Appellants Response in the Moore Case to Suggestion on Court's Jurisdiction of the Appeal

     [||843a83ca-c23a-4a73-a16d-fe4c106d59d6||] IN THE 

SUPREME COURT OF THE UNITED STATES 

OCTOBER TERM, 1970 

  

Nos. 444, 498, 281 and 349 

    
MRS. ROBERT LEE MOORE, ET AL, 

Appellants 
  

VS. 

CHARLOTTE -MECKLENBURG BOARD 
OF EDUCATION, ET AL, 

  

NORTH CAROLINA STATE BOARD OF 
EDUCATION, ET AL, Appellants 

  

VS.   JAMES E. SWANN, ET AL, 

  

JAMES E. SWANN, ET AL, Petitioners 
  

VS.       CHARLOTTE -MECKLENBURG BOARD | 
OF EDUCATION, ET AL, | 

  

CHARI.OTTE-MECKLENBURG BOARD OF 

DUCA LION, 8% AL, Petitioners 
  

VS. 

JAMES E£. SWANN, ET AL 

  
  

RESPONSE BY APPELLANTS IN THE MORE CAR 

TO THE SUGGESTION OF THE SWANN PLAINTIFF: > 

THAT THE COURT DOES NOT HAVEL JURISDICTION 

Or THZ APPEAL IN THE MOORE CASE 

  

 



  

    

To the Honorable, the Chief Justice and the Associate Justices of the 

Supreme Court of the United States: 
  

  

The "'suggestion'' now filed in the Moore case by the Swann plaintiffs 

makes three principal assertions: - That the Moore case 'is not a truly 

adversary proceeding''; that there was nothing in the Moore case that required 

hearing by a three-judge court; and that the Moore case raises ''no 

substantial questions'' but is an improper "collateral attack'' upon ''the 

judgments'' of the Swann age, 

Before replying to these claims, the appellants would respectfully 

call to the Court's attention the following circumstances. This Moore case 
  

and the Swann cases were ''consolidated for hearing' and were heard 

together by the three-judge court Belov. The pleadings and the evidentiary 

showings in the Moore case were then the same as they are now. The 

positions taken, and the contentions made, by the Moore plaintiffs were the 

same then as now. Yet the Swann plaintiffs did not then or thereafter, until 

this late moment, make any such ''suggestion'' as they now bring forward. 

The Notice of Appeal to this Court, by the Moore plaintiffs, was 

entered on June 23, 1970, the day after the three-judge court rendered its 

"Final Judgment'. More than a month ago, this Court ordered that this case 

be set for argument, along with other ''public school" cases, on October 12, 

1970. As recently as September 11, 1970, counsel for the Swann plaintiffs 

were writing to the Clerk of this Court relative to the arrangement and 

scheduling of this case for argument together with the other Charlotte- 

iiecklenburg school cases. 

  

"Suggestion' and Memorandum of Swann plaintiffs, pp. 2, 19. 

Swann vs. Charlotte-Mecklenburg Board of Education and Moore 

vs. Charlotte-Mecklenburg Board of Education, 312 F. Supp. 503, 505 (1970). 
  

  

Appendix in Moore case, p. 48. 

   



  

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After all this, the Swann plaintiffs, now and for the first time, 
tender a "suggestion" that the Court has no jurisdiction over the Moore case 
and that therefore these appellants should not be heard at all. 

Turning, however, to the grounds on which the Swann plaintiffs 
bring forward their belated "suggestion", the appellants believe that a 
logical and natural Séquence of reply would be the reverse of the order in 
which the Swann plaintiffs have stated their assertions. 

lL 
The Suggestion Of The Swann Plaintiffs That The Moore Case Raises "Nc 

Substantial Questions" 

  
    

  
  

  

As to the proposition that the Moore case raises "no substantial 
questions' and is merely an improper "collateral attack" on what has been 
ruled in the Swann case, the basic answer is that, on the contrary, the 
Moore case thrusts to the very heart of this whole controversy. Indeed, it 
raises substantial questions that are not contested in the Swann case at all. 

