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    oh Na. 

ERNEST L.L. BROWN 

ATTORNEY AT LAW 

AREA CODE 601 726-4276 

MACON, MISS. 39341 

July 13, 1970 

Honorable Jack Greenberg, Attorney 
Honorable Norman J, Chachkin, Attorney 
Honorable Melvyn Zarr, Attorney 
Suite 2030, 10 Columbus Circle 
New York, New York 10019 

Dear Sirs: 

I enclose herewith a copy of the Plan of Integration 
of Noxubee County School District, Noxubee County, 
Mississippi, and Motion of Approval Thereof, which 
I have this date filed in said cause, 

With best wishes, I am 

Yours very truly, 

ol 

= 1 zr ; A 13, prem” 
Ernest L, Brown’ 

ELB:pac 

Encl, 

 



  

UNITED STATES 

DISTRACT 0.0 RT 

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI 

UNITED STATES OF AMERICA, et al 

Appellant 

VS, NOS. 28030 & 23042 

NOXUBEE COUNTY SCHOOL DISTRICT, et al 

Appellee 

PLAN OF INTEGRATION OF NOXUBEE COUNTY 
SCHOOL DISTRICT, NOXUBEE COUNTY, MISSISSIPPI, 

AND MOTION FOR APPROVAL THEREOF 
  

COMES NOW Defendants A, R., Koon, Superintendent of Education, 

and James C, Avery, W, E, Hummer, P. E. Moore, Jos R, Miller, 

and Sam Featherston, who compose the County Board of Education 

of Noxubee County, Mississippi, acting herein by and through 

their counsel of record, and respectfully present to the Court 

the following plan of integration of the schools of said District 

and move the Court to approve the same; 

The student assignment plan prepared by the Office of 

Education (HEW), Appendix 26 to the order of November 7, 1969, 

is amended as follows: 

(A) B, F., Liddell High School and Noxubee County High School 

shall hereafter constitute one high school consisting of grades 

nine through twelve to be known as Noxubee County High School. 

Ninth Grade Mississippi History, Ninth Grade Civics, Physical 

Science, Secretarial Procedure, Vocational Agriculture. ll, and 

Vocational Agriculture III will only be offered at the former B, I. 

Liddell High School, and all students in the former Noxubee 

County High School plant taking the above mentioned subjects shall 

attend the former B, F, Liddell High School for such classes, and 

all such classes shall be fully integrated. Twelfth Grade Governmer 

and Vocational Agriculture I will only be offered at the former 

Noxubee County High School, and all students in the former B. F. 

PP SRA ANI TE PIPE By 

 



  

Liddell High School taking the above mentioned su 

k / ta, IP 

attend the former Noxitbee County High School for classes in the 

- 

said subjects, all of which classes shall be fully integrated. 

Additionally, no less than 200 Negro students now in attendance 

at the former B, F., Liddell Hizh School will be assigned to the 

former Noxubee County High School. 

(B) The Brooksville Attendance Center and Wilson Attendance 

Center at Brooksville, Mississippi, shall become one attendance 

center known as Brooksville Attendance Center, and shall encompass 

grades one through eight. History, Geography, and Civics in Grades 

Six and Seven will only be offered at the former Brooksville 

[3 -y 

Attendance Center, and all students at the former Wilson Attendance 

I) Center in Grades Six and Seven taking the said subjects shall attend 

the former Brooksville Attendance Center for said classes, Likewise 

English and Spelling in Grades Five and Eight will only be oftTered 

at the former Wilson Attendance Center, and all students at the 

former Brooksville Attendance Center taking English and Spelling 

in Grades Five and Light shall attend the former Wilson Attendance 

Center for the said classes, All of the above mentioned classes 

at the former Brooksviile Attendance Center and at the former 

Wilson Attendance Center shall be fully integrated, Additionally, 

no less than 98 Negro students now in attendance at the former 

Wilson Attendance Center shall be assigned ‘to the former Brooksville 

Attendance Center, 

(C) Macon Elementary Attendance Center and B, F., Liddsll 

Elementary Attendance Center shall become one attendance center 

known a3 Macon Elementary Attendance Center, and shall encompass 

grades one through eight. History, Geography, and Mississippi 

History in Grade Five will only be offered at the former Macon 

Attendance Center, aud all students at the former B., F., Liddell 

Elementary Attendance Center in Grade Five taking History, Geography, 

Y, and Mississippi History shall attend the former Macon Elementary 

Attendance Center for said classes, Science and Health in Grade Six, 

 



  

and History in Grade Seven shall ouly be offered at the former 

B, F, Liddell Elementary Attendance Cenfer, and all students at 

former Macon Elementary Attendance Center taking the sald subjects 

in Grades Six and Seven shall attend B, F, Liddell Elementary 

Attendance Center for the classes in the said subjects. All of the 

above mentioned classes shall be fully integrated. Additionally, 

no less than 180 students now in attendance at the former B. F. 

