading) in targeted elementary classrooms. These impacts were positive in each of the two years after transfer, between 0.10 and 0.25 standard deviations relative to each student’s state norms. This is equivalent to moving up each student by 4 to 10 percentile points relative to all students in their state. In middle schools, we did not find evidence of impacts on student achievement. When we combined the elementary and middle school data, the overall impacts were positive and statistically significant for math in year 1 and year 2, and for reading only in year 2. Our calculations suggest that this transfer incentive intervention in elementary schools would save approximately $13,000 per grade per school compared with the cost of class-size reduction aimed at generating the same size impacts. However, overall cost-effectiveness can vary, depending on a number of factors, such as what happens after the last installments of the incentive are paid out after the second year. We also found there was significant variation in impacts across districts.
• The transfer incentive had a positive impact on teacher-retention rates during the payout period; retention of the high-performing teachers who transferred was similar to their counterparts in the fall immediately after the last payout. We followed teachers during both the period when they were receiving bonus payments and afterward. Retention rates were significantly higher during the payout period—93 versus 70 percent. After the payments stopped, the difference between cumulative retention of the high-performing teachers who transferred
Friday, November 8, 2013
A new report by the Altarum Institute and the W.K. Kellogg Foundation, The Business Case for Racial Equity, details the economic impact of racial inequality and the benefits of advancing racial equity, particularly given the evolving demography of our nation. It argues, based on economic and social science studies, that increasing racial equity would benefit businesses, government, and the overall economy. It focuses on housing, education, health and criminal justice as the primary areas of inequality that need to be addressed. In education, the report posits that school integration, pre-k education, and high expectations for minority students would produce significant benefits. The arguments and research in regard to each of these education proposals are not new, but the report, unlike most, does bring these three distinct educational reforms together into a single argument about the economy.
Thursday, November 7, 2013
In recent days, a few high profile calls to focus on poverty and inequality, as opposed to education innovation and “reform,” have been issued. Tuesday, the New York Times ran a story, In Public Education, Edge Still Goes to Rich, that emphasized the fact that, while our nation proclaims to be the land of opportunity and that education is the gateway to that opportunity, our education system is rife with gross funding disparities. On average, we spend less per pupil in schools with high levels of student poverty than we do in schools with low levels of poverty. Similarly, we also allow poor states to fend for their selves. New York, for instance, spends more than twice as much per pupil as Tennessee.
Last week, everyone from an audience member watching an educational debate between Arne Duncan and Fredrick Hess to Diane Ravitch has charged the Department of Education with chasing a fool’s errand and taking poor kids along for the ride. The audience member charged Arne Duncan with policies that favor the advantaged over the disadvantaged. And Diane Ravitch has charged in her new book and in promotional events that there is no fundamental crisis in education that needs reform. Rather, we need to tackle poverty. Our other so called reforms are but a side show that undermines instead of improves education.
Two weeks ago, the Southern Education Foundation released its report on the growing levels of poverty in public schools and shrinking education budgets available to address it. Fortunately, the media gave the report substantial coverage for a week or so and the report has reverberated through the messaging of various other policy commentators. My post called it a wake-up call. If unaddressed, the diverging trends of poverty growth and budget shortfalls pose a fundamental threat to quality education.
The fact that these voices are joining in a chorus is good news. It is going to take a sustained and aggressive campaign to put poverty and equality back at the top of the agenda. For a couple of sessions of Congress, Representative Chaka Fattah, for instance, has introduced student bills of rights that would require equity as a condition of receiving federal education funds. As one of the sole advocates for equity in Congress, his efforts have yet to go any where.
At the local level, we are got mixed messages in the elections this week. In Colorado, the referendum to increase taxes for schools failed (which many consider a remedy for the state's currently constitutionally inadequate system). But in the New York City mayoral race, Bill de Blasio won. His platform called for stemming the charterization of public education and supporting the neediest rather than closing them.
