Motion for Supplemental Brief

2 pages

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Impact area
- Education
Topic
- Educational Equity
Matter
- Alexander v. Holmes County Board of Education
Case
- Alexander v. Holmes County Board of Education
U.S. state
- Mississippi
Collection
- Case Files
Taxonomy
Identifier
- ba4f6078-d167-f011-bec2-6045bdffa665

Cite this item

Case Files, Alexander v. Holmes Hardbacks. Motion for Supplemental Brief, 1969. ba4f6078-d167-f011-bec2-6045bdffa665. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/462ab08f-3c22-4c64-9ab6-d86d2db823ab/motion-for-supplemental-brief. Accessed November 23, 2025.

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    N THE UNITED STATES COURT OF APPEALS 4
 

FOR THE FIFTH CIRCUIT 

UNITED STATES OF AMERICA, 

Appellants, 

yas NO. 28,042 

HINDS COUNTY BOARD OF 
EDUCATION, 

Appellees. 

BEATRICE ALEXANDER, et al., 

Appellants, 

VS. NO. 28,030 

HOLMES COUNTY BOARD OF 
EDUCATION, 

Appellees. 

MOTION FOR SUPPLEMENTAL RELIEF 
  

1. Upon information and belief, many of the defendant 

school districts have construed this court's order of 

November 7, 1969, and the appended H.E.W. plans of desegre- 

gation, to permit the reassignment of teachers and students 

to new school buildings without any requirement that class- 

rooms be integrated; defendants intend to maintain the ra- 

cial identity of individual classrooms within school build- 

ings. 

 



  

2. Upon information and belief, racial segregation 

within school buildings w. ' be achieved by: (1) reassign- 

ment of teachers and students as inviolate units from one 

school to another, or (2) reassignment of students on the 

basis of achievement test results obtained during past 

years. 

WHEREFORE, plaintiffs, in cases consolidated under 

Alexander v. Holmes County Board of Education, and private 
    

plaintiff intervenors in U.S. v. Wilkinson County Board of 
  

Education and U.S. v. North Pike County Consolidated School 
    

District, and the NAACP LEGAL AND EDUCATIONAL DEFENSE FUND, 
  

INC., as Amicus Curiae in cases consolidated under U.S. v. 
  

Hinds County Board of Education, move this Court to: 
  

1) order each defendant school district to respond 

to the allegations contained in this motion by December 18, 

1969; 

2) enter an order enjoining defendants and their 

agents from segregating students within school buildings 

and facilities by race; 

3) order that at any given school building within 

defendant school districts, the ratio of white to black 

students in each classroom approximate the ratio of white 

to black students in the school facility as a whole. 

December 12, 1969 Respectfully submitted, 

TSAR 
LVYNy R. LEVENTHAL 

REUBEN V. ANDERSON 
FRED 1. BANKS, JB. 

538% North Farish Street 
Jackson, Mississippi 39202 

  

JACK GREENBERG 
NORMAN CHACHKIN 
MELVYN ZARR 

Suite 2030 
10 Columbus Circle 
New York, New York 10019

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Motion for Supplemental Brief

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Cite this item

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