Congress attempts to limit courts' ability to order busing in the Equal Educational Opportunities Act, 20 U.S.C. 1703.

In Milliken v. Bradley, 418 U.S. 717 (1974), the Supreme Court strikes down a desegregation plan that involved black schools in the city of Detroit and white schools in the suburbs. The Court holds that courts May not order remedies among different districts unless it shows discriminatory intention in each district or a discriminatory policy in one district that has segregative effects in other districts. The decision effectively puts an end to most judicial remedies linking white suburbs with black inner cities. The case is decided by a 5 to 4 vote, with all four of President Nixon's appointees in the majority. Prior to Milliken, all school desegregation cases had been unanimous.

President Nixon resigns and is replaced by Gerald Ford.