22 N.Y.2d 46 (1968)
School boards possess broad discretionary powers in zoning decisions, including the authority to consider racial balance as a factor when making such decisions, provided the decisions are rationally based and serve legitimate educational purposes.
Summary
Parents brought an Article 78 proceeding challenging the New York City Board of Education’s rezoning of Public School No. 6, alleging it was an unreasonable and arbitrary attempt to achieve a fixed racial quota. The board argued the rezoning aimed to correct racial imbalance, improve school utilization, and provide full-time sessions for all students. The lower courts dismissed the petition, finding the board acted within its discretion. The New York Court of Appeals affirmed, holding that school boards can consider racial balance in zoning decisions when it serves a legitimate educational purpose, and the courts will not interfere unless there is no rational basis for the board’s decision.
Facts
Public School No. 6 in Manhattan was rezoned, reducing its zone from 120 to 71 square blocks. This rezoning transferred approximately 200 students living in the former zone to other schools. The Board of Education stated its goals were to alleviate overcrowding, end “overlap sessions” (shortened school days), and improve racial balance. Before rezoning, the school was 6% Black and Puerto Rican. The rezoning plan anticipated increasing this percentage to 20% through voluntary transfers from overutilized, predominantly minority schools north of 96th Street. Students from East Harlem were to be bused into Public School No. 6.
Procedural History
The parents of the rezoned students initiated an Article 78 proceeding in Special Term, seeking to annul the Board of Education’s rezoning determination. Special Term dismissed the petition on the merits. The Appellate Division affirmed the dismissal. A dissenting Justice at the Appellate Division argued for a trial to determine the board’s factual basis for redistricting. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether the New York City Board of Education exceeded its discretionary powers by rezoning Public School No. 6, purportedly to achieve a better racial balance, thereby preventing the children of the petitioners from attending their neighborhood school.
Holding
No, because school boards possess broad discretionary powers in zoning decisions, and courts should not interfere with educational value judgments if there is a reasonable basis for the board’s conclusion.
Court’s Reasoning
The court relied on previous decisions in Matter of Balaban v. Rubin and Matter of Vetere v. Allen, which established that courts lack the power to invalidate school board plans on such grounds. The court emphasized the broad discretionary powers afforded to school boards in making educational decisions. The court stated that the Board of Education determined that the rezoning would alleviate overcrowding, provide full-time sessions, and improve racial balance. The court deferred to the board’s judgment that these factors served legitimate educational purposes. The court found no evidence that the board acted arbitrarily or without a rational basis. The court noted that the children on whose behalf the proceeding was brought were transferred to schools no farther from their homes than Public School No. 6. The court found no constitutional or statutory mandate prohibiting the board from promoting integration. The court concluded that the board’s freedom to act is “untrammeled by the courts” in this sphere. As the court stated in Matter of Vetere v. Allen, “in the area of educational value judgments, the courts do not substitute their views for those of the board if there be some reasonable basis for the board’s conclusion”. The dissenting Justice’s argument that the rezoning was an illegal “gerrymandering” of districts to accomplish integration was rejected, aligning the decision with the existing precedent allowing consideration of racial balance in school zoning decisions.