Plaintiffs' Brief

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UNITED STATES DISTRICT COURT 

CHARLOTTE DIVISION 

  

JAMES E. SWANN, et al., 

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Plaintiffs, 
CIVIL ACTION 

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NO. 1974 

THE CHARLOTTE MECKLENBURG BOARD 

OF EDUCATION, a public body corporate 

Defendant. 

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PLAINTIFFS' BRIEF 

This proceeding was initially instituted by plaintiffs on 

January 12, 1965, seeking an order for desegregation of the public 

schools of the Charlotte-Mecklenburg School System. An order was 

Go pn po. h | = nT TSN 3 & - = 2 entered in June 1965, approving of a plan for desegregation of the 

En Tn, $e ey KW. &£ on > Sym ¢ % &e - ~ schools bv the establishment of geographic attendance zones and 
pe | o x 

"eS 2 : AB wervws zu 73 X wn fo gm x ie Ky TTR, 3 & requiring the immediate nonracial employment and assignment of 

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Cac Sede ba? Casall fe LSP WLW SN J LGA Me LW rs * — Va WAT AACA « ME rove TE 2 wis 

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use of freedom of choice follow DG iAnitlias assignmen pursuansc <TC 

3 m - Pr ws 20% Tg 3 -e re I Sa 8 uy pr du 3 on - 2 -4 ~ ng Pp d= Iu 
the attendance ones » The oraerx ie wad CC dae Ww od Ch A firmed by dd 

¢ | A 2.% dq 4 oN Tad ended Lem WN » PAE | ~ bo 3 mow pads fF Fon go de 
(4th Cir. 19866). Plaintiffs have now moved the Court for further 

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relief, seeking an order requiring that the Board institute some 

  

 



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lother plan for desegregation of the schools since the plan now 

  

being followed by the Board fails to disestablish the racially 

segregated and racially identifiable schools in the System. 

Plaintiffs further seek injunctive relief against the disparities 

lexistin ng in the Negro and poor schools in general, relief against 

llthe continued use of freedom of choice as now practiced by the   
[poaza, and relief against the continued location and construction | 

log schools in a manner which perpetuates racially segregated and | 

racially identifiable schools. Plaintiffs also seek further in- 

unctive relief against the continued racial employment and as- 

signment of teachers in the System.   
> The natter was heard by the Court on March 10, 11, 12, 13 and 

17. Following the hearing, the Court directed that counsel sub- 

mit proposed findings and briefs in support of their respective 

positions. This brief is being submitted by plaintiffs pursuant 

Statement of the Case 
  

The Charlotte-Mecklenburg Board operates 107 public schools, 

76 elementary schools, 20 junior high schools and ll senior high (Te 8 

schools. There are approximately 82,314 students in the School 

1 

System, 26,630 Negro and 58,684 white. The System has approximater ‘   
ly 3,613 terchers in the School System, 903 of whom are Negro.   

Of the 76 elementary schools, 15 are all-Negro, 32 are more 

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white. Of the 20 junior high schools, 4 are all-Negro od
 

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nd 7 are more that 95% white. Of the 11 senior high schools, 2 

are all-Negro and 6 are more than 92% white. The segregation of 

|| students in the schools clearly results from the use of geographic 

attendance zones in a community with clearly defined and segregated 

racial housing. 

The City of Charlotte has approximately 65,750 Negroes and 

197,250 whites. 98% of the Negro residents reside west of the 

line running north and south along Tryon Street and then along       
 



| ® ® 
. ' | Southern Railway. White residents reside principally in the east- 

  

ern part of the City. It is clear that this racial housing pat-~ 

tern has resulted from private and public racial discriminatory     policies and practices. Irrespective, however, of the contribut- 

| ing factors to the racial housing patterns, there is a defined 

| Negro area and a white area within the City. 

Prior to 1954, and by the Board's admission until 1964, all 

|| schools within the System were operated on a racially segregated 
1H 

-
 asis, with Negro students, teachers and school personnel ass.gned 

| to all-Negro schools and white students, teachers and school per- 

| eonnel assigned to white schools. Schools were planned and lo- 

| cated so as to perpetuate these racially discriminatory practices. 