Liddell Elementary Attendance Center shall be assigned to the foruer 

Macon Elementary Attendance Center. 

(D) Shuqualak Attendance Center and Reed Attendance Center 

i. hnl% ha “m. ¢ oy f+ Jo Oo X Gi : C ak shall become one attendance center under the anme of Shuqualak 

- 

Attendance Center. Science and alth in Grades Five and Seven will 

only be offered at the former Shuqualak Attendance Center, and all 

students at the former Reed Attendance Center taking Science and 

Health ia Grades Five and Seven shall attend the former Shuqualak 

Attendance Center for classes in the said subjects, History and 

Geography in Grades Six and Eight will only be offered at the former 

Reed Attendance Center and all students at the former Shuqualak 

- 

Attendance Center taking History and Geography in Grades Six and 

f» Eight shall attend the former Reed Attendance Center {for classes 

in said subjects, All of the above mentioned classes shall be 

fully integrated, Additionally, no less than 80 Negro students 

shall be assigned from the former Reed Attendance Center to the 

former Shuqualak Attendance Center. 

 



  

I 

in suovort of said Motion, the defendants would show that tha 

gnggested Plan of Integration heretofore filed hy the Office of Eda- 

cation, Department of Health, Education aud Velfare, and which was, OY 

3 i 

tha Court, ordered to be jmaplemented in said Order dated November 7, 

1959, envisions the closing of Brooksville A ttendance Center and the 

transfer of the entire gtudent body from that Attendance Center tO 

Wilson Attendance Center; that the Brooksville Attendance Center has 

} ow 

By o £ j tomy 4 ay J ney £7 en At ond ro avi oe ym ot 

av eproliment of 145 students, anda iat Wilson Attendance Cenver aas 

pn ry pe coy) pe a wp TTY a RAE IRR Ce RGD TUR Ry PS 

ant of 949 students; that at Wilson Attendance Center there 

basing the standard classroom capacity of 27 students, and the 

standard classroom capacity of 15 students, the total capacity of 

Wilson Attendance Center is 792 students. There are Now enrolled at 

x 

Wilson Attendance Center 934 students. There are presently enr F (@
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in Brooksville Attendance Center 145 students; thus is would be totally 

impossible to transfer the 145 students at Brooksville Attendance Cexi- 

ny 

ter ot Wilson Attendance Center, which would have the effect of placing 

1079 students in an atlendance center the capacity of which 792. 

II 

The said suggested Plan of Desegregation heretofore filed Db 

the Office of Education, Department of Health, Education and Welfare, 

envisioned the transfer of all students jn Grades Nine through Twelve 

from B., F., Liddell High School to the Noxubee County Hizh School, and 

the transfer of all students in Grades Une through Eight at Macon 

Elementary School to B, F, Liddell High School, thus converting the 

Macon Elementary School and Noxubee County High School into a gingle 

high school, and the B, F. Liddell High School aud Elementary School int: 

a single elementary school. Defendants would further show that Noxubee 

County High School was constructed for a capacity of 250 students; that 

the present enrollment in Grades Nine .through Twelve is 298; that tae 

school plant consists of 6 standard size classrooms; 2 sub-standard 

classrooms; a combination Physics and “Chemistry room, having a capaci 

of 18 students per period; a combination Biology and General Science 

room, having a capacity of 20 students per period; one Home Economics 

  

 



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Tarn Or PL, SL. Se I SLE a eb ie FD I 

Department, including one classroom with & capacity Oil 20 students 

per period; one Vocational Agriculture Department, including one class- 

oe
 

- 

room with a capacity of 18 students per period; one Lanaguage Labora- 

tory, consisting of a sub-standard size classroom with a capacity of 

15 students per period; one Comaerc jal Department Room, having a 
oA 

capacity of 23 studsnis par period; one Library with a capacity of 

adents oper period; one Gymmasium, with a capacity of 500 

students per period; one Band Hall, with a capacity of 40 students; 

one Industrial Arts room with a capacity of 15 studsnts per period; 

+hat Macon Elementary School, which is situated om the same campus 

with Noxubee County High School consists of fifteen standard size 

classroous; one Library with ¢ capacity of 25 elementary students 

per period; one portable classroom, for Special Education, with a 

apacity of 12 students per period. 

