The legacies of the US Civil Rights Act, fifty years on

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Content: Political Geography 48 (2015) 159e168 Contents lists available at ScienceDirect Political Geography journal homepage: Intervention The legacies of the U.S. Civil Rights Act, fifty years on Caroline Nagel a, *, Josh Inwood b, Derek Alderman c, Ujju Aggarwal d, Claire Bolton e, Steve Holloway e, Richard Wright f, Mark Ellis g, Priscilla McCutcheon h, Katherine Hankins i, Andy Walter j, Kate Derickson k a Department of Geography, University of South Carolina, USA b Department of Geography and Africana Studies Program, University of Tennessee, Knoxville, USA c Department of Geography, University of Tennessee, Knoxville, USA d Institute for Urban Policy Research and Analysis, University of Texas at Austin, USA e Department of Geography, University of Georgia, USA f Department of Geography, Dartmouth College, USA g Department of Geography, University of Washington, USA h Department of Geography/Geosciences and Pan African Studies Department, University of Louisville, USA i Georgia State University, USA j Department of Geosciences, University of West Georgia, USA k Department of Geography, Environment, and Society, University of Minnesota, USA
article info Article history: Available online 4 August 2015 Keywords: Civil Rights Act Civil Rights Movement Race Housing Marriage Education Mobility Black church Faith-based organizations Introduction Civil rights and the emergence of a `colorblind' United States Caroline Nagel, Department of Geography, University of South Carolina, USA. During the 2013e2014 academic year the University of South Carolina (USC) commemorated the 50th anniversary of the university's desegregation with a series of events and ceremonies. Speakers at the dedication of a garden memorializing desegregation at USC described the progress that had been made since three Black1 students registered for classes at the start of 1963 academic * Corresponding author. E-mail address: [email protected] (C. Nagel). 0962-6298/© 2015 Elsevier Ltd. All rights reserved.
year, becoming the first Black students at USC since the post-Civil War Reconstruction period (1865e1877). USC certainly has become more inclusive place, with studentseBlack, white, Latino, Asiandsharing dorm rooms, recreational facilities, and classroom space in a way that would have been unimaginable before the passage of Civil Rights legislation. Yet even as we celebrate this progress, we must reflect on the ways in which equality has been hindered by the insistence, voiced mainly by whites, that racial differences are no longer meaningful. The purpose of this intervention, therefore, is to explore the ambivalent legacies of the Civil Rights Movement and to consider how the Civil Rights Act of 1964 might be understood both as a triumph of Black struggle and as a moment of white retrenchment. The Civil Rights Act, and the broader struggle for racial equality from which it emerged, can be interpreted through different geographical lenses. The Act was, in the first instance, a turning point in the history of U.S. South: the elimination of the Jim Crow system of racial separation, which was created after the abolition of slavery to ensure white domination in all realms of life. racial discrimination, to be sure, was a reality throughout the U.S., as was the struggle for racial justice (Tyner, 2006). But the most dramatic acts of resistance of the Civil Rights eradfrom lunch counter protests to bus boycotts to the famous March on Selmadtook place in the South and were directed against the exceptional modes of institutionalized racism that existed there. There was, at the same time, an important global dimension to the Civil Rights Movement. Martin Luther King, Jr. and other Civil Rights leaders had been inspired by the non-violent, anti-colonial resistance movement led by Mohandas Gandhi in India, and many Civil Rights activists linked their struggle to anti-colonial struggles in Africa. White political leaders in the U.S., meanwhile, regarded the broadcasting of white brutality against Black Civil Rights protestors as a serious threat to
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America's global prestige. The government's advocacy of Civil Rights seemed motivated less by a commitment to racial equality than a need to assert moral authority as leader of the "free world" in the ideological battle against Communism (Borstelmann, 2000; Fraser, 2000). The Civil Rights struggle and its legacies can further be interpreted against a backdrop of post-war metropolitan restructuring in the U.S. Federal housing policies from the Great Depression (1929e1939) onward had heavily subsidized suburbanization in U.S. cities while protecting white privilege in new residential neighborhoods through redlining and the sanctioning of racially discriminatory protective covenants (Jackson, 1985; Self, 2006). In the post-World War II "New South," city growth machines pursued particularly aggressive residential and industrial decentralization policies to ensure that whites would not be required to integrate with Blacks even with court-ordered desegregation. As they became more suburbanized, Southern cities increasingly resembled their counterparts in the North and Midwest, becoming more, not less, segregated in the late 20th century (Massey & Denton, 1993). Segregation through suburbanization was abetted nationwide by post-war urban renewal policies that ensured the residential containment of Blacks in inner cities. These policies included the construction of spatially concentrated public housing and the placement of expressways to block Black expansion into white neighborhoods. Moreover, the funneling of billions of dollars of federal Defense spending into outlying and predominantly white areas all but guaranteed that inner cities and predominantly Black neighborhoods in U.S. cities would be trapped in a downward spiral of disinvestment (O'Mara, 2006). The dismantling of Jim Crow signaled the emergence of a nationwide ideological discourse that interpreted these ever more glaring urban inequalities in terms of "natural" filtering processes and the exercise of "freedom of choice" in (sub)urban housing markets. This discourse animated white suburban resistance to efforts by state and federal courts to enforce desegregation in U.S. cities, most notably through school busing. Anti-busing activists, Lassiter (2004, 550) argues, successfully "recast the legal debate over the historical burdens of racial discrimination into an ahistorical defense of meritocratic individualism" and "normalized pervasive patterns of spatial inequality by refusing even to acknowledge the structural legacies of racial and residential segregation." This same populist impulse drove the suburban tax revolts of the 1970s and eventually ushered in the "Reagan Revolution." In the supposedly meritocratic, individualistic, colorblind U.S. of the 1980s, welfare became a cause, rather than a consequence, of poverty, and minority communitiesdincreasingly isolated and impoverished after decades of urban disinvestment, discrimination, and deindustrializationdwere blamed for their own predicament. The language of colorblind meritocracy, with its assumption of white racial innocence, continues to uphold unequal socio-spatial arrangements in the U.S. and to leave intact racialized ways of thinking that consistently value white lives over non-white lives, whether in the U.S. or abroad (Olds, Sidaway, & Sparke, 2005). Ideas of colorblindness in the U.S. (and in other racially divided societies) have been complemented by what Mary Thomas (2011) calls "banal multiculturalism"da discourse that invites appreciation of cultural differences while insisting on essential human sameness. Banal multiculturalism deploys "culture" as an explanatory category and celebrates meritorious members of "cultural" groups for their ability to overcome personal (as opposed to societal) hardships. As such, banal multiculturalism works to discourage frank discussion about racism and widening income inequalities. Through the lens of banal multiculturalism, the Civil Rights Act is characterized as a moment of redemption in U.S. historyda
