Thomas v. Board of Education of the Plum Bayou-Tucker School District No. 1 Appendix

    IN THE U N I T E D  STATES C O U R T  O F  A P P E A L S

FOR THE EIGHTH CIRCUIT 
NO. 71-1436

LOTS THOMAS, e t  a l . .

Plaintiff s-Appe Hants

v s .

THE BOARD OF EDUCATION OF
THE PLUM BAYOU-TUCKER SCHOOL DISTRICT NO. 1, et al..

Defendants-Appellees.

A P P E N D I X

JOHN W. WALKER 
PHILIP E. KAPLAN 
WALKER, KAPLAN & MAYS, P..A. 1820 West 13th Street 

Little Rock, Arkansas 72202
JACK GREENBERG 
NORMAN J. CHACHKIN 

10 Columbus Circle 
New York, New York 10019

Attorneys for Appellants

A.



Page
Docket Entries .......................................  la
Complaint............................................ 2a
Answer................................................13a
Defendants' Answers to Plaintiffs' Interrogatories . . 15a 
Plaintiffs' Answers to Defendants' Interrogatories . . 52a
Transcript of Proceedings February 8-9, 1971 ........  57a
Plaintiffs' Exhibits at February, 1971 Trial ........  567a
Memorandum Opinion of District Court ................  588a
Order of District C o u r t ............................. 601a
Notice of Appeal..................................... 602a
Bond for Costs on Appeal............................. 603a

I N D E X



UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS 
PINE BLUFF DIVISION

LOIS THOMAS, ASIVE THOMAS, LUCREASIA A. EVANS, 
ELOIS WOODS AND TROY E. WOODS, BY THEIR PARENT 
AND NEXT FRIEND, MRS. CORINE WOODS; ERIC DIN- 
WIDDIE, DONALD R. DINWIDDIE, RODNEY DINWIDDLE 
AND DARRYE HARRIS, BY THEIR GUARDIAN AND NEXT FRIEND, MRS. CORINE WOODS

Plaintiffsvs.

THE BOARD OF EDUCATION OF THE PLUM BAYOU- 
TUCKER SCHOOL DISTRICT NO. 1, WRIGHT, ARKANSAS, 
FRANK CONLEY, PRESIDENT; and JAMES K. BRADSHAW, SUPERINTENDENT OF SCHOOLS OF THE PLUM BAYOU- TUCKER SCHOOL DISTRICT NO. 1

Defendants

CIVIL NO. PB 69-C-46

July 22, 1969 

July 29, 1969

DOCKET ENTRIES
Complaint filed. Summons issued.
Marshal's return filed showing service on defendant Frank 
Conley by copy to his wife, Ruby Conley, Wright, Ark. 
on 7/24/09; and served James K. Bradshaw, Supt. of 
Schools of Plum-Bayou-Tucker School Dist. #1, at Wright, Arkansas on 7/26/69.

August 12, 1969 Answer filed, c/s
August 14, 1969 Interrogatories propounded to defendants filed by plaintiffs, c/s
August 28, 1969 Answer to Interrogatories propounded to defendants by the plaintiffs filed, c/s
Oct. 23, 1969 Pre-trial before Judge Harris in Pine Bluff, court trial, December 11. Set for

Nov. 26, 1969 Interrogatories to plaintiffs by defendants filed, c/s
Dec. 9, 1969 Answer to Interrogatories propounded to plaintiffs bythe defendants, c/s
Dec. 11, 1969 Case set for court trial in Pine Bluff. Continued
Feb. 8, 1971 Court trial begun before Harris, J. in Pine Bluff, 9:30

a.m. Paragraphs 12, 16, and 21 of the complaint with­
drawn by pltfs' counsel. Agreement reached as to para­graph 13 of the complaint. By agreement of counsel 
interrogatories and answers filed made a part of the 
record. Court in recess at 5:00 p.m. until Feb. 9 at 9:30 a.m.

Feb. 9 , 1971 Court trial concluded at 4:35 p.m. Briefs to be sub­mitted; Pltfs' - 20 days; defts' - 10 days.
March 2, 1971 Plaintiffs' Memorandum Brief filed, c/s
March 10,1971 
June 7, 1971 July 6, 1971
July 6, 1971

( Q

Defts' Memorandum Brief filed in response to pltfs' brief, c/s 
Memorandum Opinion & Order dismissing complaint of pltfs c/c Notice of Appeal filed by pltfs. c/s F '

Bond for Costs on Appeal filed for $250 with Carl Brooks, Surety
A true copy of docket entries I 
certify at Little Rock, Ark. this 
8th day of July, 1971.

w. h . McClellan, clerk 
U. S. DISTRICT COURT
Bv <£/ — -* M’rynell/Begue. Deputy Clerk



IN THE UNITED STATES DISTRICT COURTT 
FOR THE EASTERN DISTRICT OF AIUSANSAS p  

PINE BLUFF DIVISION ~ D

LOIS THOMAS; ASIVE THOMAS; )
LUCREASLA A. EVANS; ELOIS WOODS, )
and TROY E. WOODS, by their parent )
and next friend, Mrs. CORINE WOODS; )
ERIC DINWIDDIE, DONALD R. DINWIDDIE, ) 
RODNEY DINWIDDIE, and DARK YE KARRIS, )
by their guardian and next friend, M rs. )

CORINE WOODS, )
)

Plaintiffs, )

)
THE BOARD OF EDUCATION OF THE PLUM ) 
BAYOU-TUCKER SCHOOL DISTRICT NO. 1. )
Wright. Arkansas, FRANK CONLEY. President;) 
and JAMES K. BRADSHAW, Superintendent of ) 
Schools of the Plum-Bayou-Tucker School )
District No. 1, )

)
Defendants. )

JUL 22 igc j

COMPLAINT

I

The jurisdiction of this Court is invoked pursuant to the provisions of 

Title 28 U. S. C. I  1342(3)(4). This is an action in equity authorised by law, 

Title 42 U. S. C. i  11981 and 1983. The rights, privileges and immunities

sought to be secured by this action are rights, privileges and immunities 

guaranteed by the due process and equal protection clauses of the Fourteenth 

Amendment to the United States Constitution as hereinafter more fully 

appears.

n

This is a proceeding for a declaratory Judgment pursuant to the pro­

visions of Title 28 U. S. C. s2201 to determine the legal rights and relations 

of and between the respective parties.



II

in
A. This is also a proceeding for mandatory injunctive relief 

against the defendants requiring them to reinstate the teacher plaintiffs as 

teachers in the public school system of Plum Bayou-Tucker School District 

No. 1, and for such other appropriate relief as will remedy the wrong perpe­

trated against them by defendants, including the awarding of attorney's fees.

B. This is also a proceeding for u  aadatory injunctive relief 

against defendants requiring them to cease discriminating against black patron s 

of the district, as represented by the patron plaintiffs, by taking certain 

actions as requested below and by refraining from other acts as detailed below.

IV

A. Plaintiffs are all Negro citisens of the State of Arkansas and 

the United States.

B. Plaintiff Lois Ann Thomas was employed by defendants for 

four years as an elementary school teacher. She holds the requisite elemen­

tary certification.

C. Plaintiff Aeive Thomas was employed by defendants for one 

year as an elementary school teacher. He holds the requisite certification.

D. Plaintiff Evans has been employed by the district for 27 years 

as an elementary teacher. She pwsessas the requisite certification.

V

Plaintiff Woods brings this action pursuant to Rule 23(a) and (b)(2) 

of the Federal Rules of Civil Procedure as an individual and as the parent and 

guardian of the named minor Negro children, on behalf of a ll black patrons of 

the school district. Members of this class are so numerous as to make it 

impracticable to bring all of them before the court; and the character of the 

rights sought to be enforced by this complaint is joint and common to each.

VI

Defendant Board of Education of the Plum Bayou-Tucker School 

District No. 1 is a public body corporate which operates, manages, and 

controls the public schools of Wright and Tucker, Arkansas. Four of its five 

members are white. Defendant Frank Conley is the President of the defendanE 

Board of Education.
-2-



Defendant James K. Bradshaw is the Superintendent of Schools and 

chief administrative officer of defendant school district.

VI |

The public schools of the Plum Bayou-Tucker School District No. 1

are:

(a) The Rosenwald School located at Tucker, Arkansas, which 

has been an all-black school with grades 1 through 12. In school year 

grades 9 through 12 were moved to the previously all-white Plum Bayou school. 

The only white teacher at Rosenwald in its history spend one semester 

there during school year 19*6-67. There were approximately 135 students at 

Rosenwald during school year 1968-69. Rosenwald is to be closed during

school year 1969-70.

(b) The Plum Bayou School, located at Wright, Arkansas, was

historically the all-white school with grades 1 through 12. In 1965-66, approx 

.tely five black elementary school pupils were admitted. Plum Bayou 

will be the only school operated by defendants during school year 1969-70.

VIII

The pupil population of the district includes approximately 243 

black students and 73 white students.

IX

Ninety percent of the black students live within walking or short 

commuting distance of the Rosenwald School. A ll of the bUck students must 

be transported to the Plum Bayou School.

X

A. Defendants have allowed the physical facilities at Rosenwald 

School to deteriorate over a period of years and have refused to expend money 

for repairs.

B. Defendants have expended several thousand dollars to purchai 

school buses to transport black students from Tucker, Arkansas to Wright. 

Arkansas.

C. Defendants refuse to expend funds to make Rosenwald func­

tional as a school. Funds must be expended to make the PlurnBayou School 

acceptable to the State Department of Education.



D. The defendant■' refusal to expend fund* on the previous black 

school, which is readily accessible to black persons and to the overwhelming 

majority of students of the district is an act of discrimination. Further, 

defendants have refused to allow plaintiffs use of the Rosenwald facility as a 

community center,

XI

Defendants eliminated athletic activities when the high school becaix e 

integrated, rather than field an integrated team.

XII

Subsequent to the limited desegregation of facilities at Plum Bayou 

School, black children were required to sit together in on* part of a classroom  

and physically separate from whit* children. This division was carried as 

far as the yearbook which pictured white and black students separately.

XIII

Parents were required to pay for texts purchased with federal 

funds for math programs, notwithstanding requirements that the texts be madu 

available free of charge.

XIV

Inadequate facilities and school programs have been provided for 

black patrons in the past and unless restrained, defendants will continue to 

discriminate against black patrons. Examples of such discrimination include;

(1) no music or art program;

(2) no toilet facilities;

(3) only cold food was furnished by the district to the black 

school when th* white school always had hot lunches;

(4) children were expelled without justification;

(5) inadequate library facilities;

(6) no biracial social activity Is allowed, thereby foreclosing 

all social activity at school for black childrens

(7) no black substitute teachers were allowed at Plum-Bayou.



I

XV

Black teachers are not given the opportunity to earn extra money 

as bus drivers. Only white teachers are allowed this privilege.

XVI

Black patrons are not allowed to visit classrooms in which their 

children are present.

xvn
Defendants have openly used the most offensive of epithets, "nigger, " 

in reference to black teachers in open meetings and in front of patrons of the 

district as well as in private conferences.

XVIII

Black teachers are not allowed the same leave privileges as are 

white teachers.

XIX

A. Plaintiff Evans was placed on the Title I payroll in school 

year 1966*67 after having taught in the district for 23 years and required to 

teach remedial reading, a subject for which she had been inadequately pre­

pared by the district.

B. By placing plaintiff Evans on the Title I payroll, defendants 

have jeopardised her 26 years of teaching status with the district and discrim i­

nated against her.

XX

A. Defendants have published a manual of "Principles, Policies, 

and Objectives, " which has discriminated against the patron plaintiffs.

B. Attached hereto and marked Exhibit A is page 6 from said 

manual which provides for three directors from the Wright community, not­

withstanding that the majority of patrons reside in the Tucker community.

XXI

The white defendants have hired relatives to work in non-teaching 

administrative positions in the district even though there are qualified black

-5-



persons and other non-relatives available in the community for employment.

xxn

On May 22, 1969, defendants advised several black teachers, includ 

ing plaintiff Lois Thomas, that their contracts for the 1969-70 school year 

would not be renewed. A copy of plaintiff Thomas' letter is attached and 

marked Exhibit B. It is typical of all of the letters sent.

XXIII

Defendants failed to comply with their own manual procedures and 

substance in that no black teacher was discharged for any reason given on 

page 15 of said manual; a copy of said page is attached add marked Exhibit C.

XXIV

In terminating plaintiff Thomas and several other teachers at 

Rosenwald School, defendants reduced the total faculty by eliminating only

black teachers. Defendants terminated A sive  Thomas in 1968 so as not to

hire a black P . E. instructor and coach.
XXV

In terminating plaintiffs, defendants failed to objectively evaluate 

their qualifications with the qualifications df all white teachers employed by 

defendants to teach in the Plum Bayou-Tucker School District during the 1968- 

69 school term or with the qualifications of teachers employed by the defend­

ants to teach in the Plum-Bayou*-Tucker School District during the 1969-70 

school term.

XXVI

As a result of defendants above-stated actions, plaintiff teachers 

have sustained permanent loss of employment as a teacher in defendant school 

district solely because of their race or color in the discriminatory acts of 

defendants. Such loss is likely to cause them serious and irreparable injury 

and harm for which they have no plain, adequate or complete remedy to redre i 

these wrongs, other than this suit for injunctive relief and damages. Any 

other remedy would be attended by such uncertainties as to deny substantial 

relief and would cause teacher plaintiffs further irreparable injury and 

occasion further damage, vexation and inconvenience.

®  .

-6-



WHEREFORE, teacher plaintiffs pray that this court advance this 

cause on the docket, order a speedy hearing, and upon such hearing enter a 

preliminary and permanent injunction which enjoins defendants from employing 

any additional t< achers not now employed until this matter has been duly heard 

and adjudicated by the Court; and which further requires defendants to rein­

state plaintiffs to their teaching positions.

Teacher plaintiffs further pray that the Court grant them money 

damages to compensate them for loss of standing within the professional and 

academic communities, damage to their reputation in the teaching profession 

and in the community, and for loss of employment within defendant school 

district.

Teacher plaintiffs further pray that the Court restrain defendants 

from placing black teachers on Title 1 payrolls and from removing black 

teachers from the regular teacher payroll; and that the defendants allow black 

teachers the same opportunities to earn money as are offered to white teachern; 

and that black teachers be allowed the same leave privileges as are white 

teachers; and that they be free from the derisive and abusive epithets previous­

ly inflicted upon them; and that teacher staffs be allowed to be reduced through 

attrition; and that defendants follow their own teacher handbook procedures, 

regarding the dismissal of black teachers.

XXVII

As a result of the defendants' above-stated actions, plaintiff patrons 

have been discriminated against, as have the students of the defendant dis­

trict. Such loss has caused their children serious educational detriment and
*

irreparable injury and harm for which they have no plain, adequate or complete 

remedy to redress these wrongs, other than this suit for injunctive relief and 

damages. Any other remedy would be attended by such uncertainties as to 

deny substantial relief and would cause patron plaintiffs further irreparable 

injury and occasion further damage, vexation and inconvenience.

-7-



WHEREFORE, patron plaintiff* pray that thi* Court advance thi* 

cause on the docket, order a *peedy hearing, and upon *uch hearing enter a 

preliminary and permanent injunction which enjoins defendants from further 

separating black and white children in classrooms or any other activity at all 

associated with school or extra-curricular activities.

Patron plaintiffs further pray that defendants be enjoined from atten|pt- 

ing to implement those provisions of their "principles, policies, and objective 

handbook regarding the proportional representation of the Wright and Tucker

c ommunitie s.

Patron plaintiffs further pray that defendants be restrained from 

hiring relatives in non-teaching position* and provide equal opportunities to 

all persons in the district for employment.

Patron plaintiffs further pray that defendants be restrained from  

disposing of the Rosenwald facility and that they be required to formulate a 

plan which will suit the convenience and needs of a majority of the patrons and 

children of the district.

A ll plaintiffs further pray that because of the blatant acts of dis­

crimination by defendants that they be prohibited from expending any school 

district funds for the defense of this action but that costs of this action and its 

defense be assessed directly against them as individuals.

A ll plaintiff* further pray that the Court grant them their costs 

herein, reasonable attorneys' fees, and such further, other or additional 

relief as is equitable and just under the facts developed.

Respectfully submitted,

WALKER, ROTENBERRY. KAPLAN It LAVEY
1820 West 13th Street
Little Rock, Arkansas 72202

JACK GREENBERG 
MICHAEL MELTSNER 
CONRAD HARPER  
NORMAN J. CHACHK1N 
Suite 2030 - 10 Columbus Circle 
New York, New York 10019

By
Philip E. Kaplanapian

Attorneys for Plaintiffs



•OARS or d i u c t m s

Th* corporate name of this school district shall be 
“Plum Bayou-Tucker School District" as provided by law.

The Board of Directors shall consist of five (5) members 
elected at large by the qualified voters of the Plum Bayou- 
Tucker School District. Since the District is composed of 
two district communities, it is the expressed desire and wish 
of the Board of Directors to have each community repre­
sented as follows:

Wright Community - Three (3) Members 
Tucker Community -  Two (2 ) Members

Any person who is a bona-fide resident, property owner 
in the community, or school district, and a qualified elector 
of the District may become a candidate for a place on the 
Board of Directors by filing a petition in writing signed by 
twenty (20) or more qualified electors with the county 
Board of Education at least twenty days before the annual 
school election, at which time the ballot shall be closed.

t
The Board of Directors shall have authority to fill any 

vacancy which may occur in that body for the period cov­
ering the interval between the occurrence of the vacancy and 
the next annual school election.

The Board of Directors at its first regular meeting after 
the annual school election shall organize by the election of 
a President, Vice President, and a Secretary from among 
its members, each of whom shall serve a term of one year, 
or until his successor is elected and qualified. The Superin­
tendent, by virtue of his position, shall serve as Ex-Officio 
Financial Secretary, and shall be bonded in accordance with 
State Law. The President shall preside at all meetings and 
shall decide questions of order in accord with “Roberts

He shall have the right, as other 
to discuss and to vote on all ques- 
shall call a special meeting of the 

conditions set for a special meeting have 
In the absence of the President, the Vice Presi- 
perform the duties and have the obligations of 

No member, as an individual, may command



M h

i '

E #

PLUM BAYOU-TUCKER SCHOOL DISTRICT N O . 1
WRIGHT, ARKANSAS

FRANK C O N LEY, PfttSIDfNT 
J. P. MAYNARD, V»C* 
CLYDE ARCHER, SCCRCTARY

% STfrit. i

Mrs. Lola 0. Thomas 
616 North Magnolia 
Pine Bluff, Arkaneaa 71601
Dear Mrs. Thomas:

Pleaae consider this letter official notice 
contract will not be renewed for the 1969-70 school

If I can be of any assistance to you 
employment t pleaae feel free to call upon

Sincerely,

Jam es a .  a r a a s i  
Superintendent



CONTRACT TERMINATION

Teachers may be terminated from contracts for the follow­
ing reasons:

1. On request from contracted teacher with approval 
by Superintendent, and Board of Directors.

2. Insubordination.

3. Failure to meet standards of certification set by the 
State Department of Education.

4. For moral reasons unbecoming to the teaching pro­
fession.

5. In the event that a teacher becomes incapacitated 
physically or mentally to the point that they are unable to 
ful-fill his or her contracted obligation.

SCHOOL EMPLOYEES

A ll school employees shall be under the general di­
rections of the Superintendent of Schools.

Responsibilities of Employees shall be:

1. To file in the Superintendents office on or before 
the opening day of the school year the following: Health 
Certificate, Social Security Number, and Bus drivers should 
file the number of their Arkansas Driver’s License as re­
quired by law. This applies to all school employees under 
contract.

2. Custodians

(a ) To inform the Principal or Superintendent about 
the condition and needs of the school plant and grounds.

(b ) To keep the buildings and grounds as attractive,
safe and healthful as possible.

(c ) To work cooperatively with all school personnel.

(d ) To perform all other duties assigned by the Prin­
cipal or Superintendent as approved by the Board of Di­
rectors.



IN THE UNITED STATES DISTRICT COURT 
FOR THE

EASTERN DISTRICT OF ARKANSAS 
PINE BLUFF DIVISION

LOIS THOMAS, ASIVE THOMAS, 
LUCREASIA A, EVANS, ELOIS WOODS, 
AND TROY E. WOODS, BY THEIR 
PARENT AND NEXT FRIEND, MRS. 
CORINE WOODS; ERIC DINWIDDIE, 
DONALD R. DINWIDDIE, RODNEY 
DINWIDDIE AND DARRYE HARRIS,
BY THEIR GUARDIAN AND NEXT 
FRIEND, MRS. CORINE-WOODS

VS.

THE BOARD OF EDUCATION OF THE 
PLUM BAYOU-TUCKER SCHOOL 
DISTRICT NO. 1, WRIGHT, ARKANSAS, 
FRANK CONLEY, PRESIDENT, AND 
JAMES K. BRADSHAW, SUPERINTENDENT 
OF SCHOOLS OF THE PLUM BAYOU- 
TUCKER SCHOOL DISTRICT NO. 1

NJGt0

PLAINTIFFS )
)
) CIVIL NO. 
) PB 69 C-46 
)
)
)
)
)
)

DEFENDANTS)

A N S W E R

I.

The defendants admit the allegations contained in Paragraph IV (A), 

(B) and (D); Paragraph VI; Paragraph VII with the insertion of the words 

"1968-1969" at the end of the second sentence of Sub-part (a) thereof; 

Paragraph XXII to the extent that it refers to three Negro teachers; and 

so much of Paragraph XXI as alleges that the defendants have hired rela­

tives to work in non-teaching administrative positions in the District, but 

the defendants deny each and every other material allegation set forth and 

contained in the plaintiffs' complaint.

II.

The defendants specifically and affirmatively state and allege that 

acting for and on behalf of the patrons and pupils of The Plum Bayou-Tucker 

School District they adopted a plan for elimination of the District's dual 

school system in response to specific directive that they do so by the

( f o



- 2 -

Department of Health, Education and Welfare of the United States and

have, in all respects, acted in doing so in consideration of the best

interests of the patrons and pupils of the District without regard to

their race. The combination of the schools previously operated by the

rO District and a reduction in the number of pupils in the anticipated en-

rollment in the schools as .combined resulted in a decreased need for
<»

teachers. The plaintiff, Lois Ann Thomas and the other teachers who 

were not continued were dropped solely on the basis of evaluation of 

teacher competence and the areas of need in the combined schools which 

is applied in an objective manner in reference to all teachers without 

regard to their race.

WHEREFORE, the defendants pray that the complaint of the 

plaintiffs be dismissed and that the defendants have their costs expended 

in this action.

COLEMAN, GANTT, RAMSAY & COX 
11th Floor Simmons National Building 
Pine Bluff, Arkansas, 71601

By c , \ e t iP  ________
'^Tporneys ror the Defendants

CERTIFICATE OF SERVICE

I, Jeff Starling, one of the Attorneys for the defendants herein, do 
hereby certify that I have served a copy of the above and foregoing Answer 
upon the plaintiffs herein by mailing a copy thereof, postage prepaid, 
addressed to Walker, Rotenberry, Kaplan & Lavey, 1820 West 13th Street, 
Little Rock, Arkansas, 72202, and Jack Greenberg, Suite 2030-10 Columbus 
Circle, New York, New York, 10019, this 11th day of August, 1969, as 
their Attorneys.



IN THE UNITED STATES DISTRICT COURT 
FOR THE

EASTERN DISTRICT OF ARKANSAS
PINE BLUFF DIVISION

LOIS THOMAS, ASIVE THOMAS, )
LUCREASIA A. EVANS, ELOIS )
WOODS AND TROY E. WOODS, BY )
THEIR PARENT AND NEXT FRIEND, )
MRS. CORINE WOODS; ERIC DINWIDDIE, )
DONALD R. DINWIDDIE, RODNEY )
DINWIDDIE AND DARRYE HARRIS, BY )
THEIR GUARDIAN AND NEXT FRIEND, )
MRS. CORINE WOODS PLAINTIFFS)

)
VS- ) CIVIL NO.

) PB 69 C-46
THE BOARD OF EDUCATION OF THE )
PLUM BAYOU-TUCKER SCHOOL )
DISTRICT No. 1, WRIGHT, ARKANSAS, )
FRANK CONLEY, PRESIDENT, AND )
JAMES K. BRADSHAW, SUPERINTENDENT )
OF SCHOOLS OF THE PLUM BAYOU- )
TUCKER SCHOOL DISTRICT No. 1 DEFENDANTS)

ANSWER TO INTERROGATORIES 
PROPOUNDED TO DEFENDANTS BY THE PLAINTIFFS

Come the defendants and for their answers to the interrogatories

propounded upon them herein by the plaintiffs state:

Interrogatory No, 1. State for each public school in the district 
for the 1967-68 school year:

(a) grades served by each school;
(b) planned capacity of each school;
(c) average class size for each school-
(d) number of black pupils enrolled in each 

grade at each school;
(e) number of white pupils enrolled in each 

grade at each school;
(f) number of white children taught by black teachers 

in classroom settings, excluding Title I teachers;
(g) number of black children taught by white teachers 

in classroom settings, excluding Title I teachers.

Answer: See attached list.

Interrogatory No, 2 State for each public school in the school 
district the same information requested in question one (1) above, 
but for the 1966-69 school year.

Answer: See attached list.



-  2 -

Interrogatory No. 3. State for each public school in the 
school district the same information requested on question 
one (1) above, but as projected for the 1969-70 school year.

Answer: See attached list.

Interrogatory No, 4. For each teacher or administrative 
personnel employed by the school district for the school 
year 1967-68 state the following:
(a) name;
(b) school in which employed;
(c) race;
(d) age;
(e) grades taught or area of administration;
(f) subjects taught;
(g) educational background, including degrees received;
(h) certification;
(i) years of teaching and/or administrative experience;
(j) years of teaching and/or administrative experience 

within school district.

Answer: See attached exhibit.

Interrogatory No. 5. For each teacher or administrative 
personnel employed by the school district for the school 
year 1968-69 state the information requested in question 
four (4) above.

Answer: See attached exhibit.

Interrogatory No. 6. For each teacher or administrative 
personnel to be employed by the school district for the 
school year 1969-70 state the information requested in 
question four (4) above.

Answer: See attached exhibit.

Interrogatory No. 7. State the name and race of all teachers 
and administrative personnel employed by the school district 
for the school year 1967-68 who were not rehired for the 
school year 1968-69.

Answer: See attached exhibit.

Interrogatory No. 8. Supply the stated reason for discharge or 
refusal to renew the contracts of all those persons listed in 
response to question seven (7) above.

Answer: Sharon Johnson, Violetta Chavis, Martha Douglas,
and Otis Archer did not sign new contracts for the 1968-1969 
school year of their own accord. Hunter Douglas and Asive 
Thomas were not recommended for re-employment by the 
Superintendent because their teaching competence was unsatis­
factory.



\

i u s , n  «*i M K , t, y  i\»%»b . S l a l « *  ikt«* . »iul  r « u  «* o l  «»ll

and administrative personnel employed by the school district 
for the school year 1968-69 who were not rehired for the 
school year 1969-70.

Answer: See attached exhibit.

in terrogatory No, 1 0 , Supply the stated reason for discharge
or refusal to renew the contracts of all those persons listed 
ip response to tjiiesiipp nine (II) p|iMW.

Answer: Ellis Ramsey, Elizabeth Ramsey, J. O. Porter and
Jean C. Edwards did not accept re-employment for the school 
year 1969-70 of their own accord. Virginia Greeno was not 
recommended for re-employment because of unsatisfactory 
performance as a teacher. Dora Thomas, Armenia Kidd and 
Lois G. Thomas were not offered re-employment because the 
unification of the schools in the district resulted in a decrease 
in the number of teaching positions available, and upon the 
basis of an evaluation made by the Superintendent of the district 
as referred to in the answer to Interrogatory No. 11. The 
teaching competence of these teachers was found to be the least 
of the teachers available.

In te rro ga to ry  H o . 11. State whether or not the defendant school 
district regularly employs any general objective criteria to 
determine whether or not teachers and administrative personnel 
shall be rehired. If yes, state such criteria, when adopted 
and when effective.

Answer- No written objective criteria has been adopted by 
the district prior to April of 1969. When the Board of Directors 
of the district determined to unify the two schools in the district, 
it became necessary to evaluate the available personnel in order 
to determine upon whom the reduction in force would fall. Mr. 
James K. Bradshaw, one of the defendants, and the Superintendent 
of the School District, prepared the list of criteria to be used in 
determining teacher competence and applied this criteria in eva 
uating the personnel of the district. The nature of the criteria is 
set forth in the response to Interrogatory No. 12.

Interrogatory No. 12. Supply copies of forms or evaluation forms 
which contain the criteria described in question eleven (11) above.

Answer: See attached exhibit.

Interrogatory No. 13. State whether'or not each teacher not re 
hired in school year 1967-78 was evaluated in accordance with 
the criteria described in question eleven (11) above.

Answer: No.

Interrogatory No. 14. State the same information requested in 
question thirteen (13) above for teachers not rehired in school 
year 1968-69.

Answer: No.



- 4 -

Interrogatory No. 15. State the same information requested in 
question thirteen (13) above for teachers not rehired in school 
year 1969-70.

Answer; Yes, except those teachers who, prior to the deter­
mination of the criteria and their application, had indicated that 
they would not accept re-employment in the district for the 
succeeding year.