I'ven subsequent to the Court oxder in 1365, the Board constructed 

17 new schools which havebeen located in aress resulting in all- 

rr} , UL \ JEG T TTY. ew 8 a " 223 LE dud pe = non & . white or all-Negro student bodies. In addition, scme student   - aq $ % ~ N Be — TS wm pe np wn Bn ~ - vy jy - Fy a “ Fg =~ - bodies have been re-segregated through the use of freedom of 

| choice which permits white students assigned to predominantly 

Negro schools and Negro students assigned to predominantly white 

| schools to transfer out. 

The location of schools and use of geographic attendance 

zones as established by the Board has tended to promote homogene-~ 

ous grouping of students in the various schools, with principally 

ols and white students 3 O Negro students attending all-Negxrc sch 

attending all-white schools. These practices have further pro- 

: a < ov Ba | Poy er on de oo 4% an o - EE Tqn mm As 4 om y 4 ¢ 

in certain schools and students fromrore affluent families in 

other ‘schools. Notable disparity exists between the white and   £ffluent and less affluent schools. Pp
 

Negro schools and between the 

fees for needed supplies and supplementary material. A further 

8 

rity results from the inability of the schools in the Negro | 2s
 

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       land less affluent areas to use free textbooks supplied by the 

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State which requires that these schools use funds allotted for 

  

other purposes in order to purchase textbook materials. Noted 

  | disparities also exist in school buildings, in school materials | 

and supplies and in the curriculum, particularly in the Junior 

|| high school and high school level. Many of these disparities 

would be corrected by a greater mixture of the students, racially 

and economically. 

H In several schools where racial mixing of the students has 

J 4 taken place, students have been segregated within the schools 

| through "ability grouping”. Such discrimination or segregation of 

| the students is just as repulsive to constitutional equal protec- 

| tion as establishing racially separate schools. Moreover, despite 

| the Court order of 1965 requiring complete desegregation and non- 

|| racial employment and assignment of teachers and school personnel, 

the School Board has continued to employ and assign such personnel 

on the basis of race and has failed to disestablish the racially 

segregated staffs created prior to the 1965 order. 

$ 

Finally, school authorities are vested with the responsibili- 

l|ty of providing free lunch programs under the National School 

T vv mo) 0 By & ml Ey a PI ws om du § . ded Lunch Program, 42 U.S.C. §1759, et seg. Defendant's practice = i (13
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lIproviding a la cart services in some of the schoois deprive the 

  

       

    
  

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lchildren of the benefits of this program. 
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Argument _ 

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DEPENDANT IS CONSTITUTIONALLY 

REQUIRED TO TAXE ALL NECESSARY 
STEPS TO DISESTABLISH THE RA- 

CIALLY SEGREGATED SCHOOL SYSTEM 

{| AND MAY NOT IGNORE FACTORS WITHI 
1 THE SCHOOLS AND COMMUNITY WHICH 
| MAY TEND TO PERPETUATE RACIAL 
1 SEPARATION OF STUDENTS WITHIN THE | : 
| SCHOOL SYSTEM. | 
| alah | | (a) The Supreme Court in the second Brown opinion clearly 
| —_— 
anticipated that school officials-would take all appropriate and LEE 

lish the racially, segregated system 

 



  

effaectuation of "this interest may call for elimination of a 

variety of obstacles in making the transition to school systems 

operated in accordance with the constitutional principles set 

sical conditions of the school plant, the school transportation 

system, personnel, revision of school districts and attendance   
areas into compact units to achieve a system of determining ad-       lwill also consider the adequacy of any plans the defendants may 

they then operated. The Court there stated that school officials 

forth in our May 17, 1964 decision. ... To that end the courts may 

consider problems related to administration, arising from the phy- 

| 
| nission to the public schools on a nonracial basis. ... The courts 
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propose to meet these problems and to effectuate a transition to 

a racially non-discriminatory school system." Brown v. Board of 
  

|| Education, 349 U.S. 294 at 300-301, 99 L.ed 1083 at 1106. The 

by the Court in three recent decislons. Creen v. County School 
  

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P £ Ni. T7 mv de CYP 399% “a7 11 © A 7 BE mo » oo PP Board of New Kent County, 391 U.S. 430; Monroe v. Board of Com- 
    