Once could attempt to write off the loss in Colorado to the fact that voters had another option on the ballot that they approved--school construction funding--and that the tax increase had a few wrinkles in it. The voters did not know exactly what the money would be spent on, nor that all the money would necessarily stay with schools. The tax itself also would have instituted a graduated tax system rather than the flat one they had before. One could also discount the de Blasio win, as many other issues were on the table. But regardless of how one interprets these results, the chorus of voices reminding of us the core problem of inequality and poverty will have to grow for serious change to occur.
Monday, November 4, 2013
A new decision, Petrella v. Kansas, is out in the Kansas school finance litigation. The litigation has proceeded on dual tracks for some time. Adequacy claims have been litigated in the state court system, while other claims have proceeded in federal court. The state has sought to combine the litigation on various instances, but the courts have declined. The plaintiffs have been very careful in crafting their claims so as to prevent this consolidation.
This new decision is an attempt to undermine the earlier state litigation that had resulted in a liability find against the state. The state responded with a remedy that, among other things, included a cap on the funds that local districts could raise to support local education, with the theory being that this would further equity. A group of parents from a wealthier district then challenged that litigation in federal court arguing it violated various federal constitutional rights, including their fundamental right to direct and control the upbringing of their children. The district court previously dismissed their case for lack of standing, only to be reversed by the 10th Circuit Court of Appeals. The 10th Circuit remanded and, last week, the district court issued its opinion addressing the legal theories in the case.
The Court held that the funding cap did not infringe on the parents’ fundamental rights. Those parents still have the right to control their children’s education as they see fit. For instance, they are free to withdraw their children from public school if they wish. The Supreme Court precedent creates a relatively narrow right and plaintiffs attempted to apply it far too broadly. In fact, if school funding remedies were deemed to impinge on parents’ fundamental right to control the upbringing of their children, almost every aspect of educational policy might do the same. The court also emphasized the Supreme Court’s holding in San Antonio v. Rodriguez, which had rejected school finance challenges as violating a fundamental right to education. The district court perceived the instant case as an ill-advised attempt to circumvent the more relevant holding and rationale in Rodriguez.
Finding no fundamental right, however, only rules out the application of strict scrutiny. The court found that the plaintiffs had still plead a case of unequal treatment, which was subject to rational basis review. The state had asked that the case be dismissed entirely, but the court found that the question of whether the state had a rational basis for it funding structure was not yet resolved and, thus, the case could proceed on this question. The court did, however, dismiss all the plaintiffs’ other claims.
As to the immediate school funding issues in Kansas, this decision is positive. It prevents third parties (ie, wealthy districts) from trying to impede school finance reform. On the broader horizon, I would note that there is/should be room to still bring certain narrow claims in federal court. For instance, if educational is a fundamental right under state law or students have a constitutional right to education under state law, federal equal protection should attach to that right. In other words, a state cannot extend fundamental or constitutional rights to students and then treat them unequally in regard to that right. Moreover, strict scrutiny should apply to that inequality. Often, the federal review would be applicative of bringing a state claim and, thus, would serve little purpose. But in those instances where state courts backtrack from enforcing rights or state legislatures refuse to comply, a federal claim would offer some benefit. The instant case does not directly implicate those types of claims, but it does amount to another case rejecting a Rodriguez work-around, which is implicitly problematic for my theory.
More on this school finance theory here.
Friday, November 1, 2013
Two years after passing a sweeping anti-immigrant bill, Alabama is relenting. The bill had wide-ranging impacts on immigrant communities (and those interacting with them) that touched on almost every aspect of their lives. Some may recall that the bill included a measure that required schools to verify the immigration status of newly enrolled K-12 students. The day after the bill went into effect, news reports indicated that scores of Latino students, in particular, went missing from school. This included students who were, in fact, citizens or were legally in the country. I never caught news of these students returning. Alabama apparently achieved its presumed purpose: to encourage these families to leave the state. I imagine that few of those uprooted families have intentions of returning to Alabama, but the settlement agreement negotiated by the Southern Poverty Law Center and other civil rights group with the state protects them if they do. The state has agreed to permanently abandon this and other aspects of the bill. See here for more details.