That the present enrollment in Grades nine through twelve at 

B, F, Liddell High School is 847, and that it would be physically 

jmposgible to place these 847 high school students from B., F. 

Liddell High School in the facility at Noxubee County High School 

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and Macon Elementary School; that in order to accommodate 

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847 students from B, F, Liddell High School, it would be neces 

to convert four classrooms for instruction in Physics, Chemistry, 

Biology and General Science; to convert three classroous into Home 

Economics rooms; to convert two classrooms into Industrial Arts 

rooms; to convert one classroom into a Foreign Language room; to 

convert the cafeteria, which now has a capacity of 600, to a capa- 

city of 1200; to construct a new Vocational Agriculture Building 

+o accommodate two full-time Vocational Agriculture teachers; To 

convert the present gymnasium, with a capacity of 500, to 

a gymnasium with a capacity of 1200, and to renovate the library, 

which presently has a capacity of 40 students, to one having a 

capacity of 150 students. 

When the above outlined renovation is completed, there would 

remain only five classrooms to accommodate the 847 high school stu- 

dents from B, F., Liddell High School, which means that it would be 

necessary to construct an additional 22 classrooms, a complete mew 

  

 



  

: 

Vocational Agriculture Building, renovate the gummasium, lunchroou, 

library, band hall, and all bathrooms at Macon Elementary School, 

which are presently built for elementary students and are minature 

in size and equipment; that the cost of such program is estimated 

by a competent architect to be $1,200,000.00, Further, upon comple- 

the construction of the additional 22 

classrooms, almost all, if not all, the available playground would 

gps 3 ~ -, we 3 2% "re A re rm a I. ERE, 
guired in order to finance such renovation and con- 

ge cv brs visi 3 rv y n Th fe a 2 on IYVe \ 2d Mie ¢ Tm] ¥ struction, and that same could not be accomplished. That simply To 

rvs Perris Th Tn ters ~~ Ae Arves A eT AEE ele ile pv iy renovate the interior of Macon Elemenftary School to convert iT To a 

th school students will cost 

Fh 

appro OX ima tal Y $500, 000 » 00 @ 

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) Because of 1 ultra-crowded condition that would ex: 

the coustruction of the 22 additional classrooms, and the limita- 

tion thereby placed upon the playground space for the students, 

it woitila be desirable to construct a complete new high school, 

relocated on a larger tract of land; that the cost of such new 

high school, relocated on a larger tract of land, is estimated 

by a competent architect to be $1,200,000.00, Defendants would 

» 

further show unto the court that the defendants are wholly without 

funds with which to make such renovation and construction, and that 

it is highly doubtful that any bond issue would be approved by The 

citizens of the County for said purpose. 

III 

Defendants further show that the recommended plan of desegrega- 

tion of the school of defendant District heretofore filed by the 

Office of Education, Department of Health, Education and Welfare, 

envisions the closing of Shuqualak Attendance Center and trans- 

ferring the students from that attendance center to Reed Attendance 

Center; that Reed Attendance Center consists of twelve standard 

classrooms and four portable classrooms, and that, using 30 students 

as the capacity of a standard classroom and 15 students as the capa- 

city of a sub-standard classroom, Reed Attendance Center has a 

 



  

Present capaclty of 420 students; that the present enrollment of 

vem whe 
[8 al = ” 0 Y ca Lil a By | NT ce ofl oy oe » "y alm l= be + sro! Tmen- Reed Attendance Center is 45 students; that the pressnt enrollment 

of Shuqualak Attendance Center is 118 students, and that the transfer 

of the 118 students from Shuqualak Attendance Center to Reed Atten- 

Reed Attendance Lr
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oa PR ~ Ln dance Center would increase the en 

Center to 572 students in a facility, the capacity of which is 420 

students, and that thus an impossible situation would be created. 