Interrogatory No, 16. State whether or not the defendant school 
district had an affirmative policy of assigning Negro teachers 
and administrative personnel to positions in predominantly 
white schools for the school year 1967-68. If so, set out such 
policy, indicating when it was adopted and the names of per­
sonnel affected thereby.

— -swer: Yes. The district has consistently followed the guide­
lines established by the Department of Health, Education and 
Welfare concerning desegregation of the public schools. The 
district executed and returned to the Department of Health, 
Education and Welfare its Form 441-B agreeing and assuring 
that Department that it would abide by the applicable require­
ments for such plans contained in the statement of policies 
issued by that Department. The agreement on the part of the 
district, and its activities pursuant to the guidelines was 
approved by the Department of Health, Education and Welfare.

Interrogatory No. 17. State the same information requested 
in question sixteen (16) above for the school year 1968-69.

Answer: See the response to Interrogatory No. 16. An identi­
cal agreement was made by the defendant district with the De­
partment of Health, Education and Welfare for the school year 
1968-1969.

Interrogatory No. 18. Supply a list of all persons with whom 
plaintiffs' qualifications were compared, who made such com­
parison, in what respect the qualifications were inferior to 
those of incumbent teachers or new employees, and whether 
the school board made an independent review of the comparison 
of qualifications, if the same was made by administrative per­
sonnel.

Answer: See the answer to Interrogatory No. 12. The findings
and evaluations reflected upon this report as made by the Super­
intendent, James K. Bradshaw, were reported to and reviewed 
by the Board of Directors.

Interrogatory No. 19. Set out in full or attach copies of any 
records, papers, forms, documents or memoranda relating 
to the evaluation of plaintiffs' teaching and/or administrative 
qualifications, made by any employee of the school district, or 
any member of the school board.

Answer: See response to Interrogatory No. 12. There are no
other rec ords, papers, forms, documents or memoranda relating 
to the evaluation of plaintiffs' teaching and/or administrative 
qualifications.



- 5 -

Interrogatory No. 20. State the same information requested 
in question eighteen (18) for all black teachers not rehired 
for school years 1968-69 and 1969-70.

Answer: No written evaluations were made of teachers prior
to April of 1969, and there are no papers, records, forms, 
documents or memoranda known to the defendants relating to 
the evaluation of the black teachers not rehired for school 
years 1968-1969. The answer to Interrogatory No. 19 is 
applicable for the school year 1969-1970.

Interrogatory No. 21. Supply the same material requested in 
question nineteen (19) above for all those persons named in 
response to question twenty (20) above.

Answer: See' answers to Interrogatories Nos. 19 and 20.

Interrogatory No. 22. Set out in full or attach copies of any 
records, papers, documents or memoranda relating to the 
evaluation of teaching and/or administrative personnel 
employed by the defendant school district during the school 
years 1967-68, 1968-69, and 1969-70.

Answer: As indicated in response to previous interrogatories, 
no written evaluation of teaching and/or administrative per­
sonnel was employed by the defendant school district for the 
school years 1967-1968 or 1968-1969. The only written record, 
paper, document or memoranda relating to the evaluation of 
these personnel is shown in response to Interrogatory No. 12.

Interrogatory No. 23, Set out in full or attach copies of any 
written memoranda of meetings or discussions between teachers, 
principals and/or other administrative personnel:

(a) regarding the evaluation of any teacher or 
administrator employed by defendant school 
district, and

(b) regarding the hiring, rehiring or non-hiring 
of any such teacher or administrator for the 
school years 1968-69 and 1969-70.

Answer: There are no written memoranda of meetings or dis­
cussions between teachers, principals and/or other adminis­
trative personnel regarding the evaluation of any such employee 
or the hiring, rehiring or non-hiring of any such employee for 
school year 1968-1969. All information for school year 1969- 
1970 is reflected in the response to Interrogatory No. 12.

Interrogatory No. 24. Attach copies of the dismissal letter sent 
by defendants to plaintiffs.

Answer: See attached copies of letters from the defendant, James 
K. Bradshaw, on behalf of the defendant school district.

Interrogatory No, 25. Attach copies of the dismissal letters sent 
by defendants to all persons employed during 1968-69 not rehired 
for 1969-70.

Answer: See attached copies of letters from the defendant, James
K. Bradshaw, on behalf of the defendant school district.



- 6-

Interrogatorv No. 26. Set forth the names and race of all 
teachers in the district who have taught subjects or grades 
for which they were not certified at the time they taught those 
subjects or grades, for each school year from 1965-66 through 
school year 1969-70.

Answer:
1965-1966 Grades or 1966-1967 Grades or

Teacher's Name Race subiects taught Teacher s name Race subiects taught

Mildred Blair White 4 through 6 Violetta Chavis White 4 through 6

Darrel Heath White O. L. Archer White Science 
9 through 12

E. W. Ramsey White Math
9 through 12

E. W. Ramsey White Math
9 through 12

1967-1968 1968-1969

Asive Thomas Negro Social Science James H. Klutts White Math
5 through 8 7 through 12

Interrogatory No. 27. Set forth the name and race of all 
persons employed as teachers by the district, who at the 
time of employment did not possess an undergraduate 
degree or a full teachers certification for each school year 
from 1965-66 through school year 1969-70.

Answer: See Answers to Interrogatory No. 26.

Interrogatory No. 28. Attach copies of documents showing all 
academic work beyond the Bachelor's degree of all teaching 
and administrative personnel of the district as of May 30, 1968.

Answer: The district does not maintain a transcript of its 
teaching personnel for graduate work. The individual teachers 
have been requested to provide this information, and when it 
has been provided to the district, it will be supplied to you.

Interrogatory No. 29. Attach copies of the faculty salary 
schedule and/or faculty salary policies used and/or followed 
by the district for each school year since 1965-66 through 
1969-1970.

Answer: See attached exhibit.

Interrogatory No. 30. Attach a copy of any faculty salary 
schedule and/or faculty salary policy proposed for future use 
in the district.

Answer: See teacher salary schedule for 1969-1970. It is 
anticipated that this will be used in the future, although salary 
adjustments may be made within the frameworks provided.

Interrogatory No. 31. Supply academic transcripts of all math, 
chemistry, commercial, music and science teachers to be 
employed by the school district for 1969-70.

Answer: See attached list.



- 7 -

Interrogatory No. 32, Supply minutes of the regular 
school board meeting of May 29, 1969. Supply minutes 
of any executive session whj/h may have been held on 
May 29, 1969, or at any other time when the employment 
contracts of plaintiffs Elfingsberg, Moore, Wyrick, 
Williamson, and Crosa'may have been discussed.

Answer: No meeting of the school board was held on
May 29, 1969, nojr was there any executive session.
The defendant district does not now nor has it ever to 
its knowledge employed "plaintiffs" by the name of 
Ellingsberg, Moore, Wyrick, WilUamson and Cross.

Interrogatory No. 33. Set form exact salaries earned 
by white teachers at Chidesteh High School for subjects 
that were taught at Pleasan/Hill High School, including 
elementary grades. This/Salary comparison is to be for 
each school year since V966-67, excluding any remuner­
ation for bus driving. /

Answer: The disDnct does not operate any school by the
name of "Chideste/High School" or "Pleasant Hill High 
School", and therefore may not answer this question.

Interrogatory No. 34. Set forth the exact reasons for any 
salary disparities between Wlack and white teachers, if any, 
as demonstrated in numbe/33 above.

Answer: See response^to Interrogatory No. 33 above.

Interrogatory No. 35. Supply the names of all teachers 
since 1965-66 who have been placed on Title I EASA pay­
rolls. For each teacher so designated, supply the year 
said individual was placed on Title I EASA and the total 
teaching experience both within the district and career 
for said individual.

Answer: Years in Total
Name Year Race District Years

Lucreasia Evans 1965-66 Negro 27 27
Elizabeth Anne Ramsey 1965-66 White 4 5
Ellis W. Ramsey 1966-67 White 5 5
James Henry Klutts 1967-68 White 2 2
Otis L. Archer 1966-67 White 2 9i
James O. Porter 1968-69 White 2
Artie Davis 1969-70 Negro 3 3
Maxine Clark 1969-70 Negro 13 14



- 8 -

Interrogatory No. 36. State all years in which the district 
did not compete in competitive high school athletics.

Answer: The district has not competed in competitive high 
school atlietics since 1966-67. except in baseball and basketball.

Interrogatory No. 37. Supply the names of coaches, and 
designate said coaches by race, employed by the district 
since 1965-66.

Answer: The district does not employ an instructor
designated as a coach. Mr. James K. Bradshaw served 
in the capacity of Physical Education and Social Studies 
Instructor.

Interrogatory No. 38. State the name of the coach at Plum 
Bayou School for 1968-69. State the coaching experience 
of said individual before hiring by the district and the total 
number of years employed by the district.

Answer: 1968-69, Bruce McConnell, who was employed
by the district for one year. No prior experience

Interrogatory No. 39. State the names and purchase price 
of all texts purchased by the district with the assistance of 
federal funds.

Answer: The names of the texts purchased by the district
with the assistance of federal funds are as follows:

Greater Cleveland Math Books 
Grade 1 - $1.60 
Grade 2 - 1.60
Grade 3 - 2.16
Grade 4 - 2. 16
Grade 5 - 2. 16
Grade 6 - 2.16

Behavioral Research Laboratories
Reading Series I & II - $1.49 each. Supplementary Readers.

Interrogatory No. 40. State whether or not parents were made to 
purchase any texts which were purchased in whole or in part by the 
district with federal funds. Supply the names of such texts which 
were paid for by parents.

Answer: No.

Interrogatory No. 41. State whether or not any social activity 
is allowed for students of the Plum-Bayou High School.

Answer: The following social activities are allowed for students 
of the Plum Bayou High School:
Future Homemakers of America 
4-H Club
Junior Academy of Science 
Library Club

Student Council
The Pepettes -(students which support 

athletic team) 
Intraschool Playday 
Christmas Social



- 9 -

Interrogatory No. 42, State whether or not any black 
substitute teachers have ever been employed at the 
Plum-Bayou School.

Answer: There has been no application or request from 
Negro persons to teach in the Plum Bayou School in a 
substitute capacity.

Interrogatory No. 43. Supply a copy of the. district's 
manual of "Principles, Policies and Objectives" which 
is currently in force in the district.

Answer: See attached exhibit.

Interrogatory No, 44. Supply a list of all individuals, 
together with their race, who have been placed on Title I 
payroll by the district. Supply the total career teaching 
and district teaching experience of each such individual.

Answer:
Name Year

Lucreasia 3vtms • 1965-66
Elizabeth Anne Ramsey 1965-66
Ellis W. Ramsey 1966-67
James Henry Kluttg 1967-68
Otis l . Archer 1966-67
James O. Porter. 1968-69
Artie Davis * 1969-70
Maxine ClarK‘ 1969-70

Years in Total
Race District Years

Negro 27 27
White 4 5
White 5 5
White 2 2
White 2 9j
White i 2
Negro 3 3
Negro 13 14

Interrogatory No, 45. State whether or not plaintiff Evans 
has ever asked for special stipends or grants to attend 
remedial reading conferences or classes.

Answer: Yes.
5

Interrogatory No. 46, State whether or not plaintiff Evans 
has ever received such stipends or grants to attend remedial 
reading conferences oi- classes, institutes, or sessions.

^ wer: In accordance with the historical and long-standing 
policy of the school district, no funds have been made available 
to any teachers to attend remedial reading conferences or 
classes, institutions, or sessions.

Interrogatory No. 47, Supply copies of any petitions of school 
patrons in accordance with Arkansas Statutes, granting leave 
of school board directors to employ relatives in any year since

—n s w e r An records in the subject school district are attached.

Interrogatory No. 48. State whether or not plaintiffs Lois Thomas 
or Asive Thomas were terminated for any of the reasons, 1 through 
o which appear on page 15 of the district's manual of "Principles 
Policies, and Objectives."

3a



10 -

Answer: Plaintiffs Lois Thomas andAsive Thomas were
not terminated by the school district. Their contracts were 
not renewed, and consequently nothing in the district's 
manual of "Principles, Policies, and Objectives" applies 
to the circumstances of either of the plaintiffs, Lois Thomas 
or Asive Thomas.

STATE OF ARKANSAS )
) SS

COUNTY OF JEFFERSON)

I, James K. Bradshaw, one of the defendants in the above styled 
cause and Superintendent of the defendant. Plum Bayou-Tucker School 
District No. 1, having first been duly sworn, do state that the answers 
made to the interrogatories as hereinabove set forth are true and correct.

Subscribed and sworn to before me this 27th day of August, 1969.

Notary Public ^
My commission expires:

M k  <37 \ ° \ 1 ^

CERTIFICATE OF SERVICE

I, E. Harley Cox, Jr. , one of the Attorneys for the defendants, do 
hereby certify that I have served a copy of the above and foregoing Answer 
to Interrogatories upon the plaintiffs herein by mailing a copy thereof, postage 
prepaid, addressed to Mr. Philip E. Kaplan, Walker, Rotenberry, Kaplan 
& Lavey, Attorneys for the plaintiffs, 1820 West 13th Street, Little Rock, 
Arkansas, 72202, this 27th day of August, 1969.

Cox, Jr,
Colem^i, Gantt, Ramsay & Cox 
Simmons Building 
Pine Bluff, Arkansas, 71601 
Attorneys ffLr- the Defendants



School year 1967-68 Page 1

1. (a) Tucker Rosenwald - Grades 1-8
Plum Bayou - Grades 1-12

(b) Tucker Rosenwald - Capacity - 250
Plum Bayou - Capacity- 500

Cc) Average class size - Plum Bayou - 19.5
Rosenwald - 17.8

(d)
(c) Tucker Rosenwald

1st
2nd3rd
9th
5th
6th7th
8th

Plum
1st
2nd
3rd
9th5th

_6th7th
8th
9th

10th
1 1th
12th

Negro White Total13 0 1317 0 1722 0 2219 0 1920 0 2013 0 1322 0 2219 0 19Total ~T2'8
Bayou
White Negro Total7 5 127 6 139 3 > 1213 2 167 l 86 6 128 5 135 9 98 19 279 17 217 19 213 13 16Total T S 0

(f) Elementary - 27 High School - 18
(g ) Elementary - 29 High School - 89

Answer to Interrogatories No. 1



Page

School year 1968-69

2. (a) Tucker Rosenwald - Grades 1-8
Plum Bayou - Grades 1-12

(b) Tucker Rosenwald - Capacity - 250 
Plum Bayou - Capacity - 500

Cc) Average class size

(d) Tucker Rosenwald(e) Negro
1st 1U
2nd 133rd 17itth 195th 25
6th Ik7th Ik
8th 17

Plum Bayou
White

1st k
2nd 103rd 9Uth 75th 7
6th Jk7th 3
8th 7
9th b

10th 6
1 1th 2
12th 6

(f) Elementary - 27
(g) Elementary - 33

Plum Bayou - 13.5Rosenwald - 15 .75

White Total
0 lit
0 13
0 17
0 19

25
0 lit
0 lit
0 J 7

Total " O  33Vx

Negro Total
8- 12
5 ; 157- 163 10
k 113 79 12* 1227 3315 21

12 lit14 20Total 183 '
High School - 11

High School - 80

Answer to Interrogatories No. 2



School year 1969-70 Page 3

(a) Plum Bayou School - Grades 1-12

(b) Plum Bayou School Capacity - 500
(c) Average class size - Plum Bayou School - 25.2
(d) Plum Bayou School(e) Negro White Total

1st 20 10 30
2nd 17 7 2k3rd 19 8 27Uth 2'2. 11 335th 21 10 31
6th 25 6 J5L.7th 17 5 22
8th 20 2 229th 31 6 37

10th 12 3 15
11th Ik k 18
12th 10 2 12228 7k ~~302---

(f) Elementary - 27 High School estimate - 17 Total - kk

Cg) Elemeitary - 12k High School - 10U Total - 228

Answer to Interrogatories No. 3



Sc
ho

ol
 Y

ea
r 

19
67

-6
8

( b ) ( c ) M

Edith Workman Plum Bayou W k5 7-12
Sharon Johnson Plum Bayou W 22 3rd
Mildred Blair Plum Bayou w 58 k - 6
Elizabeth Ramsey f- Plum Bayou w 27 Reading
Voletta Chavis Plum Bayou w 2 it k - 6
James H. Klutts Plum Bayou w 22 7-12
Martha Douglas Plum Bayou w 26 8-12
Otis L. Archer x Plum Bayou w 1*0 9-12
E llis  W. Ramsey Plum Bayou w 29 7-12
Hunter R. Douglas Plum Bayou W" 29 7-12
Mary K. Measeles \ Plum Bayou w 23 7-12
Robbie Keith Plum Bayou w i+8 2nd
Juanita Moore Plum Bayou w 56 1st
Nancy W. Rosen £ Plum Bayou w 2k l*th
James K. Bradshaw Plum Bayou w 38 1-12
Artie A. Davis Tucker N. k9 5-8
Lucreasia Evans Tucker N k8 k - 8
Asive Thomas Tucker N 5-8
Lois G .  Thomas Tucker N 1st
Althea A. Gordon Tucker N 62 2ndJean C. Edwards Tucker N 5-8Annteet Brown Plum Bayou N 2 7 9-12Althia W illis Plum Bayou N 5k k - 6Maxine Clark Tucker N k3 k t hArmenia Kidd Tucker N 3rd

I f ) ( ? , ) M U ) (  j )

English BSE H/S 6yr Cert. 11 10Elem.Ed. BSE Elem.6yr 0 0
Elem.Ed. BSE Elem.6yr 36 25Reading BSE Elem.6yr k 2Elem.Ed BA Emerg.Cert. 3 uMath BS Emerg.Cert. 0 0
Home Ec. BS H/S 6yr. 3 3Sci. BS H/S 6yr. 7 1?Soc.Sci. BSE H/S 6yr. 3 3
P.E.,Soc. BA Emerg.Cert. 0 0
Sci. BSE H/S. 6yr 0 0
Elem.Ed BSE Elem. 6yr 13 13Elem.Ed BSE Elem. 6yr 29 15Elem.Ed BA Elem. 6yr. 0 0Adm. BSE H/S 6yr 13 12
English BSE Elem. 6yr 1 1
Reading
§QcgSci
ElSmIEd.

BSE
BSE

Elem. 6yr 
Emerg.Cert. 25

2
252

BSE Elem.6yr. 3 3
Elem.Ed. BS Elem. 6yr 15 1
Math BS H/S 6yr cert. 7 5Coram. BS H/S 6yr Cert. 5 1
Elem.Ed. BS H/S 6yr Cert. 33 20
Elem.Ed. BSE Elem. 6yr Cert. 12 11Elem. Ed. BSE Elem. 6 yr. 22 15

Answer to Interrogatories No. 4



Sc
ho

ol
 Y

ea
r 

19
68

-6
9

U">
<UbOCOto

(a ) (b ) (c ) (d )

Edith Workman Plum Bayou W k 6
Mildred Blair Plum Bayou w 59
Elizabeth Ramsey Plum Bayou W 28
James H. Klutts Plum Bayou w 23
Virginia Greeno Plum Bayou w 25
Otis L. Archer Plum Bayou W k l
E llis W. Ramsey Plum Bayou W 30
Robbie Keith Plum Bayou W Li 9
Juanita Moore Plum Bayou W 57
Nancy W. Rosen Plum Bayou w 25
James K. Bradsho - Plum Bayou w 39
Artie A. Davis Tucker N 50
Lucreasia Evans Tucker N li 9
Lois G. Thomas Tucker N
Althea A. Gordon Tucker N 63
Jean G. Edwards Tucker N
Annette Brown Plum Bayou N 28
Althia B. W illis Plum Bayou N 55
Maxine Clark Tucker N LiLi
Armenia Kidd Tucker N
Dora Thomas Tucker N
Bruce McConnell Plum Bayou W 23
Janet Dye Plum Bayou W 2 li
J 0. Porter Plum Bayou W 60

(e ) ( f ) Cg) (h) ( i ) ( j )

7-12 English BSE H/S 6yr 12 11k-6 Elem.Ed. BSE Elem 6yr 37 26
Li- 7 Reading BSE Elem 6yr 5 3Math -7-12 BS Emerg.Cert 1 18-12 Home Ec BSE H/S 6yr 3 07-12 Sci BS H/S 6yr 8| 2\9-12 Soc.St. BSE H/S 6yr k k2nd ElemEd. BSE Elem.6yr I k lh1st Elem.Ed. BSE Elem.6yr 30 16kth Elem.Ed. BA Elem.6yr 1 i
1-12 Adm. BSE H/S 6yr I k 135-8 English BSE Elem.6yr 2 2
Li- 8 Reading BSE Elem.6yr 26 ' 261st Elem.Ed. BSE Elem.6yr k k2nd Elem.Ed BS Elem.6yr 16 25-8 Math BS H/S 6yr 8 69-12 Comm. BS H/S 6yr 6 2Elem. Ed.U-6 BS Elem.6yr 3k 21hth Elem.Ed BSE Elem.6yr 13 123rd Elem.Ed BSE Elem.6yr 23 165-8 Soc.Sci BSE Elem.6yr 0 07-12 BSE H/S 6yr 0 03rd Elem.Ed. BSE H/S 6yr 0 07-12 Science BSE H//S 6yr 1 1

Answer to Interrogatories No. 5



Sc
ho
ol
 Y
ea

r 
19
69
-7
0

VO
41bO
(9P<

(a )

Edith Workman 
Mildred B lair 
James H. Klutts 
Otis Archer 
Robbie Keith 
Juanita Moore 
Nancy W. Rosen 
James- K, Brads he 
Artie Davis 
Lucreasia Evans 
Althea Gordon 
Annette. Brown 
Althia W illis  
Marine Clark 
Bruce McConnell 
Janet
Carroll Allison

( b ) (c

Plum Bayou W
Plum Bayou W
Plum Baynu w
Plum Bayou w
Plum Bayou w
Plum Bayou w
Plum Bayou w

w Plum Bayou w
Plum Bayou N
Plum Bayou N
Plum Bayou N
Plum Bayou N
Plum Bayou N
Plum Bayou N
Plum Bayou W
Plum Bayou W
Plum Bayou W

vO

(d) (e )

1+7 7-12
60 1-6"
21+ 7-12
1+2 7-12
51 2nd
58 1st
26 1+-6
1+0 1-12
51 i+-6
50 1+-6
61+ 1+-6
29 9-12
56 1-12
1+5 i+-6
21+ 7-12
21+ 3rd
21+ 7-12

<f> (g ) (h) ( i ) ( j )

English BSE J i/ S  6yr 13 12Elem.Ed. BSE Elem.6yr 38 27Math BS Emerg.Cert 2 2Science BS H/S 6yr 9| 3|Elem.Ed. BSE Elem.6yr 15 15Elem.Ed. BSE Elem.6yr 31 17Elem.Ed BA Elem.6yr l j l i
Adm. MSE H/S 6yr 15 1*+
Elem.Ed BSE Elem.6yr 3 3Reading BSE Elem.6yr 27 27Elem.Ed. BS Elem. 6yr 17 1 3Comm. BS H/S 6yr 7 3Lib.El.Ed. BS H/S 6yr 35 22Elem.Ed. BSE Elem.6yr 1U 13P.E. & S.S. BSE H/S 6vr ,1 1
Elem.Ed. BSE H/S 6yr. - 'i-A
Soc.Sci BSE H/S 6yr 0 0

Answer to Interrogatories No. 6



Page 7

1967-68

7. Sharon Johnson 
Voletta Chavis 
Martha Douglas - 
Otis Archer 
Hunter Douglas 
Asive Thomas

1968-69

8. Ellis Ramsey 
Elizabeth Ramsey 
Virginia Greeno 
Lois Thomas 
Dora Thomas 
Armenia Kidd 
Jean C. Edwards 
J. O. Porter

White
White
White
White
White
Negro

- White
- White
- White 

Negro 
Negro 
Negro 
Negro

- White

Answer to Interrogatories No. 7 and No. 9



* * * ^V'irmr.-. jr o  — i  ’ I

c îTrniA ?o:i rsAc: A?raAiSAL

1. Teacher Coapat-incy.
2. Ability to maintain clfib^rooa discipline.
3. Teacher-pupil rclationohip. 
h. Teachcr-teaehcr relationship.
5. Willingnas* to coop.irat*' with total school program.
6. Humber of yeara teaching experience.

Answer to Interrogatories No. 12





May 22, 1969

Mrs. L o la G. Thomas
616 North MagnoliaPine Bluff, Arkansas 71601
Dear Mrs. Thomas:

Please consider this latter official notice that yo-ar 
contract will not be renewed for the 196y-70 school year.

If I can be of any assistance to you in finding future 
employment, please feel free to call upon this office.

Sineerelv.

James K. Bradshaw Superintendent

Answer to  In terroga tories  No. 24



• a. I-* .1 W- L

•w. r̂r.Cw

' y,



Hay 22, 1969

Mrs . Dora Thcr.'.G
5900 West Holicy StreetPine Bluff, Arkansas 71601
Deer Krs. Themes:

Pletse consider this letter official not—o«s th.i>- your 
contract will not be renewed for the 1SC9-70 school year.

If I can be of sr.y aaeistar.ee to you in f i r . c i r i j future 
employment, please feel free to call upon this office.

Sincerely,

Jf.jr.es K. Bradshaw Superintendent

Answer to  In ,terra§atari*# N«. 25



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SALARIES OF TEACHING PERSONNEL

1966-67 1967-68

Robert J . H a ll - 4200.00 Armenia Kidd - 4800.00

Jean C. Edwards - 4908. 00 Maxine C la rk - 4800.00

A s iv e  Thomas - 1800.00 -  4§- M os. E velyn  D en iston - 4850.00

L u creas ia  Evans - 4500.00 M ild red  B la ir - 5628.00

L o is  G. Thomas - 4200.00 Sharon Jons on - 1911.00 -

A r t i e  Davis - 4000.00 A lth ea  B. W i l l i s - 4889.00

Maxine C lark - 4300.00 A nnette  Brown - 4850.00

Armenia Kidd - 4350.00 Jean Edwards - 5660.00

A lth e a  Gordon - 4350.00 A lth e a  Gordon - 4850.00

O tis  A rch er - 5000.00 L o is  G. Thomas - 4700.00

M ild red  B la ir - 5136.00 Lu creas ia  Evans - 5000.00

Martha Buchanan - ± 7 5 0 .0 0 Hunter Douglas - 4500.00

A n n ette  Brown - 4350.00 Robbie K e ith - 4980.00

V o lc t ta  Chavis - 4000.OC Martha Euchanan - 5250.00

E ve lyn  D en iston - 4350.00 A r t i e  Davis - 4500.00

A lth ia  W i l l i g - 4339.00 A s iv e  Thomas - 4300.00

E d ith  Workman - 4639.00 E liz a b e th  Ramsey - 5000.00

E l l i s  Ramsey - 4350.00 Kathryn M easeles - 2132.60-4

Robbie K e ith - 4489.. 00 " Juan ita  Moore - 5030.00

Juanita  G. Moore - 4539.00 Henry K lu tts - 5500.00

E liz a b e th  Anne Ramsey -,500.00 O tis  A rch er - 5500.00

Jcirrus V. Anders on 6500.00 E d ith  Workman - 5130.00

L . Heath - 4650.00 E l l i s  Ramsey -5S30.00

to Interrogatories No. 29 and 30
Nancy Rosen 

V o ie t ta

- 5000.00

Mos

.os .

Chavis



1968-69 1969-70

James K. Bradshaw - $8500.00 James K. Bradshaw - $9900.

Armenia Kidd - 5300.00 M ild red  B la ir - 6336.

Maxine C la rk - 5300.00 A n n ette  Brown - 5550.

A n n ette  Brown - 5350.00 M axine C la rk - 5500.

Jean C. Edwards - 61S0.00 A r t i e  Davis - 5200.

A lth e a  Gordon - 5350.0.0 Janet Dye - 5200.

Lu creas ia  Evans - 5500.00 A lth e a  Gordon - . 150.

A r t i e  Davis - 5000.00 Robbie K e ith - s a. v .

L o is  G. Thomas - 5200.00 Eruce McConnell - 5200.

Ju an ita  G. Moore - 5580.00 Ju an ita  Moore - 5789..

Henry K lu tts - 6000.00 C a r r o l l  A l l i s o n - 5000.

V ir g in ia  Greeno - 6000.00 Nancy Rosen - 5200.

Janet Dye - 30S5.00 - 7 Mos. A lth ia  W i l l i s - 5589.

Bruce M cConnell - 5000.00 E d ith  Workman - 5839.

J . 0. P o r te r - 5300.00 Henry K lu tts - 6500.

Dora Thomas - kSOO.OO Lucreas ia  Evans - 6000.

A .lth ia  W i l l i s - 5380.00 O tis  A rch er - 6000.

Nancy Rosen - 5000.00

Robbie K e ith - 5U8O.0*

E l l i s  Ramsey - 6339.00

E liz a b e th  Ramsey - 5500.00 '

M ild red  B la ir - 6132.00

E d ith  Workman 5630.00

00

00

00

00

00

00

00

00

00

00

00

00

00

00

00

00

00



i

1
*}
1

T ra in in g  f.