Thursday, October 31, 2013
On valuing education, he says this stereotype is an assumption based on less parental involvement at the school building itself by low-income families, but he points out that the inability to be at school is caused by job, transportation, and other barriers poor families face, not a lack of interest. He says there is no information to infer that they actually value education less. The laziness stereotype is easily debunked by the fact that many poor families work more hours and jobs than other families. They just make less money. On substance abuse, he says data shows that wealthier families actually have a higher rate of alcohol and drug abuse than poor families. They, of course, also have more money with which to indulge.
The linguistic deficient, however, was the most interesting. He does not contest that lower income parents may have less formal vocabularies, which also manifests itself in their children’s oral communication. He does contest that they are less complex or necessarily eqaute to ignorance. He points to evidence that indicates oral vocabularies are not as closely linked to reading and writing vocabularies as one might think. In short, a child’s oral linguistics are not a limit on their ability to learn to read. This makes sense because, after all, reading is new to all kids, regardless of how well they might speak. Gorski acknowledges that low-income students do tend to start school with fewer reading skills than other students, but he argues this is a function of difference in access to quality pre-k educational opportunities, not necessarily their parents’ communication skills. His debunking of the bad parent stereotype is largely intertwined with the previous four points.
So why are these stereotypes so prevalent and where do they come from? Part of it, he says, is our
Friday, October 25, 2013
• Encouraging innovation, such as giving priority to multi-district charters that seek to serve a socio-economically and racially diverse student body, or that address the needs English language learners or students at-risk of dropping out
• Ensuring that charter schools are not impeding access, through means explicit or subtle, to any and all students who are eligible to enroll, including very low income students, English language learners, and students with disabilities.
• Requiring public transparency in the lottery process; in maintaining waiting lists and documenting transfers and attrition; in adhering to state and federal due process in student discipline matters; and by disclosure of annual budgets, including funds and other support received from private sources.
Their full statement is available after the jump.
Wednesday, October 16, 2013
The article, “Public School Money Should Only Go to Public Schools,” raises policy concerns regarding the use of school vouchers to supplement tuition for private schools that the authors suggest may lead to a challenge under the Oklahoma state constitution that are relevant. This article describes the differences in accountability that private schools in Oklahoma enjoy (not having to be graded A-F as public schools) as well as concerns regarding access to private school for students who cannot afford to go there.
Monday, October 7, 2013
This summer Olesya Baker and Kevin Lang released a study through the National Bureau of Economic Research that analyzes the effect that high stakes testing has had on graduation rates, employment and incarceration. The study found that high stakes testing had a negative effect on graduation, but that the effect was minimal and potential only transitory during the period of high stakes testing implementation. The study found no effect on employment outcomes. The major finding of the study was "a robust adverse effect of standards-based exams on the institutionalization rate." High stakes exams "increase incarceration" by "about 12.5 percent." The National Education Association and the Congressional Black Caucus are also pressing this line of argument as a critique of current federal policy and the school-house-to-prison pipeline. Also of concern is the fact that low test scores are now also being used to create "parent triggers," whereby parents can transfer their children out of a school, which tends to adversely affect the school and community they leave.
Tuesday, October 1, 2013
At the start of the school year, I posted about the continuing expansion and rise in school fees and the constitutional problems they potentially present. Now comes a story out of Colorado noting the rise in the state's school fees and how unpaid fees can mount over time for some families. When those unpaid fees reach a certain level--$250--some schools are turning families over to a collection agency.
While I object to the fees in the first instance, I can appreciate the schools' frustration with people who can pay but just won't. After all, it is unfair for the costs of fees to be unevenly distributed. On the other hand, it is possible, if not likely, that many of these families are low-income or just struggling, even though they may not have formally been classified as such. Turning poor, or near-poor, families over to collection agencies for educational services that the state mandates they receive seems perverse, if not unconstitutional. The ACLU of Colorado is now pressing this latter point of whether the fees implemented by some local school districts violate the state's guarantee to a free education. Mark Silverstein of the ACLU said:"As far as I can tell, in Colorado the state constitution provides for a free public education, not a fee public education. It's almost as though some school districts got a flawed copy of the state constitution and the 'R' was missing." One parent laments that some children do not get to participate in extracurricular activities due to the fees: "It's getting to the point where it is going to separate the haves and have-nots, and that doesn't seem right to me." See more here.