Racial compulsions ordered by the United States District Court, 

defendant in the Moore case, and such compulsions are not opposed by any 
party in all the Charlotte -Mecklenburg litigation, except by the Moore 
plaintiffs only. Such, for example, is the drastic gerrymandering of school 
attendance zones, which is admitted on all sides, and declared by the United 
States Court of Appeals for the Fourth Circuit, to have been done on a 

1 racial basis and solely for racial purposes . The Moore plaintiffs, and 
oniy the Moore plaintiffs, oppose this and place it in issue and in contest. 

  

Appendix in Swann case, p. 1265a. 
Appendix in Moore case, pp. 40, 41, 42. 

 



  

  

  

    

Moreover, and of completely fundamental importance, not only 

do the Moore plaintiffs contest each and all of the racial compulsions imposed, 

from whatever source, in the Charlotte-Mecklenburg situation, but they do 

so in a sense and with a power that is unique in all the Charlotte-Mecklenburg 

litigation - for the Moore plaintiffs are the only parties anywhere in these 

cases who are pleading that constitutional rights guaranteed to them as 

individuals and citizens are being violated and trampled upon in each and all 

of these rid 

To say that the Moore plaintiffs raise ''no substantial questions 

is to say that when the Chief Justice, concurring in Northcross vs. Board of 
  

2 
Education, recently pointed to certain '"problems'' as being "basic' , he was   

in truth referring to "no substantial questions''. For the very questions there 

expressed, such as whether, as a constitutional matter, any particular 

racial balance must be achieved in the schools" and "to what extent school 

districts and zones may or must be altered as a constitutional matter', etc., 

were and are the heart of the Moore suit. 
  

  

"The rights created by the first section of the 
Fourteenth Amendment are, by its terms, guaranteed 

to the individual. The rights established are personal 

rights". : 
Shelley vs. Kraemer, 334 US 1, 

22, 68S Ct 836, 92 1.FEd 1181, 1185 
  

"[T The values of the First Amendment, as embodied 

in the Fourteenth, look primarily towards the preservation 

of personal liberty, rather than towards the fulfillment 

of collective goals''. 
Braunfeld vs. Brown, 366 US 599, 

610, 81 S Ct 1144, 6 LEd2d 563, 570 

Mr. Justice Brennan (concurring and 

dissenting) 

  

Northcross vs. Board of Education, US , 8908S Ct ’ 
  

25 LL Ed 2d 246, 251. 

   



  

    
  

Nor did the Moore plaintiffs place these questions in issue as an 

expedient response to the observations in Northcross. This suit was 
  

instituted prior to the decision in Northcross. 
  

Still further, as to one of the '"basic'' questions referred to in 

Northcross, namely,. "to what extent school districts and zones may or must 
  

be altered as a constitutional matter', it is to be remembered, as stressed 

above, that this question is nowhere at issue in the Charlotte-Mecklenburg 

litigation except in the Moore case. 

The Swann plaintiffs seek to condemn the Moore plaintiffs for 

""collaterally' attacking the rulings in Swann. Surely, however, it is 

elementary that the prohibitions against collateral attack apply only to those 

who were parties, or privies, to the proceeding in which judgment was 

rendered. 

Is it not also equally elementary that he who comes into Court 

pleading an invasion of his constitutional rights, is not to be dismissed, and 

denied hearing on appeal, simply upon the ground that in another case, lower 

court rulings - not those of a court of last resort - were adverse to his 

contentions. 

And once again, it must be emphasized that Moore is no 
  

relitigation of Swann, because (1) in Swann there was nobody to plead, and 

| nobody did plead, that constitutional rights belonging to him were being 

violated by the compulsions there imposed, and (2) Moore places in issue 

matters which were, and still are, uncontested in Swann. 

The Swann plaintiffs find fault with the Moore plaintiffs for not 

attempting ''to intervene in the Swann case in the District Court or to file 
  

an amicus curiae brief' in that case. They overlook the important fact that 
  

when the Moore plaintiffs first went into Court, the compulsions of which 

  
 



      

they are complaining had already been ordered. These compulsions were 

imposed by the District Court's orders of February 5, 1970. The Moore 

case was instituted on February 22, 1970. 

Up to that time, the Moore plaintiffs, if they were advertent to the 

matter at all, might very well have remembered that in the Swann case and 
  

in the same District Court, and also in the United States Court of Appeals, 

it had been determined that the Charlotte-Mecklenburg public school system 

was being operated as it should be and without racial compuidions 

In such circumstances, upon any question as to intervention, it 

would seem much more reasonable and appropriate to ask why did not the 

Swann plaintiffs intervene in the Moore case? Orders had already been 

entered in the Swann case, but the Moore case was just beginning. 

