In Milliken the Court has held that desegregation stops just short of the school district line. To require that school districts be merged to effect a racial balance, one of two factors must exist: a showing that the school district lines have been deliberately drawn to separate the races, and evidence that discriminatory acts in one district produce segregation in another district. A major revelation was the Court's position that a state is not necessarily accountable for the actions of one of its local agencies, the school district. This holding may well have implications for future litigation, not only in the area of desegregation but in all of education. The immediate impact of the decision will be to slow down desegregation in both North and South. The decision does not, however, foreshadow a slowdown of desegregation within individual cities. It is likely that the strategy for the next few years will be to concentrate on desegregation in small or medium-sized cities where a case for a dual system can be easily made and where the task of converting to a unitary system will be considerably easier than in a very large city. (Author/IRT)