Tuesday, September 24, 2013
A la the thesis of Diane Ravitch's new book, which I posted on yesterday, it is worth stepping back to consider what is really going on with the takeover of six Virginia schools. As LaJuana posted a few days ago, the state passed legislation creating the Opportunity Educational Institution, which grants this entity the power to take over schools that have failed to gain accreditation four years in a row. At least one district has filed suit arguing that the takeover violates the state constitution. Putting the constitutional issues aside for a moment, the persistant failure to meet accreditation standards suggests that these schools are in crisis, but are they? And if so, who is to blame?
The state's accreditation standards require elementary and middle schools to achieve the following pass rates: English – 75 percent or higher; Mathematics – 70 percent or higher; Science – 70; percent or higher; and History – 70 percent or higher. High schools are fully accredited if students "achieve pass rates of 75 percent or higher in English and 70 percent or higher in mathematics, science and history; and [a]ttain a point value of 85 or greater based on the Graduation and Completion Index (GCI)." (For further definition of the GCI see here). These flat and simple standards are the whole of the accreditation requirements.
One of the six schools in the state that has failed to meet this standard is Jefferson-Houston (formerly an elementary school, now a pre-k through 8 school) in Alexandria. The school rests on the edge of Old Town Alexandria, one of the DC area's most affluent neighborhoods. When I lived in the DC area, my home happened to be less than a mile from Jefferson-Houston. We didn't live in Old Town, but our son, had he been old enough, would have been assigned to Jefferson-Houston. The school's name also carries special meaning to me. Jefferson is in reference to Thomas Jefferson and Houston is in reference to Charles Hamilton Houston, former Dean of Howard Law School and the original architect of the NAACP's desegregation strategy.
Monday, September 23, 2013
Diane Ravitch has a new book out this week titled "Reign of Error: The Hoax of the Privatization Movement and the Danger to America's Public Schools." Ravitch does not appear to say American schools are excellent, but she argues that they are not in crisis and that the constant assertion that they are in crisis undermining them. In other words, the tail is wagging the dog in school reform. She also points out that we label students and schools as failing because we set unrealistic goals for them. This is not to say that we should set low goals, but that we can't expect students at severe disadvantage to achieve at the levels of privileged kids unless we first address those factors that make students disadvantaged. Likewise, it is not fair to compare our education system to Finland's--the top performing in the world--because Finland's poverty rate is only 5 percent whereas ours is about 7 or 8 times that rate.
Thursday, September 19, 2013
By a new era, I do not mean a forward looking or an improved era. I mean an era the state has not seen in decades. I mean an era that resembles the days before Brown v. Board of Education. LaJuana's post this morning contained a lot of news on Alabama, but the piece that struck me the most was the enormous decline in support for its schools and the push to amend its constitution in a not so good way.
My comparison to pre-Brown days is not meant to suggest that Alabama wishes to resegregate its schools--although I doubt race is irrelevant to the moves afoot in the state. It is a comparison to stark educational deprivation and inequality. The level of educational defunding in Alabama is mind-boggling and threatens to push the poorest and neediest schools--if not the entire state--into a class of their own, whose deprivations cannot be rivaled anywhere else in the country. On top of that, many wish to strip children of their constitutional right to education, something unheard of and unspeakable in this country for some time.
After accounting for inflation, the Center on Budget Priorities Report reveals a $1,200 decline in per pupil expenditures in Alabama between fiscal years 2008 and 2014. To put this number in local perspective, it amounts to a 20% decline in funding in Alabama. In other words, 1 out of 5 education dollars in the state is gone, or the money for 1 out of 5 children has vanished. To put this number in national perspective, in 2006, the Education Trust reported a national funding gap between the highest and lowest poverty districts of $1,300 per pupil. So in comparison, Alabama's funding shortfall turns the entire state into a similarly underfunded subclass. No matter where a student lives in the state, he or she might reasonably be treated as a poverty class that trails the rest of the nation. Moreover, these cuts come on top of the fact that Alabama already had one of the lowest per pupil expenditures in the nation, and distributed those funds among school districts in one of the most regressive ways in the nation. See School Funding Fairness Report. In short, awful is getting much worse in Alabama. In a high poverty, regressively funded school district in a state with an educational system in a subclass of its own, a new era of educational deprivation not seen in decades is a serious risk.
