The differentiating factor between de jure segregation and so-called de facto segregation . . . is purpose or intent to segregate. Keyes v. Denver School District, 413 U.S. 189, 208 (1973) (emphasis by Court). See also Columbus Bd. of Educ. v. Penick, 443 U.S. 449, 457 n.5 (1979).
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