Answer of Defendants to Plaintiffs' Motion to Amplify and to Particularize the Metropolitan School District Reorganization Plan
Public Court Documents
February 18, 1972

5 pages
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Case Files, Milliken Hardbacks. Answer of Defendants to Plaintiffs' Motion to Amplify and to Particularize the Metropolitan School District Reorganization Plan, 1972. 343035c3-52e9-ef11-a730-7c1e5247dfc0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/38348fcb-17a7-461e-99a7-150279a8e7ea/answer-of-defendants-to-plaintiffs-motion-to-amplify-and-to-particularize-the-metropolitan-school-district-reorganization-plan. Accessed July 30, 2025.
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L e o n S. C o h a n Deputy Attorney General STATE OF MICHIGAN DEPARTMENT OF ATTORNEY ^. • ' 'V** ‘ or. ><tv *-? " f 4 GENERA FRANK J. KELLEY A T T O R N E Y G E N E R A L LANSING 4 8 0 1 3 February 18, 1972 Mr. Frederick W. Johnson, Clerk United States District Court 133 U.S. Courthouse Detroit, Michigan 48226 Re: Bradley v. Milliken No. 35257 Dear Sir: Enclosed please find Answer of Defendants to Plaintiffs’ Motion to Amplify and to Particularize the Metropolitan School District Reorganization Plan in the above entitled cause with Certificate of Service attached for filing. Very truly yours. Enc cc: FRANK J. KELLEY Attorney General v /_-A?Eugepe Krasicky Assistant Attorney General / Messrs. Louis R. Lucas and William E. Caldwell Mr. E. Winther McCroom Mr. Nathaniel R. Jones Messrs. J. Harold Flannery, Paul R. Dimond and Robert Pressman Messrs. Jack Greenberg and Norman J. Chec’nkin Mr. George T. Roumell, Jr. Mr. Theodore Sachs Mr. Alexander B. Ritchie UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION RONALD BRADLEY, et al, Plaintiffs, v. Civil Action WILLIAM G. MILLIKEN, et al, No. 35257 Defendants, DETROIT FEDERATION OF TEACHERS LOCAL #2 31, AMERICAN FEDERATION OF TEACHERS, AFL-CIO, Defendant- Intervenor and DENISE MAGDOWSKI, et al, Defendants- Intervenor / ANSWER OF DEFENDANTS WILLIAM G, MILLIKEN, FRANK J. KELLEY, STATE BOARD OF EDUCATION AND JOHN W. PORTER TO PLAINTIFFS' MOTION TO AMPLIFY AND TO PARTICULARIZE THE METROPOLITAN SCHOOL DISTRICT REORGANIZATION PLAN. In answer to plaintiffs' motion, these defendants respectfully show that: 1. At the hearing of October 4, 1972, they informed the Court that it would take at least six months and $250,000, based upon the experience of other areas in the country, in particular Los Angeles, California, to prepare a rational, understandable metropolitan plan. The court recognized this when it suggested that the state board "present a skeletal plan so that we can recognize the dimensions of our problems.'" ' 2. These defendants respectfully submit that despite plaintiffs' claims to the contrary, these plans more than meet the legal requirements to remedy the racial segregation which this Court found to exist in the Detroit Public Schools. The Court expressly left the dimensions of the plans to the state board. 3. The personal views of Miss Marilyn Jean Kelly, extracted and quoted in plaintiffs’ motion, have no relevancy to the proceedings at bar. The State Board of Education can act only as a board, as that action is duly recorded in its minutes, and does not act by the views of one of its members. Further, it should be noted that Miss Kelly did move for the adoption by the state of any particular plan. ^. In answer to the allegations in paragraph 4 of plaintiffs’ motion: (a) There was no failure to provide for the desegregation of grades K to 3; transportation realities and the ages of the children involved preclude including grades K-3 in the plan. (b) The proposed two year implementation schedule is not only reasonable but is required ■ -g by the enormity and complexity of the changes required by the proposed plan. (c) The proposal is not to abandon schools attended predominantly by black students; the plan proposes to close only those physical plants that are "considered deficient." (d) The claim of "gerrymanded subdividing" is without merit; existing county and school district boundary lines are the basis for the DMEA and the IOZ and were used for the reasons set forth in the plan. -2 # 5. In answer to the prayer in plaintiffs' motion: (a) The plan itself sets forth the racial composition of schools and grades as projected. A more particularized projection will require computerization of vast amounts of data at great expense, which is not warranted until such time as a plan is accepted. (b) Within the time claimed by plaintiffs, it is not practical to devise specific techniques for pupil selection, assignment or transportation. Neither is the cost warranted until a plan is accepted by the Court. The general principles to be followed are set forth in the plan. (c) Plaintiffs' claimed anomalies do not exist in fact and the claim appears to be based upon an insufficient reading or understanding of the proposed plans since information amplifies and supplements the others. WHEREFORE, these defendants move the Court for a denial of plaintiffs' motion. Respectfully submitted FRANK J. KELLEY Attorney General Eugene Krasicky < Assistant Attorney GeneralDated: February 18, 1972 Business Address: ■ 7 Story Office Building Lansing, Michigan 48913 Gerald F. Young George L, McCargar Assistant Attorneys General - 3- CERTIFICATE OF SERVICE I hereby certify that a true copy of the foregoing Answer of Defendants to Plaintiffs' Motion to Amplify and to Particularize the Metropolitan School District Reorganization Plan was served upon the following named addressees this 18th day of February, 1972 by United States mail, postage prepaid, addressed to them at their respective business 'addresses: Messrs. Louis R. Lucas and William E. Caldwell Mr. Nathaniel R. Jones Messrs. J. Harold Flannery, Paul R. Dimond and Robert Pressman Mr. E. Winther McCroom Messrs. Jack Greenberg and Norman J. Chechkin Mr. George T. Roumell, Jr. Mr. Theodore Sachs Mr. Alexander B. Ritchie George L. McCargar Assistant Attorney GeneralDated: February 18, 1972