definitive break from the past that allowed Blacks to be fully woven into the national fabric. This perspective effectively transforms the Civil Rights Movement from an on-going story of Black struggle to a story of whites' success in overcoming their irrational prejudices to create a more meritocratic society. This narrative encourages white people to cast themselves as the saviors of Black peopleda phenomenon seen in Hollywood films like The Blind Side (2009) and The Help (2011). U.S. society, in short, is deeply invested in the idea that race doesn't matter, and politicians, employers, teachers, preachers, and university administrators (among others) have sought to render race innocuous through the language of cultural difference and diversity. On those occasions when whites are forced to confront the uncomfortable truth that race does matterdwhen they must listen to and witness the anger of people of colordthey often throw back accusations of divisiveness, incivility, and indeed, racism. This intervention considers the ways in which U.S. society continues to operate through systems of racial privilege long after the dismantling of formal segregation. The first three interventions (by Inwood and Alderman, Holloway and Bolton, and Aggarwal) suggest that Civil Rights legislation has largely failed to secure full inclusion and societal membership for people of color, not least because the framers of Civil Rights-era legislation never intended to challenge white racial entitlements in the South or anywhere else. Whether in the housing sector, the educational system, or in the realm of mobility rights, we see not only entrenched inequalities, but also a tendency to attribute these inequalities to factors other than racism, thereby allowing them to persist. The three contributions that follow strike a more hopeful note, reminding us that the Civil Rights Act was an astounding triumph by a longsubordinated group against a violent, white supremacist orderda triumph that continues to inspire subordinated groups in the U.S. and abroad. Wright, Ellis, and Holloway demonstrate how Civil Rights-era court decisionsdnamely, the overturning of antimiscegenation lawsdhave framed contemporary struggles for marriage equality among same-sex couples. McCutcheon and Hankins, et al., explore the continued relevance of Black faith-based organizations and spirituality in articulating claims of social justice in U.S. cities. Their contributions prompt us to think about the ways that a variety of faith-based groups and belief systemsdChristian and non-Christiandmay help to shape cities and societies along more equitable lines by directly addressing poverty and racism. These contributions collectively honor the Civil Rights Act by rejecting the language of colorblind meritocracy, by re-centering race in analyses of local, national, and international politics, and by shedding light on the unfinished business of racial justice. Civil Rights and the right of mobility: a neglected geographic agenda Josh Inwood, Department of Geography and Africana Studies Program, University of Tennessee, Knoxville. Derek Alderman, Department of Geography, University of Tennessee, Knoxville. Engagement with the Civil Rights Act of 1964 requires an understanding the socio-spatial transformations that were occurring during the late 1950s and early 1960s, when African Americans and others rose up to challenge geographies of discrimination and apartheid. This apartheid was built upon not just white privilege but white supremacy, a term that geographers have not used nearly enough to describe both the subtle and blunt force of racist white control. White supremacy, as a normative and often violent force, has exerted a powerful influence on U.S. economic, political, and cultural developmentdfrom the genocidal
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geographies of native removal coupled with slavery to the contemporary, yet no less caste-like, prison-industrial complex (Alexander, 2012). These racialized realities, rather than a social aberration, are foundational to the U.S. political landscape (Schein, 2012). Understanding this fact fosters an appreciation of the transformative nature of the Civil Rights Act, as well as its limitations. The Civil Rights Act made more meaningful changes to the racialized landscape of the United States than any piece of congressional legislation in the nation's history. Yet with notable exceptions (e.g. Dwyer, 2002; Young, Pinkerton, & Dodds, 2014), geographers have not fully grappled with the political contradictions and tensions resulting from the Act, despite the discipline's strong commitment to social justice. Here, we propose mobility as one lens through which to consider the significance of the Civil Rights Act for the spatial (re)organization of white supremacy and resistance to it. Rather than an unproblematic fact of life, mobility is a "resource that is differentially accessed," and this access is inextricably tied to social relations and the exercise of power (Cresswell, 2010, 166). As Hague (2010, 331) notes, the "right of mobility" in the U.S. has been linked to citizenship and "fundamentally intertwined with the construction of racial identities." At the urban scale, the right to the city is often realized through one's right to mobility. Moving on one's own terms is about exercising a right to appropriate, occupy, and produce urban space; therefore racialized struggles "over how the city should be organized and for whom" often center on questions of mobility (Henderson, 2006, 295). During the Jim Crow era of institutionalized segregation and discrimination, vagrancy laws and other legal sanctions were used to restrict and to regulate Black mobility and migration and to keep Blacks in "their place" socially and geographically (Blackmon, 2009). Institutionalized segregation and controls on Black mobility supported the broader political economy of sharecropping and Black labor exploitation that had replaced slavery after the U.S. Civil War (Morrill & Donaldson, 1972). It must be remembered that African Americans consistently resisted limitations on their movement through "counter-mobilities"dfrom the escape from slavery to the post-emancipation Great Migration out of the South, and from the bus boycotts and freedom rides of the Civil Rights Movement to campaigns against the construction of interstate highways through Black neighborhoods in the 1960s and 1970s (Bullard, Johnson, & Torres, 2004). Nonetheless, Blacks felt the full weight of segregation while travelingdon busses, trains, and streetcars, and in roadside hotels, restaurants, and gas stations that refused to serve Black drivers. The Civil Rights Act promised to change the politics of Black (im)mobility by redefining the right to move through space and by providing legal tools to challenge the designation of space as "white-only." Title II of the Civil Rights Act, for instance, outlawed racial discrimination in hotels and other places of public accommodationda practice, it must be noted, that was not limited to the South. Yet unfettered geographic mobilitydand the access to social and economic opportunities that comes with itdhas not yet been fully realized by racialized minorities in the U.S. Critical engagement with the legacy of the Civil Rights Act thus begins with attention to the biopolitics of mobilitydthat is, the ways in which (im)mobility becomes intertwined with "the political negotiation of life" and the survivability of vulnerable populations (Tyner, 2013, 702). In short, the exercise of control over mobile Black bodies has a profound bearing on the existence and vitality of these bodies. Recent news headlines provide ample evidence of the life-and-death consequences of African Americans' spatial "transgressions". Trayvon Martin's death at the hands of George Zimmerman can be read as a story of the excesses of neighborhood watch programs and the injustice of "Stand Your Ground" laws, which permit individuals to