Wednesday, September 11, 2013
The Leadership Conference on Civil and Human Rights, along with the American Civil Liberties Union, Anti-Defamation League, Lawyers' Committee for Civil Rights Under Law, NAACP, National Women's Law Center, and Poverty & Race Research Action Council, just release their report on the United States’ Compliance with the International Covenant on Civil and Political Rights. The report is titled, Still Segregated: How Race and Poverty Stymie the Right to Education ( Download Still_Segregated2013). This report is a follow up to an earlier report. The report focuses on three major points: 1) persistent racial and socioeconomic segregation, inequity and discrimination; 2) inadequate court responses to inequity; and 3) inadequate policy responses to inequity.
Tuesday, September 10, 2013
The Wall Street Journal ran a story Sunday on the rising costs of attending public school. Things that once were free are increasingly coming with a price tag, like bus transportation, extracurricular activities, athletics, music class, debate club. Well, one might say, those are all extra things that go beyond the basics of education. But many schools go beyond charging for optional activities. A school in Colorado charges for foreign language class, math class, and advanced placement class. Some schools charge for textbooks.
I would hope and assume that there are waivers for low-income students, but I am skeptical that this solves the problem. There is already a huge socio-economic and racial gap in terms of who participates in enriched academic programs like AP classes. Placing a pricetag only reinforces that gap. Of course, this is to say nothing of the fact that these fees exist in states whose courts have held these children have a constitutional or fundamental right to education. The ACLU picked up on this idea in Michigan and brought suit to enjoin the fees. Fortunately, the district buckled before the beginning of the school year. Without concerted activism or litigation, however, few other districts seem poised to do the same.
Thursday, September 5, 2013
Now that school is back into swing, elementary and secondary schools are feeling the full brunt of the sequester, but not all schools are feeling it the same. Most of the federal money in public schools flows through Title I of the Elementary and Secondary Education Act. While my past work has critiqued the formulas through which these funds extensively for their failure to fully account for the effects of concentrated poverty, it is true that the money flows to schools based upon the number of poor kids they have. Thus, the more poor kids a district has the more money it is loosing under the sequester cuts.
Wealthy districts, of course, have poor kids too, so they are suffering cuts as well. But those cuts amount to smaller line items and those districts necessarily have more capacity to make up the difference. Whereas, other districts are loosing more money and have less capacity. MSNBC tells the story of the affluent Loudon County, Virginia, district where district officials say the cuts "meant hardly anything," but in Virginia’s Shenandoah Valley, things are pretty bad.
When Harrisonburg students went back to school in August, there were fewer teachers and staff to greet them: The district lost an English proficiency teacher, a school social worker, a Head Start teacher, and a teacher’s aide when sequestration cut $400,000 from the school budget, according to Harrisonburg school superintendent Scott Kizner. The cuts come to a district where 70% of students qualify for a free school lunch, and more than 40% speak English as a second language.
Friday, August 30, 2013
The San Francisco Chronicle is running an in-depth four part series on African American males in Oakland Unified School District. The articles chronicle real day life for the students both inside and outside school. It also include statistical data and analytical commentary. As the chart above reveals, there were more than twice as many African American men and boys killed in 2002 as there were college ready African American males. This college versus death comparison, while grim, pales in comparison to the incarcerated versus college ready data in Oakland.
To the school district's credit, it recognized the crisis and created a special department to address it, the African American Male Achievement Office, which has special classes and programs. Although the trend in improvement started before the formal creation of this office, the number of college ready African American males has tripled in comparison to the 2002 numbers and quadrupled in comparison to 2003. Sadly, the deaths among this group have stayed relatively steady, but those numbers are beyond the full control of schools. In other words, violence and death continue to surround these young men at an alarming rate, but the school district is doing a better of helping some defy the odds.