Tl'ACH^R SALARY 

1969-70

■.Mir"; S a la ry

SCHEDULE

Annual In ertu si. up 
to  10 year’s s e r v ic e

dn tr ' Onty Ma .v f nura

B a ch e lo r 's  decree  
but not f u l l y  c e r t i f i e d $4500.00 $50 00 $900.00 S5900.00

B a ch e lo r 's  degree
f u l l y  c e r t i f i e d

|
5000.00 50.00 900.00 6400.00

M aster ’ s d ecree
|

5500.00 50.00 900.00 6900.00

Dipt oma o f Advanced 
Study 6000.00 50.00 900.00 7400.00

Superin tendent and P r in c ip a l - S a la ry  to  be determ ined by Board o f  Of roe to r s

Annual Teachers s a la r ie s  payable i f  funds arc a v a i la b le .

Answer to Interrogatory No. 29



otimber 1 1 , l?6l

ARKANSAS A G R I C U L T U R A L  A N D  M E C H A N I C A L  C O L L E G E
COLLEGE HEIGHTS. ARKANSAS

xaBo-.KiynS, Jara-s Henry •.......— — Imi«* uf Al;• iri<'i|];i|i««it
AiMiKcrth. L itt lo  iiC'Ok, ’.ri.-nz-'S. ■ . * ----- ----- --- ItTAv
T Li?.* n i  I l i r l h.  ] ) ; ,  1 3 * J  . •-T . *, J , -  ..... . !l:f. Or;." .1 «. ■i.....  oj* iiinii. Ltttln .ac .'j Arv "s gg _. g-*. .  .
S a m , -  of  | W i l l  • !•,  i  ' . ' . r e .  A ,  . 1 ,  K l u t . t s

li"U-n:.;>

Ailiiiiiiid on ( ■••nt l;.Js i'r.»::i:
,n Hose c ity , H, Sch, at 
un Ho. L it t le  Hock, Ark,l?6l

College entrance Test 
Prog. rtead-adv.form B. 13.0 

^ath-a iv.fona uB 10.8 
oalilL Mental .-later U.l4

r c r c c r O  o f  b - i- . o o .

- L . L . . C T  w .

Fn^licb !• C-iin. bci* 1
Algebra *> bh.*s;:.istry 1
beo.vjo try .’ ny sics 1
Aivjr. ..is t* Manual 2.5
Civics X band 0
i io b iiy

.<tco;io or jcxxel.e work
DEPT. CATNO.

Biol 103a
Chen lClra
Ing 103a
.'■lath : 163
For 112
2ngr 112
? a 101a
H u s [ 171a

Bath 163
Hath 113
o r .g 1C 3 b
Biel 103b
Ingr 152
P 6

1
101c.

p  3 io l 103b
^ i . ath 113  ;

Hist 203b !
w ^or 21)3 j
^ ? O T 203
;i p T? 
W lOld

213a i
m Chcm 10.!; a

Phys 20l;a
F o r 212a
For •><:

Chs.p. \
■ - ,T>%■***ÂA

2 -:>o
;;ath 1 1 3
•<; i uiiB (.1 ri</, ..
•n_. ' -»ti . A.

-*( : 1*

SupL A i d '.ciuier

■irkV'rr i:o j-.'• l’
• r . * m > r  r i :

Fall Selector 19 ̂  1 —62 
ôn notary 

Inorga.'iio 
Fr.sh Comp 
College Algebra 
Ir.trod to .’’or 

j Mech Draw 
B^sic S k ills  

! Band
Spring D--..V. ' r 1551-62 

! C o lle g e  Al- . -ra 
I Plane 1- . -n.virntrv

I ..apr,i 
,1 Dot 
■ Bnri.. 
i rv- , 
i i - “ '

c
?
c

( ?
c
>1

."resni.ar. -onpesition 
General ot-.ny

- D ra ft in ; '
-g  -nco
■Semester 1562-63 

1 Botany , j3
Trifononetry 3

History o f the US C
tor Products Indus D
" I o.t. Tor .Mensuration 2
'~ l f  ’• Tennis 3
.'a ll Semester 1963-61)
C- v y in g  

..organic Chemistry 
.■.oral Physics 
.ideology

. or .-'ire Prev ^Control 
c.' ic Probation I -

'.j.'.aral Chem istry  
-r.yin-.‘-a r in g  Problem s  
-a n e ra l  P iiysics  
Plana Trigonom etry
•• . HI U It. . I Iu Ij |*m rE

7 - 2 9 - t l i l
2-26-65

Scaoolf! 4-12-67
i-22-L7

>C

O k .P T

Hist 103b Survey o f C iv iliza tion  B
3 • Probatior* .Lraovoc 6- 2 -6 40 • Fall Z -TO;•Aar 19„u-o5
3 ' Hist 103a Aî Vr.y r ivilization C
C) Chen 2 1 !) ’ uant An . -'■■is C2 Hr.-l 20Ja Inplish . itarature D

Ch err, 
C: r.n

hh2
221

Kistorv o:
Ay.'IC."

:.-.~i 2ijb

'"ne.xir cry 
itirns

AiCadc:r.„c .-'rouatici. 1— 30-65 
Gorin* Homester 165!--65 
Hear. Ar. nv 1 Ar.cr L it

o;
3
0 , 
2 
1

3

\ r

0
1

3
li
)■
0
3

Lngl 253 T-ch r i t in a
Hut. 333 j  J _ . j
Spch 123 =i’h ' i ( -i :in g

101 g Miscelx.-.n. no Snorts
rath 123 A m ly t i r-.l fecgit- t ry

Probation B-o.noved 6 -H-
P’a l l  z.jr;ir£ t o r  1 9 6 5 -6 6

Chtdir* 30 i;a Organic Cb im istry

c
c
c
c
A
TT

It
2
h
3

Chem BOBa Physical Onenistry
Math 213 Calculus I
6 B 223 Intro to Business
Chem 2 31 Lab 0 1 ?, ssworking

r.caaf/.ic F ieb a t io n  1-22-66 
tipring -enester 15 6 5 -6 6  

Boom 3Q2*b Organic Chemistry
Cbe-m 606b Physical Cnemistiy 
r.it". l o j  Cdlu .-n A l.c b ra
.V.tn 223 Calculus I I
? -i 203 Health . S a fe ty

l’-1*-' .’.tinovccl 6—2-c>6
First Dv_-v,...-r Term 1966 

A.atr. 3 1 3  Ihociy of equations C.
Ccon 2Oja Price of ucononics c*

C
ii

l
b

I ioli<*iiili]f ills Jills.,;! I mil

(Vrtilk-.t

i.N ili«tl«*;ilt'<l.

• i I r ,  A r k .

0-1V-G7 
6-19-67

rtillcMj |«» lit* ;i fui'ivfi 1 j'.wist'rij.'

i An 11'— . 7̂  ,  X . /6 Vy

17.5

3
3
3
3
1
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3
3



Form AAM-6V4 1 M—7-65—59495—Ark P A L  Co.

A R K A N S A S  A G R I C U L T U R A L  A N D  M E C H A N I C A L  C O L L E G E
CO LLE G E  HEIGHTS. A R K A N S A S

Name.

Address.

KLU'IVS, Jamas Henry 

___________Card J 2_______

Date of Matriculation.

Dcgrec_

Date of Birth------------
Place of Birth-----------
Name of Parent_______

Date Granted- 
Major—  
Minor----------

RECORD O F HIGH S C H O O L  W O RK

Admitted on Credentials lroin:
( 1) ----------------------------------------------------- ------

( 2) --------------------------------------------------------
Memoranda

SUBJECT U NITS SUBJECT : U N ITS SUBJECT 1 U NITS
•

Total _

RECORD O F CO LLE G E  W O RK

DEPT. CAT.
NO. T ITLE  OF COURSE GR. 6EM . 

HRS. DEPT.

Math 353
Joao.vi Summer iem  1966 
Modem Abstract Alg I * 3 -

Ghent 312 Chemical Preparations A 2

Chen 413
Fall Senester 1966-67 
Adv Inorganic * c

Chem 323 Qual Organ Anal F 0 IChen 404a Physical Chem 4
Math 333 Calculus III 3
Math 493 Irtaep Study:Coll Gecm G 3 ‘

Math

Ac.

413

idcmic Probation 1-21-67,
iSpring Semester 1966-67 1 

Differential Equations ! 3
Geol 103 Geology 3
P E 123 First Aid A 3
Chen 493 Indep Stuc: Organ Qual C 3

T ITLE  OF COURSE

DF i<AN -C

r.you .v. c i i

IL JUjUtU: ja ; e

-31-67
IlonoraMc dismissal unless eontrary is indicate*..

Certified to he a correct transcript.

......$ -3 ’/_ / . r
(1 legist car)



SI*A
T

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1M—T-67— 137991—

Record of

AGRICULTURAL, MECHANICAL AND NORMAL COLLEGE
PINE BLUFF. A R K A NS A S

STUDENT'S PERMANENT RECORD

N-f-. J12.CZI__ Admitted So '-."Thor 8 .1 9 3 8

Home Address Route 1, 3cx 7-A - Sherrill, Arkansas
Graduated________ ! N y  " 3 ,  1 9 6 2  D -tiP «_________ f l «  S o

Major Business Education Minor Education

Birth v1V 19.1340 _£!?"__urkr-nsas_______________
Giurch Preference Member

Parent «>r Guardian 

Address

’ r .  '* ,rr a .  A1 irx Crorn___________ ________ _

Route 1 , - cr  7 -A -  S h e r r i l l ,  Arkansas

C O U R S E HOURS PER 
WEEK

u
a
<cc
o C

R
. 

PO
IN

TS

COURSE NO. DESCRIPTIVE TITLE ow
tc

ei
■X

i/l
a
X
SUJ

F a l l  S n e s t e r ,  1 9 5 8 - 5 9
?E d 1 1 1 p h y s i c a l  E d u c a t io n 2 l G l
Ed 111 O r i e n t  A  G u id a n c o 2 l a 2
Hun* 132 I n t r o  t o  H u m a n it ie s 3 3 c t

■Path 141 G e n e r a l  M a t h e m a t ic s 4 4 0 c
S c i 142 P h y s i c a l  S o i e u e e 3 •1 4 c
Eng 1 3 1 A E n g l i s h  C o m p o s i t io n 3 3 c 3

S p r in g  S e ise  s t e r ,  1 9 5 3 -5
\

Ed 112 O r i e n t  A G u id a n c e 2 1 A 5
PE d 112 P h y s i c a l  E d u c a t io n 2 1 c i
E i o l 1M B i o l  S c i e n c e 3 U h c K

132 E n g l i s h  ' 'o p p o s i t i o n 3 3 G A

: c . i 121 K y g ie n o 2 2 T>•» ?!■*
S S c i  V ’?. S o c i a l  S c i o n c o ' k D C

s u i iN R  s E S s io i r ,  1959
BEd 3 3 1 ‘ 15itSj-d>38 hfci/ 8 3 C 3
E du 3 3 1 Itvca G r th  t ;  D c v o lo p m e r i f i ,0 n

/
P e l l  S o n a s t o r ,  1 9 3 9 -6 0

I'h d 221 . - . y p o . . s i t in g w 5 2 D L
BEd 2 3 1 S h o r th a n d 3 3 A 9
IN d 2 3 1 H a th  o f  F in a n c e 3 3 C 3
E c o 231 P r i m  o f  R c o n o a ic a 3 3 D 0
S p a 21+L E l . ,  >. . r a i c h k >+ B 0

r  ■ H U  S - 'E S T 'A ,  1959-GC

S p a 242 4 4 3 8
M a th l* J -t • th  c ?  I ’ ’ n a n c e 3 3 C 3
B id 2 M2 P e e r  B rand 3 3 0 3
I . I d 2 .2 c i t i n g 5 2 B 4
I 'o o 232 -O-Ja.C i0 3  . . . 3 :3 D Q
/ / / / > / / / / / / / / / / / !  / / / / / ' /

C O U R S E

DESCRIPTIVE TITLE

.-dU
331
33S3

P A L IS

PrEC3LS.f?a.C'ia-l£jJf'
Hr.:?.u Gvc./th h  D ovaltp  
Ilia  t  A Fa’iU3 Soo Taduc 
SBI'ESTN, 1960-6\ 
OfTico Nachines

HOURS PER 
WEEK

Edu 231 Educationa l Psychology
2 3 1  "  ‘ -  -

BEd 3 2 1

KEd
Gao
HAdn
" : '3

'^ d

'du
Bid
Edu
Sco
Ai"h

T 2 5 ' 
223 

1 232
230 
332

420
421 
330 
240
231

r r / n

Business English 
Typo'.Titing 
Accounting 
Shorthand 
'GJJEIEI 1960-61 

■Siisty id  -.cation 
Human phy Goog 
Prir, of Accounting 
In tro  io L ite ra tu ra  
Shorthand

_ r  a  3i.y?3gi..n isjai-^a 
Audio Via I- jfc  
Omen i'a 
Tout A ".a c -S ao  
A merican In s t itu t io n  
Y N a v i- j tf C ra fts
/ / / / V  ///////

l

1 1 1

3
3

3

3

32
3

3

2
2

3 
3 
3

to
Z

O
<

Ol COURSE NO.
o

3 6 Eng 229
3 6 BAdra 434

tdu 460
C 3 / / / / /
B 6
D 0

C O U R S E

DESCRIPTIVE TITLE

SPRING ScAtSTiH 1961-62

1

1

0

4
6

/ .

Public Speaki’-g 2
Nath. Teach, Pus. Sub;) 3 
D irected  Teaching g

// G R A D U A T E D  /  / /

val Mo 
to o f ' 

<

Sum It ’ s E.-.ruodj 
.n cc rip tj S o

C  '

HOURS PER V/EEK

..cu B o i l s  G p h ip p u

2
3
G

/ /

0
12

/ ,

II-



KANSAS STATS TEACHERS CCLLSCk
RECORD SHEET 

fmm .-'iv-laad, “rl.nnsre

;:S

;• 2ci
tv.ro
7.0

4 .0
A . C'
1.0 
1.0. 
l.C
0 .  5 
1.0
1 .  C 
0 .5
V o *5

0  „ 3

Class: TU 
Years 1344

No____
Name._ ,JlTQhcr.,..£tJU ______fc_____ ________ Son.J/v

I*. O. lA ttJo.ilook...................... ...........  G-nuiit^"1®.?**

Dirth: DateP*"?.- S, 1520 |'|iu.,. England,

Parent (or Guardian), •'•Ito Arefrar ________ _______

Address: Street .2 '?  P '-c  . Par-tor.........

P. O .-A v-v?  } ’. v  ■ ■ ..............  .........State-

Date of Entrance..... Cesober Z C .  1 ....................

1 10.0 Graduation: Date......

■Mo-o o f  A .*• ’ • Second Setae vie;*, 1 ■" E-l'v 3
f.v ’ ’etrieo 3 C 234 Hist - ■ i.-.v

. 13-14
3. 3 203 B io l - -.'. ' 7. .1  'J o l - y
3 C, 330 Poy Aiua Pr-y jac lc  j r -

.'..onVfcion 4 D 142 Clan Gen Choral a iry

•T:.! .’’0 7 : d;i • crr.'tic s' "3 ~ C' CTL. ’ . "-•■••J5.CS■•a nr.l ■'•d'.nca-tioa Hr r. t ° ■ .r.o 7'‘■or, 1543-1.7.: * 11 i :vc -1 :■ .. r.-.lo- 3 T • ’•37b a-rir-.-; "-.r. a.C 7 .-15.47(01) 4 u *h*;r. •' t.... . ' ry
;A  ;; ' 4 0 •' i O J

Dr/w Gcr Hr/ ;ir;S Second Cere. ator, 1S43-? 04S:c rath CcaLkI' :o<. “Tatti 3. 3 420 Pay As;/ cf or.at .ty
1 0 110b n M-i Elen Vypoiny
3 D 333 Jour 2isic Jo r.-n. end Co;: '.:-1047 3 3 331 ? Ed Theory ol •csuotball?-v/s "'■" 'j .1 r3i03 <4)3 142 Ch ci Ganovcl 2/• Yrrorv - v. ' ■ v.isha T.ol Go-.srr* 3:- ■ - -y?^y ;.l . o»y — ■ Mr so Sursior T.t p, "Aero Civil •• •_• : : • ilatior.o 3 0 231 olol ii

Pi*!-/: ■ ~S~. 3 Course 3 r. Z> ZZ Kdu Visij 1 v"*::- •r-'-’

Coe r.d Sur-or Mr n. ” • •3 1 431
0 f £?C ? c y •--'Ilf-* ’ "C.. lory -V

Pirci 3o~.cct.ir, 194 3-1 A.VO
. - 3 0 423 11 ol ‘.ic. 71 c e /j Y'.v • :.icn

' • .7 ■ - • 5 0 233 3iol V,al .-.o ’ :.:-yo C .. Z o *‘co ■'ori-'l V'-.t. nlo~/./r 3 0 oC.O ’•: .A > __________
• • -rririr .*» t Tc c oe’Jn • ^ t’i ••or?”. ; story

Dejf re:*.. 1.

Answer to Interrogatories No. 31



PETIT!-'. . C.i XTV X. . LCT. SAT 0:- ;. .U U .n  VE « .  A 5C! COL 30.2 iD 1E'3E* 
i r  n c c c r d a r .c e  w i t h  S e c t i <  r. 8 0 -5 0 9  p e r t s r e p h  2 o f  T .r k e r .s * s  S c h e - . l  L a o s

t / 3 . d  ^

To the ’ hi-', j : you-fucker School Bo-.rdj

V.e, c l u-dcrsijTed electors o f the ?lu-< Bayou-Tucker Oohoel D is tr ic t  
i-o. 1, o f J e f f  fs  '!■ C- u t y ,  f b r s s ,  hereby cousert to the enpley.er.t 
o f CT--.tlT-.l hi iTtO.VT -iiKTT.it 'S or e -o1oyec o f the sohn l  d is t r ic t .

I ,  -~C I ' . !  -r V/> O  , 5o so le  ly  s’..e. r -ho- ti n fa  vc
t ie o c 'r s  •• 6:~‘s\:s <o ti c 'V .v «  - e t i t i  r. ir y prese: ce or uthorieed 
their ! ■ : es to a -l-.c-.-d there : ay c iv. th e ir  tores-, ce •. r<3 c e r t i f ie d  
th- t they re . l.-otrrs cu- l i f i . d  t; v c c  i r  eh.- u- 1 sch 1 e le c t !  r 

X  ... ’^7- k________'___________, 10C5.





2 4 . ■'



PETITION FOR THE EMPLOYMENT OF A RELATIVE OF A SCHOOL BOARD MEMBER 
in  accordance w ith  S e c t io n  80-509 paragraph 2 o f Arkansas School Laws

To the Plum Bayou-Tuckcr School Board:

VJc, the unders in;ncd e le c to r s  o f  the Plum Bayou-Tucker School D is t r ic t  
No. 1, o f  J e f fe r s o n  County, Arkansas, hereby consent to  th e  employment 
o f ANNETTE G. CROWN as an em ployee o f  the sch oo l d i s t r i c t .

1 #
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SION



IN THE UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF ARKANSAS 

PINE BLUFF DIVISION

LOIS THOMAS, et >1., PLAINTIFFS

V*.

THE BOARD OF EDUCATION 
OF THE PLUM BAYOU-TUCKER 
SCHOOL DISTRICT NO. I,
( f r i g h t ,  A rk a n s a s , a t  • ! . ,  DEFENDANTS.

ANSWER TO INTERROGATORIES 
PROPOUNDED TO PLAINTIFFS 

BY THE DEFENDANTS_____

Come the p la in tiffs  and for their answers to the inter­

rogatories propounded upon them herein by the defendants statei

Interrogatory Ho. 1. Is i t  the contention o f Mrs. Lois 

Thomas that she is a more highly qualified teacher than a l l  o f thu 

other ten (10) teachers mho were retained by the District? I f  

your answer is  yes, specify which o f the ten (10) teachers 

retained by the D istrict are less qualified than Mrs. Thomas and 

state in specific detail the basis for your answer.

Answert It  is not the contention o f Mrs. Lois Thomas 

that she is a more highly qualified teacher than each and every 

one of the other ten (10) teachers who were retained by the Dis­

tr ic t .

Interrogatory No. 2. You have alleged that Mrs. Evans 

has suffered damage because the D istrict placed her on the T itle  ]. 

payroll, although her salary was increased and she has acquired 

new and useful sk ills  beneficial to her teaching status. 8tate 

the specific damages which Mrs. Evans has incurred in reference 

to the D istrict placing her on the T itle 1 payroll.

Answert Mrs. Evans' contract states that she w ill be 

paid, " i f  funds are availab le ." It  is  the act o f the defendants 

in making her position subject to the ava ilab ility  o f federal 

funds, and thus removing her from the security o f the regular 

payroll that has damaged Mrs. Evans. Further, the D istrict has

CIVIL ACTION 

No. PB 69 C—46



refused to pay for the acquisition o f any new sk ills  necessary 

for Mrs. Evans to perform properly in her position as a T itle  1 

teacher. Mrs. Evans found it  necessary to expend her own money 

to acquire these necessary sk ills .

Interrogatory Mo. 3. Do you object to the standards or 

criteria  -utilized by the Superintendent and the Board o f Educa­

tion of the Plum Bayou-Tucker School D istrict Bo. 1 to objectively  

evaluate and to rank teachers so as to determine what teachers 

would be retained by said School District? I f  your answer is  

yes, specifica lly  state your objections to each standard or c r i­

teria so utilized .

Answert P la in tiffs  do object to the standards and c r i­

teria utilized by the Superintendent to rank teachers. It  is the 

contention o f p la in tiffs  that whatever criteria  or standards 

there were, were not applied objectively and evaluations were 

thus discriminatory. In addition the evaluator did not have a 

sufficient basis and experience viewing each teacher in order to 

properly evaluate. The evaluation factors are so limited, and 

each one so broad in scope, that they are not indicative o f any 

teacher's worth. Further, evaluation o f the persons closest to 

the teachers were ignored and the remaining evaluations lose 
whatever forcefulness they might have had.

Interrogatory Mo. 4i Assuming the standards or c r i ­

teria mentioned above in Interrogatory No. 3 were utilized and 

applied in a non-discriminatory manner, do you contend that they 

are basically  unfair or diacriminatory? I f  your answer is yes, 

state in deta il, in what manner, way, or particulars you con­

sider said standards or criteria  to be unfair and discriadnatory.

Answeri See answer to No. 3, above.

Interrogatory No. 5. You have alleged that the defend­

ants have allowed the physical fa c ilit ie s  at the Rosenwald 

School to deteriorate over a period o f years. In what particu­

lars were the physical fa c ilit ie s  allowed to deteriorate and i f  

this was a result o f certain damage, what appears to have caused 

the damage.



MSJ2££» Th® evidence which w ill show the defendants’ 

action in allowing the physical fa c ilit ie s  o f Rosenwald School 

to deteriorate are in the possession o f defendants. That is to 

say, the fa ilu re to nake capital ij^roveaents and necessary 

maintenance repairs are known to the defendants because o f their 

possession o f a l l  budgetary figures. More specifica lly , a to ile t  

fac ility  was not installed in the Rosenwald School Until the last  

year o f its  operation. A heating plant was not Installed until 

the last two or three school years. The school was not painted. 

Simple maintenance functions such as waxing o f floors was not 

done. This failure to make even the most basic o f maintenance 

repairs caused accelerated physical deterioration.

Interrogatory Wo. 6. You have alleged that the defend­

ants have required black children to s it  together in one part of 

a classroom and physically separate from white children. State 

the names and addresses o f the teacher or teachers who have 

imposed this policy and the date o f such imposition and the par­

ticu lar classrooms in which this policy was isposed.

Answeri Segregated seating was required by Mr. John

0. Porter, whose address is  unknown to the p la in t iffs . The 

seating was required during his tenure as a teacher.

interrogatory Ho. 7. You have alleged that children 

have been expelled from school without justification  by the 

defendants. State the name o f each child or the names o f the 

children which have been expelled from the school and the stated 

reason for such expulsion and the date o f each specific expul­

sion.

fensweri

1. Thomas Grant. School Year 1967-68, for not shaving.

2. Shirley Ann Strickland, School Year 1967-68, allegedly  

because of pregnancy.

3. Robert Johnson, School Year 1968-69, allegedly for mental 

deficiencies.

4. Murleen Grant, School Year 1966-67, reason unknown.

5. W illie Grant, School Year 1968-69, allegedly for insubordi­

nation.



6. Jirasy Paul Jones, School Year 1967-68, reason unknown.

7. Zlois Woods, School Year 1969-70, for various reasons, a l l  

known to defendants.

8. Troy woods. School Year 1968-69, allegedly for insubordi­

nation.

9. Several other children whose naaes and reasons for suspen­

sion or expulsion have been requested by subpoena fro* the 

school administration. Pull details are not known at this 

time by p la in tiffs  of a l l  suspensions and expulsions during 

the current school year.

interrogatory Mo. 8. Are you aware o f any applicant 

who was declined employment as a bus driver for the D istrict by 

the defendants a fter having made application with the defendants. 

I f  your answer is  yes, state the news and address o f each app li- j 

cant and the date o f his or her application and the date when 

said applicant was denied employment as a bus driver for the 

District by the defendants.

Answeri

1. Mildred Banks, Tucker, Arkansas, application. School Year 

1967-68, denial same year.

2. Cedine Morris, Tucker, Arkansas, application August. 1969, 

denial August 1969.

3. Boss Bryant, Tucker, Arkansas, application August, 1969, 

denial August 1969.

Interrogatory Mo. 9. You have alleged that black 

patrons are not allowed to v is it  elassroo*s in which their ch il­

dren are present. State in detail the specific occurrences upon 

which you base this allegation providing the names and addresses 

of parents who M rs  denied such v isitation  rights, the teacher 

who so denied said rights, and the naaes o f the children who were 

involved and the date o f the specific occurrence or occurrences. I 

Answert Mrs. Corine Woods was denied permission to 

v is it  the classroom in which her child was present in the Mall 

o f the school year 1966-67 by Jams K. Bradshaw.



interrogatory Mo. 10. You have alleged that the 

defendants have openly used the aoet offensive o f epithets, 

"nigger,* in reference to black teachers in open Meetings and in 

front o f patrons of the D istrict as well in private conferences. 

State the specific date and place or occasion When such epithet 

was used by defendants and the names and addresses o f the person 

or persons present when the epithet, "nigger," was so used by 

the defendants, and the specific defendant who used said epithet.

Answeri Janes K. Bradshaw uaed the offensive epithet 

in M arch . 1969, at a teacher workshop in Tucker, Arkansas at the 

Rosenwald School. He used the sane epithet a second tine in a 

meeting with the parents o f the nosenwald children in April.

1968 at Wright, Arkansas. Clyde Archer, a oeaber of the School 

Board, used the sane epithet in A pril. 1967, in a public meeting 

at Wright, Arkansas. He again used the epithet in a public 

meeting in Wright, Arkansas, in A pril, 1968, and has used the 

same epithet in public on several other occasions which cannot 

bo defined with more specificity  at this time.

Interrogatory Mo. 11. You have alleged that black tea- 

chers are not allowed the sans leave privileges as are white 

teachera. Specifically  state the names and addresses o f those 

teachers who have been denied leave privileges by the defendants, 

the grounds for the leave, the reason tor such denial and the 

date that the leave was denied.

Answen Mrs. Artie Davis was not allowed funeral leave

I

with pay, for a funeral she attended in September 1968. The 

reasons for the denial and the actual date of the denial are 

best known to defendants.



IN THE UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF ARKANSAS 

PINE BLUFF DIVISION

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Plaintiffs,)
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) PB-69-C-46
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Defendants*)

BE IT REMEMBERED, That the above-entitled cause came on 
fo r hearing on its merits before the Honorable Oren Harris, 

United States District Judge, in the Federal Courtroom, 

Federal Building, Pine Bluff, Arkansas, on February 8, 1971.

APPEARANCESZ

For the Plaintiffs: WALKER, KAPLAN, LAVEY & MAYS
Attorneys at Law 
1820 West 13th Street 
Little Rock, Arkansas 72202 
By: Philip E. Kaplan and

Ted Goodloe

O LENN H. PERRIN
Of f ic ia l  Co u rt  R rfortkr 

F ederal Bu ild in g  
EL. Do rad o . A rkanrar  t i 7Go

LOIS THOMAS; ASIVE THOMAS; 
LUCREASIA A. EVANS; ELOIS 
WOODS and TROY E. WOODS, by 
their parent and next friend, 
MRS. CORINE WOODS; ERIC 
DINWIDDIE, DONALD R. 
DINWIDDIE, RODNEY DINWIDDIE, 
and DARRYE HARRIS, by their 
guardian and next friend,
MRS. CORINE WOODS,

v.

THE BOARD OF EDUCATION OF THE 
PLUM BAYOU-TUCKER SCHOOL 
DISTRICT NO. 1, Wright, 
Arkansas, FRANK CONLEY, 
President; and JAMES K. 
BRADSHAW, Superintendent of 
Schools of the Plum Bayou- 
Tucker School District No. 1,



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For the Defendants: COLEMAN, GANTT, RAMSAY & COX
Attorneys at Law 
P. 0. Box 8201 
Pine Bluff, Arkansas 71601 
By: Jeff Starling

APPEARANCES (Continued):

Glenn H« Perrin, C.S.R, 
Official Court Reporter 
201 Federal Building 
El Dorado, Arkansas 71730

ii

GLENN H. PERRIN
Of f ic ia l  Co u rt  Reporter 

Federal Bu iu m im  
EL Do rad o . A rk an sa s  7 itso



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Opening Statement o f P la in t i f fs  • •
Opening Statement o f Defendants . •

P la in t i f f s ' Witnesses: Dr. Ctj. Rd. Rx, Rd. Rx. Court
James K. Bradshaw 12 99 I l l 116
Walter L itt le joh n 118 136 139 141 146 142 !
Neyland Hester 148 154 159 160 162 163
Jean Curtis Edwards 165 180 195 198 202 208 203
Asive Thomas 213 224 240 243
Lucreasia Evans 246 260 285 291 i
Lois Thomas 295 308 !1
Corine Woods 316 322 !

