Jasmyn Hardin, Associate Member, Immigration & Human Rights Law Review
I. Introduction
The complex relationship between race and property has been instrumental in “establishing and maintaining racial and economic subordination” in American society.[1] Attempting to stabilize the housing market after the Great Depression, the Home Owners’ Loan Corporation (HOLC) instituted redlining, a racially discriminatory housing practice.[2] The HOLC created color-coded “residential security maps,” which ranked neighborhoods of major United States cities in order of decreasing desirability.[3] Highly desirable neighborhoods received an “A.”[4] In contrast, hazardous or high-risk neighborhoods received a “D.”[5] Grade “A” neighborhoods meant that residents were “prime candidates” to receive bank loans, and the inverse was true for residents of Grade “D” neighborhoods.[6] As a result, African Americans’ were presented with limited access to property and capital, effectively stinting their ability to achieve upward societal mobility.[7] The practice of redlining was deeply ingrained with systemic racism and xenophobia, resulting in the intentional financial divestment of minority communities, subjecting them to environments that lack essential resources.[8] The lasting effects of redlining’s legacy linger deep within institutional systems, disproportionately infringing upon the human rights of the Black community.
This article explores how redlining contributed to the institutional oppression of Black people in three fundamental areas: (A) poverty, (B) health, and (C) education. Part II provides background on the historical relationship between race and property. Part III discusses the present-day intersections of race and property with poverty, health, and education. Finally, Part IV argues that the discriminatory practice of redlining has led to the deliberate, long-term disinvestment of marginalized communities, most significantly affecting Black children. This blog concludes by suggesting forward-looking policy recommendations informed by human rights law in pursuit of a more equitable society.
II. Background
The history of property rights in the United States is “rooted in racial domination.”[9] Slavery was an institutional “system of property” that entangled the relationship between white identity and property.[10] White identity was “jealously guarded” due to the exclusive access to socioeconomic benefits and property rights.[11] In fact, whiteness was the sole source of “privilege and protection,” and its absence meant being the “object of property.”[12] White slave owners reaped significant economic gains through the exploitation of their “property,” perpetuating a racial hierarchy and laying the foundation for the systemic oppression of Blacks.”[13]
Post-Emancipation, African Americans immediately pursued real property because they knew that private property ownership was the “bedrock of the American economy” and was “inextricably linked” to power and wealth.[14] Though African Americans could legally own private property, they often faced societal barriers when attempting to do so.[15] These barriers mainly arose in the form of violence by whites who opposed their purchase of land.[16]
This racial violence was further heightened throughout the Jim Crow era, which enforced legalized racial segregation.[17] The redlining process extended racial segregation into real estate and mortgage lending.[18] Residents of neighborhoods deemed hazardous and high-risk by the HOLC’s grading system were “redlined” by lending institutions, denying them access to capital.[19] This effectively barred African Americans from home ownership and economic opportunities by making credit unavailable or too costly.[20]
While prohibited in 1968, redlining practices still impact marginalized communities today.[21] Redlining perpetuated systemic racism that resulted in an imbalance in the ability to achieve economic, societal, and educational mobility through “continued housing discrimination, segregation, poverty, and racial disadvantage.”[22] As of 2018, 65% of “D” neighborhoods, per 1930s maps, remain low-income and largely reflect communities of racial and ethnic minorities, compared to 91% of “A” neighborhoods that are highly affluent and predominantly white.[23]
Accessing credit is the “underpinning of economic inclusion and wealth-building” in the United States.[24] The average Black family has 8 cents for every dollar of wealth accumulated by white families.[25] As of 2023, Black individuals experience more than double the rate of poverty compared to white individuals.[26] Concentrated poverty is the “single most powerful predictor” of the “racial-achievement gap” and the quality of the school.[27] K-12 schools in poor communities have less access to foundational resources and opportunities that ultimately provide a “lifetime of privilege or disadvantage,” impacting all aspects of life.[28]
Children who face barriers to education have an increased likelihood of involvement in the justice system.[29] Black children are disproportionately represented within the criminal justice system, as they are 2.6 times more likely to be arrested than white children for the same behavior.[30] Research shows that police officers spend significantly more time in Black, Asian, and Hispanic communities, correlating to higher arrest rates.[31] Racial profiling is a driving factor in this disparity, as Black children are more likely to be perceived as older and thus more culpable of criminal activity.[32] Persistent racial profiling and discrimination of Black youth have been linked to higher rates of depression among Black children, with a 54% increase among Black youth ages 10 to 19 since 2018 compared to a 17% decrease for White youth.[33]
Though redlining theoretically ended many years ago, most neighborhoods are still largely segregated by race.[34] Some argue that present-day segregation is solely the result of de facto segregation and thus “voluntary” and untouchable by law.[35] However, this argument fails to acknowledge that systemic oppression created a “persistent, hierarchical, and caste-like system” that is deeply baked into American society and continues to disproportionately impact communities of color.[36] The importance of providing a child with a life above the poverty line and access to quality healthcare and education is not only a domestic problem, but a global priority.
