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Patterns of Prejudice, Vol.

45, Nos 12, 2011

Teaching Obama: history, critical race theory


and social work education

DAMON FREEMAN

ABSTRACT Barack Obamas first autobiography, Dreams from My Father (1995),


explores themes of race and identity up to the late 1980s in the life of the first African
American president. The book emphasizes Obamas personal struggle as the son of
an interracial couple, and the social and environmental context that shaped his
growth and transformation. Using the tools of critical race theory, Freeman illustrates
how Obamas autobiography can be used in the classroom to explore an individuals
developing racial consciousness in the 1970s and 1980s, and as a prism through
which students can understand what it means to live in the post-civil-rightsmovement era. Obamas life history illuminates how the ideas and meanings of
racial progress in the United States are contested and struggled over on a daily basis
at both the micro and macro level.

African American autobiography, African American studies, American


autobiography, Barack Obama, critical race theory, CRT, Dreams from My Father, race,
racial identity, racism, social work education
KEYWORDS

n Barack Obamas autobiography Dreams from My Father, a telling moment


occurs when the author is a nine-year-old child living in Indonesia. He has
been living in his adopted country with his mother and Indonesian
stepfather for more than three years. One day, while waiting in the library
of the US embassy in the capital Jakarta while his mother attends to some
business, he casually leafs through old copies of Life magazine. Suddenly he
comes across a photograph of a man whose skin colour has a strange,
unnatural pallor, his facial features dominated by an uneven, ghostly hue.
The picture appears to be so grotesque to Obama that at first he thinks the
man must be a victim of radiation poisoning; but instead he discovers that
the man had tried to lighten his skin by means of a chemical treatment that

I wish to thank Richard King, the guest editor of this issue of Patterns of Prejudice, Barbara
Rosenbaum and the three anonymous reviewers for their helpful and insightful
comments. I am also grateful to the students in two autumn 2010 sections of my course
American Racism and Social Work Practice, and Abigail Reikow for allowing me to
share my thoughts on this article with them and for willingly engaging in the extra
reading and discussion that this required.
ISSN 0031-322X print/ISSN 1461-7331 online/11/1-20177-21 # 2011 Taylor & Francis
DOI: 10.1080/0031322X.2011.563161

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had gone badly wrong. The article explains that thousands of Blacks in the
United States suffered the same fate, victims of a cruel hoax promising
happiness and acceptance as a result of turning their skin white. Becoming
almost violently sick, his stomach knotting and his vision blurring, Obama
wants to demand an explanation from the adults around him. But, as he
wrote later, something held me back. By the time his mother returns, he
smiles at her as if nothing had happened. He had placed the magazines back
neatly in the pile where he found them.1
The memory was a disquieting one for Obama, and it revealed his
growing racial consciousness. Born in 1961 as the son of a white woman
from Kansas and a black father from Kenya, Obama was too young to
experience directly the energy and activism of the civil rights and black
power movements of the late 1960s and early 1970s. He also grew up
geographically remote from the most well-known centres of movement
activity, such as Birmingham, Chicago, Los Angeles, Oakland, the Mississippi Delta and New York, having spent his entire childhood living
in either Indonesia or Hawaii. Yet, as a high school and college student in
Hawaii, Los Angeles and New York City, a community organizer in
Chicago, a Harvard Law School student and, finally, as a visitor to his
fathers family in Kenya, Obama was forced to deal with questions regarding his own personal racial identity and its intersection with the
problems facing many African Americans during the 1980s. Although
Obama has rather thoughtlessly come to be known as the symbol of a
post-racial America, the episode described above actually touches on wellknown themes in the African American experience. In The Souls of Black Folk,
for example, W. E. B. Du Bois described the first moment when, as a young
child, he realized his blackness: the refusal by a young white girl in his
Massachusetts home to accept his greeting card. Although the experience
Du Bois described occurred in the 1870s, he felt the same sense of shock and
alienation that Obama felt, shut out from their world by a vast veil. Ninety
years before Obama found himself confronted with the same question,
Du Bois asked about how it feels to be a problem.2
Obamas autobiography in a sense fits in well with the African American
narrative tradition. As a presidential candidate, however, he generally
avoided the issue of race until forced to address it over his association
with the Reverend Jeremiah Wright, whose sermons were perceived by
many white Americans to be anti-white. Obama chose to confront the issue
many consider to be the most divisive in the United States in his March 2008
speech, A More Perfect Union, in Philadelphia. Although many of his
advisors tried to dissuade him, Obama saw it as a critical moment to

1 Barack Obama, Dreams from My Father: A Story of Race and Inheritance [1995] (New York:
Three Rivers Press 2004), 29 30.
2 W. E. B. Du Bois, The Souls of Black Folk [1903] (New York: Signet Classic 1982), 43 4.

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confront the elephant in the room.3 No longer the nine-year-old child


smiling on the surface and secretly hiding his pain, Obama wanted to
articulate the deep ambivalence many African Americans feel for their
country and the reasons why.
Scholars in the humanities frequently turn to biography, fiction, poetry or
speeches and writings by historically significant black figures to explore
themes such as class and gender, identity, oppression, marginalization,
slavery and segregation in African American Studies courses.4 In the social
sciences, including social work and public policy, scholars have also used
black narratives, albeit less frequently, to question values and assumptions.5
This essay explores Obamas autobiography as a unique and compelling late
twentieth-century story that can be used to explore issues of race and
specifically African American identity. The scene described above, in particular, can be utilized as a crucial and symbolic moment in an individuals
developing racial consciousness. But Dreams from My Father also functions as
a prism through which students can understand what it means to live in the
post-civil-rights-movement era. Obamas autobiography not only highlights
his own identity crisis but, more importantly, it illustrates how the ideas and
meanings of racial progress in this post-racial age are contested and
struggled over on a daily basis at both the micro and macro level.
My motives in writing this essay are both pedagogical and activist. I think
that, by using narratives such as Obamas, students can more fully grapple
with persistent questions of racial inequality in a country that supposedly,
following the civil rights gains of the 1960s, no longer practices racial
discrimination. I believe that this is especially crucial for those studying to
become social workers and social policymakers, as well as teachers, police
officers and other government officials, for these frontline workers can
3 Derrick Z. Jackson, Mutt on CP Time, discipline of Malcolm, in T. Denean SharpleyWhiting (ed.), The Speech: Race and Barack Obamas A More Perfect Union (New York:
Bloomsbury 2009), 232 3.
4 Examples include Frederick Douglass, Narrative of the Life of Frederick Douglass, an
American Slave, ed. David W. Blight (New York: Bedford/St Martins Press 2003); Du
Bois, The Souls of Black Folk; Booker T. Washington, Up from Slavery, ed. W. Fitzhugh
Brundage (New York: Bedford/St Martins Press 2003); Harriet Jacobs, Incidents in the
Life of a Slave Girl, ed. Jennifer Fleischner (New York: Bedford/St Martins Press 2010);
Keith Gilyard and Anissa Wardi, African American Literature (New York: Penguin 2004);
David Howard-Pitney, Martin Luther King, Jr., Malcolm X, and the Civil Rights Struggle of
the 1950s and 1960s (New York: Bedford/St Martins Press 2004); John Lowe (ed.),
Approaches to Teaching Hurstons Their Eyes Were Watching God and Other Works (New
York: Modern Language Association 2009); Susan Resnick Parr and Pancho Savery
(eds), Approaches to Teaching Ellisons Invisible Man (New York: Modern Language
Association 1989); Ida B. Wells, Southern Horrors and Other Writings: The Anti-Lynching
Campaign of Ida B. Wells, 18921900, ed. Jacqueline Jones Royster (New York: Bedford/
St Martins Press 1997).
5 See Roberta Rehner Iversen, Using African American narratives to analyze social
policy, Journal of Teaching in Social Work, vol. 21, no. 3/4, 2001, 7 26.

