There is no final answer to the question of whether a school district with non-English-speaking students has a legal obligation to provide a bilingual-bicultural education for those students. School districts subject to the provision of Title VI of the Civil Rights Act of 1964 may be required to provide the Office of Civil Rights with a plan for voluntary compliance with that statute and may be asked to prove that their methods are at least as effective as the approved bilingual-bicultural program endorsed by the Department of Health, Education, and Welfare (HEW). Although the courts have yet to define the requirement in the Equal Educational Opportunities Act of 1974 for "appropriate action to overcome language barriers," it is reasonable to expect that if such a definition becomes necessary, the courts will rely on the HEW regulations and policy statement for the enforcement of Title VI. It is clear that bilingual-bicultural education may be ordered by a federal district court as a portion of the remedy in cases of segregation of national origin-minority students in violation of the Equal Protection Clause of the Fourteenth Amendment. (Author/IRT)