 Although, in theory, track assignment is based on academic ability, other factors often influence placement.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.