Motion of William C. Cramer to Participate in Oral Argument as an Amicus Curiae

     [||7dc08060-4494-4b2c-9a8b-25fa75d73fa8||] S
O
N
 

KL
 

SS
 

  

IN'THE SUPREME COURT OF THE UNITED STATES 

OCTOBER TERM, 1970 

ar e 
| NO. 281 

JAMES E. SWANN, ET AL, ) 

Petitioners, ) 

Vv. ) 

CHARLOTTE-MECKLENBURG BOARD ) 
OF EDUCATION, ET AL., 

Respondents. ) 
) | 

  

I MOTION OF WILLIAM C. CRAMER | i TO PARTICIPATE IN ORAL ARGUMENT 
AS AN AMICUS CURIAE |   

Comes now William C. Cramer and files this his motion for the 

consideration of the Court: 

Movant William C. Cramer has, with the consent of the parties, filed 

a brief as Amicus Curiae in this proceeding. He hereby requests that | ' 

ii he be granted leave to participate in the oral argument of this case and 

that 20 minutes be allowed in which to present his views. 

Movant is sensible of the fact that counsel for petitioners and 

counsel for respondents in the consolidated group of cases to be heard, 

and, in all probability the Solicitor General and other interested parties, 

{{ will seek to participate in oral argument and he is, therefore, reluctant 

to add to the demands on the Court's time. He believes, however, that the 

public policy questions presented are of such supervening importance and   
that his special competence and qualifications are so unique that an oral 

presentation by him will prove informative to the Court. 

Movant submits that the issues raised in this case call into question 

the scope, purpose and constitutional validity of Sections 401 (b) and 

407 (a) of Title IV of the Civil Rights Act of 1964, Public Law 88-352, 

88th Congress, 2nd Session, 78 Stat. 241, which prohibit the assignment 

or transportation of students to overcome racial imbalance in public 

schools. Movant does not believe that any of the parties have adequately 

  
  

EE ov ee 

    
RN ae  



| *® ® 

  

canvassed the legislative history of these provisions which were enacted 

under the authority of Section 5 of the Fourteenth Amendment to the United 

States Constitution. 

Movant is a member of the U. S. Congress from the 8th Congressional 

District of Florida. At the time the Civil Rights Act of 1964 was under 

consideration by the Congress, he was a member of the Committee on the 

Judiciary of the House of Representatives, and of its Civil Rights Sub- 

committee. In that capacity, he participated extensively in the delibera- 

tions and debate which led to passage of the Act and, in addition, he 

was the author of Section 401 (b), one of the provisions to be considered 

by this Court in this proceeding. 

In view of the importance of the questions presented and the public 

policy issues to be decided, Movant believes that his special competence 

and qualifications merit his participation in oral argument and will 

materially benefit this Court in reaching its decision. 

For the foregoing reasons, Movant requests that he be granted 20 

minutes for oral presentation of the legislative history of the Civil 

Rights Act of 1964, 

   
submitted,    

   
  

’ RA C LJ 

Rayburn House Office Building 
House of Representatives 
Washington, D.C. 20515 

     
     

  

  

RICHARD C. PEET 

4442 Hawthorne Street, N.W. 
Washington, D.C. 20016 

  

 



# 
CERTIFICATE OF SERVICE 

  

I HEREBY CERTIFY that a true and correct copy of the foregoing 

has been mailed, postage prepaid, this 15th day of September, A.D., 

1970, to: 

William J. Waggoner, Esa. 
Weinstein, Waggoner, Sturges, Odom & Bigger 
1100 Barringer Office Tower 

426 No. Tryon Street 

Charlotte, North Carolina 28202 

C. O. Pearson, Esq. 
At rAavrmoyw and Cvmiincel 1a + YT ae 
ALLULILITY aiid LVOUlISe ll 101 a fs W J 

P. 0. Box 1426 

Durham, North Carolina 27702 

J. LeVonne Chambers, Esq. 

Chambers, Stein, Ferguson & Lanning 

216 West Tenth Street 
Charlotte, North Carolina 28202 

Jack Greenberg, Esq. 

Attorney at Law 

10 Columbus Circle 

New York, N. Y. 10019 

Stephen J. Pollak, Esq. 

Shea & Gardner 

734-15th St., N.W. 
Washington, D.C. 20005 

Hon. Claude Kirk, Governor 

Tallahassee, Florida 

Raymond B. Witt, Jr., Esq. 

Gaither, Abernathy & Wilson 

1100 American National Bank Bldg. 

Chattanooga, Tennessee 37402 

David Norman 

Department of Justice 

Washington, D.C. 

4 
{ 

  qd __ lh. Ag a He ————————————— — 

-v® . RM NT C . 

iting [||7dc08060-4494-4b2c-9a8b-25fa75d73fa8||]