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have, and historically have had, an enormous impact on the daily lives of
ordinary non-Whites and marginalized individuals, specifically African
Americans. When the consequences of a social workers decision include
the taking away of a child from its mother and placing that child into foster
care, for example, it is absolutely essential that those who are training to
make such decisions are provided with both a historical perspective and
critical thinking skills.
In the late twentieth century, race in the United States is primarily
articulated and practised through three frameworks: colour blindness,
multiculturalism and racial disparity. Throughout the educational system,
race is almost always discussed and analysed using one or more of these
frameworks, despite the fact that they are arguably too narrow and limited
in scope to embrace and comprehend fully what it means to have a black
president in an era of deindustrialization, growing economic inequality,
skyrocketing incarceration rates, and dysfunctional public school systems in
which the majority of children are non-white. Critical race theory (CRT)
offers a more promising theoretical perspective for social workers and
policymakers with regard to answering some of these questions, and, as
I will explore later, Obamas autobiography hints at CRT themes like racial
formation, intersectionality and interest convergence.

Background
Since the fall of 2005, I have had the unique experience, for a historian, of
teaching a required course, called American Racism and Social Work
Practice, to students in the Master of Social Work (MSW) programme at the
University of Pennsylvanias School of Social Policy and Practice. Begun in
response to demands from students and community activists for classes that
were relevant to the needs of Philadelphias poor black population during
the early 1970s, the course initially included three assumptions. First, it was
framed around a black/white paradigm, rooted in the history of slavery
and state-enforced racial segregation, for its understanding of race and
racism. Second, the black/white paradigm was essential to the course since
no other racial group in the United States had experienced oppression as
African Americans had. And, third, students needed this knowledge if they
were to become effective social workers in a city that included a large poor
black population.
At the same time, the social work profession has increasingly highlighted
the importance of racial diversity and cultural competency training in social
work education and practice. The National Association of Social Workers
(NASW), the largest professional social work organization in the world with
over 150,000 members, explicitly calls for education that promotes understanding of cultural and social diversity in the United States and the world,
as well as engaging in political and social action on behalf of marginalized

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populations. The Council on Social Work Education (CSWE), the professions accrediting body in the United States, mandates the inclusion of
respect for human diversity and social justice principles in social work
classrooms.6 Like the University of Pennsylvanias required racism course,
the idea of cultural competency emerged out of the civil rights movement
of the 1960s, and referred to non-white populations. The term has broadened
over time to include a variety of groups, as well as markers of human
difference like gender, sexuality, age, language, religion, disability and
nationality. Several scholars in social work, however, have begun to note
the problematic nature of the cultural competence approach, including its
tendency to elide complex racial dynamics and perhaps unintentionally
support a colour-blind approach to issues of race and racism.7
Furthermore, the rapid demographic changes witnessed in the United
States over the past forty years due to immigration and increasing recognition
of the importance of sexuality, gender and class have led many current and
former students to contest these assumptions. A brief review of evaluations
for the American Racism course since 2005 indicates that many students
question the centrality of the black/white paradigm to courses on race. Many
of these students, born years after the civil rights and black power
movements and growing up in multiracial environments, call for material
on other racial/ethnic groups and oppressed minorities that aligns with the
concerns of the social work profession for cultural competency. They compare
their undergraduate coursework on multiculturalism and diversity with the
racism course and find the latter lacking when it comes to teaching social
workers the skills they need to practise competently in an environment in
which many clients will not be African American.8
These two approaches to the American Racism course, which I call
traditionalist and multiculturalist, have fundamental problems that are
frequently unacknowledged. By reducing oppression to a black/white
paradigm, the traditionalist approach has tended to essentialize or flatten
the historical relationship between black and white Americans so that all of
the former become victims while the latter are all victimizers. This approach
has also led at times to intense personal resistance from some white students
6 National Association of Social Workers, Code of Ethics for Social Workers (Washington,
D.C.: NASW 1999); Council on Social Work Education, Educational Policy and
Accreditation Standards (Washington, D.C.: CSWE 2008).
7 Jerome H. Schiele, Implications of the equality-of-oppressions paradigm for curriculum content on people of color, Journal of Social Work Education, vol. 43, no. 1, 2007,
83 100; Laura S. Abrams and Jene A. Moio, Critical race theory and the cultural
competence dilemma in social work education, Journal of Social Work Education, vol. 45,
no. 2, 2009, 245 61.
8 As the chair of the Racism Sequence Committee, I have had ample opportunity to
review course evaluations from my sections as well as those taught by other
instructors. I have also engaged in countless classroom and individual discussions
since 2005 with students on these issues.

