As Justice Powell said in his concurrence in Keyes, 413 U.S. at 220, Brown I was initially construed as negative in nature, calling only for state neutrality. He explains that the doctrine of Brown I, as amplified by Brown II, did not retain its original meaning:

In a series of decisions extending from 1954 to 1971 the concept of state neutrality was transformed into the present constitutional doctrine requiring affirmative state action to desegregate school systems. The keystone case was Green v. County School Board, 391 U.S. 430, 437-438... where school boards were declared to have "the affirmative duty to take whatever steps might be necessary to convert to a unitary system in which racial discrimination would be eliminated root and branch." [underscoring added]

Thus, Justice Powell concluded, the affirmative-duty concept articulated in a rural setting in Green flowered in Swann, into a new constitutional principle of general application to large urban areas as well. Intervenors underscore "desegregate" in the above explanation by Justice Powell as a key word in Green and in Swann. For the two school districts affected by those two decisions had a current history of "segregation" accomplished by racial discrimination.

The Webster definitions of "segregation" and "integration" in connection with a recent study commissioned by the National School Boards Association were discussed by William Raspberry, in an article