much as $45,000,000 annually” offer a valid response. This is so because the Legislature provides for a fair distribution of state integration funds to districts maintaining integration programs originating under a court mandate, as explained on pages 6-7 of Intervenors' Reply to Defendant's Opposition.

To the contentions that the present “Final Order” should remain in effect, Groundswell Intervenors reiterated their earlier objection to the order's provision sanctioning student assignments solely because of their race and implementing it under the following basic rule:

“In classrooms — other than (ones for which there is a justifiable explanation) — the percentage of students must not deviate more than plus or minus 20% from the proportion of White students in the school.” [emphasis by District]

And we presented a current petition by five residents (including parents with District students) that the Board refrain from —

mandatorily classifying... and mandatorily assigning to particular classrooms, solely on the basis of their race, those students who do not want to be so classified and so assigned, because it does not take into account their educational needs, and is violative of the constitutional rights of such students and those of us who are their parents....

In conclusion, Intervenors cited in support of their motions, as well as the Los Angeles 1981 final order, Spangler v. Pasadena City Bd. of Ed., 611 F.2d 1239 (9th C.A., 1979) (trial court may not retain jurisdiction merely for matters of convenience); and Dowell (desegregation decrees are not intended to operate in perpetuity).

Intervenors also distinguished Freeman as pertaining to a school district under a desegregation order to establish a unitary system (whereas this district had always operated a unitary system); that when it had achieved a unitary status in the area of student assignments, court jurisdiction could be terminated in that area, although unitariness not yet established throughout the system, noting (118 L.ED.2d 108,134):