III. Discussion
In 1948, the United Nations (U.N.) publicly acknowledged its support through the adoption of the Universal Declaration of Human Rights (UDHR), a “milestone document in the history of human rights.”[37] The UDHR establishes the right to education and a “standard of living adequate for the health and well-being” of all people, encompassing food, clothing, housing, and medical care.[38] In accordance with the UDHR’s principles, in 1966, the U.N. adopted the International Covenant on Economic, Social, and Cultural Rights (ICESCR). The ICESCR further recognizes the “inherent dignity of the human person,” creating global conditions in which “everyone may enjoy [their] economic, social, cultural, civil, and political rights.”[39]
The United States prides itself on being a global leader, yet it is not leading on these issues. The United States is one of six U.N. members that have yet to ratify the ICESCR, which would give it the force of law.[40] President Jimmy Carter signed the ICESCR in 1977, but no further steps have been taken to ratify it.[41] Historically, the United States has been reluctant and suspicious of recognizing economic, social, and cultural rights as rights deserving of government enforcement.[42] Meanwhile, the poor get poorer, and the rich get richer, which is “neither inevitable nor acceptable in a nation of such abundant resources.”[43] Ratification of the UDHR and ICESCR would formally acknowledge and protect the human rights of historically disadvantaged groups who have been disproportionately impacted by America’s history of systemic racism and discriminatory practices. Redlining has led to the deliberate, long-term disinvestment of marginalized communities and, present day, is reflected in the form of higher poverty rates, lower economic mobility, and greater health and education disparities.[44] This reality most significantly impacts America’s most vulnerable population: Black children.[45]
A. Poverty
Children are the poorest age group in America, with 11 million children in the United States living in poverty.[46] Black children make up 14% of the total population of children, yet make up more than one-quarter of children living below the poverty line.[47] Children under five and children of single mothers experience the highest poverty rates.[48] Childhood poverty can have “wide-ranging, sometimes lifelong, effects” on children, subjecting them to a greater risk of behavioral, social, emotional, and health challenges.[49]
Though poverty alone is not a reason to suspect neglect or abuse of a child, it has increasingly been a contributory factor in removing children from their parents.[50] African Americans disproportionately make up the number of “chronically poor and homeless” families within the foster care system.[51] Societal stereotypes tend to view poverty as a moral and personal failure rather than a “predicament of more complex origins such as institutional inequities.”[52]
For example, In Re Brittney T, the child was removed from her parents as she was morbidly obese.[53] The court ordered that she participate in a nutrition program, attend meetings, keep accurate food logs, and go to the gym two to three times per week. Brittney’s parents were found to be non-compliant, as she had issues with excessive school absences; they did not take her to the gym two to three times per week and allowed her to exceed her recommended caloric intake by eating foods like hamburgers and fries. The mother responded that they were simply doing their best, citing challenges in scheduling outside of school hours, gym membership cost and travel, and access to healthy food options.[54] While a child’s health is essential and should be taken seriously, it is a disservice to the child and family to penalize marginalized individuals for factors beyond their control. Adequately addressing the role that redlining has had in erecting systemic barriers, entrenching poverty among marginalized communities, and limiting economic mobility first requires the acknowledgment that such inequalities exist.