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who react to being singled out this way. The traditionalists have also tended
to masculinize race: black American heterosexual men become the face of
racial oppression in an unspoken way, while black womens experiences
(and other subgroups such as LGBT blacks and African and Caribbean
immigrants) remain largely unacknowledged. Regional and local differences
are also obscured in favour of a Philadelphia first and, more generally, an
urban northeastern-America-centred approach, and the experiences of small
cities and suburbs remain unexamined.
On the other hand, the multiculturalist approach fails to explain or even
explore why school segregation has increased since the 1970s, why black
incarceration rates have exploded since the war on drugs escalated during
the Reagan administration, or why income inequality has greatly increased.
In 1988, for example, the average black or Latino child attended a school in
which 43 per cent of students qualified for free or reduced price lunches; by
2008, the figures had risen to 58 per cent and 57 per cent, respectively.9 The
number of incarcerated African Americans soared by 82 per cent during the
1990s; by the year 2000, 49 per cent of the nations prison population was
black, compared to 13 per cent of the general population. Black labour force
participation rates have also gradually declined from 91 per cent in 1940 to
70 per cent in 2000.10
A final problem with both approaches is that they encourage a race to the
bottom to determine which group is the most oppressed and most worthy of
study. We cannot conceivably include material on every group in the United
States that is discriminated against in a semester-long course. This, then,
fosters a group of the week format that doesnt support efforts to cultivate
critical thinking among social workers.
Nevertheless, a large number of students in the MSW programme of the
School of Social Policy and Practice are uncomfortable with discussions of
race or even with identifying their own racial identity. Some applicants to the
schools degree programmes, for example, refuse to identify their race on
their applications, perhaps indicating a growing preference for colour
blindness among many young people. For the last two application cycles
in which data were available, 11 per cent (46 of 411) of applicants to the MSW
programme in 2009 did not respond to the race and ethnicity question; in
2010 the figure jumped to 23 per cent (119 of 527 applicants). For the schools
Master of Science in Social Policy (MSSP) programme, the numbers were
similar; in 2009, 17 per cent of applicants (8 of 47) chose not to respond,
9

Gary Orfield, Reviving the goal of an integrated society: a 21st century challenge,
1 January 2009, available on the UCLA Civil Rights Project/Proyecto Derechos Civiles
website at http://civilrightsproject.ucla.edu/research/k-12-education/integrationand-diversity/reviving-the-goal-of-an-integrated-society-a-21st-century-challenge
(viewed 3 February 2011).
10 Michael B. Katz, Why dont American cities burn very often?, Journal of Urban
History, vol. 34, no. 2, 2008, 185 208 (188).

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while, in 2010, 25 per cent (17 of 68) also refused to do so.11 When I asked
both MSW and MSSP students in class and privately why they thought
applicants were refusing to identify their race, students frequently responded with statements such as it shouldnt matter, if I checked off white,
I might not be admitted or why does the university want to find out what
my race is? When I pointed out to them that their gender and birth date are
also optional questions on the schools application form, yet none of the
applicants in the MSW or MSSP programmes had refused to give their age or
state whether they were male or female, students were at a loss to provide an
explanation. Although the data and explanations provided above are
admittedly limited, they suggest, however tentatively, that race and racial
identity are problematic issues for many social work and social policy
students.

Critical race theory: a synopsis


During the last five years, the School of Social Policy and Practice responded
to some of these concerns and has substantially revised the curriculum
of the American Racism course. The course now includes material on the
history of race as an idea along with interdisciplinary approaches from law,
sociology and philosophy, including critical race theory (CRT). Primarily
emerging in the 1970s and 1980s out of studies of civil rights law and black
feminist thought, CRT seeks to explain how racial progress can occur
through laws and court decisions that abolish the most visible signs of racial
discrimination while patterns of racial inequality can appear to strengthen
in housing, education, employment, wealth, criminal justice and other areas.
In so doing, CRT scholarship has challenged liberal assumptions of the
American legal systems neutrality in regard to race. At the same time, CRT
has been heavily influenced by black feminist critiques of the civil rights
movement for its tendency to focus on male-centred rhetoric and activism, as
well as by the emphasis of the feminist movement on white middle-class
womens experiences.12 CRT now draws on and influences scholarship in
sociology, education, ethnic studies, economics, history, gender and sexuality studies, and postcolonial theory. It has also spawned subfields, such as
critical race feminism, Latino critical race studies and Asian American
critical race studies. The goal of CRT is to analyse, deconstruct and transform
11 Race and Ethnicity Application Data, Office of Admissions, School of Social Policy
and Practice, University of Pennsylvania, Philadelphia (Laura Nickrosz to Damon
Freeman, 30 July 2010).
12 For an example of this criticism, see Kimberle Crenshaw, Mapping the margins:
intersectionality, identity politics, and violence against women of color, Stanford Law
Review, vol. 43, no. 6, 1991, 1241 99.

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the power relationships that have created and reified (and continue to create
and reify) marginalized racial groups.13
CRT scholars generally counter liberal assumptions that the law and other
structural frameworks such as educational bureaucracies are normatively
colour blind. Since race is central to how American society is organized
across all spheres and networks of power, they argue, any analysis of law,
education, economics, public policy and so on cannot be racially neutral.
Moreover, critical race theorists maintain that the assertion of colour
blindness as the alternative to race consciousness actually strengthens and
reinforces racial inequality. As many CRT writers such as Derrick Bell,
Kimberle Crenshaw, Richard Delgado and Mari Matsuda have pointed out,
in order to be colour blind one must first recognize race, so the idea of colour
blindness is itself a contradiction. Recognizing the existence of race and
acknowledging the experiences of those who have been marginalized
because of race therefore becomes a necessary first step towards radical
racial reform. To not acknowledge race leads merely to symbolic gestures
and limited racial reforms at best.14
There are six common themes in CRT scholarship. First, CRT maintains
that racism is not an aberration of democracy, justice and equality, but
rather deeply embedded within the organization of American society. The
invisibility of this structural racism makes it difficult to unpack, and it
therefore allows continuing racial privilege despite the banning of the most
visible signs of racial discrimination. Second, CRT argues that race
and racism serve important psychological and material interests in the
minds of Americans. To affirm colour blindness, for instance, allows one to
isolate racism as being outside the norm of American democracy while
enabling the failure to see racial privilege. At the same time, in order for
change to occur that benefits excluded racial minorities, it must somehow
benefit the interests of the majority. Third, CRT asserts that race is a social
construction that has no biological or genetic basis. Nevertheless, racial
categories have been created by law to normalize race and reinforce white
13 For the best writings in legal studies on critical race theory, see Kimberle Crenshaw,
Neil Gotanda, Gary Peller and Kendall Thomas (eds), Critical Race Theory: The Key
Writings that Formed the Movement (New York: New Press 1995); Richard Delgado (ed.),
Critical Race Theory: The Cutting Edge (Philadelphia: Temple University Press 1999);
Richard Delgado and Jean Stefancic, Critical Race Theory: An Introduction (New York:
New York University Press 2001); Mari J. Matsuda, Charles R. Lawrence, Richard
Delgado and Kimberle Crenshaw, Words That Wound: Critical Race Theory, Assaultive
Speech, and the First Amendment (Boulder, CO: Westview Press 1993); and Adrien Wing
(ed.), Critical Race Feminism: A Reader, 2nd edn (New York: New York University Press
2003). Outside of the legal profession, CRT has had its most profound impact probably
in the field of education; see Adrienne D. Dixson and Celia K. Rousseau, Critical Race
Theory in Education: All Gods Children Got a Song (New York and London: Routledge
2006); and Mike Cole, Critical Race Theory and Education: A Marxist Response
(Basingstoke and New York: Palgrave Macmillan 2009).
14 See the works cited in note 13.