The Moore plaintiffs instituted their action in the State Court. It 

is altogether understandable that they should have done so, rather than in 

the United States District Court which had just ordered the compulsions 

which they urgently desired to oppose . For, of course, a claim of right 

under the United States Constitution can be as truly raised in a State Court 

as in Federal Court. 

  

1 
Swann vs. Charlotte-Mecklenburg Board of Education, 243 F. . 

Supp. 667 (1965) and Swann vs. Charlotte-Mecklenburg Board of Education, 

369 F'. 2d 29 (4th Cir., 1966). 

  

  

2 The Swann plaintiffs even cavil that the Moore plaintiffs should 

have included them as defendants in the Moore case. It is submitted that in 

acting to protect their constitutional rights, it was in no way necessary, nor 

indeed proper, that the Moore plaintiffs should have sued other individuals 

and non-official citizens simply because they were plaintiffs in Swann. 

In making this point, the Swann plaintiffs twice take pains to refer 
  

to themselves as ''Negro plaintiffs’ whom the Moore plaintiffs did not see fit 
| to name as defendants in Moore. If their being "Negro plaintiffs’ has either 
significance or relevance - and the appellants cannot see that it does - it 

might be noted that in Moore, there are various Negro plaintiffs, 

including, for example, Mrs. Robert L.ee Moore, whose name the caption 

of the case bears. 

  
 



  

      

In the State Court, the Moore plaintiffs obtained an injunction 

proidoitng them against the compulsions which the defendant Board of 

Education was about to fasten upon them. They well knew, however, and 

acknowledged, as they have at all times since, that they must stand or fall 

on their claim of right under the United States Constitution. 

Because of that claim, the case was removed into the same United 

States District Court where the Swann orders had been issued. There the 

Swann plaintiffs promptly asked, in the Swann case, that the State Court 

injunction, which had been issued to the Moore plaintiffs, be nullified’, and 

the District Court promptly so ordered in Swann and in Motte. Thereafter, 

the Swann plaintiffs apparently directed no further attention to the Moore 

case, until the consolidated hearing of Swann and Moore before the three- 

judge court. 

II. 

The Suggestion Of The Swann Plaintiffs 
That There Was Nothing In The Moore 

Case That Required Hearing By A 

Three-Judge Court 

  

  

  

  

Although, as emphasized above, the very foundation of the Moore 

case is the plaintiffs’ plea of violation of rights guaranteed to them by the 

United States Constitution, the Swann plaintiffs "suggest" to the Court that they 

now ''have some serious doubts'' as to whether there is anything asserted in the 

Move Complaint which would constitute any basis for federal jurisdiction. 

They say that the requirements of 28 USC §1331 are not met in 

that "there is no allegation that the matter in controversy exceeds the sum 

or value of $10,000'. It seems a paradox to eh that a plea for 

constitutional protection against governmental action based on race is not 

  

Appendix in Swann case, p. 91lla. 

" Appendix in Moore case, p. 32. 
Appendix in Swann case, p. 925a.    



        

cognizable in the Courts of the United States unless a dollar value is assigned 

to the constitutional right. 

If, however, the Swann plaintiffs do so insist - albeit with "doubts |- 

it will be found that the Complaint does contain allegations, which the Swann 
  

plaintiffs apparently overlook, that the asserted unconstitutional compulsions 

will "wrongfully and unlawfully deprive the taxpayers of Charlotte and 

Mecklenburg County', whom the plaintiffs represent, "of their property in 

the amount of’ $3, 000, 000 to $4, 000, 000 "during the current year TEL 

Moreover, the Complaint establishes Federal jurisdiction under 

28 USC §1343 (3) in that it seeks, to redress the deprivation of rights 

"secured by" provisions of "the Constitution of the United States'' relating 

to the "equal rights of citizens" - such deprivation of rights being 

accomplished by the defendant Board of Education "under color' of "state 

law, statute, ordinance, regulation, custom or usage'', in that the Board is 

a creature of the state, and its every act, indeed its very functioning as a 

Board, stems from the state. It will be further remembered that a 

substantial part of the compulsion of which the Moore plaintiffs complain was 

proposed and "programmed" by the Board itself. 

