Correspondence from Caldwell to Beer

    P H O N E  ( 901 )  5 2 5 - 8 6 0 1

M A R V I N  L.  R A T N E R  

R.  B S U G A R M O N ,  J R .  

L O U I S  R-  L U C A S  

W A L T E R  L. B A I L E Y ,  J R .

I R  VI  N  M S A L K  Y 

M I C H A E L  B .  K A Y  

W I L L I A M  E.  C A L D W E L L

• #
RATNER, SUGARMON & LUCAS

A T T O R N E Y S  A T  L A W

S U I T E  5 2 5

C O M M E R C E  T I T L E  B U I L D I N G

M E M P H IS ,  T E N N E S S E E  3 8 1 0 3

January 5, 1972 B E N  L .  H O O K S  

O F  C O U N S E L

Louis D. Beer, Esq.
Riley & Roumell
7th Floor, Ford Building
Detroit, Michigan 48226

RE: Bradley, et al. vs. Milliken,
et al., C.A . No. 35257

Dear Mr. Beer:
This letter will confirm our telephone conversation of 

Monday, January 3, 1972, insofar as we discussed your letter 
of December 23, 1971, pertaining to several construction pro­
jects which the Detroit Board of Education wishes to under­
take at this time. As Mr. Lucas and I informed you and Mr. 
Roumell .in our conversation on Tuesday, we have no objection 
to any of the proposed construction projects, except the 
proposed replacement of the Amos school.

With regard to the Amos school our objection is tentative 
pending receipt of additional information which we feel is 
necessary to a knowledgeable evaluation of the Board's proposal. 
As we have previously discussed, we would have no objection to 
the addition of fire safety sprinklers and other safety devices 
which are necessary in order to comply with the various building 
and fire code requirements. Your letter of December 23, 1971 
indicates, however, that additional needs at the Amos school, 
such as a boiler replacement, has led the Board to the con­
clusion that replacement of the entire structure would be 
economically more efficient than repair of the existing facility. 
In order for plaintiffs to fully evaluate the Board's proposal, 
we need the following additional information:

1) What are the projected costs of repairing the 
existing facility and making the safety 
additions necessary as opposed to the costs 
of constructing a replacement facility? •

2) What type of construction does the Board 
propose for the replacement facility?



2 January 5, 1972Louis D. Beer, Esq.

3) What is the time projected for construction 
of the replacement facility?

4) How many classrooms are projected at the 
replacement facility as opposed to the number 
of classrooms in the existing facility?

As previously stated, our objection to the Amos school 
replacement is tentative, pending receipt of the additional 
information requested herein and a further evaluation. Never­
theless, we take this opportunity to make some additional comments 
so that the Board may more fully understand our position with 
regard to the construction of additional classrooms, whether 
they be for replacement purposes of for additional capacity 
within the system. While there is considerable dispute among 
the parties as to the type of school reorganization that will 
be required .for Detroit, it is clear, as the case now stands., 
that sortie type ' of reorganization will be required. Because 
the particular form of reorganization has not been decided, 
however-, it is virtually impossible to evaluate the effect of 
proposed classroom construction on a desegregation plan which 
has not yet been formulated or approved. It could well be, 
for example, that the Amos school will no longer be needed under 
a new plan of operation, and plaintiffs are concerned that no 
monies should be expended for additional classroom space when 
there is a substantial possibility that the space may not be 
necessary under a new plan of operation.

Plaintiffs' position would seem particularly applicable 
to the Amos school situation. The current racial census 
indicates that Amos has a total enrollment of 521 pupils, none 
of whom are black. Furthermore, the capacity-enrollment comparison 
chart dated September, 1971, indicates that there are more than 
enough vacant seats in the other elementary schools within the 
Western constellation to house these 521 pupils if it becomes 
necessary to close the Amos school prior to the time that a new 
plan of operation is approved.

By the foregoing I do not mean to intimate that we have 
finalized our objection to the Amos proposal, and we will 
evaluate the matter further upon receipt of the additional infor­
mation requested. I am merely attempting to point out some of 
the problems we perceive in the Board's proposal at this juncture,



Louis D. Beer, Esq - 3 January 5, 1972

and at the same time indicate to the Board the basis for our 
position with regard to proposed classroom construction.

WEC:pw
cc:' Alexander B. Ritchie, Esq. 

Theodore Sachs, Esq.
Eugene Krasicky, Esq.

bcc: Nathaniel Jones, Esq.
E. Winther McCroom, Esq. 
Paul R. Dimond, Esq. 
Norman J. Chachkin, Esq. 
William Penn

Very truly yours
RATNER, SUGARMON & LUCAS

By:
William E. Caldwell