» >) | TY FB be Re y pen il / vA PE = & missioners, 391 U.S. 4350; Raney Vv. Board of Education of Gould 
ER rE EE EE aE at TE. Sr ert erm mE gh wt 1 TREY TRE CY 73H 40 ERATE CEE unt RS ll i 3 aa 

  

be one that will work and will work now to disestablish the se- 

  
tically to convert promptly to a system without a 'white' schoo   and a 'Negro' school, but just schools. Green, supra. It may   

be that in some instrnces freedom of choice will dismantle the 

  

Kdual school structure. It may be in some instances that school   
attendance areas will be sufficient. It may be necec 

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other instances to employ a combination of these or to pair 

schools or to consolidate schools. The objective, however, is 

Sismantle the dual school structure condemned in Brown. 
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Inecessity for a plan which will clearly and effectively disestab- 

lish the racially segregated school system was further spelled out 

School District, 391 U.S. 443. The Court in these cases has again 

made clear that the plan the school board proposes to follow must 

gregated school system. No one plan may not be completely accept- 

able for all school district, for communities will differ. What- 

ever plan is adopted, however, must be one which promises "realis- 

1 

 



  

n discharging its obligation to desegregate, it is impera- 
Y 8 

tive that school officials be cognizant of any factors within the 

schools ox within the community itself which might inhibit or deter 

|efforts to desegregate. In Brown, the Court made clear that dis-   charge of the Board's responsibility was not to be avoided simply 

by disagreement with them. In Cooper v. Aaron, 358 U.8. 1, the 

Court made clear that the constitutional principles set forth in   
AN Brown were not to yield to community hostilities. And where 

- actors within the community would make the plan submitted by the 

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Egy gndely un we a po. J you de = 1 5 rin 4 7 sd % | 2 ws om ule vy o AS = LATTA Y ana aq Jag Padi WRIAON Wldil inl fact work. oppaeage Vv. 

TR om = * on do 5 PAN £ Yh. 3 ony 2H 4A Oe n.2 AI Nn 2 5% 4 1 Franklin County Board of Rducation, 394 F.2& 410 (4th Cir. 1968); ———— iia SARA AA Bond At Abapdonlivselloortemdviodooin 

re. sa Bowman v. County School Board of Charles City County, 382 F.24 836 dE ae] anid TSI wa Ah — be —————— sr WL 1A "NA —— Lh A AY he, cp © at em pe pe 

  

5 do Yu < 2 "I= ’ 8 ge -¥ de a hs 4 882 ~ ow de © rp I Ra | rd = Sth Cir. 1966); United States v. Jefforson County Poard of Tduca- 

be & - R le Br Td 4 FF SPIO. A a 3 ~ — aoa - ition, 372 F.2d 836, affirmed on re-hearing en banc 380 F.2d 385, } jr na 
——— ——— 

Ii vie Ru ™v 3 3 3 $y Tend oo +) lleart den. sub nom, Caddo Parrish School v. United States, 389 U.S A Lonnie J td B 
| 

840: Brewer v. School Board of City of Norfolk, 397 P.2da 37 (4th i S— —" iy ——— — I A p40 AA RT a ot Ea LEE RE 

Cir. 1968): Adams v. Matthews, 403 P.24 181 (5th Cir., 1968). 

8 § pu um A mm wy dd andad p— \ Fm~Y 3 ~r > gt, A The clearly defined and distinct racially segregated housing 

¥ o - nn NG Pd “" oa pu, dor So Su on on on Ge eo pattern in the City of Charlotte has perpetuated and will continue 

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Ia, de Bn fT a. $8 po mung wl a, dh pw avg " b to perpetuate the same racially discriminatory school system con- 

  