use deadly force against a perceived threat. But at a more basic level it is a lesson about the racialized biopolitics of mobility and a reminder that the free movement Black people, and especially that of young Black men, continues to be judged as threatening in the U.S. By killing Martin, Zimmerman made visible white society's continued anxieties about Black mobility. Trayvon Martin's mobilitydand how it was interpreted in relation to his racial identitydclearly shaped his vulnerability to violence and ultimately his non-survivability. Ironically, the violence inflicted upon Martin by Zimmerman took place on a sidewalk, a common site of white racial control and Black resistance during the Jim Crow era. Segregation laws dictated that African Americans step off the sidewalk for whites, something that Blacks did not always do (Loukaitou-Sideris & Ehrenfeucht, 2009). The biopolitics of mobility, then and now, play out on city streets, as well as the open highway. This is no more apparent than when examining the biopolitics of "driving while Black," a popular term that captures the disproportionate number of times that police stop Black drivers for minor violations or searches for contraband. According to Meehan and Ponder (2002, 401), racial profiling and stopping by police "significantly increases as African American [drivers] move farther from stereotypically `Black' communities and into wealthier, whiter areas"dwhat they call the "race-andplace effect". The result of racial profiling for Black communities has not just been more traffic citations but also insults, humiliation, arrests, and even violence and death. "Stop and frisk" policies popularized in New York City, whereby police stop and interrogate mainly young men of color with little or no pretext, have had similar effects. Recent geographical scholarship highlights that the immobilizing effects of policing methods are felt not only by African Americans, but also by Latinos, who are increasingly subject to aggressive immigration-enforcement tactics including roving police checkpoints (Stuesse & Coleman, 2014). Given the significant amount of work that geographers have contributed over the years to mapping and analyzing the activity spaces and mobility patterns of urban residents, it is troubling to find so little engagement with mobility as a matter of civil rights or social justice. This lack of engagement allows for the policing of Black (and Latino) mobility to be framed in the supposedly neutral language of law enforcement policy. Reclaiming the emancipatory promise of the Civil Rights Act requires the politicization of racialized policing in the U.S. and greater attention by scholars to the ways in which differentiated mobilities reflect and reinforce social inequalities. School choice: freedom, rights, and the logic of exclusion Ujju Aggarwal, Postdoctoral Fellow, Institute for Urban Policy Research and Analysis, University of Texas at Austin. Choice-based education policies are often linked to the turn toward neoliberal education reform, signaled by the Reagan Administration's publication of the 1983 report, A Nation at Risk: The Imperative for educational reform (Gardner, 1983). Critical scholarship on neoliberal education reform views the concept of choice as integral to the marketization and privatization of education, especially through charter schools, and to the promotion of a consumeroriented model of citizenship (Ball & Youdell, 2007; Lipman & Hursh, 2007). But while linked to neoliberalism, the emergence of choice as a key principle of education reform in the U.S. can be traced back decades earlier to the legal battles over school desegregation. This intervention extends the historical timeline of educational reform to show how consumer-oriented citizenship and the use of market-based logics to reorganize publically owned assets took shape in the aftermath of the Civil Rights movement.
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As is well known, the Supreme Court's 1954 decision in Brown v. Board of Education of Topeka determined that separate schools could never be equal. The Brown decision signified a moment when people of color won universal rights to access education. Yet the specific way in which rights were configured after Brown ensured that public education, while universally accessible, would continue to be one of the most unequal institutions in the United States. After Brown, the question remained as to how and when desegregation would be carried out. The Supreme Court addressed this question in Brown II (1955), yet failed to provide clear guidance about how desegregation should take place. Instead, the Court granted states and municipalities the freedom to develop their own implementation plans. In 1955, as a response to Brown, economist Milton Friedman set forth a vision for the restructuring of public education that, he argued, would reconcile the Brown mandate to desegregate schools with the preservation of individual freedoms and civil liberties. While state-sanctioned segregation, Friedman reasoned, was morally wrong, state-enforced desegregation might impede an individual's right to choose the most appropriate education for his or her child and was therefore equally problematic. This conundrum could be fixed, Friedman argued, by the principle of choice, which Friedman construed as flexibility in the exercise of democratic rights: parents who were unhappy with a particular school would have the freedom to withdraw their child and reinvest in a range of optionsdprivate, public, religious, socially `selective'dthat better suited their needs. Guaranteeing rights with flexibility would provide what Friedman called a "third alternative" to forced segregation or forced desegregation (Friedman, 1955). In the wake of Brown, Friedman's theory of choice, based on preserving the co-constitutive relationship between individual freedom and capitalism, came to animate a diverse range of policy reforms and practices. These have included the creation of `segregation academies' in the South (private all-white schools subsidized by the state through tax-exempt status); the deliberate drawing of school zone lines to maintain `local' control over schools (supported by the Supreme Court's 1974 Milliken decision, which relieved state and municipal governments of culpability for segregation in the absence of explicit intent); the development of charter schools, magnet schools, and voucher programs; the passage of the No Child Left Behind Act (2001); and most recently, the Race to the Top Fund, which ties federal funding for schools to the implementation of choice-based policies. These choice-based reforms have failed to bring greater equity to communities that have long been underserved by public education. Nevertheless, both liberals and conservatives continue to hold up school choice as a panacea for inequality and as the quintessence of American freedom. Yet this version of freedom has been qualified by the right to exclude, a right that has remained constant in spite of the winning of universal rights. The right to exclude animates what critical race theorist Cheryl Harris terms Whiteness as property: the continued inscription of histories of slavery and genocide into racially contingent forms of property and rights that preserve whiteness as the baseline for citizenship (Harris, 1993). Friedman understood this interplay between choice and exclusion in a liberal, capitalist society and was keenly prescriptive about the structuring of private, individual choices as rights within the public realm. Indeed, while Brown I indicated the end of state-enforced segregation, Brown II ensured that the same endsdthe structuring of whiteness as property embedded within the statedwould be achieved through different means, through choice. The year 2014 marked the 60th anniversary of Brown, as well as the 50th anniversary of the Civil Rights Act. Commemorations of such landmark events offer very different possibilities for interpreting the significance of the Civil Rights movement. On the one