B. Health
Race significantly predicts health outcomes for children in the United States.[55] A child’s environment, encompassing their home and the broader community, can substantially impact their physical and mental health throughout their lifetime.[56] Children of minority communities are more likely to live in environments that lack adequate access to healthy food, quality healthcare, and safe play environments, making them highly susceptible to more significant health disparities as adults.[57]
A necessity as crucial as healthy food should be readily available and accessible for all, yet many low-income urban neighborhoods fall victim to “spatial supermarket redlining.”[58] This phenomenon is one in which chain supermarkets are built in the wealthier suburbs rather than the inner city or the removal of existing stores from lower-income urban neighborhoods.[59] Neighborhoods that have succumbed to this phenomenon experience are known as “food deserts,” meaning that the area is both low-income and has minimal grocery access.[60] Poor, predominantly Black neighborhoods have the most scarce access to supermarkets and greater access to dollar stores, thereby restricting access to quality, nutritious foods.[61] The culmination of reduced access and increased susceptibility to chronic disease results in shorter average lifespans and less economic mobility.[62]
Food insecurity not only affects an individual’s physical health but also their behavioral and emotional health.[63] In 2023, approximately one in seven households experienced food insecurity, with rates of food insecure Black households double that of white households.[64] A hungry child cannot focus and learn, ultimately hindering childhood development and academic achievement.[65] Children in food-insecure households are twice as likely to experience elevated activity levels and inattention.[66] Bill S.3093, or the Healthy Meals Help Kids Learn Act of 2023, has been introduced in the Senate as an amendment to the Richard B. Russell National School Lunch Act, which would permanently increase the federal reimbursement rates for free or reduced school lunch and breakfast programs.[67] With this bill, schools are better supported to continue providing students with healthy meals to increase focus and overall academic performance.[68]
Redlining’s legacy continues to permeate several cities deemed hazardous in the 1930s, and they remain “hypersegregated” today.[69] These dramatic effects are most reflective in Macon, GA, the most redlined city in America, in which 65% of neighborhoods were considered hazardous and thus unworthy of credit. As of 2018, one in four residents of Macon County still live below the poverty line, with the rate 2.5 times higher among Black residents.[70] Several families also face the compounding factor of transportation, as many residents live more than 20 miles from the nearest supermarket while lacking vehicle access.[71] Chronic diseases, such as diabetes, hypertension, and obesity, are extremely rampant throughout Macon County, as residents are left with access to fast food and other highly processed, sugary foods.[72] A map drawn in the 1930s continues to permeate adverse effects on the same neighborhoods nearly 100 years later.[73]
The Health Disparity Zones Act of 2023, H.R. 6475, would designate cities such as Macon, GA, as health disparity zones.[74] This designation would provide incentives through grants, student loan repayment programs, and tax credits for healthcare providers and local social service organizations working to reduce health disparities and improve health outcomes in impoverished areas.[75] Additionally, the Food Deserts Act, H.R. 1230, would establish a grant program within the Department of Agriculture to help reduce food deserts.[76] This funding would allow states to support the establishment and operation of grocery stores in underserved communities.[77] Both bills were introduced in the House in 2023 but have yet to become law.[78] Cities like Macon would greatly benefit from the passage of these bills as they would provide greater access to healthy food, subsequently reducing health disparities and improving health outcomes in historically redlined neighborhoods.
