From the 1960s through the 1990s lower Federal courts heard nearly 40 cases that dealt with racial segregation in prisons. The courts have consistently held that blanket policies of racial segregation are unconstitutional. As a result of these Federal court cases, prison systems around the country were forced to integrate their institutions to varying degrees. The only empirical evidence to date on what happens following a policy of forced prison desegregation was presented in a series of articles by Trulson and Marquart (2002) that examined the desegregation of Texas prisons in the aftermath of Lamar v. Coffield (1977). This was a class-action suit that forced Texas prison officials to desegregate inmate housing areas, including double cells. A critical reason that prison desegregation in Texas was achieved without large-scale racial violence was prison officials' removal of disruptive inmates from the general prison population and a matching of compatible inmates. In Johnson v. California (2005), the U.S. Supreme Court ruled that California's unwritten practice of racially segregating inmates at reception and at transfer must be subject to the strictest of scrutiny to be justified. As a result of this ruling, California prison officials are required to desegregate the cells in their reception centers and likely their long-term prison units. California is currently developing a procedure for enforcing and measuring compliance with the Johnson ruling. This article argues that random celling, based on the Texas solution to prison desegregation, is the only realistic and legally defensible strategy of prison desegregation. California must find ways of managing the inmate incorrigibles and known prison gang members, as did Texas. References