Finally, it is clear, and the Swann plaintiffs after some musings 

seem to acknowledge”, that Federal jurisdiction exists in the Moore case 

under 28 USC §1443, since the Moore plaintiffs seek protection against 

"act[s]" and compulsions imposed ‘under color of authority'' claimed to be 

"derived from'' the provisions of the United States Constitution relating to 

"equal rights''. 

  

Appendix in Moore case, p. 16. 

2 ""Suggestion' and Memorandum of Swann plaintiffs, p. 12.   
 



  

      
  

| Of equal fallibility is the "suggestion" of the Swann plaintiffs that 

there was nothing in the Moore case that required hearing by a three-judge 

court. 

It is to be noted, in the first place, that the United States District 

Court considered that the case required hearing by a three-judge conte, So 

did the Chief Judge of the United States Court of Appeals for the Fourth 

Circuit’. So did the three-judge court ot And so, apparently, did the 

Swann plaintiffs themselves. For, as has been hereinabove pointed out, they 

participated in the consolidated hearing of Swann and Moore, without any 

shadow of the ''suggestion'' they now make that Moore should not have been 

there at all. 

The Swann plaintiffs' present point seems to be that the Moore 

Complaint did not ask for an adjudication of unconstitutionality as to any 

statute, State or Federal. That is true. But in order for a three-judge 

court to come into a case, it is, of course, not by any means necessary that 

the Complaint itself shall raise issue as to the constitutionality of a 

statute. Such issue may, and often does, arise later in the development 

of the case - and, to be sure, is often raised by parties other than the 

plaintiff. 28 USC §2281 does not require anything as to the objective of the 

suit or the content of the Complaint. It provides that ''an interlocutory or 

permanent injunction restraining the enforcement, operation or execution 

of any State statute . . . shall not be granted by any district court or judge 

thereof upon the ground of the unconstitutionality of such statute unless the 

  

1 Appendix in Moore case, pp. 32-33, 38. 

2 Appendix in Moore case, p. 39. 

Appendix in Moore case, p. 46.  



      
School Board to assign children to public schools upon such considerations as 

  

application therefor is heard and determined by a district court of three 

"n 
judges . . . 

Here the defendants, being in a "'dilemma'' under conflicting orders 

from the two courts, filed, after the Moore case had been removed to the 

United States District Court, an application for an injunctive order", 

"restraining the enforcement, operation and execution" of the North Carolina 

statute involved ''and any action' by state officers "in the enforcing or 

executing or carrying out' of such statute, ''the ground of such injunctive 

1 
order being the unconstitutionality'' of the statute . The Swann plaintiffs had 

2 
earlier made a similar application in the Swann case . 

  

At the consolidated hearing before the three-judge Coui the Moor 

plaintiffs, as is authorized by the decisions of this Court, fully presented the 

contentions upon the merits of the case, which they have set forth in their 

brief to this Court, and now further desire to present in oral argument. 

"As the validity of provisions of the state constitution 

and statutes . . . was challenged, the application for 

  

Appendix in Moore case, p. 27. 
The Moore plaintiffs - though of course supporting the central 

provisions of the statute, which forbid the exclusion of children from public 

schools, and the assignment of children to public schools, on the basis of 

race - themselves also filed an application for an order adjudging a proviso of 

the statute to be unconstitutional and enjoining the enforcement of that proviso, 

The ground of this application was that the proviso was inconsistent with the 

central provisions of the statute, in that if could be deemed to authorize a 

the Board in its ''sole discretion'' might see fit, and that this could include 
the improper and unconstitutional consideration of race. In its decision, 

however, the three-judge court did not specifically address itself to this 

question. 

Appendix in Swann case, pp. 465a, 475a. 

3 As has been hereinabove noted, the three-judge court, in its 

"Final Judgment'', order that ''all parties are hereby enjoined from enforcing, 
or seeking the enforcement of" the provisions of the statute which the Court 
held to be unconstitutional (Appendix in Moore case, p. 65). The Swann 
plaintiffs pick at the point that in Moore, the School Board, though "a public 

(continued on page 11). 

10. 