hand, we might reflect on the past as history. From this perspective Brown can be understood as a turning point in U.S. historydthe culmination of struggle and a moment when the wrongs of exclusion were made right. Adopting this perspective of Civil Rights-ashistory, proponents of school-choice policies assert that inequality would be solved if parents and students only made proper use of their rights by making appropriate choices. The assumption here is that inequality is the consequence of "bad" or uninformed choices made by individuals within a system of "fair" and democratic options. On the other hand, remembering Brown and the Civil Rights Act offers us the chance to reflect more critically on our contemporary contexts. For over a decade, I worked as a community organizer in New York City's Community School District 3 (CSD3), the most racially and economically diverse school district in the largest school system in the U.S. There are two other characteristics that set CSD3 apart: it is among the districts that provide the most "choice" to parents as to where they might send their children to school, and it is one of the most segregated and unequal districts in New York City (Aggarwal, 2013; Kucsera & Orfield, 2014). Between 2009 and 2012 I conducted ethnographic research in this same district, examining how mothers of different economic means navigate the process of choosing an appropriate elementary school for their children. For the low-income mothers of color I accompanied throughout my organizing and research, CSD3's choice policies (which include charter schools, magnet programs, gifted and talented education, dual-language programs, and more) translate to exclusion, despite rights, across a range of schools, including non-charter public schools. This remains true regardless of the wealth of knowledge, immeasurable care, and high aspirations for achievement that these women hold for their children. Their persistence on an everyday basis and in multiple ways to secure a decent education for their children is informed by a particular knowledge, confirmed by a recent study from the Robert Wood Johnson Foundation, that premature death is significantly determined by access to education, which is highly stratified by race and class (Tavernise, 2012). These mothers have joined together and have organized for the desegregation of their schools. Theirs is not a new fight, but a renewed fight for freedom of a different kind. Their efforts illuminate an alternative commemoration of the Civil Rights movement, one that enlivens legacies of struggle by more critically examining and engaging our contemporary moment. Exclusion, segregation, and exploitation: the limited impacts of Civil Rights housing legislation Claire Bolton and Steve Holloway, Department of Geography, University of Georgia. Unjust housing policies and practices have long been a lynchpin of racial inequality in the United States. Fifty years after the mass movement for racial justice that culminated in the Civil Rights Act (1964) and the Fair Housing Act (1968), we continue to find housing practices that ultimately deepen segregation and disparities in wealth accumulation. To be blunt, racially unjust housing policies and practices have served as an effective mechanism of wealth theft, insofar as the ability of whites to accumulate capital through real estate has been predicated upon the segregation of Blacks in high-poverty, inner-city and suburban neighborhoods. Excluded from mainstream mortgage markets, Black neighborhoods have become convenient loci for exploitative financial practices, including "predatory inclusion," or the granting of access to credit markets and homeownership in ways that exploit minority and low-income people (McNally, 2011, 123).
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Wyly et al. (2012) argue that what once were distinctly racist housing processes in the U.S. have been coopted and transformed by deregulated financial markets. They note, for instance, that the highvolume requirements associated with mortgage-backed securities encouraged the expansion of subprime mortgage lending practices into white communities, unsettling existing racial formations. Yet one can just as easily focus on the continuities of housing regimes and the long trajectory of wealth inequality between Blacks and whites that is rooted in entrenched patterns of housing discrimination and previous cycles of predatory inclusion. Analyzing racial economic disparities in terms of wealth is meaningful because "the command over resources that wealth entails is more encompassing than is income or education ... [Wealth] captures inequality that is the product of the past" (Oliver & Shapiro, 2006, 2). Given that homeownership forms the foundation of most Americans' wealth, housing discrimination powerfully shapes racialized wealth inequalities. Such has been the relationship between housing inequalities and wealth discrepancies that Ta-Nehisi Coates (2014) makes a case for reparations to Black communities on the basis of housing discrimination, as well as the grim history of enslavement. The effects of institutionalized redlining in the United States, which starved Black neighborhoods of investment from the 1930s onward, are particularly well-documented (e.g. Hernandez, 2009). There were, however, many other mechanisms by which Blacks were excluded from the post-war expansion of homeownership and the concomitant accumulation of white wealth. One such mechanism was blockbusting, which involved generating fear among whites that their neighborhoods would "turn" Black. Speculators convinced whites to sell their homes cheaply, and then sold these homes to Blacks at much higher prices. Unable to access mainstream mortgages, Blacks accepted mortgage contracts that provided no equity and that allowed easy eviction upon default. Blacks soon realized that their newly purchased homes came with unaffordable payments and were of far inferior quality to similarly priced white homes. With the passage of the Fair Housing Act of 1968 and subsequent housing legislation, the federal government shifted its role from guarantor of racial exclusion to, at least nominally, the protector of racialized minority groups against racial exclusion. However, while Fair Housing legislation ended federally sanctioned redlining, the practice continued in private lending institutions well into the 1980s, as documented in Bill Dedman's (1988) pulitzer prizewinning "The Color of Money" series in the Atlanta Journal Constitution. Journalists and scholars also documented geographically rooted discriminatory practices like the "steering" of Black homebuyers away from white neighborhoods and towards inner-city Black neighborhoods. In the run-up to the 1980s savings and loan (S&L) crisis, lenders systematically redlined communities of color in spite of Fair Housing laws. One reason such practices persisted is that the Civil Rights laws passed in the late 1960s were stripped of their enforcement mechanisms as part of the political wrangling necessary to pass the legislation. At the same time that developers, real estate agents, and municipalities routinely circumvented Fair Housing laws, the federal government in the 1980s and 1990s facilitated a shift to predatory inclusion. During this period, urban redevelopment block grants flowed into depressed inner-city neighborhoods, spurring the construction of low-to middle-income housing through private developers and non-profit housing corporations (Newman & Ashton, 2004). As well, Congress in 1992 passed the Federal Housing Enterprises Financial Safety and Soundness Act (FHEFSSA), which set "affordable housing goals" for Fannie Mae and Freddie Mac. All of this took place against a backdrop of banking sector deregulation. These shifts in the 1980s and 1990s produced an ambiguous record on race and housing issues. Blacks and Latinos