Defendants Motion to Dismiss I

Defendants' Witnesses: ii
James K. Bradshaw 329 — i
Althea Gordon 363 364 i
James K. Bradshaw — 376 427 433 443 438
B. E. Turner 445 453
Mildred B la ir 463 468
Clyde Archer 470 — (
J. B. Maynard 473 475
Frank J. Conley 476 478
J. W. Surratt 483 486

P la in t i f f s ' Rebuttal:
Jean C* Edwards 487 R* «R V j
Lois Thomas 491 492 495 496 i

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P la in t i f fs  Rest

a i-K N N  H. K R R IN  
O f f ic ia l  Co u rt  M fortcr 

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(Whereupon, at 9:37 a.m., February 8, 1971, the 

following proceedings are had, to-wit:)

THE COURT: Pursuant to the regular trial

docket, notice, the case of Lois Thomas, and 

others, as plaintiffs, versus The Board of 
Education of the Plum Bayou-Tucker School 

District No. 1, and others, scheduled for 

hearing at this time, that is PB-69-C-46. 

Gentlemen, are you ready to proceed?

MR. KAPLAN: Plaintiffs are ready, Your Honor.

MR. STARLING: Defendants are ready, Your Honor.
THE COURT: Mr. Kaplan, do you care to make
an opening statement for the record? I do 

not believe there is any information filed 

here with reference to Rule 9 compliance about 

what issues are to be taken up at this time, 

what has been agreed to, if any.
MR. KAPLAN: Your Honor, the parties have been able

to agree to drop several of the allegations from 
the Complaint. Plaintiffs will put on no proof 

and would wish to have withdrawn Paragraph 12 of 

the Complaint which alleges pi
OLENN H. PCKRIN  

Of f ic ia l  Co u nt  Wm ontbn 
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black and white children in classrooms; Paragraph 

16 of the Complaint, an allegation regarding 
visitation to the classrooms; and Paragraph 21 of 

the Complaint, an allegation regarding relatives 

working in the School District*

Further, the parties have been able to agree that in 

regard to Paragraph 13 of the Complaint regarding 

payment for texts that had originally been purchased 

with Federal funds, that that was apparently a 

mistake and that the persons who were required to 

pay will be reimbursed.
Those are the allegations which are no longer in

contention.
Briefly, regarding the other matters, this is 

basically a teacher dismissal case not unlike those 
heard by this Court before* That is, the plaintiffs 

allege that three instructors, Mrs. Lois Ann Thomas, 

Mr* Asive Thomas, and Mrs. Lucreasia Evans, were 

discriminated against by this School District. The 

method of discrimination and the form which it
I

took, the allegations regarding those vary slightly.: 

Thus, with regard to Mr. Thomas, we allege that at 

the conclusion of the school year 1967-’68, the 

failure to rehire him was discriminatory and that 

he was not hired because he was a black man who
G LENN  H. H M I I N

O m e iA L  C ount
P i m m l  Bu i l m w  

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______________________________________________________________________________ —  -I------—
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would have been the coach in the newly un ified

Senior High School inasmuch as he was the only coach j
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in the employ o f the D is tr ic t ,  and we w i l l  show, or i 

w i l l  attempt to show, that the D is tr ic t  indeed did 

engage in a ffirm ative  discrim ination against him.

In regard to Mrs. Lois Ann Thomas, the w ife  o f Asive 

Thomas, we a lle g e  that the next school year, ’ 68-'69 ,j 

she did--was employed but was not reenployed for 

'6 9 - ’ 70 when the en tire  system was u n ified , and that 

the c r it e r ia  as they were applied to her with 

d iscrim in atorily  applied. We make no a llega tion  

that the c r it e r ia  that were used were in and of 

themselves discrim inatory. We a lle g e  that they were 

d e fic ien t and that they were not complete enough 

and we a lle g e  that they were d iscrim in atorily  

applied but not that they were discrim inatory in 

and of themselves.

In regard to Mrs. Lucreasia Evans, we a lle g e  that 

although she is s t i l l  employed by th is School 

D is tr ic t ,  she is continuously being discriminated 

against in two regards. One, she is  not paid for 

the position  o f Health Coordinator, a position  she 

held for many years without compensation, and that 

a white teacher is paid for that function.

THE COURT: Now, what function is

O LKNN  H. PRRRIN
Of f ic ia l  Co u nt  Rn f o n iin  

F io w a l  Bu i lo in *
KL Don  a do , A r k an sa s  7t7*o

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MR* KAPLAN; Health Coordinator. Secondly, that 

she is currently employed on what is known as 

T it le  I p ay ro ll, she is paid by funds from T it le  I 

o f the Elementary Secondary School Act which funds 

are not as stable as the funds from the Minimum

Foundation turn-back funds from the s ta te , and that 

i f  there was a cutback in those funds,she is  subject 

to dismissal or subject to  non-renewal o f contract 

and that her position  is ,  therefore, considerably 

more tenuous within the D is tr ic t .

There are some few a llegation s o f discrim ination

as i t  applies to the da ily  operation of the 

D is tr ic t regarding attitudes o f the D is tr ic t  towards 

pupils , towards the administration o f the newly 

un ified  D is tr ic t .  Other than that, there are no 

a lle ga tio n s .

Counsel have been able to confer before t r ia l  

regarding matters subpoenaed by p la in t i f fs .  Counsel 

fo r defendants have supplied those matters for

inspection and have brought a l l  of those matters to

the t r ia l  so that they are ava ilab le  for use during 

the t r ia l .
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We have further been able to agree that certa in  

things are in issue and are not in issue, and during 

the course o f the proceedings I think that these

F rdkral Bu ild in g  
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prior agreements will make themselves evident and
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will substantially shorten the proceedings.
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THE COURT: Mr. Starling:

MR. STARLING: Your Honor, simply in an effort to
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inform the Court of some of the background of the 

School District and to elucidate the fact that this 

is in fact a teacher dismissal case, although there 

are other allegations which will be covered. The 

Plum Bayou School District No. 1 comprises an area 

of 5 3  square miles. It is a small rural School 

District. Prior to and after 1954, the School 

District operated a dual segregated school system. 

There existed the all-white Plum Bayou School,
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which is located in Wright, Arkansas, and which 

consisted of grades 1 through 12. There also 

existed the all-black Tucker-RosenwaId School, which 

is located at Tucker, Arkansas, and which consisted 

of grades 1 through 12, also.

THE COURT: All in the same district?

MR. STARLING: Yes, sir. The two communities,

Wright and Tucker, are approximately eight miles 

apart. These schools were, in fact, operated on a 

segregated basis both as to pupils and as to
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faculty. However, in 1965-1966, the high schools, 
in accordance with an HEW suggestion operated under

GLENN H. PERRIN  
Of f ic ia l  Co u rt  R eported 

Federal. Buildup*
EL Do rad o . A rk ansas  t i t m



a freedom-of-choice plan. And then starting with 
the school year 1966-1967, because basically most 

of the black students in the all-black Tucker-

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Rosenwald School, had exercised their freedom-of- 

choice to go to the a ll-w h ite  or formerly a ll-w h ite  

Plum Bayou High School, i t  was economically 

unfeasible to maintain the a ll-b la ck  Tucker- 

Rosenwald High School. As a resu lt o f th is , in the |

school year 1966-1967, the School District 

voluntarily unitized the high school and made the

Plum Bayou High School the cen tra l school s ite  and
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th is was to ta l ly  integrated as to high school

students and as to faculty.

THE COURT: What year was that?

MR. STARLING: 1966-'67, Your Honor. Today the
single high school, that is, the Plum Bayou-Tucker—

(
Plum Bayou High School is totally Integrated, and I 

do not believe that anyone has any questions or 

allegations in the Complaint in reference to that 

premise.

The Plum Bayou and Tucker-Rosenwald Elementary 

Schools continued to operate on a segregated basis j
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as to both students and faculty after 1965-'66;
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however, on March the 28th, 1969, the School 

District, upon recommendations from the

Pd id a i. BuiLDiMa 
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Superintendent and approval by the School Beard,

voluntarily, without the force of a court order,

but voluntarily voted to unitize the two elementary I
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schools with such unitization becoming effective 

beginning the school term 1969-’70. Upon a careful 

consideration based upon economic and educational 
reasons the Board voted to close the formerly all- 

Negro RosenwaId-Tucker Elementary School and utilize
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the Plum Bayou Elementary School as the central 

school site. Starting in the school year, 1969-'70, j 

the School District operated a unitized elementary 

school and a unitized elementary high school. As 

of this date there is no longer a black or white j 

school, but there is only one school which is
jtotally integrated both as to students and as to 

faculty. In 1969-'70, when the Plum Bayou Elementar^ 

School and the Tucker-Rosenwald School were unified,
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the inevitable problem arose which has consistently 
faced school districts throughout the United States, 

that problem being the necessary reduction in the 

elementary teaching staff. Although the plaintiffs
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have made many other collateral allegations, the
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central issue in this case is whether the Plum 

Bayou School District, in reducing its teacher 

staff, discriminated against one of the plaintiffs,
G LENN H. PERR IN  

Of f ic ia l  Co u r t  E l  outer 
Federal Ru iu m n s  

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Lois Thomas, in not renewing her contract for the 

school year 1969-'70.

Your Honor, I believe that in starting, Mr. Kaplan I
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and I have agreed that certain interrogatories, 

both those propounded by the plaintiffs to the 

defendants and both those propounded by the
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defendants to the plaintiffs which are filed with
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the Clerk of the Court, we would like those, of 
course, to be introduced into evidence and neither 

has any objection to the introduction of those
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documents, so they will be a part of the transcript. 

THE COURT: They will be part of the record.

Is there any issue, gentlemen, now with 

reference to utilization of certain of the 

facilities? The Complaint and the record
|includes objections to closing the Rosenwald 

School, and in view of what Mr. Starling has 

just said, that the high school at Rosenwald 

was closed beginning with the ’66-’67 school 

year, and the elementary school at Rosenwald 

was closed beginning with the *69-'70 school
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year, and the Complaint alleges certain 
derelictions of the School Board in maintaining 

the facility as it should and contends there 

are certain discriminatory practices
G LENN  H. P IR R IN

Official Court Rvo rtri 
Fkdsral Guildins 

EL Dorado. Arkansas titss



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in with reference to that facility. Is there 

s t i l l  any issue on utilization of the schools? 

MR. KAPLAN: Your Honor, because of the passage of

time and intervening events, we do not wish to have 

as a part of our prayer any relief which would 

require the reopening, remodeling, or usage of the 

Tucker-Rosenwald School as a school facility by 

th is School District. We may put on some slight 

b it  o f evidence concerning that facility as back­

ground evidence o f discrimination, but nothing more.

THE COURT: Very well, you may proceed.

MR. KAPLAN: Thank you, Your Honor. Mr. Bradshaw:

JAMES K. BRADSHAW.
ca lled  as a witness on behalf of the plaintiffs, being first 
duly sworn, t e s t i f ie d  as follows:

DIRECT EXAMINATION
BY MR. KAPLAN:

Q- Mr. Bradshaw, t e l l  the Court your name and address,
please.

James K. Bradshaw, Wright, Arkansas.

Mr. Bradshaw, what position do you hold with the Plum 
Bayou-Tucker School District?

Superintendent o f Plum Bayou-Tucker School District.

How long have you held that position?

A.

Q.

A.

Q.

OLJEMN H. PCRftIM  
Official. Court — w w  

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Bradshaw - D irect 

A. Since 1 9 6 6 - ' 6 7 .

Q. Did you hold i t  that fu l l  academic year?

A. No, s ir ,  the last--commencing April the 4th.
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Q. Who was the Superintendent immediately before you?
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A. James V. Anderson.

Q. And is i t  true that he unfortunately passed away during
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that school year?

A. That is correct.
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Q. And you took over the duties from him?
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A. Yes, s ir .

Q Had you already been employed in the district?

A. Yes , s i r , I  had.
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Q. And in what capacity?

a . I  h a d  worked as Physical Education teacher, Social

Studies, and acting as Head Teacher.

Q. At the —
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A. Plum Bayou-Tucker High School.

Q. A l l  r igh t. And that was at the school in Wright, is
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that correct?

A. That is true.

Q. A l l  r igh t. Had you also lived in the Wright community
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for some period o f time?

A. Yes, s ir ,  I  had.

Q How long had you actually taught in the Plum Bayou-Tucker j

School D is tr ic t?

O LCNN H. PCRRMM 
O m c iA L  Co u nt  Rn o u i  

F i o d u l  Bu h m m  
CL Do n aoo, A m u m m  ? i t n



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I have had 16 years' service in the Plum Bayou-Tucker 

School District counting th is year.

And have those 16 years been continuous?

Yes, s ir ,  they have.
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Prior to your assumption o f the ro le  o f Superintendent, 

in what areas o f endeavor did you possess your
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certification?
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I attended Arkansas State College o f Arkansas at Conway 

receiving a Bachelor's Degree. I  a lso attended Peabody 

College for one summer picking up approximately seven 

hours, and have also been in attendance to Arkansas
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iUniversity, F a y e tte v ille ,  one summer, and then I  attendedj
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a summer session at the Graduate Center in L i t t le  Rock.

And are you--do you have a c e r t if ic a t io n  from the
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State Department o f Education?

I  have a Master's Degree with approximately 18 hours in
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School Administration.

Now, prior to your assumption o f your duties as 

Superintendent, were you c e r t i f ie d  as Physical 

Education teacher o r--  

Yes , I was.
Where did you have your c e r t if ic a t io n ?  What f ie ld ?

My in terest was in Physical Education with a minor in

Socia l Studies.

And were vnu c e r t i f ie d  to teach in both o f those areas?

O LENN M. PCItNtM
O m c iM . C o u rt  K v o m a

n S M L  BUILMM
EL Do rad o , a m u n m  » i m



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B r a d s h a w  - Direct 15

A. Yes , s ir  , I was.

Q. In both o f them?

A. Yes, s ir .

Q. A l l  r igh t. And since that time have you been c e r t i f ie d  

with an Adm inistrator's C ertifica te?

A. I have gained 18 hours in School Administration which I 

am permitted to work in administration by the State 

Department in the size school which I am working.
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Q. R ight, in a small school d is t r ic t  lik e  th is ,—
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A. That is  true.

q. —“but you do not possess an Adm inistrator's C e r t if ic a te  

from the State?

A. At the present time I  do not have.

Q. Okay. At the time that you took over your duties as 

Superintendent, were there any black teachers at the
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school in Wright, and le t 's  r e fe r  to the former a ll-w h ite  

school as the school in Wright?

A. Yes, we did have. We had two.

Q. Who were they?

A. We had a Mrs. W ill is  and Miss Br<*m.

a And was that the f i r s t  year that they taught?

A. I  beg your pardon?

Q. Was the 1966-'67 school year the first year that they 

taught at the white school?
A. I  b e lie ve Mrs. W illis  and Miss Brown was there in__________

OUENN H. PCR  It IN
O ff ic ia l  Cou nt  R b p o n v u

PCDCMAL BUIUMMO 
EL. DONAOO. A  MCA MSA* T ITM



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1965-’66 school year.

What did they teach?
Mrs. Willis worked in the area of elementary education

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plus spent some time in library work. Miss Brown was 

employed as Commercial teacher.
Miss Annette Brown is a daughter of one of the School

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Board members, is that right?
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That is true.
Was she a School Board member at the time?

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At the time of her employment?
Well, at the time she went over to the Wright community,

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the white school, if you remember.
Yes, I believe he was on the Board at that time, and if 

I recall, Miss Brown came from the Wabbeseka School to
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the Plum Bayou School District.
Pricr to the actual unification of the high school, did

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you have any conferences with any of the black high

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school teachers concerning employment at the former white 

facility in Wright?
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Would you repeat, please?
Yes. Prior to the actual unification of the high school, 

which took place in 1966-'67, were you involved in any 

discussions with any of the faculty at the all-black 

Tucker School concerning their employment at the white

school? __________________
GLENN H. PERRIN

Official Court Wrpowtrr 
Pkdkral Building 

EL Dorado Arkanra* fitro



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A. Yes, I held numerous meetings with those teachers and 

discussed the unification of the school and—

a All right, now, we are talking only about the high

school, Mr. Bradshaw, I don’t want to mislead you, in

1966-'67. Is that the first year that the high school 

was unitized?
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A. That is true.
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Q. All right. Now, were you Superintendent prior to that 

time?
A. No, I was not.
Q. But did you have meetings with some of those faculty

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members?

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A. At the unification of the high school, no, I did not have 

contact with those teachers.
a I see. Now, at the unification of the high school, how j 

many black teachers came over to the Wright School, the
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all-white school?
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MR0 STARLING: Your Honor, I am going to object to

that line of questioning because I feel it is 
irrelevant and immaterial. There are no allegations 

in the Complaint concerning that any of the teachers j 
in 1966-’67 were discriminated against in reference 

to the unification of the high school. As I 
understand the Complaint, the only real allegations 

concerns the unification of the two elementary______
G LENN H. K M I N

Official Court R v o «m  
Fim ral Suildihs 

EL Dorado. Arkansas tits©



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schools which took place in ’68-,69 or the year
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' 69-'70.

MR. KAPLAN: Your Honor, the evidence sought to be

adduced here shows the flow of what happened to all

of the black teachers from the time that unification I

commenced in '66-'67, and it's our intention and

our feeling that all of this evidence will show

a pattern of discrimination against black teachers,
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and we have to start at the beginning, especially

here where it only goes back two years before the 

actual unification.

THE COURT: Well, there is a lot of information

in this record, Mr. Starling, with reference to 

the history and background, particularly on the 

interrogatories and answers thereto, which 

includes, [ think, beginning in 1965, and you 

in your opening statement gave historical 

background. I think the Court is going to hear 

it. Certainly will consider only evidence 

that's relative to whatever issue finally 

develops here.

MR. KAPLAN: Do you recall the matter before you,

Mr. Bradshaw?
THE COURT: What was the question, now?

At the unification in 1966-'67, Mr. Bradshaw, of the
GLENN H PERRIN

O f f ic ia l  Co u rt  R kfortsr 
Fkokral Bu il o in s  

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jhigh school, how many black teachers came from the former ! 

Tucker High School, Tucker-Rosenwald High School, over
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to Plum Bayou?
A. I believe at that time Mr. Anderson did have Mrs. Willis

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to come over.

Q. All right* And she was the Elementary School Librarian, 

Elementary School Teacher-Librarian, is that correct?

A. Right, she worked in elementary education and library.

Q. Did any high school teachers come over?
|A. Well, it is my understanding that Mrs. Willis was working j
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in the area of high school at the Tucker-Rosenwald

School.
Q. But when she came to the Plum Bayou School in Wright,

she no longer had any duties in the high school, is that

B r a d s h a w  - Di r e c t

correct?
A. As far as classroom teaching, no.
Q. All right. Did she have any other duties in the high 

school?
A. None other than working in the library.

Q. All right.
THE COURT: Who was this, now? Mrs. who?

THE WITNESS: Willis.
Q. Now, the next step in unitization of the school took 

place in what year? '69-'70?

A. '69 and ' 7 0 . _________________________________________

OLENN H. PERRIN  
Of f ic ia l  Co u rt  Reporter 

Federal Bu ild in o  
EL Do rad o . A rkambar t it r o



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Q. Now, did you, then, as already having assumed your i

duties as Superintendent, have conferences with the
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faculty at the Tucker-Rosenwald School concerning 
unitization?

A. Yes, sir, I did.
Q. Can you tell us when, to your recollection, the first of

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those conferences occurred, where it was, and what was
said?

A. Well, I do recall meetings held after the Board had
decided that the schools would be unitized,— I believe

jthis Board meeting was held March the 28th, 1969,— that 

the schools would be unitized, and that we would operate 

one elementary school, and at that time I did hold 

meetings with the teachers at both school sites and 

informed them that upon unification of the elementary 

schools that it would mean a necessary reduction in 
teacher force, that we did have 15 elementary teachers 

and that only 10 would be needed after unification of 
the schools.

Q. Now, let's talk about student composition in each of
these schools at the time of unification. Do you recall 

the approximate size of those first eight grades in that 

last part of the school year '68-'69 right before

unification?
A. I may not be able to give you accurate figure without

G LENN H. PERRIN  
Official Court E■porter 

Federal Building 
E L Dorado. Arkansas 7«tso

B r a d s h a w  - D i r e c t  20



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looking in my material, but I think in 1968-'69 there 
was 132 students at the Tucker-Rosenwald Elementary
School.

And they were all black, is that correct?
That's correct.

All right. Now, can you recall the figures at the Plum 

Bayou School, black and white? Would it help to refer 

to the interrogatories to refresh your recollection?

If you would permit me, let me find my figures here.
All right.

Now, you are wanting figures for Grades 1 through 8?
1 through 8.
At the Plum Bayou?
Plum Bayou School.

r ̂ -S^t, one second, please, sir. We had approximately
98 students.

In Grades 1 through 8?

That is correct.

And what was the approximate racial composition of those
students?

I would say probably 40 percent.

THE COURT: Forty percent what?

THE WITNESS: Forty percent Negro; sixty percent
white.

All right. And that year--
O LCNN H. PKRRIN

Official Cod ft IIp o f t w  
Pkdcral Builoim*

IL  Dorado. Arkansas tits



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THE COURT: What year was that?

MR. KAPLAN: ’68-*69.

Now, that was at the Plum Bayou School, is that correct?
That is  correct.

All r igh t. Now, total in your district for that year, 

•68-'69, what was the approximate black percentage?

In the D is tr ic t ,  I  would say approximately 85 percent,
80 to 85 percent.

Was black?

Yes, s ir .

A l l  r igh t. So that i f  you included the eight grades 

over at Tucker-Rosenwald together with the eight grades 

that were at Plum Bayou, the ultimate percentage would 

work out between 80 and 85 percent black—
That is correct.

- - in  those grades? What was the approximate size o f 

your black facu lty in those years, in that year in 
particu lar, in '68-'69?

I  b e lieve  we had at that particular time eight teachers 
at the Tucker-Rosenwald School.

And they were black?

That is  correct.

And how many teachers did you have in those grades at
the Plum Bayou School?

I be lieve  we had seven at that time,
OLCNN H. P tR R IN

Offic ial . Co u nt  R t r o r m i
WIOIKAL BU IUNM

I L  Don ado . A rk an sa s  t i t m

six white, one blacki



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Q. So then you had a to ta l in the f i r s t  eight grades o f 

15 teachers, nine of whom were black?

A. That is correct.

Q. A l l  r igh t. Now, when you told the teachers that there 

would be some requirement for consolidation of that 

teaching force, did you instruct them or inform them in 
any way as to haw that was going to be accomplished?

A W ell, yes, I met with the teachers and told them that 

we would need to come up with some type of evaluation 

form to be used in doing this.

Q. Did you discuss with them any form that you had in mind?

A. W ell, 1 asked the teachers at one particular meeting to

help me come up with certain criteria that could be used 

in doing this.

Q. Was that one o f your early meetings?

A. Yes.

a And was that in about March, late March or early April

of 1969?
A. Yes, s ir ,  i t  was after the decision to unify the two 

elementary schools.
Q. And did they supply you with any criteria?
A. Yes, sir, they did. In fact, at one of the meetings,

the Negro teachers at the elementary school, Tucker- 

Rosenwald, did suggest certain criteria to be used and 

c r it e r ia  which they felt would be fair.
eLJCNN H P IM IN  

Official Court W ciri' I  
Fidhial Suiubimd 

■L Dorado. Arkansas titro



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Bradshaw - Direct 

a Did you embody those in the criteria that you later did
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use?

a . Yes, sir, I certainly did. In fact, some of the criteria!
ithat the teachers suggested appear on the evaluation 

form which was approved.

a Now, had you spoken with the Principal or Head Teacher 

at the Rosenwald School about evaluations, also?

A . Yes, sir, I had.

Q. Who was that man?
i

A. Mr. Edwards.

Q. Was that Mr. Jean Edwards?

A . That is correct.
Q. And was he the Principal or the Head Teacher?

A . He was considered Principal or Head Teacher, 
a Now, did he also evaluate teachers on--using the written

formulation that year?

A. Yes, sir, he did.
Q. And did he turn that in to you?

A. Yes, sir, he did. I

Q. Do you have a copy of that?
II

A . My attorney has. j
Q. Mr. Bradshaw, I will hand you a document that has been 

marked for identification purposes as Plaintiffs'

Exhibit 1. Is that the form that Mr. Edwards gave to

you?_________________________________
GLENN H. PE R K IN

O rric iAL  Co u nt  W o n t—
P eocnal Ru iu m m n  

EL DONAOO. ANKANNAN TIT—



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Yes, sir, this is the form.

Do you recall approximately when he gave that to you? 

No, sir, I don't recall the exact time, but it was 

after--after March the 28th.
All right, sir. Did you later use the evaluation form 

that he gave you in making your own evaluations about 

various teachers in the District?
No, sir, I did not. I did look at the form, but I did 

not use Mr. Edwards' evaluation.

Is there any reason why you did not?

Yes, sir, there is several reasons why I did not.

Why didn't you?
Well, at first I thought perhaps this was the best way 

and not such a great burden would be placed upon me, 

but then I actually changed my mind and decided that I 
would not use this evaluation, and for these reasons: 

First, Mr. Edwards only evaluated the teachers within 

his school. He did not evaluate these teachers in 
reference to all of the other elementary teachers, which 

had to be done and only I could do. I was the one that 

was acquainted and had been in contact with these 

teachers over a three-year period of time, and it was my 

decision, me being the Superintendent, it was my 

ultimate responsibility for decisions of this nature, 

and I would take the blame for those teachers not being
a u m N  M PKRR IN  

Offic ial . Co u nt  R v o n t b i  
P ndcnal Bu ilo in o  

KL Don  ad o . A nkandan  t it *o

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B r a dshaw - D i r e c t I lb

re-contracted with, so Mr. Edwards knew nothing about 

the qualities or capabilities of the teachers at the 

Plum Bayou School, so he could not evaluate his teachers 

in reference to all of the elementary teachers in the 

Plum Bayou-Tucker School District, therefore, I was the 

only one in position to do ttis, so I assumed my 
responsibility as Superintendent in evaluating all of 

the teachers.

Q. Now, on the form, Plaintiffs' Exhibit No. 1— I am sorry,

did you conclude?

A. Yes, sir, I am through.
Q. On that form he does not purport to rank or evaluate

A.

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anyone at the Plum Bayou School, is that correct?

That is correct.

That has to do only with the Tucker School?

That is correct.

All right. Now, are you saying that you did not use 

his evaluation even for the purposes of helping you in 

your evaluation with that limited group of teachers?

I believe I made the remark that I did look at his 

evaluation, but I did not use it.
He had been the teacher that had been with them all year 

and for several years beforehand, is that correct?

Mr. Edwards had been employed there for I would say 

approximately five or six years.
O LKNN M. PK R M N  

O m c w L  Co u rt  Rv o m w  
F im m a l  Bu i u i m

■L. DOOAOO. A M U W M  71700 i



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B r a d s h a w  - D i r e c t I 27

Q. As Head Teacher-Principal?
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a. He had been there as Head Teacher, absent a year, and 

then had returned.,
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Q. Correct* Was absent to go into the National Teacher 

Corps., is that correct?

A. That is correct.
Q. On loan from the District?

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A That is my understanding. i
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Q. All right. And that was an arrangement that had been
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entered into with Mr. Anderson and that is why you only j
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have an understanding of it, is that correct?

A. That is correct.
a All right. Now, do you know, or did you ever ask Mr. 

Edwards if he had had, had in his possession, prior 

written evaluations of all of these teachers?

A I did not call for such.
Q. Did you know whether he had any?

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A I Hid not know whether or not he had made a complete 

evaluation of teachers prior to this or not.
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Q. Did you ever ask him?

A I did not ask him.
a Are the criteria that are on Plaintiffs' Exhibit 1 the 

same criteria that you used?
A No, sir. These are not the criteria which was submitted

to the Board and approved by the Board.
O LBNN M PERR IN

Off ic ia l . C o v e r  R e o r r m  
P bdsnal Bu i l w m  

EL  POOAPO. A R M N tM  7«T*0



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Bradshaw - Direct 28
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Q. Are these some o f the same c r it e r ia  that the black
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teachers suggested in the meeting?

A. These are s im ilar.
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Q. Mr „ Bradshaw, during the school year 1968-’ 69, the year 

in which these evaluations took place, how frequently 

were you at the Tucker School?

A. Now, le t  me ask--may I ask you a question?

Q. Of course.

a . Are you in reference to just v is ita t io n s  to the school 

or v is ita tion s  to the school prim arily for observation
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in the classroom?

a Well, I am interested in both, and when you answer the 

question w i l l  you t e l l  us which one you are re fe rr in g

to?