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with freedom of choice. Moreover, 
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.® a - - 7 Te 4 eae Su ga . — @o a hey PEL Oa Be B , TH ow on 3 € os feographic attendance zones, even were the Board to discontinue 

readon of cholce, would not dismantle the dual school structure 

  2 we S 0% on oa 3 be enbur €* om - EV om De son 22% vd Tat TE in the Charlotte-Mecklenburg School System. Much more is required 
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| oo | Fp - on A ne mn an - . Gs @ doay any om pg Ins the racord here demonstrates and constitutional mandates re- 

fguirea that the Roard do what is necessary in order to desegregate. ki ; 

ro Sn A Lh Cp ———— 

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Bf tan wp le} wid x 4 2 3 4 You 4 b= an 3 be pa dn gon Eee authorities cited above; see also Louisiana v. United States, | 
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{ o> a ny -y py EY rg . P | 1380 +3; VLRB v, Wewport News Shipbuilding and Dry Dock Co.., H Dada EE TL Tr — ——e iT as pe mA A gly Oo o— 
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hme 11 & 249 WT & : vette Ie . IF08 U.S. 241: United Gtates v. Crescent Amusement Company, 323 U.S. i A EE arverr mr re ar _ lean Lo 14 

1174 Tim SW oF & vd $3 . 3 yo 9% i j3%: 31:3 fa Laces Ye Stan dard Oil comp LanyY , 221 0.8. he | | ae ate BE TF POCA . at aaah A a a 
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NY mndwmdnd £8 i. Wve 3 Be Be i 3 de og ane Ew go TAN Pl PENNA Plaintiilis have submitted testimony of four poseible feasible 

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‘methods that might be employed by the School Board to desegregate. 

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| School District and Monroe v. Board of Commissioners, supra. The 

is just as repugnant to the requirements of Brown as that shown   
  

| 

| 

| Court there stated that the practice as shown by the record here 

| ! 

| in Goss v. Board of Education, 373 U.S. 683. | | 

| 
: II 

| 

THE SCHOOL BOARD SHOULD BE EN- 
JOINED TO PROVIDE EQUAL EDUCA- : 
TIONAL OPPORTUNITIES FOR ALL 
STUDENTS IN THE SYSTEM IR- 
pO DIM TIITY AY Mm 

R SPE > hd VE 83) 4 

COLOR OR ECONOMIC CONDITIONS. ho
e 

l|located in less uffluent areas are deprived of educational oppor- 
| 

  
1 3 schools. School facilities as established by the Board has not   

reason contributing to the disparit 0 a 3 147
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all Negro schools and schools generally in the legs affluent areas 

  are simply unable to provide equal facilities, supplies and ma- 

terials as those provided in the white and more affluent schools. 

Js efforts have been made by the Board to equalize the funds for 

all schools. Further, free textbooks alloted by the State cannot 

be used by the students in the all-Negro or in less affluent 

schools. Again, the Negro and less affluent schools are required   
materials. Moreover, despite the disparities in the achievement 

levels of the students in the schools, no efforts have been made 

by the Board to enrich the educational programs for the students 

in the under achieving schools, Even before Brown, the Supreme 

Court enjoined unequal educational opportunities. Sweatt v.     Painter, 339 U.S. 629; McLaurin v. Oklahoma State Regents, 339 U.S. 
      

is clearly, equally violative of the Equal Protection Clause. 

    
  

ID om pao gam ™ 4 ’ end £& » FAAS YS de Brown v. Board of Education, supra.; Griffin v. County School 
{ pr ms - or -—— a a ——— ——— ——  ————  — 

Board of Prince Edward County 377 U.S, 218; Griffin v. Illinois, 
  

    
- 9 = 

 



  

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is designated as the responsible agency for providing free lunch 

enefits for the children in the Charlotte-Mecklenburg School 

  

System. Having undertaken this responsibility with respect to 

ome students or schools, defendant is constitutionally obligated 

to make those benefits available to all children in the system. 