gained access to homeownership, but at a price. Speculators, for instance, used federal funds to perform bogus rehabilitations on houses that were then sold at high prices to unsuspecting homebuyers who would later face high-cost repairs (Galster, 1996). Meanwhile, neoliberal banking reforms made higher-risk loans lucrative, and predatory practices proliferated alongside "competitive" mortgage lending. Lenders steered Blacks living in segregated neighborhoods, historically isolated from mainstream financial institutions, towards subprime loans (Rugh & Massey, 2010). Shapiro, Meschede, and Osoro (2013, 4) note that leading up to the foreclosure crisis, "borrowers of color were consistently more likely to receive high-interest risky loan products, even after accounting for income and credit scores" than were white borrowers. The result of such predatory lending (along with other dubious financial practices) was a housing market crash, a foreclosure crisis, and a recession from which the U.S. economy has yet to recover. This crash viciously reversed gains made in previous decades, though even in the heyday of the housing boom, the wealth gap between Black and White Households had remained wide. Between 2005 and 2010, Black households lost more than half their median net worth, while white households shed only about 16 percent (Kochhar, Fry, & Taylor, 2011). People of color remain at the margins of housing markets in the United States, facing housing exclusion on multiple fronts. Many would-be minority homebuyers again struggle to obtain loans after the subprime crisis. Meanwhile, renters continue to live in poor housing in segregated areas, as policies meant to de-concentrate povertydincluding the controversial HOPE VI program that funds the restructuring of public housing and the Moving to Opportunity (MTO) program designed to move public housing residents into better neighborhoodsdhave been largely ineffective. Even people of color who purchase a home consistently find themselves in segregated neighborhoods with lower levels of home equity than whites (Shapiro et al., 2013). Exclusion alone, however, has not created the current situation of housing inequality in the United States. Rather, we understand the combination of exclusionary actions with predatory inclusiondthe purposeful profiting from the disadvantaged position of minorities in housing and financial marketsdas forming the central dynamic of housing inequality. The cataclysmic effects of the subprime mortgage crisis on black and Hispanic wealth remind us that the openings of the post-Civil Rights era did not create a linear path of progress from exclusion, but instead reconfigured dynamics of marginalization and inequality. Geographical research on housing markets and racialized urban space must give further attention to this cycle of predation and restriction and its role in exacerbating wealth disparities in the U.S. Likewise, geographers should more explicitly connect housing discrimination to other pressing racial issues, such as police violence and mass incarceration. Finally, on a more hopeful note, geographical scholarship should critically analyze governmental and non-governmental initiatives to redress longstanding forms of discrimination and to achieve racial justice in the housing sector (see Hankins, et al.'s intervention below). Loving's legacies Richard Wright, Department of Geography, Dartmouth College. Steve Holloway, Department of Geography, University of Georgia. Mark Ellis, Department of Geography, University of Washington. The 1964 Civil Rights Act was a pivotal moment in the struggle toward racial justice in the U.S.dthe point at which the federal
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government took a definitive stance on the side of racial equality. The Act reshaped interactions between whites and people of color, most notably by eliminating formal segregation in public places. But changes in rights also reached into more intimate spaces, including marriage. In 1967 the Supreme Court in Loving v. Virginia struck down state-level restrictions on interracial marriage. As in other realms, the promise of full racial equality in matters of intimacy and love remains only partly fulfilled, borne out in the relatively low rates of intermarriage between Blacks and whites almost five decades after Loving. Despite its limitations in transforming intimate relationships, however, Loving has been a model and inspiration for advocates of same-sex marriage rights. Here we consider the legacy of Loving for intimate relationships and more specifically for the fuller achievement of marriage equality. Prior to Loving most states at one time or another had laws on the books prohibiting mixed-race marriages. This situation began to change after World War II, when the California Supreme Court ruled in Perez v. Sharp (1948) that the state's ban on interracial marriage violated the Equal Protection clause of the 14th Amendment. Between 1948 and 1965 twelve additional states overturned their anti-miscegenation laws, leaving seventeen statesdmost in the former Confederacydthat still prohibited marriage between people in various racial groupings. This geography ended with Loving. Richard Loving, a white man, married Mildred Jeter, who was Black, in 1958. Their ceremony took place in Washington, DC because Virginia, where they lived, still prohibited mixed-race marriages. A few weeks after their wedding, the Lovings were arrested in their home for violating Virginia's anti-miscegenation statutes and sentenced to jail. The Lovings took up the judge's offer to suspend the sentence if they left the state immediately, and they moved to Washington, DC. Washington, DC might have allowed mixed-race marriages, but all mixed couples faced discrimination, especially in the rental market. As their exile wore on them, Mildred Loving wrote to Attorney General Robert Kennedy explaining their predicament. Their case was eventually argued before the Supreme Court, which ruled unanimously in their favor citing the Equal Protection clause. While the ruling invalidated all remaining U.S. state laws banning interracial marriage, it took decades for some states (notably South Carolina and Alabama) to remove anti-miscegenation statutes from their books. The long-term impacts of Loving have been dramatic in some respects and modest in others. On the one hand, the number of mixed-race marriages increased substantially in the post-Loving years growing from 150,000 in 1960 to 1.6 million in 1990 to 3.9 million in 2010. If we count Latinos as a racialized group, then the number of mixed-race marriages in 2010 increases to 5.4 million, or 9.5% of all marriages. With 15% of recent heterosexual marriages crossing racial lines (Wang, 2012), the total mixed-race marriage rate will soon pass the 10% level. On the other hand, patterns of mixed marriages reveal the persistence of racial barriers to intimacy, particularly between Blacks and whites. While 17.5% of married Asians and 20.6% of married Latinos were partnered with someone outside their group in 2010, only 9.2% of married Blacks and 4.4% of married whites were in mixed marriages in 2010. These rates have geographies. Mixed-race marriages are more prevalent in states and metropolitan areas with disproportionately large Asian and Latino populations (American Community Survey, 2010). Some patterns of intermarriage can be explained by group sizedthat is, members of a numerically dominant group are more likely to have romantic contact with others like themselves. With whites representing about two-thirds of the U.S. population in 2010, they are less likely to be in mixed-race marriages than smaller groups. But the mathematics of race and race mixing is never simple. Group size alone cannot explain why the Black mixed-race marriage rate is
relatively low. Latinos and Blacks are approximately equal in population but the former had over twice the mixed-race marriage rate of the latter in 2010. Nevertheless, despite the persistence of barriers to interracial intimacy, there are signs that historical proscriptions against Blackwhite intermarriage continue to diminish. Latino and Asian newlyweds are still much more likely than Blacks to be in mixed-race marriages (25.7% of Latinos and 27.7% of Asians in 2010), but the data suggest a gradual rise in the mixed-race marriage rate for newlywed Blacks, climbing to 17.1% in 2010 (Wang, 2012). If the Black intermarriage rate continues to increase while Asian and Latino rates stall or decline (likely as these populations grow and the availability of within-group marriage partners increases), then the mixed-race marriage rates for Blacks will inch closer to the rates for these two groups. The Loving decision occurred when marriage was more prevalent than it is today, and concerns about patterns of intermarriage may seem misplaced at a time when the significance of marriage as a social institution is diminishing. In 1960, 72% of U.S. adults were married, and getting married was an important early-adult life transition. The denial of that transition to mixed-race couples had devastating consequences for their dignity and access to legal partnership rights. In 2010, only 50% of U.S. adults were married, and there is no sign of any arrest in the