A. W ell, there is times when I  was in the Tucker-Rosenwald 

School three or four times a week, but I tr ied  to make 

i t  a practice to v is i t  these classrooms at leas t once 

a month prim arily to make classroom observation.
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Q. And how much time did you spend, to the best o f your 

re co lle c t io n , in each of the classrooms?
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A. I  tr ied  to spend approximately 15 minutes.
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Q. F ifteen  minutes?
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A. Yes, s ir ,  upon v is ita t io n  to the classrooms.

Q. When you went into the classroom, did you ever c a ll  for 

a lesson plan?

GLENN H. PERRIN
Of f i c i a l  Co u rt  Report —

F ed eral. B u ild in o  
EL Do r a d o . A r k a n s a s  7 1 7 * 0



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Bradshaw - Direct 29
A. Yes, I requested lesson plans from time to time.

IQ. Was it your normal practice to ask for a lesson plan?
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A. Yes, I would like to see primarily whether or not the |
teachers were following their lesson plans.

Q. Did you have a conference with the teachers at the times 
that you went into the class or immediately thereafter 
to discuss with them either what they trying to 
accomplish or what their objectives were or what they 
had actually done in that period of time?

A. I usually talked to Mr. Edwards from time to time after 
I made classroom visitations. As far as calling these 
teachers in every time I made a visitation, no, sir, I 
did not.

Q. Did you ever have any discussion with any individual 
teacher about anything that they were doing in the 
classroom or your personal evaluation of their perform-
ance?

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A. Well, I think at one time I did have a conference with
one teacher at the Rosenwald School concerning classroom I
activities.

a Any others--do you remember who that was?
A. I recall this being a Mrs. Dora Thomas.

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Q. All right. Now, you had an evaluation form that you 
used, also, is that correct?

A. That is correct.
GLENN H. PERRIN  

Of f i c i a l  C o u r t  R epoR i er  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  t i 7 so



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Q. All right. And that is contained in the interrogatories 
which are in this record, is that correct?

A. Yes, sir.
Q. Did you have the benefit of Mr. Edwards' evaluation form 

prior to the time that you made up your evaluation form? j 
A. Prior to making up my evaluation form?

i

Q. Yes, sir.
A. No, sir, I did not.
Q. And had you chosen the items which were going to go into 

your evaluation before you saw his items or had you 
discussed the items with him?

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A. We had discussed these criteria at the teachers' meetings; 
which I have already stated that we had held and that 1 
came up with, and then Mr. Edwards submitted his report
to me.

Q. Do you have a copy of the--

Bradshaw - Direct 30

A. Yes, sir.
Q. --evaluation form that you used?
A. Yes, sir, I do.
a All right. Would you tell the Court the factors or the 

criteria that you did use?
A. Yes, sir. Teacher Competency was one of them; Ability 

to Maintain Classroom Discipline; Teacher-Teacher 
Relationship; Teacher-Pupil Relationship; Cooperative 
with the Total School Program; and listed was the number

O L IN N  H. PERRIN  
Of f i c i a l  C o u r t  R v o n n  

F e d e r a l  B u ild im q  
EL Do r a d o . A r k a n s a s  t it r o



Bradshaw - Direct

i of years teaching experience in the District.
i

21 a Did you use the teaching--the number of years that a 

s j j  teacher had taught either in the District or his total

fi ;j

7

8

9 !
10

11
12

A.

Q.

A.

Q.

experience?

No, sir, I did not use that particular one.

All right. So that although it appears on the evaluation 

form, it did not weigh in any way in your mind, is that
correct?

No, sir, the only way that I would have used that one 
was the other factors resulting in a tie then I would 

have looked at the number of years teaching experience. 

All right. Now, did you consider that although the
13

14

15 A.

Rosenwald teachers had been at the Rosenwald School 
that they were actually a part of the same system?
Beg your pardon?

i

i

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19

20 

21 

22

23 !!

24

25

a

A.

a

A.

Q.

Did you consider that the black teachers who had been at 

the Rosenwald School, did you consider them to have been 

part of the same system and that their years, if they 

would have counted for seniority, would have counted just 
as much as any other teacher?

By all means, every teacher was a part of our system.

So that you then used five factors, is that correct?
That is true.

All right. Did you break these down in any way in 

evaluating them?
OLCNN H PERRIN

O f f i c i a l  C o u n t  R b f o n t w  
F e d e r a l  B u i u n i m  

» L  Do r a d o . A n k a n n a i  t i 7k



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Bradshaw - Direct 32

A. Yes. Under Teacher Competency"I took into consideration 
certain factors.

Q. What factors?

A. Such as ability to relate to the student, the teacher's I 

ability to relate to the student. Also preparation, 

which would take into consideration academic training, 

such as the transcript, naturally we would have to look j 

at that. Also certification, that would have to be 

taken into consideration. And such things as whether or j 

not a teacher was flexible or had initiative in the 

classroom, that would also have to be considered.

And then under "Ability to Maintain Classroom Discipline"j 

I think under there we would have to take into 

consideration whether or not the teacher had the ability 
to maintain control to the point where there was a 

mutual respect between students and students and teachers; 

and whether or not there was--the classroom situation 
was conducive to a learning situation.

And then under your "Teacher-Pupil Relationship", you 

would have to take into consideration whether there was 

cooperation between the teachers and whether or not there |
was— teachers were friendly towards one another. 1 felt

j

like that teachers should show an interest in what other 

teachers were doing, also sharing materials that were 

available for use, and by all means sharing the
O L IN N  H. PERRIN

Of f i c i a l  C o u n t  R npontnn

P k d in a l  Ru il o in o

EL DOKADO. AlHIAW A I T17NO



Bradshaw - Direct

responsibility within the school.

And "Teacher-Pupil Relationship", 1 felt like teachers 

should show warmth and love for each child that they 
are working with, also show an interest in whatever 
activity the child might be engaged in. There should be 

mutual respect between the teacher and the student, the 
student and the teacher, and there should be a confidence 
between student and teacher, teacher and student, and 

by all means I felt like the teacher should have empathy. 
And as far as the "Cooperation with the Total School 
Program", this I simply meant cooperation among teachers, 

teachers cooperating with the administration, the Board j
i

of Education, in trying to meet the objectives of the
I

school.
Q. Could you do that in your 15-minute evaluation of each 

teacher?
A. I beg your pardon?

Q- Could you do that in your 15-minute evaluation once a 
month of the teachers at the Rosenwald School?

A. Well, over a period of three yaara I think you could i
pretty well get some idea of how these teachers would
fit.

Q. And did you spend that 15-rainute period for the three- 
year period?

A. I said I spent on the average, sometimes I spent more
• L * N N  H. PCRRIN

Of f ic ia l  Co u k t  Rr o t w  
P u m h a l  Bu ild i mo 

■L. Don a do. A m a w m  t i t m



I

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Bradshaw -  Direct

than 15 minutes in a classroom. f
Q. But all three years?

i

A. Beg your pardon?

Q. All three years? |
A. Like I say, on the average I spent approximately 15 

minutes in the classroom on visitation.
I|

a I see. Now, let’s talk about one teacher in specific,

Lois Ann Thomas. Now, with Lois Ann Thomas, do you know 
what grade she was teaching when you first encountered i
her?

a. Yes, sir, at that particular time Mrs. Thomas was 

employed as a First Grade Teacher.
i

Q. Do you know what grade she had taught immediately before 

that or if she had taught any other grade?

A No, sir, I do not.
q. You do not know whether she had—

34

A. Unless it you will give me time, I will go back and find 
the number of years teaching experience that she has had

19 1ji20 Q.
21 |h !
22 f  A.
23 II Q.

24 ||
25

and then I can give you some idea.
Well, do you know whether or not she taught the Third

Grade?
I do not know.
And do you know whether or not she had, at the 
recommendation of any school official in the District, 

been switched from the Third to the First Grade■______
OLKNM M. W H IN

O m ciAL. c o u n t  R o o m
F B O t L  B U ILW M

n .  d o b a d o . a m u w m  t i t *©



Bradshaw - Direct- 35

5 i!

7 II

9 11
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1#
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A.

Q.

A.

Q.

A.

Q.
A.

Q.
A.

I  d o  n o t  k n o w .

A l l  r i g h t .  I  would lik e  y o u  t o  take a  look at P la in t i f f s ' 

Exhibit N o .  1, Mr. Edwards' evaluation, where he ranks 

"D isc ip lin e Within the Classroom" for Mrs, Lois A.

Thomas a No. 2. Perhaps before we discuss the sp ec ific  

evaluation, we ought to , for the record, discuss what 

the various numbers "1 ", "2 ", "3 ", "4 ", and "5" are in 

the r a n k i n g  system. And No. 1, I  take i t ,  is  the highest 

r a n k  you c a n  get, is that right?

Yes, that is correct.

A n d  that is  true on both Mr. Edwards' evaluation and o n  

your evaluation?
I

That is true.

A l l  r igh t. Now, Mr. Edwards ranks Mrs. Lois A. Thomas 

with a N o .  2 in “D isc ip lin e Within the Classroom". I
I

notice that you gave her a No. 5.

That is true.
i

I s  there some reason fo r that, s ir?

Yes, s ir .

Would you t e l l  us what that is?
i

This was based upon my personal observation and upon my 

classroom v is ita t io n  to Mrs. Thomas' room, I  found the
l

children were not w e ll-d isc ip lin ed  and that they were 

not paying attention  to the instruction , they were up 

out o f their seats moving around on several d iffe ren t

OLSNN H. PCRRIN
O rric iA i. Co u r t  R o o m u  

r n a t L  Ru il b iw  
BL  POMDO. A w u w m  T IT K



r  3 j e t  .1, - ! ) r ° '

1 Jr ' ' • 1. 1 I n } a id  t s  i s

2 r■C L  ̂ J v o i ’ r  ° x p e r

3 y a *'■ r p- •; , f ,j V £>

4 T f 1 t
i  ' — ?n u •- ■. ia 1 ,

5 k* h ' o I 1 o r i p e r i o d

6 c g , , t ° a c t " f*r w i l l  h a v i• 7 t" i-' nt w i 11 h a v  e  t K e i  r

8 a t r e t  i or t c  t h e  t y p

9 f t i "  i-n g  a t t h a t  p a r t i

10 N ov , t h e  r a n  k i n g  t h a

n t ■ <■ t w p * h e r  c l a s s

12 i -  *■ a t  vh a t  i t  ir, d i

13 ! /. T ' r
I

< , - p a n  my p e r s o i

14
\ i  p 1  i  n e i n  t h e  c 1

15
- y o u  a c m u - ’ t f o r

16 e v e r v  d a y r a n k e d  h e r

17 F r  in r  L pa  1 a r i  d e a d  T

• 18 W ° i 11 1 V Ol . r e p e a t  t h e

19 V p  s  . O p y o u  a c c o u n

20 t l' C ; - i n ' '  i m !  a n d  He

21

22

23

24

25

r e s u l t e d  i . i  t h e  1  ' > w e r  r a t i n g  t h e r e .

t K e i r  . s e a t - ?

’ i ,• i.

w o u l d  i n d i c a t e

h > o i  b u i l d i n g  e v e r . '  d a y ,  g a v e  h e r  a  N o .  2 ,  w h i c h  i s  

c  a - ' s  i d e r a h l y  b e t t e r  t h a n  t Ke N o .  b 1  w e s t  r a n k i n g  t h a t  

y o u  g a v e  h e r  f o r  d i s c i p l i n e ?

I ~ i g h t  a n s w e r  t h a t  Ln t h i s  r e s p e c t ,  t h e r e  i s  a  

• i i f t e r e r c e  b e t w e e n  Mr d d w a r d s  a n d  m y s e l f ,  a n d  i t  s

O L C N N  H P E R R IN  
O f f i c i a l  C o u r t  R k f o m t u  

FCOEIrai B u il d in g  
C L Do r a d o  A r k a n r a r  717BO 92,.



P r a  d s  h aw - D i r  e r t
_____ ' 7

1 i] • j c i t e  p o s s i b l e  t h a t  h e  o b s e r v e d  s o m e t h i n g  t h a t  I  d i d  n o t

2 oh s a r v e .

3 ^ K e l l ,  l e t  me j u s t  c  T r e a t  t h a t  s i t u a t i o n .  He g a v e  h e r

4
a *N o * 1 Ln d i s c i p l i n e  w h i c h  i s  t h e  h i g h e s t ,  i f  y o u  w i l l

3
t a k e  3 l o o k  a t  P l a i n t i f f s ’ E x h i b i t  N o . 1 ,  a n d  y o u  g a v e

«
h o r 1 - '•  * h a t  1  am t r y i r . & t o  g e t  a t  i s  h o w c o u l d

t h t a n w h o  i s t h e r e  e v e r y  l a y  g i v e  h e r  t h e  h i g h e s t

«
p a s t i l l e  r a n k i n g  a n d  y o u  w h o  w e r e  t h e r e  o n c e  a m o n t h  o r

9 so  a n d  ib s e r v e d  1 5  - L o u t e ?  g i v e  h e r  t h e  l o w e s t  p o s s i b l e

10 r a n k i n g .  How c a n  y o u  a c c o u n t  tor t h a t . 5

11 1  " i g h t  m s w e r  t h a t  in  t h i s  w a y ,  t h i s  i s  b a s e d  u p o n  my

12 1
p e r s o n a l  o b s e r v a t i o n  mi d i f f e r e n t  o c c a s i o n s ,  s e v e r a l

ipr^nt occasions when I entered the classroom, this
14 if- what I observed, and this resulte ! i n  the weak rating

15 !
| in "Classroom Discip l ine" .

16 jj
|l

**• ^  1 niJ consi ler ,  in raking your evaluation, that the

i7;; me; who j i 1 observe her constantly, was there constantly,

• hat given h e r  a "1" Die that have any bearing on your

19 e > a l u a t i on ?

20 M'1' . Kaplan, I believe I t e s t i f i ed  that I did not use Mr.

2i ;| Edwards ' eva Luat i in .

22 '• Or the "Teacher-Teacher Relationship" vou gave her a

23 "k".  i s  there sonetning i n  y nir observation with the

24 ither members of the taci l tv that have l e a d  you to

25 11
ij. _ .jj. ’ ’ '3r e deserve' t h e  n e x t  t tb.e lowest r a n k i n g ?

G L E N N  H P E R R IN
O f f i c i a l  C o u r t  R e po rter  f d

F e d e r a l  B u i l d i n g  ^
*L D o r a d o  A r k a n s a s  mto M



Rrad«haw - Oi ’-eci

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Ihis " V  r e p r e s e n t s  a l a i r  r a t i n g  w h i c h  I f e l t  my 

persona! o b s e r v a t i o n  o her, " T e a c h e r - T e a c h e r  R e i a t i o n -  

s h i r " >  I r<>i t  t h i s  w a s  a f a i r  r a t i n g  t o r  M r s .  T h o m a s .

11 h o w e v e r ,  w a s  t h e r e  a n y t h i n g  t h a t ,  w o u l d  i n d i c a t e  

t h a t  s h e  i e s ^ r v e d  ' r l y  t i e  n e x t  t o  t h e  l o w e s t  i n  h e r  

r e  1 a t  i n n  h i p s  w i t h  o t h e r  t e a c h e r s  i n  t h e  D i s t r i c t ?  W h a t  

w a s  i t  i n  h e r  r e l a t i o n s h i p  w i t h  o t h e r  . f a c u l t y  m e m b e r s  

t h a *  c a u s e d  h e r  t o  h a v e  s u c h  a  p o o r  r a t i n g ?

A s  t a r  a s  c  omip.g o u t  a n d  p i n p o i n t i n g  one t h i n g ,  t h i s  w a s  

b a s e d  o v e r  a t h r e e - y e a r  p e r i o d  a n d  i t  w o u l d  b e  r a t h e r  

d i f f i c u l t  t o  i o ;  h u t ,  " r a n k l y ,  on my o b s e r v a t i o n  a n d  my  

v i s i t a t i o n s  o v e r  t h e r e ,  1  j u s t  d i d  n o t  f e e l  l i k e  t h e r e  

w, ! ?  t h e  a s s o c i a t i o n  b e t w e e n  M r s .  T h o m a s  a n d  t h e  o t h e r  

c l a s s r o o m  t e a c h e r s  as  t h e r e  w a s  b e t w e e n  t h e  o t h e r  

t e a c h e r s  t h a t  w a s  t h e r e .

16 1
1

Do y o u  r e c a l l  M r s . T h o m a s  ' e m p l o y m e n t  h v t h e  H e a d S t a r t
il17 i Dr og r a n :

II

18 ll
y V p  i. T 1» •» <

19 Q. \ ̂  . -J a  » ' w a s  t h a t - - w h o  r u r o m m e n d e d  h e r  f o r  t h a t p o s i t i o n ?

20 h I e l i e v e  I m e n t i o n e d  t o  M r .  E d w a r d s  t h a t w e  w e r e i n

21 ; t-1 p ' o '  s m e  o n e t o w o r k  i n  t K e  H e  a  ! t a r t P r o g r a m .

22 'w- Who w a - t h a t . W h a t  l i d  t n a t  e m p l o y m e n t e n v i  s  i  on , w a s

23 i i a f t e r  s c h o o l h e t o r e  s c h  o o 1 , s u m m e r 7

24 - w a s  i u r i i e t h e s u m m e r .

251: D u r th e  s u m m e r . And w h i c h  s u m m e r  w a s t h a t ?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

Q U .r i n«



Bradshaw - D irec t 39
il

l ; j  A .

2 Q.

3 A .

4 Q.

5 A.

6 Q.

8

9 A.

10
I

11 !

12

13 Q.|
14 i| A'

15 - Q.
i

16 II

17

19

20 Q.

22

23

24 A .

25

Let me just--
Please cake all oi the time you need.
1 think maybe that might have been the summer of '68-'69. 
immediately before her last year, is that correct?
Possibly after her last year, I don't recall specifically. 
Now, to work in that Head Start Program, did it require 
any special talents, skills, or ability? What were you 
looking for?
Well, in this particular program we were working with 
pre-school children which primarily preparing them to 
make social adjustments. She was working with approxi­
mately three other people in this particular job.
And did she have a classroom of her own?
No, they worked as a group.
As a group. And were they doing things like skills with 
"Reading Readiness" and "Fine Motor Controls" and things 
like that to get children ready?
Well, they had various activities, I am not all that 
acquainted with the Head Start Program.
Now, is there some reason that you would accept someone 
for employment in that who you had ranked so low in 
both "Classroom Discipline" and "Teacher-Teacher 
Relationship"?
There was an application made by Mrs. Thomas. I don’t 
recall whether or not we had any other applications at

GLENN H PERRIN
O rr ic iA L  C o u r t  R eporter  

F e d e r a l  B u i l d i n g  

EL D o r a d o ___ A r k a n r a r  t i t i b



Bradshaw - D irec t 40

1

2

3

4 Q.

5 A .

6 Q.

7 A.

8 Q.

9

10

11

12

13
|i

A.

14
1!

15

i
16

17

i!
18

19

20
Q.

21 A.

22

23

24 Q.

25

that particular time and we did need approximately four 
people to work in this area; therefore, she was employed 
by the O.E.O. Office to work during this summer.
Didn't it have to have your recommendation and approval?
I submitted names to the 0.Eo0.
Was she qualified for that job?
I assumed that she was.
Can you account for--would you take a look at Plaintiffs’ 
Exhibit No. 1, Mrs. Cois Ann Thomas, Mr. Edwards 
evaluated her with a No. 1 on "Cooperative with the Total 
School Program" and you ranked her No. 4, the next to the 
lowest. How do you account for that?
I m ight--I might make this remark on that, that as far 
as being as cooperative as the other 15 teachers that 
she was compared with, that's the way I felt that she 
would rank in this. 1 do not feel like Mrs. Thomas was 
as cooperative as she could have been in respect or in 
regard to a Reading Program which was implemented in our 
school.
In what way was she non-cooperative in that program?
We specifically stated that these materials were to be 
followed and these materials were not always followed 
in this classroom.
Ann from where did you get your information concerning 
t h a t  and in what ways didn't she follow the accepted

GLENN H PERRIN 
O f f i c i a l  C o u r t  R i p o r t i *

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 3 0



Bradshaw - D irec t 41

2 A.

10

11

12

13

14

15

16 

17

18

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20

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.:3

24

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Q.

Q.

program or the outlined program?
Well, I visited the classroom, like I have already 
stated, that I was in the classrooms from time to time, 
and other materials were being used. If I may, let me 
explain this Reading Program or give you some idea of 
the Reading Program that I am in reference to. We 
implemented the Economy Company's Reading Approach, we 
had a representative from this company to meet with us 
in a Teacher Workshop which involved all elementary 
teachers, and he was the one who gave instructions that 
it was very important to strictly stick to these 
materials and not bring in these other materials until 
a later date, and we found that some of the teachers 
w q x q not following the instructions that had been given, 
and it was reported to me, and I observed this in some

of the classrooms.
And in particular her classroom?
Yes, upon observation in her classroom I did see that 
other materials were being used.
Did you ask her--
This resulted--this resulted in the "4 ranking, which

is fair.
I see. N:>w, did you ask her whether she had sufficient 
copies of Economy for her classroom?
Everv teacher was supposed to have sufficient number.

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a o o  A r k a n s a s  7 1 7 3 0 n a



Did you know whether or not the Tucker School did have 

copies of Economy in su f f ic ien t  numbers for their 

s tudents ?

Had they not, then the request should have been made to 

me through Mr. Edwards.

Did you consult with her in your evaluation or when you 

observed that she was not following the accepted program, 

did you ask her why and i f  she had the materials?

I did not ca l l  her out and lecture on th is,  but we did 

have meetings —

No, s i r ,  I didn’ t mean lecture her, I meant did you ask 

her why she was not adhering to the program?

No, s i r ,  1 did not. I f  I may be permitted to state th is,  

we did have meetings and reemphasized the importance of 

sticking to this material and the instructions which the 

representative of the Economy Company had given us.

But you didn t ask her whether she herself  or any of tne 

other teachers indeed in the D is tr ic t  at the Rosenwald 

School had had materials su f f ic ien t  for their  class?

I w i l l  repeat again, i t  they did not have, then the 

request should have been made known for materials through 

Mr. Edwards and Mr. Edwards would have been in contact 

with me.

Well, what I am trying to get at, Mr. Bradshaw, is that

when you observed def ic ienc ies  with any of these

GLENN H P E R R IN  
O f f i c i a l  C o u r t  R eporter  

F e d e r al  B u il d in g  
EL Do r a d o  A r k a n s a s  7 i7so



43Bradshaw - Direct , 0_ _  . . .  4 3
*1 teachers at Rosenwald, you d idn 't  discuss any of them

2 with the teachers, did you?

3 A .  I  usually talked to Mr. Edwards —

4 Q- I see.

5 i1 A. --from time to time
6 Q -  Would you take a look at your evaluation of a l l  of the

W teachers in the D is t r ic t ,  the 15 teachers in the
8 | '

Distr ic t?  Would you t e i l  me i f  any black teacher ranked
9 above any white teacher?

10 A .  I f  any black teacher ranked above--

1 1 ; j  Q- Any white teacher.

12 A. --any white teacher?

13 j j  Q -  Now, perhaps--yes.

14 i A. Yes.!
I S Q- A l l  r igh t .  Which one? Which one or ones?|
16 ! A. I think we w i l l  find Mrs. Gordon, Mr. Edwards, Mrs.
17 Evans, and Mrs. W i l l i s .

• Q- A l i  r igh t .  Now, l e t ' s  discuss for the Court's benef it ,
19

for the record's benef it ,  how the rankings were
20 achieved. How did you rank the teachers in the D is tr ic t?

21 A .  Well, I had the teachers l is ted  here by name, and by

22 going across, looking at each c r i t e r ia  which was l is ted

23 or. th is, and taking into consideration the things which

24

il should be considered in each c r i t e r ia ,  I  rated each

2 5  ’
-  - - -  i|j

' i

t e a c h e r  with a  number, “ l "  through "5M. I went on down

G L E N N  H  P E R R IN  ^  
O f f i c i a l  C o u r t  R e p o r t e r  - y j f c g j  J R  

F e d e r a l  B u i l d i n g

■ L  D o r a d o  A r k a n s a s  t i 7 » o  j  W jA



and went through each teacher doing th is, and a fter  each 

teacher had been rated, we to ta l le d — I then to ta l led  the 

points and ranked the teachers according to their points. 

Q A l l  r igh t .  And the lowest point to ta l  then became the 

highest ranked teacher, is that correct?

A. That's r ight.

Q- So that i f  you had a l l  " l ' s " ,  you would be No. 1 or

t ie  for No. 1 with someone who had the same ranking, is 

that correct?

A That is true.

Q- A l l  r igh t .  Let 's  just take a look at your ranking. Your 

f i r s t  ranked teacher is Mrs. Mildred B la ir ,  is that

correct?
i

A. Yes, s i r ,  that is correct.

Q- And she's white and she was the Principal of the 

Elementary School?

A .  She was considered the Head Teacher.

Q. She also taught, however, is that correct?

A. True.

Q. Did she furnish evaluations to you for the white 

teachers?

Bradshaw - Direct

A. She gave me her evaluation orally.
Q. No written evaluation l ike Mr. Edwards did?

A .  No, she did not.

A1l r ight .  The second ranked teacher was Miss Dye, is

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O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

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“T

Bradshaw - Direct 45
1
i that correct?

2 A. That is correct.

3 Q. How long had she been teaching in the District?

4 A. I believe Miss Dye had been with us for one year.

5 0. And that was her total experience, also, is that correct?

« A. That is correct.

• Q. Was she certified?

8 A. She had a degree.

8 Q. That is not what I asked you. Was she certified?

10 A. Yes, she is certified in Secondary Education.

11 Q. At the time ol this evaluation was she certified in the

12 subject she was teaching?

13 I A. Beg your pardon?

14
|| Q. At the time ot the evaluation was she certified in the

15 subject matters that she was teaching?

1« i a . She was teaching in the Elementary School, she did not

1 7 ! at that time hold an elementary certificate.

• a  Now, you said before that one of the factors that you

19 considered in "Teacher Competency" was whether a person
'•1 •

20 was certified to handle the material that they were

21 ji supposed to be teaching. Now, Miss Dye was not even

22 certified to teach in the elementary school, was she?

23 A. As far as holding a certificate which is issued from the

24 State Department of Education, she did not hold one for

25 elementary school, but when we take into cons

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Bradshaw - Direct 46

10

n
12

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li
li

la !!

17

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19

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2i ;

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her a b i l i t y  to re la te  to the students and get across the 

material which she is working with, I have never seen a 

teacher with that a b i l i t y ,  and then when I take into 

consideration academic background and training and look 

at these transcripts, we can consider Mrs. Wall an asset 

to our D is tr ic t  because she holds a transcript with 

approximately a 3.5 or 3.8, which is very good, which 

we are lucky to get a teacher of this ca l iber in our 

small School D is t r ic t .  We have never had a teacher with 

these qua l i f ica t ions ,  and she is an excellent teacher.

Q. Doesn't the State Department of Education say that to 

teach in an elementary school you have to have an 

elementary c e r t i f i c a t io n  and that there are factors, 

methods, courses, courses in dealing with young children, 

that do vary from secondary to elementary education and 

that is why they require a special elementary 

ce r t i f ica t ion ?

A . Yes, s i r ,  that is true; but, Mr. Kaplan, this is not as 

bizarre as i t  may seem to have someone with a high 

school c e r t i f i c a t e  working in the elementary. Many 

times teachers w i l l  get their degrees in secondary 

education and then find that their love is for the 

smaller children in working in the elementary school, 

and then once they have gone to work in the elementary 

school, they then proceed working toward r emoving those

GLENN M PERRIN
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F e d e r al  B u il d in g  
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defic ienc ies ,  which Mrs. Wall is doing at the present 

time.

'j.- And she s t i l l  hasn t done i t ,  has she?

A She is working toward removing the de f ic ienc ies .

Q. We LI, what 1 am saying is ,  now two years later she s t i l l  

has not accomplished the removal of those de f ic ienc ies ,

has she?

A. No, s i r ,  she has not.

Q. A l l  r igh t .  Well, that's--now, l e t ' s  take a look at your 

third ranked teacher.

THE COURT: Who is Mrs. Wall? 1 don 't--

MB. KAPLAN: Mrs. Wall is the former Miss Dye.

Miss Janet Dye married in the interim and has now 

become Mrs. Jan«t Wall, is that correct,  Mr. 

Bradshaw?

THE WITNESS: That is true.

Q ■ So when we speak in this record of Miss Dye or Mrs.

Wall,  we are speaking of the same person?

A. That is true.

Q. A l l  r igh t .  Now, your third ranked teacher is also white, 

Mrs. Keith, is that correct?

A. That is correct.

Q- A l l  r igh t .  Now, your fourth ranked teacher is Mr.

Edwards who had some eight years of experience in the 

D is t r ic t ,  is that correct?

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Bradshaw - D irec t



Bradshaw - Direct

A. That is correct.

Q. And almost a l l  of those years were as Head Teacher, is 

that correct?

A. He worked as Head Teacher and teacher,,

Q. And you evaluated Miss Dye, now Mrs. Wall, two positions 

over him, is that correct?

A. Yes, that is correct.

Q- I. see.

A According to the evaluation form.

Q. Uh-huh„ Now, I notice that Mr. Edwards received only a

"2" in "Teacher-Teacher Relationship". Is there some 

reason why he was, as Head Teacher and Principal,  not 

given a No. 1 rating in that regard?