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racial privilege. Fourth, CRT contends that the symbolism and meaning
of racial groups can and have changed over time and place depending
on social, political and economic needs. Fifth, CRT recognizes the intersectionality of various identities, and that to focus solely on race, class,
gender, sexuality, disability or even region without acknowledging the
complex ways in which these identities and oppressions can overlap and
intersect with one another may lead to further patterns of marginalization.
Finally, CRT insists that the voices of people of colour are unique and must
be heard in order to understand how structures of power actually work.
Marginalized voices are sometimes more effective in comprehending both
the intended and unintended consequences of laws or actions by public
bureaucracies.15
Despite its growing use by both legal and non-legal scholars, CRT
has actually had little practical impact on legal education; among law
schools, only the University of California, Los Angeles offers a formal
programme.16 Nevertheless, several conventional legal scholars have criticized CRT. Daniel Farber and Suzanna Sherry, for instance, maintain that CRT
represents radical multiculturalism and seeks to overthrow the foundation
of American legal thought and its institutions. They also contend that
CRT has antisemitic and anti-Asian implications because of its critique of
merit. According to Farber and Sherry, if critical race theorists are right that
objective educational standards only protect the privileges of heterosexual, elite white males, and therefore that success in that system is not
only problematic but suspect, then it stands to reason that the disproportionate number of successful students and faculty of Jewish and Asian
descent do not deserve their status. As US Court of Appeals Judge Richard
Posner has noted, Jewish professors comprise half of the faculty at many
top law schools while making up less than 3 per cent of the national
population.17
Posner disagrees with Farber and Sherrys claims that CRT thinkers are
radical multiculturalists or borderline antisemites. The charge of radical
multiculturalism, he argues, lacks precision; he prefers the term radical legal
egalitarians, since Farber and Sherry specifically criticize law professors.
Posner also asserts that the hallmark of an anti-Semite is to be preoccupied
with Jews, which critical race theorists are not; they may be insensitive in
lumping together Jewish Americans with white Americans, but this does not
15 Delgado and Stefancic, Critical Race Theory, 6 9.
16 For the UCLA School of Law Critical Race Studies Program, see the website Critical
race studies @ UCLA School of Law at http://crsonline.wordpress.com (viewed
5 February 2011).
17 Daniel A. Farber and Suzanna Sherry, Beyond All Reason: The Radical Assault on Truth in
American Law (Oxford and New York: Oxford University Press 1997); Richard A.
Posner, The skin trade, New Republic, 13 October 1997, 40 3. See also the favourable
review of Farber and Sherrys book by another federal judge, Alex Kozinski, Bending
the law, New York Times, 2 November 1997.

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translate into antisemitism.18 But Posner concurs with Farber and Sherry that
CRT repudiates the enlightenment tradition of rational enquiry and analysis.
By endorsing narrative storytelling and rejecting objectivity and reasoned
argumentation, they contend, CRT invariably supports the distortion of
public discourse. They argue that the stories critical race theorists tell are
substitutes for facts and careful analysis, and that any criticism of this
methodology is interpreted as a personal, and sometimes racist or sexist,
attack on the storyteller. In other words, they argue that autobiography
cannot be used to generalize about social problems. Posner, and Farber and
Sherry insist that critical race theorists ultimately do more harm than good in
public policy debates, especially to people of colour whom they claim to
represent. In their minds, CRT is so dangerous that it may reinforce racist
notions of non-Whites intellectual inferiority by endorsing the use of
storytelling over reason.19
The charges against CRT of radical multiculturalism, antisemitism and the
rejection of reason are serious and should be considered. The term radical
multiculturalism not only lacks precision, as Richard Posner suggests, but it
is inaccurately applied to CRT; many critical race theorists are actually quite
sceptical of multiculturalisms ability to explain why racial inequality
continues to exist. Moreover, CRT focuses on the structural processes of
racial formation rather than on cultural diversity, as Michael Omi and
Howard Winant made clear in their groundbreaking work of twenty-five
years ago, Racial Formation in the United States. They defined racial formation
as the process by which social, economic, and political forces determine the
content and importance of racial categories, and by which they are in turn
shaped by racial meanings.20 Utilizing this definition, critical race theorists
have sought to understand how allegedly race-neutral laws and public
policies in education, criminal justice, housing, health care, social welfare and
other areas have marginalized and continue to marginalize particular racial
groups and individuals who fall within and between those groups (such as
black transgender persons).
At the same time, CRT also seeks to understand how some formerly
marginalized groups and individuals seem to make racial progress while
overall structures of race and power remain intact. A classic example of this
is Brown v. Board of Education, the 1954 US Supreme Court decision that
declared legally mandated racially segregated schools unconstitutional.
On the one hand, Brown has been celebrated as perhaps the single most
important victory over racial inequality in the twentieth century. In addition
to its domestic support, the decision received considerable international
attention and served to buttress American foreign policy during the Cold
18 Posner, The skin trade, 40, 42.
19 Ibid.; Farber and Sherry, Beyond All Reason, 12.
20 Michael Omi and Howard Winant, Racial Formation in the United States: From the 1960s
to the 1990s, 2nd edn (New York and London: Routledge 1994), 61.

