One part of the 1982 civil rights struggle against building a Polychlorinated Biphenyls ("PCB") landfill in Warren County, North Carolina, was a suit by the National Association for the Advancement of Colored People ("NAACP") under Title VI of the 1964 Civil Rights Act. Although the suit was unsuccessful, the Warren County protests led to a 1983 General Accounting Office study and a 1987 United Church of Christ's Commission on Racial Justice (CRJ) study, both of which found that hazardous waste facilities were more likely to be located in minority communities. The Warren County protests and the two studies helped build a broader environmental justice and civil rights movement that eventually led to President Clinton's requirement that federal agencies ensure that their grant recipients comply with Title VI. Community protests similar to those in Warren County are valuable in winning Title VI cases like Shintech, but revitalizing Title VI as an effective statute to protect minority groups requires a broader national movement for social justice that can influence national elections.
Mank, Bradford, "Title VI and the Warren County Protests" (2007). Faculty Articles and Other Publications. 116.