A. Well, "2" represents a strong ranking in that, and as

far as pinpointing any one particular thing, I think

this would be a fa i r  assessment on this particular part. 

I could say Mr. Edwards was strong in his “Teacher- 

Teacher Relationship".

Q. But not strong enough for a No. 1?

A. There was con f l ic ts  at times, from time to time, between 

Mr. Edwards and a teacher.

Q. Isn 't  that absolutely normal and what you would expect 

from a Principal?

A. Yes, that is correct.

Q. It is ,  isn ’ t i t?

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Bradshaw - D irec t

A. That is correct

Q. Now, I notice that the only other "1" was for Miss Nancy 

Rosen who had only taught two years, or Mrs* Nancy Rosen. 

What position did Mrs. Rosen have?

A. Mrs. Rosen was teaching the Fourth Grade at the Plum 

Bayou Elementary School.

Q. And her rapport with the other teachers was such that 

she did rank a No. 1 but the Principal of the black 

school did not?

A. She got along real we l l ,  yes.

Q. Did she have a husband who taught in the D is t r ic t ,  too?

A. She did not.

Q- After Mr.--No. 4 ranking for Mr. Edwards, the next person 

is a Juanita Moore. Is she white, also?

A. She is white.

Q- A l l  r igh t .  And the No. 6 ranking was for Mrs. Althea 

W i l l is  who was a black teacher, is that correct?

A. That is correct.

Q- She had taught 34 years in the D istr ic t?

A. Yes. She has 34 years' teaching experience.

Q- At the time that she was evaluated in this fashion, 

weren't her duties almost exclusively  as Librarian?

A. She was working in the Elementary School and parttime 

Librarian.

Q. Well, could you evaluate for us the percentage o f  her

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EL D o r a d o  A r k a n s a s  7 1 7 3 0



soBradshaw - Direct
j. . --------------------------------------

time that she spent in Librarian duty and then in 

classroom duty?

A .  Approximately two hours or two periods was spent in the 

Library.

Q. And did she have her own class in the Elementary School? 

A .  Yes, she did.

Q. Her own Home Room?

A As far as Home Room, the upper elementary grades were 

departmentalized.

Q- And what did she teach?

| A. I think she was working in the area of Science, probably 

in Social Studies, and may have had a Reading class, 

jj Q- Was she teaching remedial courses in those?

i j  A. She was not teaching what you would c a l l  remedial.

Q- No. 7 is also white, is that correct,  Nancy Rosen?
i
i A .  Nancy Rosen, yes.

! Q-
i
!i

A.

Q. 

H A. 

Q.

A .  

il Q-

And she had taught in the D is t r ic t  two years. Was that 

her to ta l  teaching experience, also?

I believe that is correct.

No. 8, Art ie  Davis. Was Art ie  Davis black or white?

Mrs. Davis is black.

And she taught for three years and was your No. 8 ranked 

teacher?

That is correct.

A l l  r ight.  Now, 1 would l ike  you to again look at

G L E N N  H P E R R IN  
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F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 i 7 * o



P la in t i f f s '  Exhibit No. 1 and note that out of seven 

teachers, Mr. Edwards ranked her his f i f t h  teacher, and 

you have her the best of a l l  of the teachers that Mr. 

Edwards ranked.

A. There again there is just a d if ference between Mr.

Edwards and myself and i t ' s  possible that he saw certain 

tra its  and a b i l i t i e s  in these teachers that I did not 

see.

Q. Now, would you agree, Mr. Bradshaw, that as Principal and 

Head Teacher, the things that the Principal and Head 

Teacher, the man who is with them fu llt ime, sees, may 

have considerable weight and value in what that teacher's 

abilities rea l ly  are?

A. May 1 answer you in this way,--

Q. Well, can you answer me yes or no, and then explain?

A. Would you repeat your question?

Q. Certainly. Would you agree that the man who is the 

Principal,  the man who is with the teacher fu llt ime, 

that what he sees in the teacher, in a particular 

teacher, has considerable value and considerable weight 

in what that teacher's true value and true performance 

are/
A. I will answer that yes, that is true, but the thing 

about th is, Mr. Edwards only was evaluating seven 

teachers and we had 15 which had to be evaluated as a

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O f f i c i a l  C o u h t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n r a e  7 » 7 » o



Bradshaw - Direct.,

l \

2 !l Q.
3

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8 A.

9

10 : Q.

1 1 !

12 I

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14

A.

15

16

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20

Q.
A.

21 II Q.

22

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group.

That is exactly what I am getting to, Mr, Bradshaw. But 

i n  the fact of his evaluation of those particular 

teachers, of the ones that he is familiar with, his 

evaluation has considerable merit and probably more 

merit than anyone e ls e 's  evaluation, wouldn't you agree, 

i n  regard to those particular teachers?

Again, I did say that 1 had v is i ted  the classrooms, 1 

knew these teachers —

That is not my question, Mr. Bradshaw. My question is, 

in regard to these teachers, i sn ' t  his evaluation the 

best evaluation?

I would not say that his evaluation is the best 

evaluation, no, s i r ,  I w i l l  not say i t .

Whose would be better? Yours?

Because I v is i ted  a l l  teachers, I was acquainted with 

a l l  15 teachers, a l l  15 had to be evaluated as a group. 

I could not evaluate just the Negro teachers and just 

the white teachers , we had to be evaluated as a group 

and 10 teachers selected, the 10 most capable teachers. 

A l l  r igh t .  Now, we are talking about your statement 

just a moment ago with which you did agree that the 

Pr inc ipa l 's  evaluation would have considerable weight 

and would have considerable force regarding any teacher 

which he supervises. You s t i l l  agree with that , don■t

GLENN H PERRIN
O f f i c i a l  C o u r t  R i p o r t u  

f e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 i 7 » o



2

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Bradshaw - Direct 

you?

A. Yes, s i r ,  I agree with that, yes, s i r .

Q- A l l  r igh t.  Now, l e t ' s  take a look at just this one

inconsistency where he ranks Mrs. Art ie  Davis f i f t h  in 

the teachers that he had personal knowledge of ,  f i f t h  

out of a group of seven, and yet you have ranked her the 

highest teacher out o f  that whole group of seven teachers. 

Now, how do you account for that, s ir?

A Again, I say there is just a d if ference between Mr.

Edwards and myself, and i t ' s  quite possible he saw a-- 

d i f fe ren t  t ra i ts  and a b i l i t i e s  than I did.

Q. A l l  r i g h t „ And that those t ra its  and a b i l i t i e s ,  because 

he was the Principal, should have had considerable 

weight and considerable relevance, i s n ' t  that correct?

A . I am saying th is,  in reference to a l l  15 teachers, 1 was 

the only one in a position to evaluate a l l  15, because 

Mr. Edwards knew nothing about the a b i l i t i e s  or 

qua l i f ica t ions  of the teachers in the Plum Bayou 

Elementary School.

Q- A l l  r igh t .  But you never looked or never considered or 

gave any weight at a l l  to his evaluation, right?

A. I believe I t e s t i f i ed  previously that I did look at his 

evaluations but I did not use them.

Q- And gave them no weight at a l l?

A . 1 did not.

G L E N N  H P E R R IN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

Cl__Dow Ann__A a . . . .  . . _t . . . .



Bradshaw - D irec t 54

x ! Q.

2

3

4

i ,

fi A.

7 Q.

8

9

10 A .

11

12 Q.

13

14 i! .
II A'

15
a

16 A.

17 Q.

18
: A-

19
Q.

20

21 A.

22 Q.

23

24

25 A

All right. Now, let's look at the ninth ranked teacher. 
The ninth ranked teacher is Miss Evans. Now, Miss Evans 
is his--is Mr. Edwards'--who is a black lady and who is 
one of the plaintiffs here, is the first ranked teacher 
of Mr. Edwards, is that correct?
That is correct.
All right. Is there--can you now pinpoint for me any­
thing in Mrs. Evans' performance which would cause her 
to he ranked by you any less than Miss Artie Davis? 
Nothing more than this was my personal observation, this 
is how 1 felt that she ranked.
All right. Your tenth ranked teacher, Maxine Clark, is 
a white woman, is that correct?
No, she is not, she is a Negro.
Maxine Clark is?
Yes, sir.
A l l  r igh t.  No. 11, Miss Ramsey. Is i t  Mrs. Ramsey?

Yes, she is a white teacher.
A l l  r igh t ,  she is white. No. 12, Miss Gordon, a 20-year 

teacher.

She is a Negro.
Negro. All right. Now, Miss Gordon was actually
t e a c h i n g  elementary school at the time this was made, is 
that correct?

That is true.
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O f f i c i a l  C o u r t  R k f o r t k r  

P k d k r a l  B u i l d i n g

> 1 ___ D Q i



Bradshaw - Direct

1 {
- •

Q. But her c e r t i f i c a t io n  was as a high school Economics

2 Teacher, is that correct?

3 A. May 1 make this statement? The transcripts that 1 have

4 come up with, she has been issued two elementary

5 c e r t i f i c a t e s ,  but i t  is my understanding that at one

6 time she was c e r t i f i e d  as a high school Economics

• Teacher and had this c e r t i f i c a t io n  transferred from

8 secondary education co elementary education.

9 Q- Do vou know when that, was?

10 A. No, s i r ,  I do not.

11 Q. She was qua l i f ied ,  however, to teach as a high school

12 Economics Teacher, Home Economics Teacher, is that

1A || correct?
I

14 M A. To my knJ  --------------------------- O  > —”  * —  "  —  W  0

15 Q. When you unified, did you have need for a Home Economics

16 Teacher in the high school?

17 MR. STARLING: Your Honor, I am going to object on

• the basis again that this particular l ine of

19 questioning is ir re levant,  because Mrs. Gordon is

20 not a p la in t i f f  to this lawsuit and she has made no

21 , a l legat ion she was discriminated against in any way

22

23

in reference to being a Home Ec Teacher or not being 

a  Home Ec Teacher.

24 THE COURT* Well, 1 don t know just where Mr.

Kaplan is attempting to go in this line of

G L E N N  H P E R R IN  1
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F e d e r a l  B u i l d i n g  /  m
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B r a d s h a w  - Direct 56

1
1 'I questioning, and the Court has been listening

2 very carefu l ly  to i t  thus far, i t  appears to

3 the Court that you are trying to ra ise a

4 question as to the capabil ity  of the evaluator

5 more than anything e lse .  This witness is in

6 the kind of position, i t  seems to the Court

• at this time, of being required to answer your

8 questions comparing himself with Mr. Edwards

9 as the evaluator, and I don't know how this is

10 going towards your contentions here as to

11 discrimination, Mr. Kaplan. Sooner or later

12 !l you got to come to that point.

181
MR. KAPLAN: Your Honor, 1 respectfu l ly  disagree

14 with the Court, I think that is exactly the point

15 we are at now, that the evaluations in and of them-

i6 !; selves of this individual indicate and coupled with

17 P his responses to the questions here this morning
00rH

•
that the evaluations were in and of themselves

19 unfair and discriminatory.

20 THE COURT: Well,  1 know that is what you
i;

21 contend, but I don’ t think you are going to

22 have much success in getting this witness to

23 admit, to agree to i t .

24 MR. KAPLAN: Oh, I grant he w i l l  not admit i t ,

25 ij
--------- 1|.

j!

Your Honor „

GLENN H PERRIN
O f f i c i a l  C o o  f t  RworrM I  J  

F e d e r a l  B u i l d i n g  /  t  
EL D o r a d o  A r k a n s a s  7i7*o / # %



• V

Bradshaw - Direct

1ll
2

3

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5 1' Q.

6

7

8

9 A.

10 Q.

11 ! A.

12 :l

13 Q.

14 i‘
!| A.

is i;

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171;
i (

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il A.

19

20 Q.
1

21 jj A.

?2 Q.

22 A.

24

!|
29

THE COURT; That is what you are arguing, you 

keep on arguing with him about i t .  As I  said, 

again, sooner or la ter  you are going to have to 

come to that point.

Now, the bottom teacher, coming from the bottom, are a l l  

black, is that correct,  those teachers who have been 

scheduled to be rel ieved of their duties, your No. 15,

14, 13, and 12 teacher?

Counting from the bottom-- 

Counting from the bottom.

--we would have had f iv e  teachers that would have been 

re l ieved .

Were any white teachers rel ieved?

One.

THE COURT: Is Kidd white or black?

MR. KAPLAN: Black.

THE WITNESS: She is a black teacher.

There would have been one which would have been re l ieved ,  

one white.

And who was that?

Mrs. Ann Ramsey would have been released.

And why was she not released?

Because a fter  the evaluation had been made, she and Mr. 

Edwards informed me that they would not seek employment 

with the D is tr ic t  for the '69-'70 school year.

GLENN H PERRIN  
Off ic ia l  Court  R eporter 

Federal Building  
EL Dorado  A rkanrae  7 i7»o



ji Q. All right. Who was released, then?
!| A. Beg your pardon?
Q. Who was released, then?
A. Mrs. Lois Thomas, Mrs. Dora Thomas, and Mrs. Kidd.
Q. Now, directing your attention back again for a moment to

those meetings at the--with the black faculty members, 
did they take place at the Rosenwald School?

A. Yes, sir, they did.
Q. Did you have conferences with those teachers who were 

later replaced, or who were not rehired, I am sorry? 
i A. Yes, after the evaluation I did meet with these teachers 

and inform them that their contracts would not be 
renewed. I told them that if 1 could be of any help, 
feel free to call upon me, and I later sent a letter to 
them stating that their contracts would not be renewed.

THE COURT: Now, which teachers were these?
THE WITNESS: This is Mrs. Dora Thomas, Mrs. Lois
Thomas, and Mrs. Kidd.

Q Did you tell the teachers that they would have to be 
given tests, that all of the teachers in the District 
would have to be given tests?

A. Yes, sir, Mr. Kaplan, at first I considered the use of 
a written objective test, one which was to be prepared, 
administered, and graded by National Testing Service, 
because 1 felt like this would be fairest to all

GLENN H PERRIN
O f f i c i a l  C o u r t  R k f o k t k r  

F k d e r a l  B u i l d i n g

________________________________El nn.Ann -»i ../>

Bradshaw - Direct



59Bradshaw - Direct
— '

‘ i
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6 A.

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21 | Q.
22 A .

23

24 0.

I!

concerned and most certainly would have been the easiest 

for me, simply have all 15 teachers take the test and 

the 10 teachers scoring the highest would be retained, 

the five lowest would not be re-contracted with*
And what changed your mind?

Because of the objections raised on the part of the 

Negro teachers at Tucker-RosenwaId Elementary School*

And that is what made you change your mind, sir?

Yes, sir.

All right. Now, this school year, 1970-'71, how many 

black teachers do you have and how many white teachers 
do you have?

In 1970-'71?

Grades 1 through 8.

May I look in my records, please, sir?

Of course. Perhaps I don't mean 1 through 8. When you 

told me that you had 15 teachers right before the 

unification of whom nine were black, you were speaking 

of 1 through 8, were you not?

Yes, sir.

All right. That's what I want to know.

At the present time we have, in the elementary school, 
five black, five white.
And did have, in the elementary level, before the 

unification, nine black and six white, is that correct?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R b f o r t r r  

F c d c r a l  B u i l d i n g

________________________________ EL Dorado  A rkansas  t i t » o



Bradshaw - Direct 60

A .  That i s  correct.

Q. Okay. Now, has your D is tr ic t  been operating at a surplus 

each year since unification?

A .  Yes, in the past two or three years by being rather 

conservative and by there being a l i t t l e  increase in 

revenues being co l lec ted ,  we have been able to accumulate 

a l i t t l e  surplus in our funds.

Q. Now, I did ask you to bring with you a record of the 

revenues and expenditures of the D is tr ic t  in those 

years, is that correct?

A .  Yes, I be l ieve  so.

Q. Would you just read for the record what those revenues

and expenditures were for the years that they were asked? 

I am trying to find the number r ight now. I t ' s  No. 7,

Mr. Bradshaw, for the school year '68-'69 up through 

'70- ‘ 71.

A .  May take me some time to find th is.

Q. Yes, s i r .

A .  Expenditures and revenues for years *68-'69, '69 - ‘ 70, 

and December 30, 1971. In 1968-'69, Plum Bayou-Tucker 

School D is tr ic t  had an expenditure of $168,990.00 and 

a revenue and balances of $223,115.00.

Q .  N o w ,  t h a t  is w h a t  you t o o k  in , is that correct?

A. That is what we took in, plus a carry-over of money from

GLENN M PERRIN
O f f i c i a l  C o u r t  R b r o r t k r  

P r d r r a l  B u i l d i n g

1968-'69.



Bradshaw - Direct 61ji
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Q.

A l l  r ight.

In 1969-'70 school year, we had an expenditure of 

$132,711.00, with a revenue and balance amounting to 

$ 2 2 7 , 3 7 6 . 0 0 .  And then in 1970-'71, July 1 through 

December 30, we had an expenditure of $87,718.00, with 

a revenue and balance of $159,237.00.

Okay. Now, I also asked you to bring with you a l i s t  

of a l l  persons who had been paid from the T i t l e  I Budget. 

That should be Item No. 4, s i r .

As of this year, 1970-’ 71, would you t e l l  us who the 

black--I am sorry--who the T i t l e  I personnel are and 

what they do and then t e l l  us their race?

1970- 71 school year 7 

Yes, s ir  .

Yes, we have a Mrs. Art ie  Davis, who is a Negro, who is 

an instructor in the elementary school. We have a 

Lucreasia Evans, a Negro, who is a Remedial Reading 

instructor in the elementary school. A Robbie Keith, 

who is white, who is parttime Health Coordinator in the 

Plum Bayou-Tucker School. And then we have a Charlene 

Archer, who is white, and who is secretary and serves 

as bookkeeper.

Is she related to a member of the School Board, too?

Yes, s ir  , she i s .

A l l  right. Now, Artie Davis, the black instructor, does

OLENN H PERRIN
O f f i c i a l  C o u n t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

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she have a class of her own? Does she teach First Grade, 
Second Grade, or what?

Mr. Kaplan, in the Fourth, Fifth, and Sixth, we have our 

children split up on levels, we have placed these boys 

and girls on a level to where they can actually function, 

we ceased to teach them as a Sixth Grade group, because 

we found that some would be working on Third Grade level 

while others were on Sixth Grade level, but she primarily 

is considered, I think, as the Fifth Grade Home Room 
Teacher, if 1 am not mistaken.

And Miss Evans is the Remedial Reading instructor, is 
that correct?

That is correct.

Has she ever gone, at the expense of the District or 
Title I, to any kind of a reading institute?

Let me ask you a question, now. Are you in reference to 

reading institutes where she is going to get credit for 
this, college credit?

No. Let me go back a little bit. At the time that she 

was made a Remedial Reading instructor, and she has been 

one since Title l has been in effect in your District, 
is that not correct?

That is correct.

Who made the decision to make her Remedial Reading 
instructor?

GLENN H PERRIN
OrriciAL Court Reporter



Bradshaw - Direct 63

1 A. It is my understanding that M r .  Anderson selected Mrs.
2 Evans, and Mrs. Evans c  indented to go into this
3 particular program.
4 Q Do you know whether she had any special training or
5 qualifications for Remedial Reading?
6 A At that particular time and at the present time there are

9 no other requirements by the State Department of
H Education other than be a certified elementary teacher.
9 Q. Has she ever talked to you about acquiring any special

10 skills through institutes, non-credit or otherwise?

»!| A. Yes, Mrs. Evans did mention to me that she would like to
12 1 have her educational expense deferred by the District.
13 Q- And have you ever done that?
14

1 A. No, the District has not followed the practice of
15 deferring the expense for additional hours for the
16 !! teachers.
17 Q. And have you ever done or provided expenses, living

1 18w  II expenses or tuition expenses, for any white teachers to
19 attend any reading institutes?
20 A No, s ir , we have not.
21 ;| THE COURT: Are you going to be sometime yet
22

23

with this witness?
MR. KAPLAN: Yea, Your Honor.

24 THE COURT: I think perhaps we better take a
25

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break, then. We have been here a little over

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Bradshaw - Direct

an hour and a half. We will take a few minutes-- 

MR. KAPLAN: Yes, Your Honor.

THE COURT: if convenient at this time.

MR. KAPLAN: It is, Your Honor.

THE COURT: We will be in recess for about ten

minutes. You may step down during that time.

THE WITNESS: Thank you, sir.

(Whereupon, at 11*07 a.m., a short recess is taken; 

thereupon, at 11:23 a.m., the parties present as 

heretofore, the fallowing further proceedings are 

had, to-wit:)

THE COURT* Proceed, Mr. Kaplan.

MR. KAPLAN: Thank you, Your Honor.

BY MR . kAPLAi\ :

|i 0- Mr. Bradshaw, in 1969- 7C , is it true that the white 

persons on the Title L payroll were the same Robbie 

Keith, as Health Coordinator, the same Miss Archer or 

Mrs. Archer, as secretary, and a Danny Young, who was 

an instructor?
A Yes, they were on the Title 1 payroll, 

u And those were tne only whites, is that correct? 

a Yes, air, that is correct.
O LCNN H PERRIN

O f f i c i a l . C o u f t  R e p o r t * *  

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Bradshaw D irec t 65

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A i l  r igh t . And that the addition to the-—the only other 

person that we have not previously mentioned was Maxine 

Clark, who was a black instructor, is that right?

That was for the school year 1969-'70?

Right.

That is correct.

Okay* How long was Danny Young employed?

Mr. Young served as Science teacher for one semester. 

Now, can you t e l l  us why he is no longer on the T i t l e  I 

payro l l?

Because the T i t l e  I O ff ice  informed us that our Science 

P '̂^gram was no longer e l i g ib l e  to be financed under the 

T i t l e  1 program; therefore, i t  was a required subject 

to be taught by the ntate Department of Education and 

we had to remove this from our program*

I see. Now, in 1968--

THE COURT; Now, le t  me see about this. You 

had to remove I t  from your program?

THE WITNESS: Remove i t  from the T i t l e  I program--

THE COURT: All  r igh t.

THE WITNESS: --and put i t  back under the regular 

school program, finance i t  with our local funds.

THE COURT: I see.

Now, Robbie Keith, the year before that, in ’ 68-'69, 

was il'-c) ' he rtealth Instructor, is that correct?

GLENN H PERRIN
O p p i c i a l  C o u r t  R e p o r t e r  

P c d c r a l  B u i l d i n g  

E L  O n m n n ___



1 A. Mrs. Keith was placed under the Title 1 program as a

Bradshaw - D irec t

2 parttime Health Coordinator--
3 Q- 1 arn sorry, Health Coordinator.
4 A -  --during Mr. Anderson’s administration in 1965-'66 school
5 year.
6 Q- Now, she has been pard since then at the rate of
7 approximately $540.00 except for the first year, is that
8 correct ?
9 A  That is c irrect.

10 'u- And the . irst year she was paid some lesser sum, some
11 three hundred and something?
12 ! A .  Yes, sir.
13 Q- All right. But since that time she has been paid
14 : $540.00?
15 A .  Yes.
16 || Q- All right. Do you know if Mrs. Evans was ever a Health
17 Coordinator at her school?

i i
18 A I don't know if she was or not.
19

0, When it came time to consolidate, did you ever consider
20 Mrs. Evans for that position?
21 A .  Well, we only had one Health Coordinator at that time,
22 and after I carae--became Superintendent, 1 retained Mrs.
23 Keith as the Health Coordinator.
24 D- Do you know whether during the time that Mrs. Keith was
25 i|____ j|. Health Coordinator that Mrs. Evans was performing exactly

GLENN H PERRIN
Official Court Reporter /  v*«h 

Federal Building t  
EL Dorado Arkansas 7i7»n S  ftL



Bradshaw - D irec t 67

the same duties?

A. I did not know that *

Q. Have you ascertained anything in that regard since the 

time that this lawsuit was f i led?

A .  No, s i r ,  I have not.

Q. Have you asked Mrs. Evans about that?

A .  No, s i r ,  I have not.

Q- The f i r s t - - o r ,  in 19b8-'69, the only blacks on T i t l e  I 

were Mrs. Evans and a Teacher Aide named Odessa Davis, 

is that correct?

A .  I believe that is correct.

Q- And everyone e lse was white, and there were only two

instructors, a Mr. Klutz and Mr. Porter, is that correct?

A .  I f  you w i l l  permit m e ,  I w i l l - -

Q. Of course.

A .  --get those and give you accurate answers. May I read

through these?

Q. Of course.

A .  In the year 1965-'66, we had Mrs. Evans under the T i t l e  I 

program; Mrs. Ann Ramsey was also placed under T i t l e  I 

program for 1965-'66, who was white; Mr. James Henry 

Klutz, 1967-'68, who was white; Otis L. Archer, 1966-'67, 

wh' wa.̂  white; lames 0. fo r te r ,  at semester, 19--in 

September, 1968-'69, who was white, and was replaced by 

M r .  M a n n ,  f o u n g  at semester o f  '68-'69 school year, who

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F e d e r a l  B u i l d i n g  

E L  Do r a d o  A r k a n r a e  7 i7 »o



Bradshaw Direct

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w a s  w h i t e ,  Mrs. Artie D a v i s ,  i n  1 9 6 9 - * 7 0 ,  who I s  a  

Negro; Maxine Clark, 1 9 6 9 - ' 70, who is a Negro; 1970-*71, 

w e  h a v e  two people a s  teachers under the T i t l e  I program, 

Mrs. E v a n s  a n d  Mrs. D a v i s .  Those are the teachers who 

h a v e  been placed under the T i t l e  I program and the two 

that is presently employed under the T i t l e  I with T i t l e  1 

funds.

Mr. Bradshaw, is the T i t l e  I teachers paid from funds 

provided by T i t l e  1 o f  the Elementary-Secondary School 

Act, Public Law-- 

That is correct.

--Public Law 8910, is that correct?

True.
|

And the rest of your faculty is paid from Minimum 

Foundation, is that correct?

Correc t .

And that is a l l  en t ire ly  or basically  state-supported 

money, is that correct?

True.

A l l  r ight. Now, the contracts of the T i t l e  1 teachers, 

are they dependent on receipt of T i t l e  1 funds?

Yes, this is where their money comes from, the T i t l e  I

funds.

A l l  r igh t .  Now, i f  there are no T i t l e  I funds, what 

happens to those teachers?

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EL D o r a d o  A r k a n s a s  7 1 7 * 0



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A .  We would simply move these people back to the regular

school program and pay them from the Minimum Foundation

l u n d s .

Q. Do you have funds to do that with?

A At the present time we do have, i f  this was necessary.

Q. Have they been told that?

A .  I have not necessarily made the remark that we would do 

this, but i f  we w i l l ,  l e t ' s  look at Mrs. Clark, who was 

placed under T i t l e  1, 1969-'70 school year, she is 

employed for 1970-'71 under the regular school program 

which means she has been transferred from T i t l e  1 back 

to the regular program.

u. Mr. Bradshaw, did you have or has this School D is tr ic t

Bradshaw - D irect

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h a i  d  history o f  a t h l e t i c  e v e n t s ?

Y e s  ,  s i r ,  w e  h a v e .

A n  a t h l e t i c  p r o g r a m ?

Yes , s i r .

A n d  i n  w h a t  s p o r t s  h a s  t h i s  s c h o o l  s y s t e m  t r a d i t i o n a l l y  

c o m p e t e d  o n  a n  i n t e r s c h o l a s t i c  b a s i s ?

20 A . Basically two sports, basketball and baseball.
ii

21 ii Q. Was there such competition in the school year 1966-'67?

22 A. No, s i r ,  there was not.

23 Q. In n 6 - ' 6 7 ?

24 A. No, s ir .

2 5  ! Q. A l l r ight.  Had there been the year before that, b5- ’ 66?

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Bradshaw - D irec t 70

'll A . Yes, sir, there had been.
2 Q. All right. Now, that year there was still the dual
3 system in its entirety except for limited freedotn-of-
4 choice, is that correct, on the high school level?
5 A . That is true.
6 Q. Did you have a white high school coach?
7 A . We do not hire a person as coach, solely for coaching,
8 Q. All right. Do you have--
9
l A . --we employ--

10 Q. I beg your pardon, please continue •
11 A . --we employ a person to handle the Physical Education
12 [i and teach a portion of our Soc ial Studies.
13 Q.

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All  right. And did you have such a person in 1965-'66 

who was white?
T^at is c irrect.
Do you remember who that was?
Yes. James K. Bradshaw.

That was you?
Right.

A l l  r igh t.  During 19b6-'67--I beg your pardon, l e t ' s  

go back to '65-'66 again--was there such a person at

the Rosenwald School?

E m p l o y e d  t ■> e iach,--  

Yes , sir.
--1965-166?

GLENN H PERRIN 
O f f i c i a l  C o u h t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

« L  D o r a d o
17&



Bradshaw - D irec t

Q- Yes, s i r .

A. I don ' t  kn bw .

Q. In 66- 167, w a s  t h e r e  a c o m b i n a t i o n  P . E .  m a n ,  S o c i a l

S t u d i e s  t e a c h e r ,  a t  t h e  w h i t e  P l u m  B a y o u  S c h o o l ?

A. ’ 6 6 - ’ 6 7 ?

Q. 1 6 6  -  1 6  7 .

A. Yes.

Q. And who was that?

A. Myself.

Q. A l l  r igh t.  And was that the year you then assumed your 

duties later in the year as the Superintendent?