T
o
 

  
 



      

injunction was properly heard by three judges. Stratton 
  

vs, St. Louis 3S, W.BR. Co., 282US 10, - 715.1. Bd 135, 
  

91 S Ct 8. The jurisdiction of the district court so 

consti, and of this court upon appeal, extends to 

every question involved, whether of state or federal law, 

and enables the court to rest its judgment on the decision 

of such of the questions as in its opinion effectively dispose 

of the case'. (And cases cited). 
Sterling vs. Constantin, 287 US 378, 
393-394, 53S Ct 190, 77 LL Ed 375, 383 
  

III. 
The Suggestion Of The Swann Plaintiffs 
That The Moore Case Is Not A Truly 

Adversary Proceeding 

  

  

  

The first and basic answer to this assertion is the undeniable fact, 

already pointed out, that the Moore defendants proposed, and have defended, | 

and are still defending, racial compulsions which the Moore plaintiffs 

unalterably oppose, and which the Moore plaintiffs have attacked from the 

beginning of this case, and at all stages, and are still attacking in this Court. 

Nor is it to be overlooked thai the Moore plaintiffs are the only 

parties in all the Charlotte-Mecklenburg litigation who have done so and are 

doing so. And if their voice is stilled, as the Swann plaintiffs are now seeking 

to accomplish by ''suggestion'’, then these compulsions will go uncontested 

in this Court. 

  

4 (continued from page 10). 

agency of the State of North Carolina'', and its members and the Superintenden 
of the school system, do not come within the terms of 28 USC §2281, "any 
officer'' of the state or "administrative board or commission’, for that the 
Board did not ask for ''an injunction against itself" (''Suggestion'' and 
Memorandum of Swann plaintiffs, p. 15). It is difficult to follow the logic of 

this, but in any event it is indisputable that the Board wound up being enjoined, 

along with all other parties in both cases, including the Governor of the State, 

the State Controller of the Department of Public Instruction and a State Court 

Judge, And there can certainly be no doubt but that the decree of the three- 

judge court effectively restrained and stopped any enforcement, and any 

effort in any quarter to enforce, the statutory provisions which the Court 

  

ruled unconstitutional.’ 

x 

] 

  
 



        

But, say the Swann plaintiffs, the Moore defendants "are 

cooperating' with the Moore plaintiffs. In support of this pronouncement, 

the Swann plaintiffs declare that (1) the Answer in Moore admits "every 

allegation of the Complaint', and (2) the defendants ''responded to the 

Moore plaintiffs' Request for Admissions by admitting every fact asserted" 

and ''on the same og 

A reading of the Answer in the Moore case will show that the Swann 

plaintiffs have somewhat overstated themselves in their unqualified 

announcement that it admits "every allegation of the Cowptaini'e. Moreover, 

the Moore defendants have only admitted what they could not truthfully deny. 

The bulk of the Complaint consists of allegations as to the express findings 

and orders of the District Court, regarding the Charlotte-Mecklenburg public 

school system. There is no basis on which the Moore defendants could deny 

these allegations. Nor could the Swann plaintiffs. 

Similarly, as to the Moore plaintiffs' Request for Admissions, in 

the manner provided by the Federal Rules of Civil Procedure, and the 

responses of the School Board thereto, these related entirely to certain 

exhibits which were attached to the Request for Atnitesions With one 

possible exception, these were prepared by the School Board itself. The 

Board could hardly deny its own handiwork. 

As to the deliberate and purposeful racial motivation in the 

gerrymandering of the school attendance zones, and in the long-distance 

assignments even beyond those zones, there is no denial of this from any 

  

"Suggestion'' and Memorandum of Swann plaintiffs, pp. 7, 10. 

2 
Appendix in Moore case, pp. 34-37. 

: Supplement to Appendix in Moore case. 

12. 

  
 



      

direction. It is expressed in the orders of the District Court and in the 

opinions of the three-judge court and of the Court of Aopesils’. Would the 

Swann plaintiffs, nevertheless, have the Board of Education to deny it? 

As to the Board's giving its Answer to the Request for Admissions 

without any delay at all, it was obvious that the three-judge court would 

want evidentiary showings to be complete and ready when it convened - which 

was only two days from the time when the Moore plaintiffs obtained the 

exhibits in question and called on the Board of Education for admissions 

relating to them. The Court, in fact, examined these exhibits and formally 

2 
received them in evidence . 

