B. It infringes upon the liberty of parent Intervenors to guide the destiny of their children free from improper state action against them and their children, in violation of the Due Process Clause of the 14th Amendment;

C. It infringes upon the liberty and privacy of student Intervenors by state action in violation of the Due Process Clause of the 14th Amendment and Article IX.

D. If ordered by the Court, it infringes upon the other branches of government and upon the rights of Intervenors to the governing participation concerning the District to which they are entitled, in violation of the guarantee of a republican form of government, under Article IV, Section 4, and of the Due Process Clause of the 14th Amendment....

41. The mandatory assignment of student Intervenors, and others similarly situated, because of their race, to particular schools within said District violates, and would violate, the rights of said Intervenors, and others similarly situated, in that it subjects, and would subject, them to discrimination on the ground of race under a program and activity receiving federal financial assistance, in violation of Title VI of the Civil Rights Act of 1964....

43. The mandatory assignment of student Intervenors, and others similarly situated, because of their race, to particular public schools within said District violates, and would violate, the rights of taxpayer Intervenors, and others similarly situated, in that it uses, and would use, tax moneys for an unconstitutional purpose, in violation of the laws and Constitution of California.

On December 15, 1980, this complaint in intervention in behalf of the Groundswell group and individual parents and students was filed after the Court overruled objections by both the plaintiffs and the Board.