C. Education
All children deserve access to a “high-quality education in a safe and nurturing school environment,” yet this is often “not the reality” for students of color in the United States.[79] Schools in low-income neighborhoods have “steadily transformed into hardened, prison-like environments.”[80] The 1954 Supreme Court decision, Brown v. Board of Educ., “required an end to ‘separate but equal,’” but only so far as not to disturb the “relative privilege accorded by whiteness.”[81] Historical disempowerment and oppression of Black children in education is the result of “stealing education laws,” which have persistently undermined the commitment to equal access to a high-quality education.[82] “Stealing education laws” allow affluent communities to hoard educational resources, perpetuating a “perfectly legal mechanism” that further oppresses and subordinates Black children, their families, and their communities.[83]
The quality of a child’s K-12 education is highly determinant of their future employment and income and should be treated as such.[84] Theoretically, Brown eliminated segregated schools, but this holding did not result in “actual educational equality” for Black students.[85] Black children are more than twice as likely to attend high-poverty schools.[86] For example, in Ohio, research shows that most Black and white students continue to attend separate schools, with significant disparities in the number of educational opportunities afforded.[87] While test scores are only one factor, half of Black students attend schools whose academic performance would be ranked in the bottom 5% of schools attended by white students.[88] Only 5% of Black students attend schools with an average test score of 96 or above, a 20% difference compared to white students.[89] Predominantly Black schools have access to fewer resources, less qualified teachers, and spend an average of $733 less per student per year compared with predominantly white schools.[90] Research shows that Black children achieve better averages on standardized tests when allowed to attend schools with lower concentrations of poverty.[91] Seventy years later, the “actual educational equality” promised in Brown has yet to fully materialize for communities of color.[92]
Given the importance of a K-12 education in setting up a child for a lifetime of success, one should not be limited in accessing educational opportunities merely because of their family’s address. For certain loans, banks still require applicants to provide a diploma of education.[93] Higher levels of education provide an advantage for borrowers.[94] Drastic disparities in educational equality put minority students at a disadvantage from the very beginning. The Examining Educational Redlining in Lending Act, H.R. 8142, would require the Bureau of Consumer Financial Protection to assess the use of specific educational data for credit applications.[95] This bill seeks to prevent decisions from disproportionately affecting protected class members, ensuring equal access to credit and supporting economic mobility.[96] Furthering this initiative is bill H.R. 6457, the Minority Entrepreneurship Grant Program Act of 2023, requiring the Small Business Administration to create or expand grant programs at minority-serving institutions seeking to foster, promote, and increase opportunities for minority entrepreneurship and business ownership.[97]
Addressing the systemic injustices felt by historically redlined communities requires a substantial investment on all fronts. Bills such as H.R. 837, the Restoring Communities Left Behind Act, would be instrumental in “counter[ing] the last legacy of redlining policies.[98] This bill would allow the Department of Housing and Urban Development to establish a grant program strengthening local partnerships to implement “neighborhood revitalization support activities in economically distressed areas.”[99] Such investments would provide for the purchasing and developing of vacant or distressed properties to create more affordable housing, increase private homeownership for minorities by providing pre-purchase counseling and down payment assistance, and improve parks, sidewalks, and street lighting.[100]
These investments would also increase access to jobs with livable wages and affordable childcare within minority communities, reducing poverty as families have adequate income to support themselves.[101] The sheer necessity of healthy food in living a long, disease-free life makes access to it even more critical, and your neighborhood should not be determinative. The quality of education provided in predominantly Black schools needs to be improved, starting with more funding for schools and allowing for more investment in students and teachers. Education lays the foundation for a child’s future and is imperative in ending the negative cycle perpetuated by a history of systemic racism.
IV. Conclusion
The importance of providing a child with a life above the poverty line and with access to quality healthcare and education is not only a domestic problem, but a global priority. By adopting the UDHR and ICESCR, the U.N. has further recognized the “inherent dignity” of all people, establishing the right to education and a “standard of living adequate for health and well-being.”[102] The United States remains one of six of the 193 member states in the U.N. that have yet to ratify the UDHR and ICESCR.[103] Ratification of these measures would formally acknowledge and protect the human rights of historically disadvantaged groups who have been disproportionately impacted by America’s history of systemic racism and discriminatory practices.