CONCLUSION 

As has been seen, the Swann plaintiffs consider that there should 

be stronger confrontation of the case asserted by the Moore plaintiffs. Yet, 

instead of furnishing such confrontation they seek to avoid it and prevent it 

by suggestion’ that the Moore plaintiffs be not heard but dismissed. 

The Moore plaintiffs, on the other hand, seek to place their 

constitutional position in challenge and in opposition to any and all parties who 

uphold any of the racial compulsions imposed below. They do not seek to 

avoid, but welcome, any consolidating action which the Court may deem 

appropriate to that end. 

  

Appendix in Swann case, pp. 882a, 823a, 1265a. Appendix in 

Moore case, pp. 40, 41, 42. Swann vs. Charlotte-Mecklenburg Board of 

Education and Moore vs. Charlotte-Mecklenburg Board of Education, 312 F. 

Supp. 503, 509-510 (1970). 

  

  
  

  

In similar vein, the Swann plaintiffs purport to see something 

highly suspicious in the fact that the ex parte preliminary restraining order . 

in the Moore case was signed by the State Court Judge on a Sunday night 

("Suggestion and Memorandum of Swann plaintiffs, pp. 3, 5, 19). They should 

know that such preliminary injunctive orders are almost characteristically 
obtained in situations of immediacy and urgency. The Moore plaintiffs alleged 
that grievous compulsions were in the process of being implemented and were 

about to be imposed upon them to their "irreparable injury' (Appendix in 
Moore case, p. 17)... The preliminary order notified the defendants of an 

early date on which they would be fully heard as to whether the orders should 

or should not be continued in effect. 

  
 



  

      

It is respectfully submitted that it would indeed be ironic to 

exclude from this contest the only parties who assert their individual 

constitutional rights against the racial compulsions which have been decreed 

in the courts below - and the only parties who oppose each and all of those 

‘compulsions. It would be tragically wrong if hearing were now denied to 

the very persons who raise and plead the constitutional rights which are 

here hanging in the balance, and which will undoubtedly be here effectively 

vindicated or conclusively foreclosed. 

Respectfully submitted, 

Whiteford S. Blakeney | ji 

North Carolina National Bank Building Is 

Charlotte, North Carolina 

  

Attorney for the Appellants 

Of Counsel: 
  

William H. Booe 

Law Building 

Charlotte, North Carolina 

  
 



  

CERTIFICATE OF SERVICE 

I, the undersigned attorney for the appellants in the case of 

Mrs. Robert Lee Moore, et al vs. Charlotte-Mecklenburg Board of 
  

Education, et al, do hereby certify that copies of the appellants' "Response 
  

By Appellants In The Moore Case To The Suggestion Of The Swann Plaintiffs 

That The Court Does Not Have Jurisdiction Of The Appeal In The Moore 

Case' have this day been served, by the depositing of such copies in the 

United States Post Office in Charlotte, North Carolina, with postage prepaid, 

upon each of the following, who are counsel for the appellees, at the 

following addresses, namely: - William J. Waggoner, Esq., Attorney at Law, 

Barringer Office Tower, Charlotte, North Carolina 28202, and Benjamin S. 

Horack, Esq., Attorney at Law, 806 East Trade Street, Charlotte, North 

Carolina 28202. 

I do further certify that copies of the aforesaid document have this 

day also been served in the same manner, upon each of the additional named 

attorneys, who appear as counsel in the related cases of Swann vs. Charlotte+ 
  

Mecklenburg Board of Education, at the following addresses, namely: - 
  

James M. Nabritt, III, Esq., Attorney at Law, 10 Columbus Circle, New 

York, New York 10019, Julius L. Chambers, Esq., Attorney at Law, 

416 West 10th Street, Charlotte, North Carolina, Robert B. Morgan, Esq. i 

Attorney General of the State of North Carolina, Raleigh, North Carolina, 

Ralph Moody, Esq., Deputy Attorney General of the State of North Carolina, 

Raleigh, North Carolina, and Andrew A. Vanore, Jr.,Esq., Assistant 

Attorney General of the State of North Carolina, Raleigh, North Carolina. 

This 5th day of October, 1970. 

  

~ Whiteford S, Blakeney aa 

Attorney for the Appellants [||843a83ca-c23a-4a73-a16d-fe4c106d59d6||]