    Griffin v, Illinois, supra.; Griffin v., County School Board of 
  

  

  Defendant provides free lunch for basically all students in 

: : 

| the elementary schools. Because of a la carte services at some 

  of the junior high and senior high schools, students attending 

these schools are deprived of the free lunch benefits. Defendant 

should be enjoined to present a plan to the Court for providing 

free lunch benefits for all students in the school system who may 

| al ataYe eh Fa 
Concly sion 

————————— i —— 
| 

| rn} o fa $ net nf anda . ££ 3 y x 
The plan for assignment of students now being followed by 

[| | 
be 2 on) NY mn ue od 2 rm Bo © wu 2 vy or @“ 3 4 

the School Board ? A483 continued use QL reedom of ch oi ce and the 

(a
! pe
 

4 

continued planning and location of schools and additions to e   | ing schools have clearly failed to disestablish the racially 

| segregated school system. Y%efendant is constitutionally obligates ja
l   

ll to now go further and institute a plan which will in fact elimin- 

ate the all-Negro and all-white schools. Plaintiffs have sub- 

  ted four nroposals which might be followed by the defendant. 
» 

The first alternative plan, however, is merely a beginning of   
leading to complete desegregation. The Courts 

I have established that it is the defendant school board's re- 

| sponsibility and not that of the plaintiffs to come forth with a 

plan that will work. Should the defendant fail to do this, the 
be 

responsibility then devolves upon the Court. In such circum- 
EN 

    

  

  

  

: 2 2 4 " be JF JSPR 3 he Bay om YT § & - do on do ped 

stances, some courts have directed their own plans, United States 

“28. o 3 ES Tuy rv on Ov 4 PNY y va \Y 5 

v. Jefferson County Board of Fducation, supra.; Coppedge V. 
tt va ni TS ——— 

EE re —— ’ 1 lk ——th 

{ wr "9 & ~> +4 ° of - 9% Y ‘ - on ty ~~ > 

| Pranklin County Board of Fducation, supra. Some COuxts have 
  

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tion of Oklahoma City Public Schools v. Dowell, supra.; some 
  

courts have called upon or directed the school officials to make 

use of federal agencies established pursuant to Title IV of the 

Civil Rights Act of 1964, 42 U.S.C. §2000c et seq.; Banks v. St. 
  

James Parish School Board I. Supp ,» (E.D. La. No. 16,173, Dec 
a nb ——   

10, 1968) a copy of which is attached hereto. Irrespective of 

the procedure to be directed by the Court, it is clear that the 

defendant is constitutionally obligated to do more and plaintiffs 

submit that whatever plan is directed or approved should require 

for each school in the system he percentage assignments of Negro 

and white students to reflect the total number of Negro and white 

students in the school system. Plaintiffs further submit that the 

defendant should be enjoined from continuing to use freedom of 

choice and from locating and constructing schools in a way which 

perpetuates the racially segregated school system. All planned 

construction of new school facilities and all additions to exist-~ 

ing facilities should be enjoined pending a showing by the School 

Board of how these facilities will be integrated. 

Defendant should also be enjoined f£rom failing to provide 

and to insure equal educational opportunities for all students in 

the system and should be required tp present to the Court a plan 

setting forth how this will be accomplished. Defendants should 

also be required to submit a plan setting forth how it will pro- 

vide free lunch for all children in the school system who qualify, 

It is clear that defendant has failed to desegregate sachers 

and has failed to employ and assign teachers and school personnel 

without regard to race or color. Defendant should be enjoined to 

present a plan for desegregation of teachers in the system to be 

affective with the beginning of the 1969-70 school vear providing | 

for the employment and assignment of all teachers in the system 

without consideration of race and the disestablishment of past 

racial assignments so that each school in the system will reflect 

the percentage of white and Negro teachers and school personnel 

“33   
 



{ 

| 

I % » 
i 
i 
i 

  

  
in the school system. 

I The Court should retain jurisdiction of this cause pending 

| further and complete desegregation of the school system. 

Respectfully submitted, 

  

{| CONRAD ( 0. ® . PEA $3 REO! N 

i 203 1/2 East hapel Hill Street 

Charlotte, North Carolina   
| 

J. LeVONNE CHAMBERS 
| JAMES E. LANINII NG 

Chambers, Stein, Ferguson & 
Lanning 

216 West Tenth Street 
SS aiocte) North Carolina 

  

1
6
 | JACK GREENBER 

JAMES M. NABRIT, III 

10 Columbus Circle 
New York, New York   

Attorneys for Plaintiffs 

CERTIFICATE OF SERVICE 
      

| The undersigned hereby certifies that copies of the foregding 
} 

| Brief were served upon counsel for the defendant by depositing a 
i 

| copies of same in the United States Mail, postage prepaid, ad- 

dressed to: Brock Barkley, Esqg., Attorney at Law, 8l4 Law Building, 

Charlotte, North Carolina 28202; and William:Waggoner, Esq. 