The lasting effects of redlining’s legacy linger deep within institutional systems, disproportionately infringing upon the human rights of the Black community. The practice of redlining has been instrumental in erecting barriers for people of color, which are complex and, in some cases, impossible to overcome. Neighborhoods redlined in the 1930s continue to feel those effects today, as they are subjected to highly impoverished environments, lacking sufficient access to healthy food, quality education, and accessible healthcare. Adequately addressing the role that redlining has played in erecting systemic barriers, entrenching poverty among marginalized communities, and limiting economic mobility first requires the acknowledgment that such inequalities exist. Black children do not choose their race, family, or environment. Yet, these factors remain highly determinative of their future employment and income, effectively limiting their ability to enjoy the economic, social, cultural, civil, and political rights protected under international law.[104] And, in the United States, a nation of “such abundant resources,” this reality is frankly “neither inevitable nor acceptable.”[105]
[1] Cheryl I. Harris, Whiteness as Property, 106 Harv. L. Rev. 1707, 1716 (1993).
[2] Shaker et al., Redlining, Racism and Food Access in US Urban Cores, 40 Agric. & Hum. Values. 101, 103 (2022).
[3] Bruce Mitchell, HOLC “Redlining” Maps: The Persistent Structure of Segregation and Economic Inequality, Nat’l Cmty. Reinvestment Coal. (Mar. 20, 2018), https://ncrc.org/holc [https://perma.cc/5Y8J-XW79].
[4] Shaker et al., supra note 2.
[5] Id.
[6] Id.
[7] Id.
[8] Shaker et al., supra note 2, at 101.
[9] Harris, supra note 1, at 1716.
[10] Id. at 1721.
[11] Id. at 1726.
[12] Id. at 1721.
[13] Id. at 1713, 1716.
[14] Roy W. Copeland, In the Beginning: Origins of African American Real Property Ownership in the United States, 44 J. Black Stud. 646, 649 (2013).
[15] Id. at 646.
[16] Id.
[17] Harris, supra note 1, at 1721.
[18] Carolyn B. Swope, The Relationship of Historical Redlining with Present-Day Neighborhood Environmental and Health Outcomes: A Scoping Review and Conceptual Model, 99 J. Urb. Health, 959, 959-60.
[19] Mitchell, supra note 3.
[20] Id.
[21] Shaker et al., supra note 2, at 103.
[22] Id.; Dita Cahyani & Lilis Widaningsih, Identification of the Marginalized Urban Communities Characteristics and Preferences, 2019 KnE Soc. Sci. 178, 179 (2019).
[23] Jesse Meisenhelter, How 1930s Discrimination Shaped Inequality in Today’s Cities, Nat’l Cmty. Reinvestment Coal. (Mar. 27, 2018), https://ncrc.org/how-1930s-discrimination-shaped-inequality-in-todays-cities [https://perma.cc/NR7L-KB5S].
[24] Mitchell, supra note 3.
[25] Meisenhelter, supra note 23.
[26] The Poverty Rate Among Black Americans Increased in 2023, J. Blacks Higher Educ. (Sept. 30, 2024), https://jbhe.com/2024/09/the-poverty-rate-among-black-americans-increased-in-2023 [https://perma.cc/6RY4-TKTW].
[27] Janie Boschma & Ronald Brownstein, The Concentration of Poverty in American Schools, The Atl. (Feb. 29, 2016), https://www.theatlantic.com/education/archive/2016/02/concentration-poverty-american-schools/471414 [https://perma.cc/4VYD-3AE8].
[28] LaToya Baldwin Clark, Stealing Education, 68 UCLA L. Rev. 566, 628 (2021).
[29] Jason Fenster, Education is Key to Public Safety, Just. Pol’y Inst. (Feb. 15, 2012), https://justicepolicy.org/press/education-is-key-to-public-safety [https://perma.cc/7ZDG-8AKX].