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War.21 On the other hand, school desegregation was undermined by the US


Supreme Court itself in its 1974 Milliken v. Bradley decision. In Milliken, the
Court ruled that a federal judge could not order school desegregation across
city and suburban district lines in the Detroit area. Moreover, the Court ruled
that Brown applied only to de jure racially segregated schools and not in
situations of de facto segregation in northern states. As the dissenters in
Milliken pointed out, the Courts majority essentially upheld property rights
over the rights of poor black children to attain an equal education and
undermined Browns rationale.22 Critical race theorists argue that, since the
material interests of suburban, property-owning middle-class Whites did not
align with the interests of poor Blacks from Detroit, racial desegregation was
therefore not possible.
In addition, CRT can be criticized for having conceptual limitations due to
its arguable tendency to portray white supremacy as unchanging, or its
failure to foresee the possibility of the election of a non-white president such
as Barack Obama.23 James Kloppenberg, a historian who has written the first
intellectual biography of Obama, claims that Obama was exposed to but
ultimately rejected the arguments of critical race theorists in favour of legal
pragmatism. Legal pragmatists acknowledge that law is a product of power
and social relations, but they contend that social change can be attained
through the legal system.24 Although Kloppenbergs analysis is convincing,
I would argue that one of the purposes of Obamas autobiography is to show
how race and racial inequality continue to shape the daily lives of African
Americans in a nation that supposedly has moved past racism. His autobiography, I believe, fits well with the goals of critical race theorists. I am not
challenging Kloppenbergs argument but my goal in this essay is to show
how Obamas life history can serve to illuminate CRT themes.

CRT and Dreams from My Father


In the field of social work, there has been relatively little application of CRTs
core principles and insights to research and education. A recent search
21 Derrick Bell, Silent Covenant: Brown v. Board of Education and the Unfulfilled Hopes for
Racial Reform (Oxford and New York: Oxford University Press 2004); Mary L.
Dudziak, Cold War Civil Rights: Race and the Image of American Democracy (Princeton,
NJ: Princeton University Press 2000).
22 For a general articulation of this argument, see Bell, Silent Covenant; and Joyce A.
Baugh, The Detroit School Busing Case: Milliken v. Bradley and the Controversy over
Desegregation (Lawrence: University Press of Kansas 2011).
23 Posner, The skin trade, 43. I also wish to thank the anonymous reviewers of this
essay for pointing out these criticisms.
24 James T. Kloppenberg, Reading Obama: Dreams, Hope, and the American Political
Tradition (Princeton, NJ and Woodstock, Oxfordshire: Princeton University Press
2010), 38 9, 127.

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discovered only three scholarly articles that focused specifically on the use of
CRT in social work education.25 The American Racism course at the
University of Pennsylvanias School of Social Policy and Practice assigns
MSW students several classic CRT readings as well as critical historical
analyses of race. They have especially warmed to the insights of historians
and critical race scholars such as Kimberle Crenshaw, George Fredrickson,
Ira Katznelson, Charles Mills, Mae Ngai, Dorothy Roberts, Michael Omi and
Howard Winant.26 Obamas Dreams from My Father serves as another
potential source for students. The remainder of this essay explores how
the autobiography and its themes can be understood through a CRT lens.
I will only focus on portions from the first two parts of the book that portray
Obamas childhood, his teenage and college years, and his experiences as a
young adult community organizer during the 1970s and 1980s.
Obama began writing his autobiography, published in 1995, in 1990 while
he was still a student at Harvard Law School. His unique heritage as the son
of a Kenyan father and a white American mother and his election in 1990 as
the first black president of the Harvard Law Review proved to be an irresistible
draw to publishers perhaps eager to find a story of racial progress that
contradicted popular assumptions. In the same year as Obamas election,
Nelson Mandela, South Africas first black president, was released from a
twenty-seven-year prison sentence, and the government ban on the African
National Congress was lifted, but these highly celebrated moves failed to
guarantee the collapse of the apartheid system. The year before, in 1989, in
New York City, a twenty-eight-year-old white female jogger was brutally
assaulted and raped in Central Park, which led to the unwarranted
convictions of five teenage black and Latino males. Later that summer, racial
violence between Blacks and Italian Americans in Brooklyns Bensonhurst
neighbourhood led to the murder of sixteen-year-old Yusuf Hawkins. In the
world of American politics and policy, many people of colour resented the
administration of President George H. W. Bush for openly race-baiting in its
25 Abrams and Moio, Critical race theory and the cultural competence dilemma in social
work education; CarolAnn Daniel, Outsiders-within: critical race theory, graduate
education and barriers to professionalization, Journal of Sociology and Social Welfare,
vol. 34, no. 1, 2007, 25 42; Larry Ortiz and Jayshree Jani, Critical race theory: a
transformational model for teaching diversity, Journal of Social Work Education, vol. 46,
no. 2, 2010, 175 93.
26 Crenshaw, Mapping the margins; George M. Fredrickson, Racism: A Short History
(Princeton, NJ and Woodstock, Oxfordshire: Princeton University Press 2003); Ira
Katznelson, When Affirmative Action Was White: An Untold History of Racial Inequality in
Twentieth-century America (New York: W. W. Norton 2005); Charles W, Mills, The Racial
Contract (Ithaca, NY: Cornell University Press 1997); Mae M. Ngai, Impossible Subjects:
Illegal Aliens and the Making of Modern America (Princeton, NJ and Woodstock,
Oxfordshire: Princeton University Press 2005); Dorothy Roberts, Punishing drug
addicts who have babies: women of color, equality, and the right to privacy, Harvard
Law Review, 104, no. 7, 1991, 1419 82; Omi and Winant, Racial Formation in the United
States.