Weinstein, Waggoner, Sturges and Odom, Attorneys at Law, Barringer 

ce Towers, Charlotte, North Carolina. O th
 

ra
 

p
e
 

I This 24th day of March, 1969. 

  

  

I Attorneys tor Plaintiffs     
I - 14 - | 

  
| 
i 
! 

| 
{ 
i 

 



    

IN HE U TED STATES DISTRICT RT. : 
FOR THE : 

EASTERN DISTRICT OF LOUISIANA 
NEW ORLEANS DTVTSTON 

WILFRED BANKS, et al., plaintiffs 
¢ UNITED STATES OF AMERICA, plaintiff-Intervenor, | CIVIL ACTION 

3 a “  YIRBUS | NO. 16173 
sT. JAMES Pf \RISH SCHOOL BOARD, et al., | ¥ Gre SECTION vpEn. : 

LSet EG ¥ Defendants. » h 0 7 

Sy RT St ORDER 2 Naan {200 hs, 
CR Upon “consideration of the record herein and the arguments of 

_gouns el on Wednesday, November 27th, and upon agreement by sounsel 

it is’ “hereby adjudged and decreed: 
ey tel 5) 

Si 2 ‘that the defendants shell seek the assistance of the 

i Educational Resource Center on school desegregation which is located 

| ay, 6200 Hampson Street, New Orleans, Louisiana 70118, in the prepara- 

eted of'a plan to effect a unitary non-racial system. They are further 

4 ordered to make freely available to the center all information relating 

“to. the operation of the school district that the center ‘shall request. 
GF LE = LAT: i 

Fo 2, The ‘plan shall in all respects conform to the requirements 

laid dorm by the United States Supreme Court in Green v. New Kent 
  

2: oun, Va., 391 U.S. 430, and by the Fifth Circuit Court in Adams v.   

  

HE No. 26501, August 20, 1968 and Graves v. Walton County Board 

  

: of Education, No. 26452, September 24, 1968. In particular the plan 

shall: Le sano 

ARE "be designed for implementation at the commencement of she 
 1969- 70 school year and SEall provide for the assignment of all students 

Hoy. means of geographic attendance zones or pairing of schools, or grades, 

“op both... a fete is 3 : +s Ihe 

a be Jovi sed in such a manner shat, while maintaining the 

: highest ‘possible quality of public education for all children, no 

school! now operated by the parish shall be attended only by students   of the Negro race. In order to acconplish this, the plan may provide 
a physically inferior e L for’ ‘the closing of such/schools or for the assignment thereto of sub- — 

“ste antial numbers of students of the other race. 

Fhe’ LORE 
8 Si state in tabular form, for each school in tie system; the    

  

bag 1% will serve and 3he number ang per cent of vhite and Negro - 
A . oe 

11dren to be enrolled in each grade in she following manner: 
ue 2 \ 
School’ Grade ‘Total No. of Students Hidis 4 Negro % 

  

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: coat “: 3, The plan cared by the Center shad be filed no later 

« ‘¥<than January 25, 1969. The plaintiffs and defendants shall have until 

February 1, 1969 to file amendments thereto. No amendments may be 

filed or proposed, the necessary effect of which would pe to continue 

the existence of any Xl Nauro schools. If amendments are filed, and 

..a further hearing becomes necessary, the Court will at that time 

‘assign a date for such hearing. 

a wy, No later than March 1, 1968, the defendants shall file a 

: plat providing for the complete integration of faculty and administra- 

\tive staff. The plan shall state for each school: 

of The name and race of the principal, the number of white and 

| Negro teachers to be assigned. The plan shall state the 

; name and race of any person now serving as principal or 

a assistant principal who will not be so assigned for the 

1969-70 school year and the reason why such person will 

“. no longer be so assigned. 

| New Orleans, Louisiana, November , 1968 ! 

  

UNITED STATES DISTRLCT JUDGE 

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