Supplemental Appendix of Appellant (Detroit Board of Education v. Bradley)

    t*

No. 72-8002
IN THE UNITED STATES COURT OF APPEALS 

FOR THE SIXTH CIRCUIT

BOARD OF EDUCATION OF THE SCHOOL 
DISTRICT OF THE CITY OF DETROIT, 
a school district of the first 
class,

Appellant,
vs.
RONALD BRADLEY, et al, 

Appellees.

On Appeal from the United States District Court 
For the Eastern District of Michigan 

Southern Division

SUPPLEMENTAL APPENDIX OF
APPELLANT BOARD OF EDUCATION OF THE SCHOOL DISTRICT 
OF THE CITY OF DETROIT, A SCHOOL DISTRICT OF THE 

FIRST CLASS AND OTHER DEFENDANTS

RILEY AND ROUMELL
George T. Roumell, Jr.
Louis D. Beer 
Jane Keller Souris 
Russ E. Boltz
C. Nicholas Revelos, Of Counsel 
720 Ford Building 
Detroit, Michigan 48226 
Attorneys for Appellants and 
certain other named Defendants



CROSS-EXAMINATION

BY MR. BUSHNELL of 
DR. ROBERT GREEN:

(964) Our schools are producing failures.
General Motors would ever begin to produce the kinds of 
that we produce in our public schools they would be out

If
failures
of



business torao .orcA : That is ray concern and ̂ ^laope I don’t 

soana overly passionate here at the moment, but I feel verv 

stn.ongiy about the role that education can play in humanizing 

young people, in humanizing this nation, and a very significant 

part of this- humanization, process is learning to live with and 

to respect es.ch other. And when people are separate frora 

each other, as long as we have the Birminghams, the Bloomfield 

Hills, the Lxvonias, and I live in East Lansing, so 1 have to 

drive down every morning -to testify and when I drive in from 

East Lansing, like this morning, it took us one hour to drive 

from East Lansing to about Southfield, and it took us almost ' 

s.n hour t_o get that is about 60 miles -—  it took us another 

hour to get from Southfield downtown, and I ■very carefully 

looked and I asked ray two assistants to look too. We counted 

three black faces between Southfield —  and I mean the traffic 

was bumper-to-bumper at spots. From Southfield all the way 

down to Eight Mile we counted about three black faces. End 

1 see the schools as being directly related to that.

- We did not educate the white - adults who

went to the Detroit Public School System who - are now living in 

Livonia. We did not educate young whites who were educated 

at Central. I can remember when Central was predominantly white. 

1 can remember when Southwestern was predominantly white, j 

can remember when Eastern High School was at about a 60

A Cftfi COURT REPORTERS  
1300 GRISWOLD BUILDING 

DETRO IT, M IC H IG A N  48226
(313) 965-8270 '



percent white DODu7a-Hon t.*, v — xo„, .men my older brother att-nd--
-r *-tern High School, _ , .•*•*=>• a ceacher in f-b«, .,. ■ 1* .. \P _X £ /̂"3> ̂ ^VT|

' 3 5 > abo?-t those year«
wean he graduated in about 1935

- >--».* y  <£Le*.jr'<g

wortham High School “h^V -ox baa u percent .■*>,,,, - ̂ cne whites Tfled.. _■ Northwest jL'etj-°J-t has fled to Oak pa-V -, -- .• juivonia^ '■
Bloomfield F-Jii-* - -v4-̂  a - .ci * - . „' L-3t tlxqn'C b»-»r>rr • ̂ _> - mg oxgnxxxcantly
raided to what «  have not done in our public schools. Tf 
,,e dxa a head count we «ould find a good ^  ^
-£-©-oiCiOnts todav ~*nr? .. . -

3 anotiia;c Gooct examols, ^he hr- M  a-- ' '-n'~ J-act blacks
can’t buy houses in Warren i- ,
„ - 3 failura <* « *  Detroit Publi

’ ~ ■oCc.rri„ Livonia was sticks and ,„ ® dna v>°oas when I was a kx
That s«b«r-ban community wa3 huH t s-*
. . "Ullt oecaua- the Detroit Public

ochooi System did not ppr^rr, i-r. r •
, b S tactiDB. Xt was built
°eCaOSa ”  SSd 311 * W t .  elementary school a n  ■ ■.* ois' a U  wnita juni<hxgh schools an^ -< -* v» .,“ a-ul wnxte hxgh schools,

I hc^e,.sir, you as an attorney for the
3Cnp°l Board would begin to see this n~ - .