DAMON FREEMAN

189

use of a recently paroled African American murderer in Massachusetts,


Willie Horton, in commercials aimed at Democratic presidential candidate
Michael Dukakis in the 1988 election. Other writers and intellectuals
excoriated the Bush administration, his predecessor Ronald Reagan and the
rest of the Republican Party for its subtle portrayals of poor black women as
welfare queens, while the much publicized crack wars were causing record
numbers of black male homicides in cities across the nation. In Washington,
D.C., for example, the number of murders nearly quadrupled from 123 in
1985 to 483 in 1990.27 The troubling racial atmosphere in the United States led
many commentators and intellectuals such as Arthur M. Schlesinger, Jr to
write books about the disuniting of America that warned of a growing racial
balkanization of the country.28
Students should be aware of this larger social context that shaped Obama
and his writing in order to comprehend his autobiography. Dreams from My
Father functions as both a Story of Race and Inheritance, as its subtitle has it,
and as a coming-of-age account of the 1970s and 1980s, written at a time when
growing racial strife, divisions and violence seemed inevitable in American
society. Finally, it is also important for students to understand that, while the
characters in Obamas autobiography are real, their identities have been
hidden and in some cases may be composites of different individuals in one
person. Such writing techniques are useful when authors wish to retain
anonymity for particular individuals or when the narrative structure of the
book calls for a particular order.29
At the same time, the book touches on themes that complicate the
understanding many social work and social policy students have of race and
diversity. Although many Americans and others throughout the world
undoubtedly know of Obamas biracial heritage, most are probably unaware
of the skin-lightening incident described at the beginning of this essay. It is
recounted early in the autobiography and bookends the second chapter,
although the chapter is supposed to be about his life in Indonesia. Following
27 Roger Ormond, Mandela free after 27 years, Guardian, 12 February 1990; David E.
Pitt, Joggers attackers terrorized at least 9 in 2 hours, New York Times, 22 April 1989;
Susan Saulny, Convictions and charges voided in 89 Central Park jogger attack,
New York Times, 20 December 2002; Ralph Blumenthal, Black youth is killed by
Whites; Brooklyn attack is called racial, New York Times, 25 August 1989; Maureen
Dowd, Bush says Dukakiss desperation prompted accusations of racism, New York
Times, 25 October 1989; Isabel Wilkerson, Urban homicide rates in U.S. up sharply in
1986, New York Times, 15 January 1987; Lynne Duke, Urban League report paints
bleak picture of black advancement in 1987, Washington Post, 15 January 1988; Bill
McAllister, To be young, male, and black; as groups problems worsen, fatalistic
attitude is widespread, Washington Post, 28 December 1989; Eric Charles May,
Districts homicide toll reaches 483; man found shot in car in NW dies, Washington
Post, 1 January 1991.
28 Arthur M. Schlesinger, Jr, The Disuniting of America: Reflections on a Multicultural Society
(Knoxville, TN: Whittle Direct Books 1991).
29 Obama, Dreams from My Father, xvii.

190

Patterns of Prejudice

her divorce from Obamas father in 1964, Ann Dunham met and married an
Indonesian student in Hawaii named Lolo Soetoro in 1967. The couple
moved with Barack to Jakarta when Lolo, as the young Obama called him,
and all Indonesian students were ordered to return to the country after the
military leader Suharto came to power following an attempted coup in 1965.
The resulting political upheaval over the next two years saw more than
500,000 killed and as many as 1.5 million Indonesians imprisoned. In both
overt and subtle ways, the chapter highlights the material deprivation and
political repression suffered by many Indonesians during the four years
Obama lived there.30
Yet what stands out about the chapter is, ironically, the comfort Obama
takes from racial politics in the United States and, more broadly speaking, his
American heritage. In Suhartos Indonesia, power was expressed openly and
brutally; executions were sometimes held in public, and Obama as a young
child frequently saw people who had been tortured. In America, he wrote,
[power] generally remained hidden from view until you dug beneath the
surface of things; until you visited an Indian reservation or spoke to a black
person whose trust you had earned. But, in Indonesia, power was
undisguised, indiscriminate, naked, and that realization frightened Ann
Dunham. She was determined to raise her son not only as an American, but
also as a black American. Whenever Obama rushed home excitedly to tell her
about a military demonstration taking place, she would respond by telling
him about civil rights marches in the American South. She would come
home, Obama remembered, with books on the civil rights movement, the
recordings of Mahalia Jackson, the speeches of Dr. King. Obamas mother
made it clear: To be black was to be the beneficiary of a great inheritance . . .
More than once, my mother would point out: Harry Belafonte is the bestlooking man on the planet.31 Ironically, race and specifically African
American history became a comforting space for Ann Dunham and her
young son to inhabit. When Obama saw the photo in Life magazine of the
black man who had attempted to turn his skin white, he reacted not as a postracial American, but as an African American who had been raised by his
white mother to be very conscious of race.
By the summer of 1971, Obama had returned to Hawaii to live with his
grandparents; his mother would soon divorce Lolo and follow a year later.
Although from his mothers standpoint he had returned to a safe space,
Obama increasingly felt isolated and alone. He attended the prestigious
30 For more general information on the history of what Suhartos supporters called The
New Order, see Marilyn Berger, Suharto dies at 86; Indonesian dictator brought
order and bloodshed, New York Times, 28 January 2008; R. E. Elson, Suharto: A Political
Biography (Cambridge and New York: Cambridge University Press 2001); and
Theodore Friend, Indonesian Destinies (Cambridge, MA: The Belknap Press of Harvard
University Press 2003).
31 Obama, Dreams from My Father, 41 51.

DAMON FREEMAN

191

Punahou School throughout his teenage years, a school founded by


missionaries in Hawaii that evolved to educate many sons and daughters
of the islands upper-class elites. At school, Obama struggled with raising
himself to be a black man in America, and beyond the given of my
appearance, no one around seemed to know exactly what that meant.32 He
admitted he was partly drawn to basketball because of the preponderance of
black men in the sport on television. He frequently checked out library books
written by James Baldwin, W. E. B. Du Bois, Ralph Ellison, Langston
Hughes, Richard Wright and, most important of all, Malcolm X, and at night
he would shut the door to his room while he devoured their writings on
race. He increasingly found himself drawn to the few black male figures on
the island, including one old man named Frank. Nearly eighty years old,
Frank had been a poet in Chicago for many years, writing at the same time as
Wright and Hughes. He would later warn Obama before he left to attend
college to be suspicious of his education. The real price of admission, Frank
cautioned, was leaving your race at the door. Theyll train you so good,
youll start believing what they tell you about equal opportunity and the
American way and all that shit. Frank did not explain this to keep him from
going to college, but to counsel him: keep your eyes open.33
Two examples from Obamas years as a student at Occidental College,
which he attended from 1979 to 1981 before transferring to Columbia
University, illustrate his ongoing struggle with race and racial identity.
Affectionately known as Oxy, the school is a small liberal arts college in
Los Angeles. As a student there, Obama met another light-skinned black
female student named Joyce. When Obama asked her one day whether she
was going to attend the colleges Black Students Association meeting, she
responded that she was not in fact black but multiracial. Joyce defended her
choice to identify as multiracial due to her mixed Italian, French, African and
Native American heritage, and accused Blacks, not Whites, of forcing her to
make a choice. Obama interpreted Joyces response as problematic, and
noted that she avoided associating with Blacks on campus. It wasnt a
matter of conscious choice, necessarily, he concluded, just a matter of
gravitational pull, the way integration always worked . . . Only white culture
could be neutral and objective. Only white culture could be nonracial,
willing to adopt the occasional exotic into its ranks. Only white culture
had individuals.34 Although Obama at the time lacked the language of
critical race theory, his interpretation of Joyce illustrates the problem of selfidentifying as black in the late 1970s and early 1980s. Since it was no longer
fashionable to proclaim pride in blackness, as it had been a decade
before during the black power movement, Obama hinted at how African
Americans in a predominately white institution like Oxy, which in 1980 had
32 Ibid., 76.
33 Ibid., 97.
34 Ibid., 99 100.