decline. As in Europe, other living arrangements are on the rise, including unmarried partnerships of all stripes, and single-person households. Yet marriage still matters, especially for those systematically excluded from it. Aside from physical and psychological advantages, marriage provides significant material benefits and rights, especially in relation to taxes, inheritance, insurance, and pensions. Long after the Loving decision, such rights are out of reach to many same-sex couples. The situation is very fluid but at the time of writing, thirty-five states and the District of Columbia recognize that gay and lesbian couples have the right to marry ( states/). But as in the pre-Loving era, state recognition of marriage equality often only applies to rights or benefits within each state; it does not grant access to hundreds of federal benefits for married couples. The Supreme Court in United States v. Windsor (2013) took an important step toward marriage equality by establishing that couples in a same-sex marriage are entitled to federal benefits. This ruling overturned part of the 1996 Defense of Marriage Act (DOMA) that pertained to federal benefits. Rules for eligibility, however, vary by agency. For example the Treasury Department and U.S. Citizen and Immigration Services recognize all same-sex partnerships whereas the Social Security Administration only recognizes same-sex marriages if the union is legal in the state of domicile. Despite this variability in rights, Loving remains relevant in the current struggle for same-sex marriage equality. It provides a legal precedent for a fundamental right to marriage, and it frames this right as a civil right (Stein, 2004). Loving also evokes the moral weight of the Civil Rights Movement, and prominent civil rights figures (including Mildred Loving herself) have referred to Loving in their support of marriage equality. Loving, it should be noted, is one of the few instances in which the Supreme Court has ruled state marriage law to be unconstitutional (another example was the court's ruling against state-level polygamy laws). The governance of family affairs, including marriage, has historically been relegated to the states. The Loving decision, however, came at a time when the Supreme Court was inclined to support the power of the federal government against the claims of states' rights advocates, who sought to preserve a white-supremacist social order. The importance of asserting a federal right to govern marriage law is clear in current marriage equality activism. Thus, the advocacy organization Freedom to Marry explicitly describes the need for a "national resolution" to same-sex marriage, much as happened with the
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elimination of racial restrictions on marriage through the Loving decision.2 The implications of Windsor, however, are unclear. While that ruling does affirm the applicability of due process to same-sex marriage, it also, ironically, overturns an attempt to federally regulate marriage. The concern that led to DOMA was that states were beginning to grant same-sex marriage rights; social conservatives were seeking to affirm federal power over the states to enforce those conservative values. In Windsor, the Court ruled that DOMA unconstitutionally frustrated the authority of states to define, recognize, and protect, as a class, people in same-sex marriages. It did not extend federal protected-class status based on sexual orientation. We question the current Supreme Court's willingness to assert federal authority over state-regulated family matters, noting a recent decision (Robicheaux et al. v. Caldwell, September 2014) to uphold Louisiana's right to prohibit same-sex marriage. Decades after Loving, it is clear that civil rights are still a work in progress. The "new" black church Priscilla McCutcheon, Department of Geography/Geosciences and Pan African Studies Department, University of Louisville. The recent anniversary of the Civil Rights Act of 1964 elicits questions about the state of Black institutions and especially the Black church, which has long provided the backdrop to calls for peace and justice. I understand the term "Black church" to refer to a diverse set of institutions rooted in a shared history of racial oppression and continued fights for Black liberation and freedom. The Black church includes not only historically Black Protestant denominations, but Black congregations within historically white denominations. Some even extend the term to include groups beyond the Black Christian experience (Lincoln & Mamiya, 1990). The Black church is an institution formed during slavery, when Blacks often worshiped beyond the watchful eye of whites. It embodies what Lincoln and Mamiya (1990) call the dialectic between "resistance and accommodation." On the one hand, the Black church should be understood within the context of slavery, the Civil Rights Movement, and the Black freedom struggle. On the other hand, Black churches often served as intermediaries to facilitate assimilation into white society. At times, both roles have existed within the same church. This intervention raises the question of how the contemporary Black church (and its component institutions) sees itself within the larger context of changing Black communities and neighborhoods. It considers, as well, how geographers might engage with the Black church in research and advocacy work. W.E.B. DuBois (1903) described the Black church as one institution that had largely remained hidden from white society. While many question the relevance of the Black church today, most do not question its relevance during the Civil Rights era. Black churches were not only faith communities, but spaces for people to organize and to protest for justice (Lincoln & Mamiya, 1990). Questions about Blackness and the most direct path for liberation, however, often played out differently within individual Black churches, denominations and religions. Among Black Christians, there were varying opinions regarding an appropriate response to racialized inequalities and whether the Black church should be used to address social justice at all (Lincoln & Mamiya, 1990). During the Civil Rights Movement, the Pan African Orthodox Christian Church emerged from the frustration of its leader, Rev. Dr. Albert Cleage, with the tepid response to racial inequality that he felt from mainstream Christian denominations (Cleage, 1972). The Nation of Islam, as well, openly challenged Black Christians
and Black preachers on their approach to racial equality (Gardell, 1996). Despite differences in outlooks and strategies, the Black church coalesced during the Civil Rights era around a clearly identifiable set of issues relating to state-sanctioned segregation. Issues affecting Black people today, however, are considerably more difficult to address in a context in which the dismantling of Jim Crow is widely assumed (especially by whites) to have ushered in an era of colorblind racial equality. In many ways, the Black church, like other Black institutions, cannot assert itself on issues affecting Black people today using the same tactics that it used in the past. The tension between the internal workings of the Black church and community change remain important to discern, especially as geographers begin to pay more attention to religious organizations and their role in community formation and mobilization (Inwood, 2011; McCutcheon, 2015). An understanding of the Black church requires a deep engagement with spirituality on both an institutional and individual level. Holloway (2006: 186) notes the importance of engaging with the spiritual in religious spaces and of taking care not to "deny either the `reality' of spirits or sensations of the sacred for the believer, or the `reality' of how such sensations inform normative identities, societal discourses or institutions." I echo Holloway in urging scholars to engage with "the spirit" in religious spaces. Simply, how does the spirit inform the prophetic voice of the Black church, and how is this voice translated into action? Theologians have long explored the spiritdnot just in the Black churchdand its connection to community work and activism. Social-science scholars, however, have seemed more reluctant to