[30] Janaya Trotter Bratton & Rickell Howard Smith, Growing up a Suspect: An Examination of Racial Profiling of Black Children and Effective Strategies to Reduce Racial Disparities in Arrests, 45 N. KY. L. REV. 137, 149-50 (2018).
[31] Dee Gill, Research Brief, Police Patrol Black Areas More Frequently Than Others with Similar Homicide Rates and Income Levels, ULCA Anderson Rev., https://anderson-review.ucla.edu/smartphone-records-reveal-racial-disparities-in-neighborhood-policing [https://perma.cc/4PHN-J6B6].
[32] Bratton, supra note 30, at 154.
[33] Cullen et al., Children and Racial Injustice in the United States: A Selective Annotated Bibliography and Call to Action, 41 Child. Legal Rts. J. 1, 4 (2021); Bratton, supra note 30, at 158-59; Farzana Akkas & Allison Corr, Black Adolescent Suicide Rate Reveals Urgent Need to Address Mental Health Care Barriers, Pew, https://www.pewtrusts.org/en/research-and-analysis/articles/2024/04/22/black-adolescent-suicide-rate-reveals-urgent-need-to-address-mental-health-care-barriers [https://perma.cc/Q9YE-ZS34].
[34] Tracy Hadden Loh et al., The Great Real Estate Reset, Separate and Unequal: Persistent Residential Segregation is Sustaining Racial and Economic Injustice in the U.S., Brookings (Dec. 16, 2020), https://www.brookings.edu/articles/trend-1-separate-and-unequal-neighborhoods-are-sustaining-racial-and-economic-injustice-in-the-us [https://perma.cc/SZF3-WN2L].
[35] Clark, supra note 28, at 570; See “De facto” segregation is a term used to describe a situation in which legislation does not “overtly segregate” people by race, but segregation nevertheless continues. See “de facto segregation,” Cornell Law School Legal Information Institute, https://www.law.cornell.edu/wex/de_facto_segregation [https://perma.cc/8VVM-UW3X].
[36] Id. at 571.
[37] Universal Declaration of Human Rights, Dec. 10, 1948, U.N. [hereinafter Universal Declaration], https://www.un.org/en/about-us/universal-declaration-of-human-rights [https://perma.cc/SN75-2PSR].
[38] Id., at art. 25-26.
[39] International Covenant on Social and Cultural Rights, Dec. 16, 1966, U.N. [hereinafter International Covenant], https://www.ohchr.org/sites/default/files/cescr.pdf [https://perma.cc/XS72-KJXP].
[40] Ann M. Piccard, Abstract, The United States’ Failure to Ratify the International Covenant on Economic, Social and Cultural Rights: Must the Poor Be Always with Us., 13 The Scholar 231 (2010).
[41] Id.
[42] Id.
[43] Id.
[44] Cullen et al., supra note 33, at 1.
[45] Cullen et al., supra note 33; Bratton, supra note 30.
[46] Areeba Haider, Report, The Basic Facts About Children in Poverty, Ctr. Am. Progress (Jan. 12, 2021), https://www.americanprogress.org/article/basic-facts-children-poverty [https://perma.cc/UQ8F-A6U6].
[47] Id.
[48] Id.
[49] Id.
[50] Jessica Dixon Weaver, Beyond Child Welfare – Theories on Child Homelessness, 21 Wash. & Lee J. C.R. & Soc. Just. 16, 27 (2014).
[51] Id. at 31.
[52] Id. at 28.
[53] 15 Misc. 3d 606 (2007).
[54] Id.
[55] Cullen et al., supra note 33, at 6.
[56] Id. at 4.
[57] Id.
[58] Shaker et al., supra note 2, at 102.
[59] Id.
[60] Id.; see also Hannah Elmore et al., “It’s expensive To Be Poor”: The Underlying Causes and Impact of Macon’s Food Deserts, Macon Newsroom (May 20, 2021), https://macon-newsroom.com/10250/arts-entertainment-2/food/its-expensive-to-be-poor [https://perma.cc/ZA76-FNA3].
