 During the mid- to late-1980s, federal court cases in Mississippi and Georgia took up the question of unfair race-based tracking in school systems.However, "Quarles v. Oxford Municipal Separate School Distric"t, "NAACP v. Georgia", and "Montgomery v. Starkville Municipal Separate School District" each ruled in favor of school districts based on the argument that tracking was being properly utilized for the purpose of assisting students’ ability to learn—in spite of statistical imbalances in track assignment.In Mickelson’s (2003) detailed study of between and within school tracking/segregation in Charlotte North Carolina, she argued that tracking was used as a tool to maintain white privilege by placing African-American students in lower academic tracks.