engage with spirituality and the workings of the spirit within congregations. I argue that much like Blackness, it is impossible to disentangle the work of Black churches from their spiritual goals and from Black people's visceral connections to the spirit. The recent commemoration of the 50th anniversary of the Civil Rights Act presents itself as a time to reassess the broader goals of the Civil Rights Movementda movement that Joseph (2010) reminds us has not reached an end point. This anniversary also presents itself as a time to reassess how institutions that were strongholds during the Civil Rights Movement continue to respond to social inequalities. While the Black church continues to be an important institution in civil rights struggles, one cannot rely on historic assumptions about the Black church to assess the contemporary church. Geographers are poised to ask timely questions about the role of Black churches in contemporary Black communities. For example, how are the internal spiritualities of the Black church connected to the shifting external spatialities of cities and neighborhoods? How do individual Black churches retain relationships with Black people and Black communities in contexts of demographic change, like those created through gentrification and Black suburbanization? What are the lines of social difference that exist within the Black church (e.g. class, gender, sexuality, and generation), and how might these differences inform (or hinder) advocacy work and community participation? How does community outreach vary between urban and rural areas, or between North and South? Otis Moss Jr. (2012), pastor of Trinity United Church of Christ in Chicago, IL, notes the surprisingly progressive stance on social issues of church members in rural Blackville, SC, which he attributes to the spatial proximity of the town's residents and their dense interpersonal relationships. Such observations complicate our assumptions about the conservative social values of people in rural spaces, and they indicate how geographers might begin to explore relationships between spirituality, church institutions, and place. The new Black church builds on the history of its individual institutions while simultaneously recasting its mission. Black
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churches are governing organizations (in the Foucauldian sense), particularly in the neoliberal state where responsibility for community welfare often falls on voluntary institutions. The Black church has had this role since its inception, though many have called into question how well the Black church accomplishes this role and whether it should be tasked with such responsibilities to begin with. In any event, the new Black church continues to build relationships with Black communities in tangible ways, using their physical resources for community good, even as memberships often dwindle. Some churches, for instance, are using their land for community gardens in areas with little access to safe, healthy, and affordable food. Two such examples are Truly Living Well Urban Farm in Atlanta's Fourth Ward and Trinity United Church of Christ' community garden in Chicago, IL, which focus on growing food, improving dietary practices, and teaching environmental sustainability. Hunger and poverty will not be solved by more community gardens near Black churches or in Black neighborhoods. However these community gardens do address in a tangible way pressing community needs and concerns, and they form the community ties needed to address racial injustice. Such racial injustice, to be sure, remains an endemic feature of U.S. societyda fact brought to light (for the white public) by the media's recent attention to police violence against Black men and women. The Black church has been at the forefront of protest against police violence and has positioned itself as an interlocutor between the state, the police, and Black communities. It was not surprising, therefore, that following the 2014 police killing of a young Black man, Michael Brown, Missouri Governor Jay Nixon would reach out to the Black community of Ferguson, Missouri by addressing the Black congregation of Christ the King United Church of Christ. While Governor Nixon's visit seemingly confirmed the position of the Black church as a representative of Black communities, his visit also demonstrated to me how the Black church is sometimes used as an auditorium, and Black congregations treated simply as an audience, by those who wish to gain legitimacy in Black communities. The inscrutable expressions that greeted Governor Nixon at Christ the King might have been due to his attempt to mimic of the traditional call-and-response style of many Black pastors while delivering a speech that seemed intended to pacify Black protesters. The Black church is a spiritual and cultural space, deeply rooted in Black communities and movements for social justice. To be clear, I do not mean that Black churches should not be used for gathering and organizing people, or that white politicians should not engage with Black communities through the Black church. I mean to suggest, instead, that the prophetic voice of Black churchesdthat is, the inextricable connection between Black spaces, Black struggles, and Black spiritualitydmust continue to be the leading voice in Black churches and Black communities. "Committing to a place": the place-based, faith-based legacies of the Civil Rights Movement Katherine Hankins, Georgia State University. Andy Walter, Department of Geosciences, University of West Georgia. Kate Derickson, Department of Geography, Environment, and Society, University of Minnesota. In recent years Black Millennial activists and organizations like Black Youth Project 100 and the Dream Defenders have mobilized against the carceral state, drawing attention to the violence hidden beneath banal multiculturalist discourse (Thomas, 2011). By continuously challenging the idea that we are in a post-racial moment, these activists, along with Black public intellectuals like Cornel West, Michelle Alexander, Ruth Gilmore and Ta-Nehisi
Coates, constitute an important legacy of the Civil Rights Movement. Here, we highlight another, often overlooked, legacy of the Civil Rights Movement seen in faith-motivated community development practices across the United States. These place-based expressions of faith have roots in the Civil Rights Movement and carry forward the theological vision of "beloved community" that motivated, unified, and sustained the Movement, especially in its early phases. In particular, we draw attention to the Christian community development movement inspired by the model of John Perkins, a Black civil rights veteran from Mississippi. In Perkins's words, the goal of Christian community development is to make beloved community happen "in the places where we are" (Perkins, 2009, 114), a praxis that, according to Marsh (2005, 174), explicitly addresses the "unfinished business" of the Civil Rights Movement with respect to minority economic power and racial reconciliation. The early Civil Rights Movement was cultivated within and spread through the Black church of the South, as McCutcheon reminds us in her intervention. Prominent leaders of the Movement, such as Martin Luther King, Jr., drew from biblical scripture to articulate visions and justifications for civil rights. Their congregations offered bended ears and social networks to circulate these ideas and to put strategies into action. Church buildings, such as Ebenezer Baptist on Auburn Avenue in Atlanta, where Reverend King preached, were key sites of planning, political organizing, and voter registration efforts. Crucially, church buildings were also safe spaces. Civil Rights activists in Selma, Alabama, for instance, sought refuge in Brown Chapel A.M.E. Church from the violent reaction of state troopers and local police on Bloody Sunday. However, we heed McCutcheon's suggestion that analyzing church space may limits our understanding of the full importance of the institution. It was, in fact, religion and spiritual belief that offered a language of human dignity and equality through which people interpreted and communicated injustices and through which they envisioned a society rid of racial oppression, political