Correspondence from Guinier to Bair

Correspondence
November 7, 1985

Correspondence from Guinier to Bair preview

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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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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?

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