The origins of race-based tracking reach as far back as the federal court ruling in "Roberts v. The City of Boston" in 1850, a case that upheld separate school curricula for blacks and whites on the belief in inherent racial differences in intelligence. With the "Brown v. Board of Education of Topeka" Supreme Court ruling of 1954, which determined that the separate school statute established by "Plessy v. Ferguson" was unconstitutional, the stage was set to address between-school segregation/tracking. However, for schools in most southern regions of the United States, integration did not occur until the early 1970s. Moreover, desegregation at the school level often led to pronounced tracking within schools, as Grant ( 1988) chronicled in "The World We Created at Hamilton High". Haney’s (1978) historical analysis at the secondary school level found that less qualified teachers were assigned to teach racially tracked classes.