The plan of dssegregation hereinabove outlined and proposed by 

7 : oN 3 or - 03 73,2 ve mn 550 x gum 2X wa lefendants would result in placing an additional 228 Negro studs a 

3 hae + mo: Nn viihas rind FO A BR EG Tar 1 mA in the former Noxubee Count y High School for classes, and 94 more 

ll High School for classes; it would likewise 8 oO
 

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place an additional 143 Negro students in former Macon Elementary 

Cen ter for classes, and 112 Negro students on permanent 
Attendance 

assicmment, and 8C white students in the former B, F. Liddell Ele- 

ment ary Attendance Center for classes. The effect at the former 

Brooksville Attendance Center would be to place an additional 244 

Negro students therein for classes, and 58 on permanent assignment, 

with 39 white students £0 be placed in the former Wilson Attendance 

Center for classes. At Shuqualak, an additional 100 Negro students 

would be placed in the former Shuqualak Attendance Center for classes, 

and 47 on permanent assignment, and 21 white students will be placed 

in former Reed Attendance Center for classes, 

V 

Defendants aver that upon the approval and implementation of 

the above, outlined plan of integration of the schools of the 

defendants’ District, the schools of said District will not be 

identifiable by race and will constitute a unitary, non-racial 

school system, 

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oT TAT 

MA "3 LING OF 
  

TRMTLRTO AMD ERTIFICATE 

I, Ernest L, Brown, Attorney of r 

County School District, do hereby certify 

7 
he led, by United States Mail, postage 

copy of the foregoing Plan of Integration 

e 

of Noxubee 

fenda 

paid, a true 

nt, Noxubee 

1A - - ~ 

G18 aay 

and. correct 

County School 

District and Motion for Approval Thereof to the following: 

Honorable Dan M., Russell Jr,, Judge 

United States District Court for 
the Southern District of 

Mississippi 
Federal Building 
Gulfport, Mississippi 39501 

Honorable A. F, Summer 
Attorney General of Mississippi 

New Capitol Building 

Jackson, Mississippi 39205 

Honorable Jerris Leonard 
Assistant Attorney General 

Civil Rights Division 
United States Depar 
Washington, D. C. 

a aT 
tment U 

20530 
of 

Honorable Ben 
Civil Rights 

United States 

906 Milner Buil 
Jackson, oe oy 

Sis Miss 

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il, Honorable 

Honorable 
Honorable 

5383 
Jackson 

Me iv yi 4 

Reuben Anderson, 
Ra Tce 
DAIKS 3 Jr 

wv Med i Honorable 
Honorable Noryen Jd. 

Honorable Melvy 

Suite 2030, 

New York, New Yo 

Jack Gre 

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this u WITNESS MY SIGNATURE, 

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Justice 

Attorney 

A1eor rney 

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Torney 
Attorney k's] 

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UNITED STATES DISTRICT COURT 
FOR THE SOUTHERN DISTRICT OF MISSISSIPPI 

UNITED STATES OF AMERICA, et al 

Appellant 

VS. NOS. 28030 & 28042 

NOXUBEE COUNTY SCHOOL DISTRICT, et al 

Appellee 

AFFIDAVIT OF BI-RACIAL COMMITTEE 
  

SERSONALLY APPEARED BEFORE ME the undersigned authority in 

and for Noxubee County, Mississippi, Bennie Sanders, John Roland, 

and the Reverend W. M. Harper, three leaders of the Negro commu- 

nity of Noxubee County, Mississippi, and V. M. Geno, Carl W. Craig, 

Jr., and Dr. W. C. Anderson, three leaders of the white community 

of Noxubee County, Mississippi, each of whom, being by me first 

duly sworn, on oath, depose and say: That they compose a Bi-Racial 

Committee of the Citizens of Noxubee County, Mississippi; that the 

proposed Modification of the Plan of Desegregation of the Schools 

of Noxubee County, Mississippi, as shown by a Motion, which Motion 

is to be filed in the United States District Court for the Southern 

District of Mississippi by the Noxubee County Board of Education 

and the Superintendent of Education, has been this day presented to, 

and lucidly explained to us, and we thoroughly understand the same. 

Affiants further depose and say that they do heartily agree with 

and endorse the said Proposed Modification of the Plan of Desegre- 

gation of the Schools of Noxubee County, Mississippi, as reflected 

by the above mentioned Motion. 

  

  

  

  

  

  

  

: et? by 

HAI) hngag L  Drad lrg se ff FEZ [EL 
BENNIE SANDERS | : JOHN ROLAND; 

5 Fg Den fob A y yo Ji AAS 

</ - At s/ 7) 7 ¢ / / i / 3 \ vi L 4 § ZL 7 | tne] J 

~~ THE REV, W. /M. HARPER V. M., GENO 

ft rid 7 / / / 5 ; 5 

Bayo / YN Ao A Fr lL Lon CH ep=L Pr 2 AS a 

> CARL W. CRAIG, JR. DR. W. C., ANDERSON" 

SWORN TO AND SUBSCRIBED BEFORE ME, this the _,/77° day of July, 1970. 

(Seal) 7 4 (7 Ame ary 
Notary Publi 
  

ah AST <7 7 
My commission expires Z’/»../. /. fad