The full series is available here.
Wednesday, August 28, 2013
In a review of the 41 NCLB waivers that the Department of Education has granted, the Campaign for High School Equity finds:
that many states have failed to address clearly and fully the needs of our most vulnerable students. Some states, with the approval of the U.S. Department of Education, abandon a primary focus on subgroup accountability—a central tenet of NCLB—and weaken efforts to close achievement gaps and improve education for all students. Significant progress has been made under NCLB to ensure that the needs of all students—including underserved students—mattered; a school could not be deemed successful, regardless of overall performance, if a subgroup of students was struggling. Provisions of NCLB have ensured that the achievement of all students by subgroup was counted; school progress regarding improving achievement of subgroups of students was publicly reported, and when a school did not adequately improve student achievement for subgroups of students, an intervention was triggered to better support student success. While NCLB has many provisions that need revision, subgroup accountability provisions have shone a bright light on the achievement of all students and have ensured that the children who need it most get help. Yet, our analysis shows that several of the Administration’s approved ESEA waivers undermine subgroup accountability, instead of making it the central focus of statewide accountability systems.
Tuesday, August 27, 2013
Vouchers v. Desegregation: U.S. Department of Justice Seeks to Block Vouchers in Desegregating Districts
Louisiana Gov. Bobby Jindal spearheaded the expansion of the state’s voucher program from New Orleans to the entire state this year. He did not, however, bother to assess how the program might affect student assignment and enrollment in districts that are still operating under court orders to desegregate. Now, the U.S. Department of Justice has filed a motion in district court to block the application of the voucher program to those districts. The motion argues that students in at least 22 districts that are still under desegregation orders have received vouchers “without authorization from the appropriate federal court frustrates . . . .” Those vouchers “imped[e] the desegregation process in school districts operating under federal desegregation orders.”
Gov. Jindal responded on Meet the Press, stating
We’ve got a scholarship program. One hundred percent of the kids are low-income. One hundred percent of the kids are in failing schools—C, D, or F schools. Ninety percent of the kids are minorities. Eight thousand of those parents have chosen to take these dollars and send these kids to better schools, to other schools where they can get a better education, where it’s a better fit for their children. Now the Department of Justice, using the same rules that were there to prevent discrimination against minority children, is going after some of these parents and some of these kids and saying, ‘We don’t know that we want to allow you to make this choice. We want you to go to a federal judge.’
School choice advocates are also lambasting DOJ and the role this would play in impeding choice. They seem to ignore, however, that it would be impossible to enforce desegregation orders if districts and states were free to create exit options and exceptions that would undermine desegregation. In fact, various creative exit options, albeit race-neutral on their face, were a major stumbling block to the initial creation of integrated schools in the 1950s, 60s and 70s. Or, choice advocates assume that the voucher program will have no negative effect on the demographics of these school districts. Even if their assumption proves to be correct, it has always been standard procedure to verify the effect of new policies on student assignments in desegregating districts, rather than wait until after the fact when the damage is already done. While the state and districts are largely free to assign students, however, they see fit in “unitary” districts, there are constitutional constraints on other districts for good reason.
Gov. Jindal's full interview is here.
Monday, August 26, 2013
As mentioned a couple of weeks ago, the UNC Center for Civil Rights is representing a group of parents in Pitt, NC, who allege that the district has taken steps that violate its affirmative duty to desegregate. In reviewing their proposed findings of fact, the crux of their claim is that the school district had three student assignment options on the table in 2008 and choose the most segregative of the three. Plaintiffs evidence at trial indicates that the district chose the segregative plan because, during its previous student reassignment plan in 2001 or so, white parents had objected to sending their children to some schools with substantial percentages of minority students and the district sought to avoid this reaction this time. In other words, the plaintiffs allege that the district is segregating students to avoid white flight and that white flight is not a legitimate factor upon which to assign students.