~ a=> - se® it and understa
* " n «*•» a wxtnass to ieav*=> mr -\^ - .- ~ u~ jOD ailf3 to leave the
•nxvarsity and j am not rerebnnr _ .

' *J “ your comment abonf
L- .X ’X* V? —. ?- ci — *-■***-% u*at oc^eit^r —  -.r̂— /». - *, .•* 'xua «- 9-*-re Scnvei ts*»>*



_ ________________  ___JLQ21

Troa.

lostarcay m  response to a question you indicated that in • 

terms of 98 percent black schools in the South ana 98 percent 

olaclt schools in Detroit it was your opinion that the black 

perception would be the same, and I believe yon said —  •••

Yes . ' . : " ■.. -

well, 1 woula like toypose this to yout in a particular - 

Southern school district, higher elementary, fifth or sixth 

grade children, if they were to live in the northwest comer 

of the- school district and be bussed past a white school to an 

all-Black school in the southeast comer of the district, and 

then contrast that or compare it with the city - of Detroit, the 

fifth or sixth grade black child who walks to an elementary 

school, say, three blocks away, and it is 90 percent black, 

hut he knows all the children who live in that school attendance 

area, black or white attend. Now, would it ha your testimony 

that the percentages of those two children about the school 

system would ha the same?

I would say that in general both youngsters would be very 

cognisant of the aact that there has bean very definite racial 

treatment in terms of how their particular situation is struc­
tured at that moment.

how, I have talked -about an attendance cone where everyone in 

the cone goes to school, black or white. -

A C M E  C O U R T R E P O R TE R S 
1300 GRISWOLD BUILDING 

DETRO IT, SVHCHJGAN 43226  
(313) 965-8.270



1024

it

it

r,

O

0

Iho aware of that.
I want you to look at it fron the point of view of the child

vis-a-vis the school system -—

MR. LUCAS;' I hesitate to interrupt, but 

I think I6to going to have to object to the hypothetical questioifi 

in that it is not comparing two things. It is comparing one 

child bussed to a school versus a walk-in black school in the 

Uorth. A think a proper hypothetical would be a black school 

in the South versus a walk-in black school in the North, or 

two bussing situations. But, 1 think the hypothetical is

improper under the circumstances. . ’

~ HR. YOUNG: I think the witness can answer

that question properly.

THS COtikT: We will leave it to the witness

(By i'ir. Young) Would there be some difference in the -impact 

on the child in his perception?

I would say I agree? first of all. The situations are not

parallel here. But, even looking at it in terms of how you 

structure the question, both youngsters would yet perceive a 

grownup8s kind of perception about their situation as it relates 

to their circumstances —  I should say as it relates to that 

Particular school —  as one which has been contrived and

structured around a concept of segregation and unfairness.

So, your testimony is that although the situation as outlined

ACME COURT REPORTERS
1300 GRISWOLD BUILDING 

DETROIT, M ICH IGAN  48226  
. 1313) 965-82 70

‘ 1 I

i V 3 ;; .



*

. o y* 3 * t4

i.r.voact on the child voula ds

Scale, 3! can assure yon 

similar. - ,

¥ ":>u don 6 .u *t hinl•wi? vould c.ha

Id be verv-X • •.»a o -i-i >e* SaQ3| aua

WO youngse:;ro and follow th,en thro

dv*0 themi a Hacial attitude QvUL.rvey

re their -v*iry X- wsponsS3 would be highly

vntj>TG: i’hat*s all- i'hanlc you.

It;-:
f *i i; 
i i

MR. YOUNG