192

Patterns of Prejudice

only 71 black students out of more than 1,600 and only two black professors
on campus, could feel a tense ambivalence about race.35 In such a setting, he
noted, racial self-identification became more of a handicap than a positive,
a preview of colour blindness. Race and racism as a result were increasingly
seen as aberrations from the norm rather than a deeply embedded element
within the structure of Occidental College. Interestingly, it is during this time
that Obama began to dispense with his nickname Barry, given to him by
white classmates in Hawaii, and to use his given name of Barack, although
it is not clear from the autobiography when exactly he made this decision.
Ironically, the second example occurred in response to campus protests
against the apartheid system in South Africa. Obama joined a student
organization at Oxy to demand that the college disinvest from that country.
Their protests mirrored national efforts that had been underway since the
1960s, but picked up steam during the mid-1980s following the South African
governments declaration of a state of emergency against black protesters.36
The culmination of Obamas involvement was a speech he delivered at a
campus protest designed to bring attention to the matter during a college
board of trustees meeting. The speech was also the first opportunity he ever
had to address an audience. Although several people congratulated him on
the speech, Obama felt he had been a willing participant in a farce, a
pleasant afternoon diversion, a school play without the parents. Later that
evening, Obama explained his feelings of despair to a friend named Regina
who congratulated him on the speech. He felt he had had nothing to say and
his speech had made little difference to black South Africans. I dont believe,
he stated emphatically, that what happens to a kid in Soweto makes much
difference to the people we were talking to. . . . So why do I pretend
otherwise? Ill tell you why. Because it makes me feel important (emphasis
in original). Instead of comforting Obama, Regina responded by criticizing
him for his self-centredness.
Youre just like . . . all the other brothers out here. The rally is about you. The
speech is about you. . . . Its not just about you. Its never just about you. Its about
people who need your help. . . . Theyre not interested in your irony or your
sophistication or your ego getting bruised. And neither am I.37

The moment was a critical one for Obamas personal and intellectual
growth, for he reminded himself of the words its not just about you over
and over again in the future. At that moment Obama realized he could no
35 Scott Helman, Small college awakened future senator to service, Boston Globe, 25
August 2008.
36 Ibid. See also Larry Gordon, Occidental recalls Barry Obama, Los Angeles Times, 29
January 2007; and Les De Villiers, In Sight of Surrender: The U.S. Sanctions Campaign
against South Africa, 19461993 (Westport, CT: Praeger 1995).
37 Obama, Dreams from My Father, 105 111.

DAMON FREEMAN

193

longer live in fear of rejection from Blacks or Whites due to his mixed racial
background, and that his past obsession with (and worry about) his biracial
heritage actually limited his intellectual horizons. But, without being
explicitly stated in the autobiography, his mental and emotional breakthrough exposed the limitations of the colour-blind approach to thinking
about race expressed by individuals such as Joyce and tacitly supported by
the social structures at Oxy. Race was clearly a problem for people of colour
at the college in 1980, but for many white students it was far easier to protest
against an overtly racist government in South Africa more than 10,000 miles
away than to grapple with the hidden structures of race surrounding Oxys
students on a daily basis.
Obama carried the lessons he learned at Occidental first to Columbia
University in New York, where he finished his college career, and throughout
a couple of years of working on Wall Street as a financial writer. Capitalism
never held much appeal for him though; as a Columbia senior in 1983, he had
decided to become a community organizer but he failed to find a position by
the time he graduated. Obamas desire, however, eventually overwhelmed
him and he quit Wall Street to search for a community organizer position,
often times broke and hungry. What drove him was the sense that he
belonged in the black community, and his imagination that the black
community was still in the making, built on the promise that the larger
American community, black, white, and brown, could somehow redefine
itself*I believed that it might, over time, admit the uniqueness of my own
life.38 Rather than run from race or assert colour blindness, he sought to
ground himself in the long history of the African American struggle with the
idea that that movement could eventually transform the rest of American
society.
After several fruitless months of searching, Obama finally found a
position in 1985 as director of the Developing Communities Project (DCP),
a church-based organization in Chicagos South Side; his salary was $10,000
per year. During his three years as director, the organizations staff grew
from one person (himself) to a staff of thirteen, and its budget tripled in size.
But Obamas most distinctive moments occurred in the southernmost part of
Chicago where he worked to establish a tenants rights organization in the
Altgeld Gardens housing project, two thousand apartments arranged in a
series of two-story brick buildings with army-green doors and grimy mock
shutters. Directly to the north and the east were a sewage treatment plant
and the largest landfill in the Midwest, respectively. To the west and south
ran the Calumet River, where nearby residents sometimes fished; but the
marine life was frequently strangely discolored, with cataract eyes and
lumps behind their gills. People ate their catch only if they had to. Although
Altgeld Gardens lacked the infamous reputation of Chicagos high-rise
38 Ibid., 134 5.

