Amendment to Complaint

Public Court Documents
July 21, 1992

Amendment to Complaint preview

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  • Case Files, Sheff v. O'Neill Hardbacks. Amendment to Complaint, 1992. a0a0de58-a546-f011-877a-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/357d80cf-367a-4fb8-8091-5c011e3c1ce9/amendment-to-complaint. Accessed July 29, 2025.

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MILO SHEFF, et al. 

Plaintiffs SUPERIOR COURT 

JUDICIAL DISTRICT OF 
HARTFORD/NEW BRITAIN 
AT HARTFORD 

No 

WILLIAM A. O'NEILL, et al. 

Defendants JULY 21, 1992 

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AMENDMENT TO COMPLAINT 
  

47. These disparities in educational achievement between the 

Hartford and suburban school districts are the result of the 

education-related policies pursued and/or accepted by the defendants, 

including the racial, ethnic, and socioeconomic isolation of the 

Hartford and suburban school districts. These factors have already 

adversely affected many of the plaintiffs in this action, and will, 

in the future, inevitably and adversely affect the education of 

others. 

50. For well over two decades, the State of Connecticut, through 

its defendant O'Neill, defendant State Board of Education, defendant 

Tirozzi, and their predecessors, have been aware of: (i) the separate 

and unequal pattern of public school districts in the State of 

Connecticut and the greater Hartford metropolitan region; (ii) the 

racially and economically segregated population patterns in the 

Hartford region and (iii) the consequent need for substantial 

educational changes, within and across school district lines, to end 

this pattern of isolation and inequality. 

  

  

 



      

71. [deleted] 

BY: 

Wesley W. Horton 
Moller, Horton, & Rice 
90 Gillett Street 
Hartford, CT 06105 

Julius L. Chambers 
Marianne Engelman Lado 
Ronald L. Ellis 
NAACP Legal Defense & 

Educational Fund, Inc. 
99 Hudson Street 
New York, NY 10013 

Helen Hershkoff 
John A. Powell 
Adam S. Cohen 

American Civil Liberties 

Union Foundation 

132 West 43rd Street 
New York, NY 10036 

Respectfully Submitted, 

M7 Gere 
  

Philip D. Tegeler 
Martha Stone 
Connecticut Civil Liberties 

Union Foundation 
32 Grand Street 
Hartford, CT 06106 

Wilfred Rodriguez 
Hispanic Advocacy Project 
Neighborhood Legal Services 
1229 Albany Avenue 
Hartford, CT 06112 

John Brittain 

University of Connecticut 
School of Law 

65 Elizabeth Street 

Hartford, CT 06105 

Ruben Franco 
Jenny Rivera 
Puerto Rican Legal Defense 

and Education Fund 
99 Hudson Street 
New York, NY 10013 

  

  

  
 



      

CERTIFICATE OF SERVICE 
  

This is to certify that one copy of the foregoing has been mailed 

postage prepaid by certified mail to John R. Whelan and Martha M. 

Watts, Assistant Attorneys General, MacKenzie Hall, 110 Sherman 

y 24 

Street, Hartford, CT 06105 this ZZ day of July, 1992. 

IL Fear   

Philip D. Tegeler

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