A Yes, t h a t  i s  c o r r e c t .

Q- A l l  r ight.  And who had your counterpart position as

P.E. instructor at the black school, do you reca l l?

A I believe i t  was in January, 26th or 28th, that a Mr.

Thomas was e m p l o y e d  o v e r  t h e r e  t o  h a n d l e  S o c i a l  S t u d i e s .  

Q- A l l  r i g h t .  And t h a t  is t h e  p l a i n t i f f  in t h i s  s u i t ,

Mr. Asive Thomas?

A That is correct.

Q. And be w a s  e m p l o y e d  s o m e t i m e  i n  J a n u a r y  o f  ' 6 7 ,  w h i c h  

w o u l d  m a k e  i t  s c h o o l  y e a r  ' 6 6 - ' 6 7 ,  i s  t h a t  c o r r e c t ?

A. That is correct.

Q. And he was employed as a combination P.E. instructor and 

Social Studies teacher?

He w a s  employed as a Social Studies teacher because we
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O f f i c i a l  C o u r t  R e p o r t e r  

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Bradshaw - D irec t 72
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do not have organized sports in the elementary school. 

Well, was he at that time a coach, was that where his 

primary f i e ld  of endeavor was?

I think perhaps he has a degree in Community Recreation, 

non-teaching, as his transcript reads.

Well, is he c e r t i f i e d  to be a coach in the State of 

Arkansas and Physical Education teacher?

I assume that he is probably c e r t i f i e d  at the present 

time.

Well, at the time--immediately a f te r  he was hired--at the 

time he was hired he was s t i l l  in school, is that 

correct?

That is true.

And he was finishing his last semester at an institu tion 

nearby, Arkansas AM&N, is that correct?

The f i r s t  semester that Mr. Thomas was employed, he was 

employed on a substitute blanket contract.

That's r igh t.  Now, a fter  the semester ended, we then 

would go to school year '67-'68, is that correct?

That is correct.

And then in that summer period he had graduated, is that
also correct?

1 believe that is correct.

And he was certified, is that correct?
I do not have in my possession his c e r t i f i c a t e ,  but 1

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g



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assume that he received his degree, but, now, as far as 

his c e r t i f i c a t io n ,  I cannot t e l l  you, other than I think 

he was c e r t i f i e d  for Physical Education only.

Q. A l l  r igh t.  Now, his degree does show that he has a

minor in both Social Studies and in the—Social Sciences 

and the Natural Sciences, is that correct?

A. No, s i r ,  that would be a c on f l ic t  in that, and the

evaluation of the transcript which is made by the State 

Department of Education. He does not have a minor in 

Social Studies according to the State Department of 

Education.

Q- A l l  r igh t .  He does not have minor which qua l i f ies  him 

for c e r t i f i c a t io n ,  is that correct?

A. Right.

Q- But he does have a minor which allows him teach one or 

two hours of Social Studies, is that correct?

A. I would assume that he could teach in this area but 

would be--the school would receive an advisement or 

warning.

Q. Now, did you ever ask him how many hours he needed to 

correct the deficiency?

A. 1 did talk to Mr. Thomas, Mr. Edwards and I  had a

discussion on this, and we knew that he was short in the 

area of Social Studies.

Q- Do you know how long i t  took him to make i t  up?
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Bradshaw - D irec t



Brad ;haw Direct

1 A

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To my knowledge, he has not made i t  up.

1 see. Have you--

1 have papers here to show that he is s t i l l  de f ic ient 

approximately 10 hours.

May 1 see those.

Yes, s i r .  I f  you w i l l  give me one second,--

Surely.

--1 w i l l  find i t  for you.

Now, keeping in mind this document, s i r ,  frequently a 

man who is c e r t i f i e d  in this state as a P.E, teacher 

teaches Social studies courses or General Science

courses, is that correct?

W el l , --

It s not uncommon in the state ,  is it?

No, s i r ,  i t  is not uncommon.

And in order to teach those courses and tor the school 

not to get an advisory warning, he does not have to have 

fu l l  c e r t i f i c a t io n ,  i s n ' t  that correct?

But he must return to pick up additional hours.

He must return to pick up additional hours?

Yes

A-L r ight.  Now, in school year '67-'68, Mr. Thomas

23 c ontinued in the employment of the

24 right

25  a

ii Yes.

> G L E N N  H  P E R R I N

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Bradshaw - Direct 75
ij Q.

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--at the Rosenwald School?

That is correct.

A l l  r igh t .  Do you know what subjects he taught and how 

many hours he taught them?

I do know that he was working in the area of Social 

Studies, I do not offhand reca l l  the number of Social 

Study courses or other courses that he was giving 

instruction in.

And in that period of time also did he teach any Health 

courses or anything l ike  that?

At the present time l do not r e ca l l .

A l l  r igh t.  Did you have anyone at the white school, at 

the Flum Bayou School, who was c e r t i f i e d  as a P.E. 

instructor-coach?

A t  t h a t  particular time and at this time we s t i l l  do not 

have anyone in the area of Physical Education in our 

elementary schools, we just do not have.

That is not what I am asking, I am asking in the whole 

Plum Bayou School do you have anyone who was a P.E. 

instructor in 1967-'68?

'67-'68?

That's r i g h t .  Your f i r s t  fu l l  year as Superintendent. 

W v - i l ,  I  w a s  L h e  only one t h a t  was tu l ly  qua l i f ied ,  fu l ly  

c e r t i f i e d .

A l l  r igh t.  To be a coach and P.E. instructor, is that

GLENN H PERRIN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

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Bradshaw - D irec t

1 correct ?

2 A. Physical Education, r ight.

A l l  r ight.  And to you knowledge, Mr. Thomas was also
4

fu l ly  qua l i f ied  to be a coach-P.E. instructor, is that
5 !; correct?

6  A . According to the le t te r  that I received from the State
7

Department, he was c e r t i f i e d  in Physical Education,
8  1 that is correct.

9 Q. And you do not need any additional c e r t i f i c a t io n  to be
10 a coach, do you?

11 ;j A None.

12 '  Q .
il A l l  r ight.  Now, in school year, the very next one,

13 '68-'69, did you resume competitive sports?

14 A( I '68-'69?

15 Q -

“ [ I  A .

Yes, s i r .

Yes, s i r ,  we did.

1 7 I I  a

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In the same two f i e ld s ,  basketball and baseball?

18 i l  A -
That is correct.

19 Q. Okay. So for two years you operated without competition,
20 is that correct?

21 |j A . That is correct.

72 Q . Te l l  us why you withdrew from competition, s i r .

23 A. Well, for this particular reason, at that particular
24

time, as you know, we had integrated our high school in
25 |

1966- '67, we f e l t  l ike we were well  in advance for a
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GLENN H P E R R I N

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progress made in this d irect ion , our surrounding schools 

had not done this, and we f e l t  that i t  would be best to 

not engage in competitive sports with the other schools 

for a year or two until  integration had been better 

accepted, and this was done. We resumed our competitive 

sports with other schools without incident, which we are 

quite proud of.

Q. Did you send a le t te r  to the patrons of the D is tr ic t

explaining to them why you had withdrawn from competitive

sports ?
A Seems l ike I r eca l l  some remarks being made as to why 

we were not.

(Whereupon, a document is shown to counsel for the 

defendants. )

MR. STARLING: I have seen i t .  No objection.

Q. Mr. Bradshaw, I hand you a document that has been marked 

P la in t i f f s '  Exhibit No. 2 for id en t i f ica t ion  and ask you 

i f  that is the le t te r  that was sent bearing your 

s ignature?

A. Yes, this is my signature.

Q. And are those reasons the accurate reasons why and the 

reasons that the Board had in mind why interscholastic 

sports were discontinued?

A. That is correct.

Q. A l l  r igh t .  Now, item No. 2 in that categorization--there

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  Dorado Ar k a n sa s  T1710

Bradshaw - D irec t



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Bradshaw - Direct

are only two items--says something about the school f e l t  

--says exactly the school f e l t  that interschool sports 

should be discontinued unti l  a later date, decision is 

based on the prevention of incidents between Negro and 

white in our community. Have you ever had an incident, 

or did you subsequently upon resumption ever have an 

incident?

A. Well, l e t  me re la te  this to you, I be l ieve  i t  occurred 

in 1965 or '66 during the summer, we had an integrated 

Youth Corps., and i t  is my understanding that there was 

some c o n f l i c t ,  in fac t ,  as far as there was blows 

exchanged between the two groups, and this is the type 

thing which we were trying to prevent, and I  think we 

successfully prevented this by discontinuing competitive 

sports, because these things are—brings con f l ic ts ,  

bu i l t  up tension, and we f e l t  that i t  was best to wait 

unti l  this thing was better accepted, which i t  has been, 

we have reinstated i t ,  and we have done so without 

inc ident.

78

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Now, in 1968-*69 when you reinstated i t ,  who was your 

coach?

1968-169?

Yes „

We employed a Bruce McConnell, I  be l ieve i t  was, in

1968-’ 69.

GLENN H PERRIN
O f f i c i a l  C o u r t  R k p o r t k r  

F i d c r a l  B u i l d i n g

E L  Dorado Arkanrar t i t «



I

1 i i  Q‘ Did he serve as Basketball Coach?

He served as Social Studies teacher and Physical 

Education teacher,-- 

Q- Did he serve--

--he, indeed, with his Physical Education, he did coach

Bradshaw - D irec t

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on his own.

A l l  r igh t .  But he did coach—did he get paid for i t?  

Well, he was employed as a Physical Education instructor 

and Social Studies and was paid a salary.

Yes, s i r .

We tr ied to put in a few extra dollars for the extra

coaching.

Well, were you able to do that for him because of his

duties as Coach?

I believe we have a policy which states that teachers 

performing extra duties or additional work may draw a 

l i t t l e  additional funds, true.

How many years had he taught at that time?

That was Mr. McConnell’ s f i r s t  teaching experience other 

than his supervised practice teaching.

I see. For the record, is Mr. McConnell black or white? 

Mr. McConnell is white.

Did he also coach the baseball team?

He did, yes.

How many hours—how many hours do you have, classroom
GLENN H PERRIN 

O f f i c i a l  C o u r t  R k f o k t c d  

F c d c r a l  B u i l d i n g

_ ________ EL D o r a d o ___ a . . . . . * .  . . . .

79



Bradshaw - Direct

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hours, during the day?

W e  have seven periods.

Of the seven periods, do you know how many Mr. McConnell 

spent in Social Studies?

Yes, he was assigned two. In 1968-'69, he was assigned 

two Social Study courses.

And how many P.E. courses? The rest  of the day?

Four.

Four. And then one Study Hall?

One o f f  period.

Off period.

W e  try to give our high school teachers-- 

And did he work for you in '69-*70?

T h a t  i s  c o r r e c t .

And in *69-'70 how many Social Studies courses did he

teach?

H e  taught one course plus one Study Hall and four 

Physical Education classes.

During a l l  of this period of time from '65 r ight up 

through today, have you ever been in "A" status with 

the State Department?

No, s i r ,  we are working toward that c la ss i f ic a t ion .

You have always been on “B-Waming" or "B-Advisory", is 

that correct?

Right.__________________________________
GLENN H PERRIN  

Of f ic ia l  Cou rt  R eporter 
Federal Buildino  

EL Dorado  A rkanrar  vitro

80



Bradshaw - Direct 81

Q- A l l  r ight.  Now, when you resumed, then, your competitive' 

sports, your Coach and P.E. instructor in the high school 

was white, is that right?

A That is true,

Q- Is there some reason--did you know in the--during the 

end of 1967-'68 school year that you were going to 

resume competitive sports?

A. Would you repeat that, please?

Q. Did you know at sometime during the end of ’ 68--I am 

s o r r y - - '67-*68 school year that the next school year 

would see a resumption of competitive sports?

a. Yes, we had given i t  consideration.

Q. When had you made your decision, you know, your basic 

commitment to go ahead and return to the basketball 

scheduling and baseball scheduling?

A. Well, things had smoothed out, integration had been 

accepted in our schools, and I  recommended that we 

reinstate i t .

Q. Do you r e c a l l ,  to the best of your a b i l i t y - - I  rea l ize  

i t ' s  a long time ago— to the best of your a b i l i t y ,  

approximately when in the '67-'68 year you made that 

commitment or decision?

A. I think i t  was during the summer of *67-’ 68.

Q- Was Mr. Thomas--

THE COURT: Now, what summer?
OLENN H PERRIN

Official Court Reporter 
Federal Building 

EL Dorado, abkanrar t i t m /  37-



Bradshaw - Direct

2 a

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THE WITNESS: Summer of '68.

And that was before the year ’ 68-'69?

Before that school year commenced, true.

Who did the scheduling at that late  date?

I beg your pardon?

How did you get scheduling at that la te  date?

This is done usually during the months of July and 

August.

For the next year?

True.

A l l  r igh t .  Now, was Mr. Thomas ever considered for that 

coaching job?

No, he was not.

For the P.E. job?

No, he was not.

Why is that?

Because--may I g ive you the reason why Mr. Thomas was 

not retained with the School D istr ic t?

Yes, I would l ike  that.

The reason that Mr. Thomas was not retained in the Plum 

Bayou-Tucker School D is t r ic t ,  I  considered him as a weak 

Social Study instructor. Since he was teaching Social 

Studies, he was not fu l ly  c e r t i f i e d  as a Social Studies 

teacher, I discussed this with Mr. Edwards, and Mr. 

Edwards agreed that he was weak in this area, and I  did

OLENN H PERRIN
O f f i c i a l  C o u r t  R p o r t w

F i o u a l  B u i l o i n s  

EL Dorado Arraii. . .  ■



Bradshaw - Direct

11| not fecotnmend to the Board that Mr. Thomas be reemployed

2 for the upcoming school year.

3 Q- As a Social Studies teacher?

4 A. Right.

5 I Q. Now, my question--
II

6
THE COURT: Now, what year was this?

THE WITNESS: This was for the 1968-’ 69 school year.
8 Q- Now, at that time that you recommended that he not be
9 retained as a Social Studies teacher, you did know that

10 his f i e ld  was Physical Education, did you not?

11 1 A- True.

12 Q- Now, what I am asking you is ,  you were to resume
13

Physical Education and competitive sports for the next
14

year, why was he not considered as the P.E. teacher-Coach?
15

A. Because our D is tr ic t  has never hired an individual so le ly '

16 for the purpose of teaching Physical Education or
17 ! coaching.

18
II Q- Now, Mr. McConnell taught f iv e  periods or four periods

19
o f --

20

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A. Physical Education.

21 || Q- --Physical Education, and when you reported his status
22

to the State Department of Education on the form for 

School D is tr ic t  Employees, you reported him as a p.E.

24 j teacher, did you not?

25

|

A. True.

GLENN H PERRIN
Official. Court Reporter i  Ŵ M  J  \  

Federal Builoino 9  m L  W  
CL Dorado Arkansas tit bo 1 / m k



84Bradshaw - Direct
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And that was his duty, primary duty, was P.E. teacher? 

P„E. and Social Studies.

A l l  r igh t .  P.E. and coaching, and that is the way you 

reported him to the State, is that right?

But we l i s t  him as a Social Studies teacher.

No, no, to the State you l i s t  him as a P.E. teacher,

do you not?

In our annual high school report we must l i s t  each 

teacher showing what courses they teach, and he was 

l is ted  as a Social Study teacher and Physical Education,

yes, s i r .

A l l  r igh t .  But his primary duty was Physical Education, 

i sn ' t  that correct?

Yes , that 's  true, because he did spend four years of 

study in the area of Social Studies and Physical 

Education.

And you l i s t  him--are you familiar with a report called 

Data Concerning Employees of Local School D is tr ic ts ,

sir?

Yes, s i r ,  I am.

A l l  r igh t .  Now, that is f i l l e d  out every year for a l l  

school d is t r ic ts  l i s t in g  every person employed by the 

d i s t r i c t ,  their c e r t i f i c a t io n  or non-cert i f ica t ion , and 

what they teach and how much money they make, is that

correct?

GLENN H PERRIN
O ff ic ial  Count  R eporter 

F ederal Building  
EL Dorado  A rk an sas  t i » »



Bradshaw - Direct 85

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A- That is correct,.

Q- Now, for '68 - ‘ 69--these reports are prepared by the local 

school d is t r ic ts  themselves for submission to the State, 

is that correct?

A True.

Q- Now, for '68-'69, the year in question here, you did l i s t  

Bruce McConnell as a P.E. teacher, did you not?

A. True.

Q- A l l  r igh t .  And that was what you considered him to be 

primarily, isn ' t  that correct?

A. True.

Q- A l l  r igh t .  Now, he also had duties, two hours a day, 

as a Social Studies teacher, is that correct?

A. That is true.

Q- A l l  r igh t .  Now, you had at the same time persons in

your D is t r ic t  who were completely non -ce r t i f ied , i s n ’ t

that r igh t ,  in '68-'69?

A .  I think perhaps we might have had one.

Q. A l l  r igh t .  Let me re fer  you to Mr. James Henry Klutts ,

K - l -u - t - t -s ,  the gentleman you spoke about previously.

At that time he had an emergency c e r t i f i c a t e ,  d idn 't  he?

A. Yes, Mr. Klutts was employed to teach Math. In gett ing 

his degree from A S M  College, he had not planned to 

enter into the teaching profession--

Q- Well, what I am interested in —

GLENN H PERRIN
O w i c u l  C o u n t  R p o n t u  

F e d e r a l  B u i l d i n g

___________________________________EL D o r a d o  A r k a n e a e  7 i 7 » o



86

A. May I continue?

Q- I have no objection to your continuing at a later time 

with counsel, I am interested now in bringing out the 

fact that he was not c e r t i f i e d ,  is that correct?

A. He was working on an emergency c e r t i f i c a t e  because he 

did not have his education hours,--

Q. A l l  r ight.  Now,--

A. --which he did get.

Q. Now, when was the f i r s t  year that he was employed?

A. I would have to check.

Q. Please do. For the record, Mr. Bradshaw, Mr. Klutts is 

white, is he not?

A. That is true. I believe 1967-'68 was Mr. K lu t ts1 f i r s t  

year as teacher.

Q- And what kind of a c e r t i f i c a t e  did he have that year?

A. Mr. Klutts held a B.S. Degree with emergency—with an

emergency c e r t i f i c a t e .

Q. A l l  r ight.  Now, that emergency c e r t i f i c a t e  causes you 

to have less than an "A" rating, does i t  not?

A. There are several things to be considered which would 

prevent the school from being MA“ rating.

Q. You can't possibly have one when you have even one single 

non-cert i f ied  teacher, is that correct?

A. I am not so sure of that.

Q. In 1968-'69 he s t i l l  d idn 't  have a c e r t i f i c a t io n ,  did he?

G L E N N  H P E R R IN  
O f f i c i a l  C o u r t  R c p o r t u  

F e d e r a l  B u i l d i n g

E L  POWAPO ARKAN«A« 7I7»Q

Bradshaw - D irec t



A. He was working for i t .

Q- Is the answer that he did not have i t?

A. What was the year?

Q. '68-'69, his second year in the D is t r ic t .

A. That is correct.

Q. In "69-'70, his third year in the D is t r ic t ,  did he have 

i t  yet?

A. I believe his c e r t i f i c a t e  was--the emergency was l i f t e d  

from his c e r t i f i c a t e  in the end of that school year.

Q. So that a fter  three years in the D is tr ic t  he f in a l ly  had 

his emergency status l i f t e d  and he went to fu l l  status, 

is that right?

A. That is true.
Q. A l l  r igh t.  Now, l e t ' s  go back to Asive Thomas again at 

the end of the school year, '67-'68. Was he ever 

considered for the job of P.E. teacher--

A. He was not.

Q. --in the Plum Bayou District?
A. He was not.
Q. Why wasn't he?
A. Because for the past 16 years, I have been with the

D is tr ic t  for the past 16 years, and 1 know in fact the 

individual that has been employed as Physical Education 

instructor has handled a portion of the Social Studies, 

and this is the reason that Mr. Thomas was not

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o  A r k a n s a s  7 1 7 3 0

Bradshaw - D irec t  37



considered because I considered him a weak instructor 

in the area of Social Studies.

Q- And that's  primarily because he was not c e r t i f i e d ,  is 

that right?

A .  Primarily.

Q- A l l  r igh t .  Did you ever ask him how long or how soon 

i t  would take him to complete his fu l l  c e r t i f ica t ion?

A. No, I did not ask him.

Q. Did you ever check with the State to see how many courses 

he could s t i l l  teach, even uncert i f ied, without warning 

to the D istr ict?

A -  No, I did not.

Q- Now, you do know that you can, as a P.E. teacher, teach 

a limited amount of non-P.E. subjects and s t i l l  not 

cause your D is tr ic t  warning, do you not?

A .  May I give you this information? I f  you are working on

an emergency c e r t i f i c a t e ,  I believe the State requirement 

is th is, that a teacher must pick up six additional hours 

to enable them to have this c e r t i f i c a t e  renewed enabling 

them to teach the following school year.

2- Well, 1 am asking you now about a teacher who is teaching 

on a regular c e r t i f i c a t io n ,  one hundred percent 

legit imate and proper, as a P.E. teacher, he is s t i l l  

allowed, even though non-cert i f ied in another area, to 

teach a limited number of courses without any harm to

G L E N N  H P E R R IN  
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F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 * 0

Bradshaw - D irec t



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the D is t r ic t ,  is he not, as long as he has some kind of i 

minor in that f ie ld?

Would you repeat your question?

Yes, s i r .  A P.E. instructor is allowed, is he not, by 

the State Department of Education, to teach in an area 

where he has not enough hours for c e r t i f i c a t io n  but has 

some hours without causing the D is tr ic t  to suffer any 

i l l  consequences?

Well, you are going to be advised and warned by the 

State Department, true.

After how long?

One year.

A l l  r igh t.  Did you ever consult with Mr. Thomas about 

how many hours he needed at that time or whether he 

would be w i l l in g  to get them?

I bel ieve I answered that I had not consulted with Mr.

Thomas.

A l l  r igh t.  Now, i f  he were hired, i t  would have meant 

that the Coach in the high school would have been Mr. 

Thomas, would i t  not?

May I answer that in this way?

Yes, s i r .

I am not so sure that Mr. Thomas would have been a good 

instructor in Social Studies had he been fu l ly  c e r t i f i e d  

in Social Studies.

GLENN H PERRIN 
O f f i c i a l  C o u r t  R b p o r t k r  

F c d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n r a r  7 1 7 * 0



Bradshaw - d i r e c t 90

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Well, that is not what my question i s .  My question has 

to do with who was going to be the Coach. I f  he had 

been hired to be the P.E. teacher, he would have been 

the Coach, would he not?

That's true.

And that would have meant that the Coach would have been 

black in that school, is that correct?

That is true.

A l l  r i gh t .  Mr. Klutts continued to work three years in 

the D is t r i c t  on emergency c e r t i f i c a t i o n .  Was there any­

one e lse  who worked on less than f u l l  c e r t i f i c a t i o n  in 

that School D is t r ic t?

In what year?

In any of the years, '66-'67, or ’ 65- ’ 6b, the f i r s t  

year you had freedom-of-choice , through to the present, 

s i r .  I think I did ask you to  bring some records with 

you, and whatever information you have.

I  h a v e  t h e  ' 6 7 - ' 6 8 ,  6 8 - ‘ b 9 ,  ' 6 9 - ' 7 0 .

That w i l l  be f ine .

In 1 9 b 8 - ' 6 9  and ' b 7 - ' 6 8  year, we had a Vo letta  Chavis 

with an emergency c e r t i f i c a t e .

Was she white or black?

She was white.

What did she teach?

I b e l ieve  this was the fourth Grade.

G L E N N  H P E R R IN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL Do r a d o  A r k a n s a s  7i7>o



Bradshaw - D irec t

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'II,

And that was in what year, sir?

196 7- ’ 68.

A l l  r ight.  And she taught at the Plum Bayou School in 

Wright, Arkansas, is that correct?

That is true.

A l l  r ight.

James Henry Klutts in 1967-‘ 68 with an emergency 

c e r t i f i c a t e .  A Hunter Douglas, who also taught In 

‘ 67- ‘ 68, with an emergency c e r t i f i c a t e .

And where did he teach and what?

He was handling Social Studies and Physical Education 

at the Wright School.

And he was white?

That is true.

And he did not have a fu l l  ce r t i f ica t ion?

He did not.

What was his status?

Social studies and Physical Education.

I apologize, 1 didn't mean that. Did he have emergency 

or 90-hour?

He did have emergency c e r t i f i c a t e .

A l l  r ight.

‘ 67- ’ 68, Mr. Asive Thomas, emergency c e r t i f i c a t e .

A l l  r ight.  Is that a l l  lor '67-'68?

That is true.

G L E N N  H P E R R IN  
O f f i c i a l  C o u r t  R k p o r t m  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n e a e  7i7So



I

Bradshaw - Direct

A l l  r igh t .  So that of the people you mentioned, i t  was

2 Chavis, Klutts, and Douglas, white, who were white
3 persons, and Mr. Thonas, is that correct?

4 A . That is true.

5 ■ Q. Now, for ‘ 68-'69, would you t e l l  us?

6 A. 168-169, James Henry Klutts. That is a l l .

7 Q. For ‘ 69- ’ 70?

8 A. James Henry Klutts.

9;i a Do you have the records for 1970-'71, or do you know of

10>i
i||

your own knowledge?

11
1 A- Were those subpoenaed?

12 a I do not think so.

13 A . 1 do not have those with me unless they were subpoenaed.
14 Q. Offhand in your capacity as Superintendent do you r e ca l l
15

hiring anyone this year for positions who happened to be

16 non-certified?

17 A. Yes, 1 do have one that I r e ca l l  that is not fu l ly

18!j c e r t i f i e d .

19 Q. And who is that, sir?

20 A. That is my Science teacher, a Dennis Ward.

21 i Q. And is Mr. Ward black or white?

22 A. He is white.

23 Q. Did Mr. McConnell teach just two years in your D is t r ic t ,

24

j|
s i r  ?

25 A . That is true.

GLENN H PERRIN 
O f f ic ia l  Co u rt  R eforte*  

F ederal Bu ild ing  
EL Do rad o . A rk an sas  7t7so



iil Q.

Bradshaw - D irec t

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29 A.

Since the time that the three elementary teachers were 

not rehired pursuant to the unification of the D is tr ic t ,  

have you had occasion to hire any other elementary

school teachers?

Yes, we have employed one, one other elementary teacher. 

And what school year was that for?

That was for the 1970«'71 school year.

A l l  r ight* At the current period of time, r ight now, 

do you have vacancies in your elementary department?

No, s i r ,  I do not have.

Who is your Fourth Grade teacher now?

Fourth Grade teacher, 1 be l ieve  that is Mrs. Clark.

And the Third Grade teacher?

Mrs. Wall.

Is that the same Janet Wall?

Janet Dye Wall.

Who was the teacher that you hired this year?

A Mrs. Florida Roann.

Is she s t i l l  teaching?

Yes, she is .

Is she on leave or is she actually there?

No, she is not on leave.

Did you ever have occasion to rate Mr. K lu t ts , to 

evaluate him or rate him?

No, s i r , I did not.

GLENN H PERRIN
O f f i c i a l . C o u r t  R c p o m t i  

F c d c r a l  B u i l o i n o

l< M .A▲



Bradshaw - D irec t 94

Q.

A .

ji Q-

A.

a
10

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17 ij a
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18 Q.

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22 Q.

23 A .

24

25

Now, at the time that he was employed by you, even on 

an emergency c e r t i f i c a t io n ,  you made him Head Teacher,

did you not?

That is true.

Now, did you consider, the way you did with other 

teachers when you were making your evaluation, his

transcript?

1 beg your pardon?

Did you consider his transcript when you were considering 

him for his promotion to Head Teacher? I take i t  i t  was 

a promotion, was i t  not?

Well, primarily i t  is .  He is a Math teacher and he 

just simply carries the t i t l e  of Head Teacher.

Does he have some duties and respons ib i l i t ies  in that 

regard--

Yes.

--that are of a supervisory nature?

T r u e .

Did you consider, in evaluating him for that position, 

his academic transcript and his c e r t i f i c a t io n  status? 

No, 1 did not.

You didn't?

No, s i r .  1 f e l t  l ike  the man could do the job, so I 

appointed him to that position with the approval o f  the 

Board.
GLENN H PERRIN

O F F I C I A L  C O U H T  R K P O R T M  

F b o c r a l  B u i l d i n g



I'
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r
1L

95

a I see. Since this proceeding has started, have you had 

an occasion to look at his transcript?

A .  Yes, I have.

MR. STARLING: Your Honor, I am going to object, i f

I can, because again, Mr. Klutts, as Mr. Kaplan has 

pointed out, is a high school teacher, and there is 

no a l legation in the Complaint that anyone in the 

high school, none of the p l a in t i f f s - - o r , one 

p la in t i f f  is involved, in reference to the 

evaluation form, there is nothing in there that 

indicates that the high school teachers have been 

discriminated against. This was an evaluation 

tested only the elementary teachers, and Mr. Klutts 

is in a high school or high school teacher and Head 

Teacher at the high school, and there has been no 

a l legat ion  or alleged in the Complaint concerning 

the high school teachers.

THE COURT: Well,  I believe he t e s t i f i e d  he

did not evaluate him, so that w i l l  probably 

s e t t le  the question.