disenfranchisement, and economic exploitation. As Marsh (2005, 3) recounts, even so-called "secular" organizations central to the movement's beginnings, such as the Student Nonviolent Coordinating Committee (SNCC), articulated their purpose in "theological language that could not have been more unapologetic in its specificity and scope, or more subversive of the racial status quo." In galvanizing support for the Civil Rights Movement, churches shaped the geographies of social mobilizations in important ways. Churches contextualized the language of justice and injustice in the places of everyday lives, providing meaningful answers not only to "why" they should struggle for civil rights but also "where" and "how" they should do so. Understanding the Civil Rights Movement as a multitude of place-based expressions of faith helps us to identify the legacies of the Movement in current community development practices. Yet the significance of churches as a locus for civil rights mobilization is often overlooked because the Movement evolved in ways that disembedded it from the pews and local church communities. The struggle to undo the particular injustices inhibiting beloved community in local communities gave way to a more generalized struggle for abstract absolutes. As Marsh (2009, 25e26) puts it, "The new goals were rather more elusive: `End racism'; `Change the system' ... These goals indicated a striking change from the days when voter registration, political organizing, and educational reform were the measure of success. The movement went cosmic, but cosmic ambitions disconnected from local commitments created strategic confusions." In the decades since the Civil Rights Movement, churches themselves have altered their relationship to, and embeddedness in, place, reflecting in some instances the biopolitics of immobility in changing African American communities that Inwood and Alderman (this issue) name. The scaling-up of the church, seen in
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the rise of the mega-church and televangelism, and the suburbanization of an emerging Black middle-class from the 1980s onward, have disconnected the Black church from the places where many of its congregants live. Inner-city neighborhoods in cities across the South are dotted with Black churches, some of them a century old, serving distant congregations. Although churches are, as Foley, McCarthy, and Chaves (2008, 121) note, "among the institutions of civil society, [that] are often the last to leave deteriorating neighborhoods and dwindling communities and the first to return", their social and political role in the changing urban structure varies across denominations and geographical context (Owens, 2007). For example, Ebenezer Baptist on Auburn Avenue in Atlanta remains a key institution in articulating and shaping the progressive political consciousness of its congregants, who often drive in from Atlanta's African American middle-class neighborhoods, whereas the suburban megachurches of pastors like Eddie Long preach the prosperity gospel, wherein the path to salvation is seen as working through the accumulation of material wealth. Christian community development, which today consists of thousands of people and organizations, grew out of John Perkins' frustrations with both the church's loss of commitment to place and with the unfulfilled promises of the Civil Rights Movement. He formulated his "3 Rs" approach to community development in this context. The first "R", reconciliation, entails breaking down the social boundaries that enable relations of oppression between groups. Reconciliation is not achieved through "social mix" in the neighborhood but in lived interactions based on mutual respectful across racial and cultural differences. Relocation, the second R, not only transgresses the spatial boundaries that prevent reconciliation but also expresses the mandate to Christians to "love thy neighbor as thyself," which entails living in solidarity with people and working as partners in undoing injustice where they live (Gornik, 2002). Redistribution calls for the reallocation of material resources and opportunities to benefit historically and geographically excluded others. Through the "3 Rs" Perkins sought to "interrupt the way things are" in society as well as the church (Perkins, 2009: 47). In the late 1980s Perkins joined with likeminded activists doing similar work in Chicago, Atlanta, Philadelphia, and other cities to form the Christian Community Development Association (CCDA). Today, the CCDA is a multi-racial/ethnic nationwide network of activists applying the 3 Rs in geographically specific ways, from advocating for housing policy reform to addressing "predatory inclusion" (described earlier in this intervention by Bolton and Holloway) to minimizing displacement from gentrification. The intention, in Perkins' (2009, 114) words, is to make "a good life possible for people in the place where we are," be it an inner-city ghetto, a new immigrant suburb, or a rural trailer park. In their concrete application, CCDA organizations can look like that of FCS Urban Ministries in Atlanta, which acts as an umbrella organization for multiple nonprofits groups that focus on the high-poverty neighborhood of South Atlanta (see Hankins & Walter, 2012). These nonprofits include, among others, a housing organization that provides affordable rentals and refurbished homes with no-interest loans and an economic development organization that operates a coffee shop and thrift store in the neighborhood. These non-profits, as well, provide a social network for "intentional neighbors" who have moved into the neighborhood to live in solidarity with the poor. These kinds of organizations, with an emphasis on "gentrification with justice" as Bob Lupton, a CCDA architect puts it, to some degree challenge the dominant understanding of faith-based organizations (FBOs) as tools of neoliberalism (Hankins & Walter, 2012; see Hackworth, 2012 for a discussion of FBOs and neoliberalism). The victory of the Civil Rights Movement was the achievement of formal civil and political rights and the eradication of legal, race-
based discrimination. The importance of these accomplishments cannot be understated. But the limits of the liberal, rights-based framework have been laid bare by the unpunished killings of Trayvon Martin, Michael Brown, and Eric Garner, and the mass incarceration of Black people. The persistence of these conditionsdalong with the remarkable rise in wealth inequality and decline in social mobility in the United Statesdhighlight the ways that racialization, racial violence, and white supremacy endure with devastating consequences. Clearly, there is more work to be done to engender cultural, political, and economic equality. However, scholars and activists should not lose sight of the work that is being done, such as the faith-motivated, place-based mobilizations we have described. These efforts are a hopeful legacy of the Civil Rights struggle, albeit one whose political, economic, cultural and geographical impacts and possibilities should be critically assessed.
Conflict of interest
None declared.
Endnotes 1 We capitalize Black, but not white, throughout this intervention. Black denotes a cultural identification for African Americans, many of whom cannot pinpoint a particular country of origin due their history of forced migration. White is not capitalized because of the historical use of "White" by many white supremacist organizations and because those described as white in the U.S. context have the privilege of identifying specific countries of origin to describe ethnicity (e.g. Irish American or Italian American). 2 As this intervention went to press, the U.S. Supreme Court ruled in a 5-4 decision that under the 14th Amendment to the U.S. Constitution, states must issue licenses to same-sex couples and must recognize marriage licenses issued in other states. This was a surprising and definitive stand for marriage equality at the federal level.
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Title: The legacies of the U.S. Civil Rights Act, fifty years on
Author: Caroline Nagel
Subject: Political Geography, 48 (2015) 159-168. doi:10.1016/j.polgeo.2015.06.004
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