194

Patterns of Prejudice

projects, the several thousand poor Blacks who lived there suffered from a
sense of isolation and alienation. The Chicago Housing Authority (CHA)
neglected to repair the malfunctioning plumbing and heating, and the
buildings lacked air conditioning. Residents also endured putrid smells
coming from the treatment plant, which worsened depending on the
temperature and wind direction. Children living in Altgeld could see only
that things were used up and that there was a certain pleasure in speeding
up the decay.39
While working in Altgeld, early in his career, Obama discovered the gap
between white liberal activism and the needs and concerns of poor Blacks.
His supervisor, a former white union organizer named Marty, had worked
for months to organize a meeting between labour officials representing one
of the few steel operations left in the city and the DCP. During the meeting,
Marty made his pitch about the importance of worker-retraining for those
living in the South Side who still had one of the remaining jobs, and joining
forces with the DCP to negotiate with the city on worker protection. One of
Altgelds residents, a woman named Angela, was present at the meeting but
she didnt understand a word Marty was saying. Obama realized that, for
poor black women like Angela who lived in places like Altgeld, the real issue
wasnt keeping the steel plant open but finding ways of helping the
chronically unemployed in her neighbourhood and teaching black teenage
dropouts how to read and write. In other words, Obama wrote:
it was different for black folks. . . . just as it had been different for Angelas
grandparents . . . Marty wanted to wish such differences away as part of an
unfortunate past. But for someone like Angela, the past was the present; it
determined her world with a force infinitely more real than any notions of class
solidarity.40

Just as in his teenage and college years, when he met and interacted with
Whites who wished to deny the history of race, Obama saw, rather, the need
to embrace it. Building on that history was important for people like Angela,
and her voice, as critical race theorists have argued, needed to be recognized.
Two further examples from Obamas time in Chicago exemplify the need
to recognize the powerful and sometimes hidden role that race plays in the
lives of poor Blacks. After working there for several months, Obama
managed to gain some headway with Altgelds residents. One of them,
a woman named Ruby, threw herself into the work, at first reluctantly but
later with enthusiasm, of building a tenants organization that would try to
address the problems of the housing project. She later became a leader in the
organization. One day she arrived in Obamas office looking different, and
suddenly he realized that she was wearing blue contact lenses that covered
39 Ibid., 164 6.
40 Ibid., 168 70 (emphasis in the original).

DAMON FREEMAN

195

her natural dark brown eyes. Rendered speechless by her appearance,


Obama voiced his disapproval of the change and made Ruby feel ashamed.
Thinking about the experience for several days afterwards, he scolded
himself for making her feel bad for a small vanity in a life that could afford
few vanities. He reminded himself that, no matter how poor or well-off
African Americans might be, they were still very much affected by the larger
societys white cultural dominance. He also remarked that very few Blacks
were willing to admit our doubt and confusion to whites, to open up our
psyches to general examination by those who caused so much damage in the
first place . . . there seemed no reason to expect that whites would look at our
private struggles as a mirror into their own souls, rather than yet more
evidence of black pathology.41 In Obamas mind, talk of building black selfesteem to counter these effects was at most a temporary measure; it failed to
serve as the centrepiece of an effective black politics. Although black selfesteem might lift some Blacks out of poverty, he thought the problem was
poverty itself. Give that black man some tangible skills and a job. Teach that
black child reading and arithmetic in a safe, well-funded school. With the
basics taken care of, each of us could search for our own sense of selfworth.42
The final example from his days in Chicago occurred in 1986, when the
citizens of Altgeld successfully gained the support of the city to open a new
employment and training centre in the area, and Harold Washington, the
citys first black mayor and a folk hero to many black Chicagoans,
announced that he would attend the ribbon-cutting ceremony. Suddenly,
Obama and the women he worked with became very popular locally; the
alderman and state senator who represented Altgeld and had ignored them
for years now eagerly wanted to be included in the ceremony, and several
local ministers who had failed to even consider what their churches could do
for Altgeld called, suggesting that they should be included on the
programme. Sensing an opportunity, Obama wanted the tenants to get the
mayor to agree to come to another meeting. But the moment was lost when
Washington arrived amid a gathering of photographers, police officers and
other city and state officials, charming everyone in attendance. After the
ceremony, Obama again experienced an empty feeling, similar to that
following his speech against apartheid at Occidental College years earlier.
While Washington embodied all the hopes of poor Blacks in Chicago that
things could change, all Obama thought of that day were
the constraints on that power. At the margins, Harold could make city services
more equitable. Black professionals now got a bigger share of city business. We
had a black school superintendent, a black police chief, a black CHA director. . . .
41 Ibid., 191 3.
42 Ibid., 194.

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Patterns of Prejudice

But beneath the radiance of Harolds victory, in Altgeld and elsewhere, nothing
seemed to change.

Obama wondered if Washington had the same thoughts as he did, if he felt


as trapped as those he served, an inheritor of sad history, part of a closed
system with few moving parts, a system that was losing heat every day,
dropping into low-level stasis. I wondered whether he, too, felt a prisoner
of fate.43

Thinking through Obamas insights


Like many critical race theorists in the 1980s, Obama had come to question
what civil rights legislation and the advancement of black political power
really meant in the face of persistent racial inequality. More specifically, what
did Harold Washingtons victory as Chicagos first black mayor mean for
poor Blacks in Altgeld Gardens like Angela and Ruby, the two women who
became community leaders? Despite the creation of a new black political
regime that emerged from the civil rights era, Obama realized that the
futures of poor Blacks in places like Altgeld were limited. By the beginning
of 1987, long-time residents of Altgeld began to feel that conditions were
gradually worsening; indeed, the number of homicides in the city jumped
from 666 in 1985 to 747 one year later.44 Obama nearly witnessed a shooting
himself later that summer when two boys chased another boy with a pistol.
The boy managed to escape, but not before three shots were fired at him.45
Although he continued to work for another year in Altgeld and other South
Side neighbourhoods, Obama could not help but wonder how effective his
work had been.
Almost forty years after the end of the civil rights and black power
movements, race continues to affect the lives of poor Blacks in the United
States in both overt and unseen ways. American society has clearly banned
the most visible signs of racial discrimination, yet racial inequalities persist
and even become more entrenched. We may find that our language
and ideas expressing and concerning race are outmoded and rooted in
nineteenth- and early twentieth-century frameworks. Using a CRT lens,
Barack Obamas autobiography may provide some insights through which
students can think what it means for a society to have elected its first black
president while simultaneously having growing levels of school segregation
and incarceration for young African Americans.

43 Ibid., 223 31.


44 Wilkerson, Urban homicide rates in U.S. up sharply in 1986.
45 Obama, Dreams from My Father, 251.

DAMON FREEMAN

197

Damon Freeman is an assistant professor of history and social policy in the


School of Social Policy and Practice at the University of Pennsylvania. He is
completing an intellectual biography of African American psychologist
Kenneth B. Clark (under contract with the University of North Carolina
Press). Recognized for excellence in teaching, he is beginning a new project on
the social history of Berman v. Parker, a 1954 US Supreme Court decision that
legally sanctioned urban renewal in Washington, D.C.

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