In 1954, the United States Supreme Court decided "Brown v. Board of Education" and ordered the desegregation of students by race in public schools. Many of the states as well as the federal executive branch of government expressed some level of opposition to this order. Over time, courts have taken alternative positions on the education of persons of color, some of which have the potential for undermining the original ruling in the Brown decision. This research will offer an analysis of these trends in American education, exposing the paradox of how an emphasis on supposed achievement tends to trump educational equality for African American students. The merits of transitioning to a supports-based system of accountability--facilitated by collaboration among multiple stakeholders--are analyzed for viability as both a conceptual and pragmatic next step for fulfilling the promise of "Brown."