[61] Elmore et al., supra note 60; Kelly Bower et al., The Intersection of Neighborhood Racial Segregation, Poverty, and Urbanicity and its Impact on Food Store Availability in the United States, 58 Prev. Med. 33 (Jan. 2014), https://pubmed.ncbi.nlm.nih.gov/24161713 [https://pubmed.ncbi.nlm.nih.gov/24161713].
[62] Id.
[63] Elmore et al., supra note 60.
[64] Hunger & Poverty in America, Food Rsch. & Action Ctr. (last visited Sept. 21, 2024), https://frac.org/hunger-poverty-america#data [perma.cc/ESF2-TEA8].
[65] Elmore et al., supra note 60.
[66] Maria Melchior et al., Food Insecurity and Children’s Mental Health: A Prospective Birth Cohort Study, PLOS One (Dec. 26, 2012), https://doi.org/10.1371/journal.pone.0052615 [https://perma.cc/H4EL-NUMD].
[67] Healthy Meals Help Kids Learn Act, S. 3093, 118th Cong. § 2 (2023).
[68] How Does Hunger Affect Learning?, No Kid Hungry (April 24, 2023), https://www.nokidhungry.org/blog/how-does-hunger-affect-learning [https://perma.cc/LXP5-5UXY].
[69] Meisenhelter, supra note 23.
[70] Id.
[71] Elmore et al., supra note 60.
[72] Id.
[73] Mitchell, supra note 3.
[74] Health Disparity Zones Act, H.R. 6475, 118th Cong. § 2 (2023).
[75] Id.
[76] Food Deserts Act, H.R. 1230, 118th Cong. § 2 (2023).
[77] Id.
[78] H.R. 1230, 118th Cong. § 2; H.R. 6475, 118th Cong. § 2.
[79] Cullen et al., supra note 33, at 15.
[80] Id.
[81] 347 U.S. 483 (1954); Harris, supra note 1, at 1756.
[82] Clark, supra note 28, at 629.
[83] Id. at 566.
[84] Dionissi Aliprantis & Mukund Jayaram, K-12 Schools in Ohio are Separate and Unequal, Fed. Rsrv. Bank Cleveland (Oct. 16, 2023), https://www.clevelandfed.org/publications/economic-commentary/2023/ec-202316-k-12-schools-in-ohio-are-separate-and-unequal [https://perma.cc/6JFU-CGVT].
[85] 347 U.S. 483 (1954); Cullen et al., supra note 33, at 16.
[86] Emma Garcia, Schools are Still Segregated, and Black Children are Paying a Price, Econ. Pol’y Instit. (Feb. 12, 2020), https://www.epi.org/publication/schools-are-still-segregated-and-black-children-are-paying-a-price [https://perma.cc/F32S-W274].
[87] Aliprantis, supra note 84.
[88] Id.
[89] Id.
[90] Education Inequality: K-12 Disparity Facts, United Negro Coll. Fund, https://uncf.org/pages/k-12-disparity-facts-and-stats [https://perma.cc/7KAD-79B9].
[91] Garcia, supra note 86.
[92] 347 U.S. 483 (1954).
[93] Your Level of Education Correlates with your Credit Score, RentPlus (last visited Nov. 1, 2024), https://www.rentplus.com/2017-9-20-your-level-of-education-correlates-with-your-credit-score [https://perma.cc/YS5Y-V58C].
[94] Id.
[95] Examining Educational Redlining Act, H.R. 8142, 118th Cong. § 2 (2024).
[96] Id.
[97] Minority Entrepreneurship Grant Program Act, H.R. 6457, 118th Cong. § 3 (2023).
[98] Restoring Communities Left Behind Act, H.R. 837, 118th Cong. §§ 2-3 (2023).
[99] Id.
[100] Id.
[101] Haider, supra note 46.
[102] International Covenant, supra note 39; Universal Declaration, supra note 37.
[103] Piccard, supra note 40.
[104] International Covenant, supra note 39.
[105] Piccard, supra note 40.