Correspondence from Guinier to Bair
Correspondence
November 7, 1985

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Case Files, Sheff v. O'Neill Hardbacks. Initial Outline of Testimony: William Gordon, 1992. b970e699-a946-f011-877a-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/1eaa88be-2dab-4c7f-9b77-d64144af4f36/initial-outline-of-testimony-william-gordon. Accessed August 19, 2025.
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* » Privileged and confidential INITIAL OUTLINE OF TESTIMONY: WILLIAM GORDON Qualifications [see attached sheet] stress experience in designing desegregation plans RESUME Growth of school segregation in the Hartford region: knowledge Have you examined school enrollment trends in the Hartford region during the past 30 years? What documents have you reviewed? Are these the types of data you generally rely on in your field? What conclusions have you drawn about the levels of racial concentration in the Hartford schools? increasing racial segregation, poverty concentration in city of Hartford schools What have the recent enrollment trends been in Hartford vs. the suburbs--since 19807? suburbs--down 11000; city up 710; black and hispanic influx; white outflow. See EXHIBIT (large map)--what does this represent? based on exh 85? How is the region defined? Why is it instructive to use black and hispanic percentages, as you have in this chart, in addition to total minority? Introduce as summary. What is current proportion of black vs Latino students in Hartford? When did state start regularly collecting racial data? What was minority percentage in Hartford schools at that time? 2=a?? 40m24.6 22 Has there been a steady rise in percent of minority students up to the present time? Was the state aware of this trend? Do the minority student and staff reports analyze the increasing racial concentrations? is there text? does the text often focus on concentrations of minority students in urban areas of the state? (refer to 1992 MINORITY STUDENTS AND STAFF REPORT--Exh. 85) State contribution Have you reviewed the system of public school administration in the state of Connecticut? From your perspective as an expert in educational administration, what the extent of state control over local education in Connec- ticut? Aren't school district lines also set by the state? Does the state tell children where they can attend public school? Have you reviewed the state’s role in local school construction? What documents have you reviewed? Have you looked at state reimbursement rates; looked at process local districts must go through to get a school built? Reimbursement State reimburses local districts %¥ for school construc- tion (see Brewer deposition for details) Approval State has approval power over every school built. Approval over every aspect of school plan, including [program], [students who will attend], and [location]? Local district not permitted to build--even using its own funds--without state approval (refer to SCHOOL CONSTRUCTION GRANTS MANUAL) have you looked at where and when schools built in the Hartford region? Did you supervise the preparation of Exhibit 155? What does it represent? dots? Does it include schools closed prior to 1988? Sources: Exhibit y . Does it include two new schools in Hartford? New Manchester school? introduce EXHIBIT 155 What ‘is Exhibit 156? What trends are apparent from reviewing this exhibit? In your opinion, has the state’s funding of school construction been significant? Has the state’s funding of school construction in the region promoted school segregation? Is it fair to say that the state has funded the massive expansion of a segregated school system in the Hartford region? Introduce 156 into evidence Closed schools/lost opportunities how many students did you say the suburbs have lost since 1980? Does this mean there are 11,000 seats available in the suburbs right now for city students? Why not? So--looking at 156--were suburban schools closed during this time period when all this new school construction was going on? see EXHIBIT . Do you know why these schools were closed when the city was experiencing overcrowding? Would it have been more expensive or less expensive, Dr. Gordon, to use existing suburban school buildings rather than build new schools in the city? (lf all 11,000 seats are not available in suburbs, it’s because state has given suburbs permission to decommission some schools at the same time state knew more seats were needed in Hartford!! And state approved and funded these unnecessary schools! This is outrageous. Give examples.) Current construction plans/ past 5 years Is the state still spending money on school construction in the Hartford area? last 5 years state actually has the highest reimbursement rate for the most segregated and poverty concentrated schools--this is tragic--Hartford just had bond resolution for $2 million to build racially isolated schools. State would reimburse Bartford for: .. %. None of these schools are necessary. All Hartford's overcrowding problems will easily be handled through desegregation. Are you saying that the state should stop spending money to build more segregated schools? Failure to act Foundation Based on your review, did the state do anything to counter these trends of increasing racial isolation in the Hartford schools? No. State has repeated failed to act. He has examined dozens of plans, reports, recommendations, study commis- sions--in all his years of work on desegregation, he’s never seen a state that has studied the problem so repetitively, yet done so little. State had the information and the means to address this problem a long time ago. But instead of trying to solve the problem, they contributed to it. What other conclusions have you gleaned from your review of the historical record? Documents show that 1) state was aware of the problem, 2) state knew of the harms of increasing racial and economic segregation, 3) state knew of plans and strategies that could have constructively addressed the problem, but failed to act, 4) state repeatedly made recommendations that were obviously insufficient to address the problem, and 5) state repeatedly opted for creation of committees and studies rather than acting to address the problem. Mention Ross Perot--just do it. [see attached annotated list of historical documents for partial descriptions of individual documents] Contours of a remedy w= [see deposition outline] have you developed a plan for the hartford area? What process should be followed? What are some of the general goals of a desegregation plan? Why is a planning process important?