Q What is--you have discussed for the record the current

black.-white teacher situation in the f i r s t  eight grades. 

What is i t  in the Ninth, Tenth, Eleventh, and Twelfth?

A  Ninth, Tenth, Eleventh, and Twelfth, we have two black 

teachers, one black Librarian.

OLENN H PERRIN
Of f ic ia l  Cou nt  R eports*

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 1 0

Bradshaw - Direct



i| q. And the two black teachers are s t i l l  Miss Brown, or

2 Mrs.--is i t  Miss Brown? Miss Annette Brown?

3 A. Miss Brown, Mrs. W i l l i s ,  and Mr. Sanders, Mr. Cornelius

4 Sanders.

5 Q. And what does Mr. Sanders do?

Bradshaw - D irec t

6 !i A-

7

8 Q.

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i° ! Q-

ii A.

12 Q.

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15 |

16 Q-
i17 A.

18
ft

19 A.

20 Q.

21 1
! A.

22

23

24 Q.

Mr. Sanders is teaching Social Studies and Physical

Education.

How many periods a day does he teach Social Studies?

One.

Just one?

One, and one Study Hall.

And is he c e r t i f i e d  in both Physical Education and 

Social Studies?

Yes, soon as he gets his transcript from the State 

Department of Education he w i l l  be fu l ly  c e r t i f i e d .

But he is not yet ,  is that right?

Right.

How many white teachers do we have in the high school? 

As of ’ 70-'71 school year in the high school?

Yes, s i r .  Well, grades Nine through Twelve.

A l l  r igh t ,  we have six white in the high school for a 

to ta l  of ten whites, to ta l  of eight blacks, in the 

overa l l  school, high school and elementary.

That is for your whole system?

True.___________________________________
GLENN H PERRIN  

O f f i c i a l  C o u r t  R e p o r t * *

F e d e r a l  B u i l d i n o



Bradshaw - D irec t

2 A.

3 Q.

* A.

5 1! Q.

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Does that include you, s i r ,  or is that without you?

Yes, I would be included.

Including you?

True.

And how about your pupil population as of the time that 

you have that teacher census, what is your pupil census,

by race?

We are running approximately 90 percent black, 10 percent 

white.

I see. Do your children go to the Plum Bayou School?

HR. STARLING: I object, Your Honor, I r ea l ly  don't

see any relevance to the fact whether Mr. Bradshaw’ s 

children go to the Plum Bayou School or not.

THE COURT: What is the purpose of i t?

MR. KAPLAN: Just another element to show this

ind iv idua l ’ s attitude and the way he views this 

sys tern.

ME. STARLING: Well, does the fact —

THE COURT: I think that is  far-fetched, Mr.

Kaplan, and such a speculative thing for his 

view and his view of this system. I think 

Mr. Bradshaw is answering your questions pretty 

forthwith.

MR. KAPLAN. Your Honor, I  think that where he 

sends his children, in view of the fact that he

GLENN H PERRIN
O f f i c i a l  C o u r t  R b f o r t k r  

F c d c r a l  B u i l d i n g

VI nn.ADo Ar k a n s a s  71790



l ives in Wright, has some relevance, and i f  he 

sends his children to this school or not.

THE COURT: I don’ t think i t  has a thing to do

with i t .

MR. KAPLAN: I f  Your Honor please, I  would l ike  to

make an o f fe r  of proof from the deposition.

THE COURT: A l l  r igh t .

THE WITNESS: Your Honor, may I  have a word with

my lega l counsel?

MR. KAPLAN; Your Honor, I would o f f e r  to prove 

that i f  he were allowed to answer this question, he 

would say that they do not attend these schools 

but attend schools in North L i t t l e  Rock and that he 

did so answer on deposition.

I believe that 's  a l l ,  Your Honor.

MR. STARLING: Your Honor, I  am going to, except

for just about 15 minutes of questioning, or 10 

minutes of questioning on just two subjects, I am 

going to defer the major part of my cross 

examination of Mr. Bradshaw simply because he is 

going to be a witness for me in the application of 

my case, of the defendants' case. What questions I 

do have to ask Mr. Bradshaw would probably take 

around 10 minutes and no longer i f  the Court would 

l ike for me to resume.

GLENN H PERRIN 
O f f i c i a l  C o u r t  R u f o r t c r  

F i d i r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



99
THE COURT; You may proceed, then,

CROSS EXAMINATION

BY MR. STARLING;

Q. Mr. Bradshaw, the p la in t i f f s  have a lleged, in reference 

to one of the p la in t i f f s ,  Mr. Asive Thomas, that you 

terminated him in 1968 so as not to hire a black P„E. 

instructor and a Coach. In reference to that 

a l legat ion , I ask you, what race is the man who now holds 

the job of Social Studies teacher, P„E„ instructor, and 

Coach?

A. Mr. Cornelius Sanders is a black instructor.

Q. Now, Mr. Bradshaw, when was Mr. Asive Thomas employed

by the School D istr ic t?

A. 1 b e l i e v e  that was January 26th or 28th of 1967.

0. And what was he employed to do by the D is tr ic t  at that

time?

A. Teach Social Studies.

Q. Do y o u  have a  position a t  the--or did you at that time, 

the t i m e  being 1966- ' 6 7 ,  h a v e  a position in the Tucker - 

R o s e n w a l d  Elementary S c h o o l  which was a P.E„ instructor

a n d  a  C o a c h ?

A. No, s i r ,  we d i d  not have.

Q Do y o u  have a position, o r  did you have a position at 

the Tucker-RosenwaId School at that time for a P.E.

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o  A r k a n s a s  7 1 7 * 0

Bradshaw - Cross



Bradshaw - Cross

11 ins true tor ?

2 A. No, s i r ,  we did not have, because--

3 Q. Then what was the purpose for which you employed Mr.
4 Thomas ?

5ji A. Hr. Thomas was employed to teach Social Studies.
Kt Q. And did Mr. Thomas teach Social Studies at the Tucker-
7

Rosenwald School from January, *66, through May of 1967?
8 ! A . Yes, s i r ,  he did.

9 i a Was Mr. Thomas’ contract renewed for the school year

10 196 7 -'68?

11 A. Yes, i t  was.

12 Q. Now, what was Mr. Thomas contracted with to teach for
13 the school year 1967-'68?

14 A. Social Studies.

15 !
|

Q. Was he contracted to teach P.E.?

16 A . No, s i r ,  he was not.

171! Q. Was he contracted to be a Coach?

18
i! A. No, s i r ,  he was not.

18 Q. Was Mr. Thomas’ contract renewed to teach Social
20

Studies at the Tucker-Rosenwald Elementary School for
21 j| the upcoming year, 1968-69?

22 A . No, s i r ,  he was not, because 1 f e l t  Mr. Thomas was weak
23

24

25

i n  the a r e a  of S o c i a l  S t u d i e s  a s  f a r  a s  t h e  i n s t r u c t i o n s  

h e  w a s  p r o v i d i n g  t o  t h e  s t u d e n t s ,  a n d  I  d i s c u s s e d  t h i s  

w i t h  t h e  H e a d  T e a c h e r ,  M r .  E d w a r d s ,  a n d  M r .  E d w a r d s

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

C L  D o r a d o  A r k a n i a i  7 i 7 » o

10 0



!

Bradshaw - Gross

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1
agreed that he was weak, and 1 did not make r e c ommen d a t i  oi)i

2 to the Board for his contract to be renewed for the

3 upcoming school year.

4 Q. And was Mr. Thomas c e r t i f i e d  in the area of Social

*lj
|i

Studies ?

6
1 A. He was not c e r t i f i e d .

7 ■: Q. Did you not i fy  Mr. Thomas in writing as required by the

8 Arkansas Law that his contract would not be renewed for

9 ! the upcoming year 1968-'69?

10 A. Yes, s i r ,  I did.

U 1 Q. I show you a copy of a l e t te r  and ask you, can you

identi fy  that, please, s i r ,  as a le t te r  which you sent 

to Mr, Asive Thomas informing him that his contract 

would not be renewed for the school year ’ 68“ '69?

Yes, s i r ,  this is a copy of the l e t t e r .

Would you read the contents of that le t ter?

Yes, s i r .  "Mr. Asive Thomas, 616 North Magnolia, Pine 

Bluff, Arkansas. Dear Mr. Thomas: The Plum Bayou-

Tucker School Board met in special session, Apr i l  22nd, 

at 7:30 p.m„, and at that time i t  was decided that your 

contract would not be renewed for the 1968-'69 school

year
Now, Mr. Bradshaw, when Mr. Thomas came to work at the 
School District with the Tucker-Rosenwald Elementary 
School in ‘67-'68 as a Social Studies teacher, who was

G L E N N  H P E R R IN  
O f f i c i a l  C o u r t  R i p o r t i r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a n r a i  7 17 S O

101

1



Bradshaw - Cross 102

1
1 his counterpart in the Plum Bayou High School during

2 that period of time?

3 A. In 1967-'68?

4 Q. Yes.

5 A. Mr. Hunter Douglas.

6 Q. Now, was Mr. Hunter Douglas white or black?

• A Mr. Douglas was white.

8 Q. Now, what was Mr. Hunter Douglas employed to do at the

9 Plum Bayou High School during the school year 1967-'68?

10 A. Mr. Douglas was employed to teach Social Studies and

11 Physical Education.

12 ‘ Q. Did the Plum Bayou High School at that time employ a

13 Coach?

14 j A. No, s i r ,  we have never employed a Coach as such.

15
1
i Q. Did the Plum Bayou High School at that time employ just

16 1 a P.E. instructor?
1

17
|
j A. No, s i r ,  we did not.
1

1 8  |j Q. Now, during the school year 1967-1968, did Mr. Hunter

19 Douglas, who is white, teach Social Studies and

20 Physical Education at the Plum Bayou High School?

21 A Yes , s i r , he d id .

22 Q. And did you renew Mr. Hunter Douglas’ contract for the

23 '! school year 1968-1969 as a Social Studies and P.E.

24 teacher ?

25 i A. No, s i r ,  I did not.
I|------------------------------------------------------------------- — ------ -------------- —

GLENN H PERRIN
O f f i c i a l  C o u r t  R p o r t e r  i jag f c

F e d e r a l  B u i l d i n g  t \£?
ii E L  D o r a d o  A r k a n s a s  7 i 7 » o  a l a  f l  / *



.r o s s

l

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t)

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lit

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nv -

b e .  d , : s e  I f e l t  t h a t  M r .  D o u g l a s  w a s  v e r y  w e a k  i n  t h e  a r e a  

- o c t a l  S t u d i e s .  1  d i s c u s s e d  t h i s  w i t h  t h e  H e a d  

T e a c h e r  a t  t h a t  t i m e ,  a n d  h e  a g r e e d ,  a n d  M r .  D o u g l a s  h a d  

aadi -  n o  p r o g r e s s  a s  . a r  a s  p i c k i n g  u p  h o u r s  i n  S o c i a l  

t u l l e s ,  a n d  I r e c o m m e n d e d  t o  t h e  B o a r d  t h a t  M r .  D o u g l a s  

s o t  : e  r e e m p l o y e d  f o r  t h e  u p c o m i n g  s c h o o l  y e a r .

I s  t n i s  t h e  s a m e  t i m e  t h a t  y o u  r e c o m m e n d e d  t o  t h e  S c h o o l  

b o a r ;  t h a t  M r .  A s i v e  T h o m a s  w h o  w a s  d o i n g  e x a c t l y  t h e  

s a m e  t h i n g  a t  t h e  T u c k e r - R o s e n w a l d  E l e m e n t a r y  S c h o o l  

c o n t r a c t  n o t  b e  r e n e w e d ?

Y e s ,  s i r ,  t h a t  i s  c o r r e c t .

A n n  J i d  y o u  w r i t e  M r .  D o u g l a s  a  l e t t e r ?

I did.

I s n o w  y o u  a  l e t t e r  d a t e d  April 3 0 t h ,  1 9 6 8 ,  a n d  a s k  y o u

I I  y o u  c a n  i d e n t i f y  t h a t  a s  a  l e t t e r  w h i c h  y o u  s e n t  t o  

M r .  H u n t e r  D o u g l a s ?

Y'-.- , t h i s  i s  a  c o p y  o i  t h e  l e t t e r .

w o u l  i y o u  r e a d  t h a t ,  p l e a s e ?  

i , d i r .  " D e a r  M r .  D o u g l a s :  T h e  P l u m  B a y o u - T u c k e r

S c h o o l  B o a r d  m e t  i n  s p e c i a l  s e s s i o n ,  A p r i l  2 2 n d ,  a t  

7 : 3 0  p . m . , a n d  a t  t h a t  t i m e  i t  w a s  d e c i d e d  t h a t  y o u r  

c o n t r a c t  w o u l d  n o t  b e  r e n e w e d  f o r  t h e  1 9 6 8 - ' 6 9  s c h o o l  

y e a r  . "

Ls t h a t  e x a c t l y  t h e  s a m e  l a n g u a g e  t h a t

G L E N N  H PERRIN 
O e i m c i a l  C o u r t  R e p o r t e r  

F e d e r a l  Building

y o u  u s e d  i n  y o u r

.03

F  l n n s i r t n  A  d v  a  m o  • c



Bradshaw - Cross 104

1 | 

2

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20

21 :i

72

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25 ;

l e t t e r  to Mr. Thomas?

A. Yes , s i r  , i t  is .

Q- Mr. Bradshaw, did you not renew the contract with Mr. 

Hunter Douglas for exact ly  the same reasons that you 

did not renew the contract for  Mr. Asive Thomas who was 

bas ica l ly  doing the same thing Mr. Douglas was doing?

A. Yes, s i r .  The reason their  contracts were not renewed 

is because both gentlemen were weak in the area of 

Social Studies as far as the instructions that they were 

g iv ing  to the students.

Q. And was Mr. Douglas--! b e l ie ve  you t e s t i f i e d  he was 

white, is that correct?

A. That is true.
I

Q- Mr. Thomas was black?
j

A. Right.

Q. And who is the man, or the name o f  the man that you 

hired at this point to take the place of Mr. Hunter 

Douglas who you had just  terminated?

A. Mr. Bruce McConnell.

Q. And what was Mr. McConnell hired to do?

A. Mr. McConnell was hired to teach Social Studies and

Physical Education.

Q- Was Mr. - - r e v e r t in g  back just a second, was Mr. Hunter 

Douglas, who you terminated, was he c e r t i f i e d  to teach 

Social Studies?

G L E N N  H P E R R I N  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

ci rv U .C ,



Bradshaw - Cross 105

1 A.

2 0.

3

4 A.

5 q.
i j6

V  | A .

8

9 , Q.

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n  ; j  A .
12 'I

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t;

16 ii

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2 1  ij Q .

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23 Q.

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No, s i r ,  he was not.

Then are you saying that neither Mr. Douglas nor Mr. 

Thomas were c e r t i f i e d  to teach Social Studies?

Neither were.

Was Mr. Bruce McConnell, who you hired to replace Mr. 

Hunter Douglas, c e r t i f ied?

Yes, s i r ,  Mr. Douglas—Mr. McConnell was fu l ly  c e r t i f i e d  

in the area of Social Studies and Physical Education. 

What kind of teacher in Social Studies was Mr.

McConne11?

I would say that Mr. McConnell was above average in this 

area.

Now, what happened to Mr. McConnell after--how long did 

he remain a teacher?

Mr. McConnell was with Plum Bayou-Tucker D is tr ic t  for 

two years and then received employment in Wabbeseka

D is t r i c t .

And when Mr. McConnell l e f t  your School D is t r ic t ,  I ask 

you the name of the man who you hired to replace him?

Mr. Cornelius Sanders.

And is Mr. Sanders black or white?

Mr. Sanders is black.

Mr. Bradshaw, I just have a couple of more questions I 

want to ask you at this time. I ask you in reference to 

the p la in t i f f s '  a l legation 19 in the p la in t i f f s '

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e de r al  B u il d in g  
E L  Dorado A rkamaas 7 1-?tn



Complaint where they alleged that Mrs. Lucreasia Evans, 

who is a p la in t i f f  in this case, has been discriminated 

against because she was placed on the T i t l e  I payroll .

Mr. Bradshaw, when was Mrs. Evans placed on the T i t l e  I 

payroll?

Mrs. Evans was placed on the T i t l e  I payroll in 1965-'66 

school year prior to me becoming Superintendent of the 

Plum Bayou-Tucker School D is tr ic t .

Now, since you have become Superintendent, has Mrs.

Evans ever requested that you remove her from the T i t l e  I 

payroll and transfer her back to the regular payroll?

She has never made the request to be taken o f f  the 

T i t l e  1 payroll and transferred back to the regular 

payro l l ,

Are there any special requirements or standards that a 

teacher under a T i t l e  I program must meet to retain her 

status as that, as T i t l e  I teacher, other than simply 

c e r t i f i c a t io n  as any other teacher would have to have? 

That is a l l ,  they must have an elementary c e r t i f i c a t e .  

Now, I be l ieve on your direct examination you t e s t i f i e d  

that there were other teachers at this time during the 

period 1966 through 1969 who were also placed on the 

T i t l e  I program?

That is true.

And were some of these teachers white?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 17 :



107Bradshaw - Cross 
A. Yes, sir.
Q. I take it that some of the teachers were black? 
A. True.
Q.

A.

Q.

A .

Q.

A .

Q.

A.
Q.

Did Mrs. Evans’ salary increase as a result of her being 

placed on the T i t l e  1 program?

Yes, Mrs. Evans' salary, 1 think, had increased from 

$ 3 , 8 8 9 . 0 0  up to, through the '69-'70 school year, up to 

$6,000.00, which means approximately a $2,111.00 increase. 

What is she presently making in reference to the 

teachers who are placed on the regular payroll?

A t  the present time, Mrs. Evans is the highest paid 

elementary teacher in the Plum Bayou-Tucker School 

D is tr ic t  other than the Head Teacher, and I believe that 

Mrs. Evans is drawing approximately $311.00 more than 

any other teacher.

Mr. Bradshaw, was Mrs. Evans one of the 13 elementary 

teachers who were evaluated by you in reference to 

which teachers would be retained and which teachers would 

not be retained due to the unification of the school

system in 1969 and '70?

Yes , s i r ,  she was.

And according to that evaluation was Mrs. Evans one of 

the ten teachers retained by the School D istr ic t?

Yes , s i r .

Mr. Bradshaw, when you ranked those teachers
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

F I  n n B . n o .  . . . . . . . .  . . . .

or

ILK



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Bradshaw - Cross
108

evaluated those elementary teachers, did you evaluate 

them in reference to the subjects they taught or the 

grades they taught or how did you evaluate them?

I evaluated the teachers on their overa l l  a b i l i t y .

And I am assuming from that answer, then, you are-- is  i t  

true that since Mrs. Evans was retained under the 

evaluation, that in the event T i t l e  I funds became 

unavailable, she would s t i l l  be retained by the D is tr ic t  

because she ranked higher than the other teachers?

True, Mrs. Evans being ranked in one of those ten would 

have, say, i f  T i t l e  I money had not been availab le ,  she 

would have been retained by the D is tr ic t  under the 

regular school funds.

Now, I ca l l  your attention, Mr. Bradshaw, to the 

interrogatories propounded by the defendants to the 

p la in t i f f s ,  and those have been introduced into evidence 

in this case, and sp ec i f i c a l ly  to Interrogatory No. 2 

where the defendants asked the p la in t i f f s ,  and I quote, 

"You have alleged that Mrs. Evans is suffer ing damages 

because the D is tr ic t  placed her under the T i t l e  I 

payroll ,  although her salary was increased and she has 

acquired new and useful sk i l ls  benef ic ia l  to her teach­

ing status. State the spec i f ic  damages which Mrs. Evans 

has incurred in reference to the D is tr ic t  placing her 

under the T i t l e  I program."

GLENN H PERRIN 
O f f ic ia l  C o u r t  R e p o r t e r  

F ed e r al  B u il d in g
EL D nR inn  A b i t  a  u a  a «



Bradshaw - Cross

In response Co this Interrogatory, the p la in t i f f s  

answered: “Mrs. Evans' contract states that she w i l l  be

paid, ' i f  funds are a va i lab le ' ,  i t  u  the act of the 

defendants in making her position subject to the 

a va i la b i l i t y  of federal funds, and thus removing her 

from the security of the regular payroll that has damaged 

Mrs. Evans. Further, the D is tr ic t  has refused to pay 

for the acquisition of any new sk i l ls  necessary for Mrs. 

Evans to perform properly In her position as a T i t l e  I 

teacher. Mrs. Evans found i t  necessary to expend her 

own money to acquire these necessary s k i l l s . "

In response to that answer of the p la in t i f f s ,  I ask you 

i f  the T i t l e  I funds became unavailable, would Mrs.

Evans s t i l l  be retained by the D is tr ic t  in reference to j 

the evaluation o f  the 15 teachers?

Yes, since Mrs. Evans ranked as one of those 10 teachers, 

she would be transferred back to the regular school 

program because she was evaluated as a teacher and her 

overa l l  a b i l i t y  and not evaluated as just a T i t l e  1

teacher.

i s  there any teacher that you know of that has had this

hapnen to her, that she was a T i t l e  I teacher and had 

the funds taken away?

WeU> yes ’ Vlr* K lu tts , and then our Science teacher, 

both o f  these teachers, plus Mrs. Clark.

GLENN H PERRIN 
O r r i c i A L .  C o u r t  R b p o n t k n  

B u i l d i n g / ✓



Bradshaw - Cross 110

lij a

2 A .

3

4

h
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6 Q.

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8  A .

9 Q.
10

11 i
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24

Who is Mrs. Clark?
Mrs. Clark is our Fourth Grade teacher or working in the 
elementary level, who is a Negro teacher. She was on the 
Title I program last year and we had to move her back to 
the regular program this year.
Now, in your evaluation of the 15 elementary teachers, 

was Mrs. Clark evaluated one of the 10 top teachers?

Yes.
Do the contracts of the other teachers who are under the 
Title I payroll, both white and black, which you have 
testified the District has, do their contracts all 
state "if funds are available"?
Every contract that is issued in the Plum Bayou-Tucker 
School District will bear that insertion, "payable if 
funds are available" , no matter whether they are Title I 
or regular salary funds.
You say the regular salary funds contracts say the same 
thing?
Yes, sir.
And that is what?
"Payable if funds are available,,"
Did Mrs. Evans ever request that she be given the 
opportunity to take additional studies at the expense
ot the District?
Yes, sir, she has made the request.

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7i7so



-Tj-

—  i|-
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Q. And what was your response to that request?

A .  Well, 1 simply told her that the D is tr ic t  could not or 

had not had a practice of deferring educational expense 

for an individual teacher.

Q. Prior to the request by Mrs. Evans for additional

studies, has the Plum Bayou-Tucker School D is tr ic t  ever 

expended D is tr ic t  funds for the acquisition of new 

sk i l ls  by teachers?

A. No, s i r ,  we have not.

Q. A n d  a fter  the request by Mrs. Evans that she be allowed 

to acquire additional sk i l ls  at the expense of the 

D is t r ic t ,  has the D is tr ic t  ever allowed any teacher to 

do this, black or white?

A .  N o ,  s i r ,  w e  h a v e  n o t .

MR. STARLING: I believe that 's  a l l ,  Your Honor.

THE COURT. A n y t h i n g  further, Mr. Kaplan?

MR. KAPLAN: Yes, just on those related items, I

have a few things. would you l ike  to f in ish those 

up now?

THE COURT: A l l  r igh t .

REDIRECT EXAM LN AT ION

BY MR. kAFLAN:

Q. Mr. Bradshaw, when you reported to the State in 1967-'68 

Mr. Hunter Douglas as an employee of the D is tr ic t ,  you

GLENN H PERRIN 
O f f ic ia l  C o u r t  R eporter  

F ed e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7 »o

Bradshaw - Cross



1 1 2
Bradshaw - Red irec t

2  1 A .

3

i Q.

5

6  A  

T '  Q. 

8

9

1 0  A .

1 1  l l  Q .
j

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15 !

18

17 !l

Q.

18

19

2 0  Q .

21

22

2 : i  A .

24 g.
ij

25

l i s t e d  h i m  a s  a  p „ E „  i n s t r u c t o r ,  d i d  y o u  n o t ?

i \ i .  a n d  S o c i a l  S t u d i e s ,  t h a t  i s  t h e  a r e a  i n  w h i c h  h e

w a s  w o r k i n g .

A l l  r i g h t .  B u t  y o u  l i s t e d  h i m  a s  a  P . E .  i n s t r u c t o r ,  i s  

t h a t  c o r r e c t ?

I  a s s u m e  t h a t  i s  c o r r e c t .

O k a y .  N o w ,  f o r  ' 6 8 -  6 9 ,  w h e n  y o u  h i r e d  M r .  M c C o n n e l l ,  

h e  a g a i n  d i d  t e a c h  f o u r  h o u r s  o f  P . E .  a n d  o n l y  t w o  o f

S o c i a l  S t u d i e s ?

T r u e .

A l l  r i g h t .  Am I  c o r r e c t  i n  my r e c o l l e c t i o n  o f  y o u r  

t e s t i m o n y  t h a t  y o u  d i d  n o t  a s k  M r .  T h o m a s  h o w  m a n y  h o u r s  

Oi. i f  h e  w a s  w i l l i n g  t o  r e m o v e  h i s  d e f i c i e n c y  i n  S o c i a l  

S t u d i e s ?  I s n ' t  t h a t  c o r r e c t ?

N o ,  I  d i d  n o t  p e r s o n a l l y  a s k  h i m .

O k a y .

A t  t h a t  p a r t i c u l a r  t i m e  w e  d i d  h a v e  a  t r a n s c r i p t  w h i c h  

c o u l d  b e  r e v i e w e d  a n d  t h i s  i n t o r m a t i o n  c o u l d  b e  

a s c e r t a i n e d .

A l l  r i g h t .  N o w ,  w i t h  M r s .  E v a n s '  s a l a r y  i n c r e a s e ,  a l l  

o f  t h e  t e a c h e r s  i n  t h e  D i s t r i c t  h a v e  h a d  s a l a r y  i n c r e a s e s  

i n  t h a t  p e r i o d  o f  t i m e ,  i s  t h a t  c o r r e c t ?

True.

N o w ,  I a s k e d  f o r  a  s u b p o e n a e d  i t e m  w h i c h  a s k e d  f o r  t h e

| s a l a r y  s c h e d u l e  o f  t h e  D i s t r i c t  f o r  1 9 6 5 t o  t h e  p r e s e n t .

G L E N N  H  P E R R I N  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g / / o
PI n n o * r \r t  A .  . . .  ,



Bradshaw - Red irec t 113

1  n o t i c e  o n  r e v i e w  t h a t  t h e r e  w a s  n o  s u c h  i t e m  t h e r e ,

2 C o u l d  y o u  t e l l  u s  w h a t  t h e  p o l i c y  w a s ?

3 A . I n  w h a t  y e a r  w a s  t h i s ?

4 0. W e l l ,  a l l  o f  t h e  y e a r s  f r o m  ' 6 5  t o t h e  p r e s e n t •

n A . I  h a v e  o n e  h e r e  b e f o r e  me t h a t  w i l l  g i v e  y o u t h e

6 i n f o r m a t i o n ,  1 9 6 6 - ‘ 6 7 ,  * 6  ? — ' 6 S , ‘ 6 8 - ' 6 9 ,  ' 6 9 - ' 7 0  , w h i c h

7 ! w i l l  s h o w  y o u - -

8 Q. A l l  r i g h t .

9 ! A - - - e a c h  t e a c h e r  a n d  t h e i r  s a l a r y .

10 , Q. T h i s  s h o w s  t h e  s a l a r y  o f  a l l  o f  t h e  t e a c h i n g p e r s o n n e l ,

11 i s  t h a t  c o r r e c t ?

12 i A. T r u e .

13 Q. N o w ,  am I  c o r r e c t  i n  s a y i n g  t h a t  t h e r e  w a s  n o s a l a r y

1
14 j :

j
s c h e d u l e  f o r  y o u r  S c h o o l  D i s t r i c t  d u r i n g  a n y o n e  o f  t h o s e

15
)

y e a r s  ?

16;1 A. Y e s ,  s i r ,  w e  d o  h a v e  a  s a l a r y  s c h e d u l e .

!
17 Q- A l l  r i g h t .  A n d  w h a t  i s  t h e  s a l a r y  s c h e d u l e ?

18
1i A .

j
I  ma y  h a v e  a  c o p y  o f  o n e  h e r e .  I n  1 9 6 7 - ' 6 8 , t h i s  i s

19 t h e  s a l a r y  s c h e d u l e ,  a n d  w e  s h o u l d  h a v e  o t h e r  c o p i e s .

20 Q. A n d  t h i s  s a l a r y  s c h e d u l e  i s  a n  i t e m  t h a t  w a s a p p e n d e d

2! jj t o  t h e  i n t e r r o g a t o r i e s ,  i s  t h a t  c o r r e c t ?

22 I A . I b e l i e v e  s o .

23 T HE  C O U R T :  W h i c h  o n e ?

24 M R . K A P L A N :  U h - -

25
II

T H E  C O U R T :  2 9 ?

G L E N N  H P E R R I N  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

El__ D o r a d o __A r k a n s a s  71730 M



Bradshaw
114

- Red irec t

j! U-

10 A.

11 Q.

12f|

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16 Q.

17

18
1 A .

19 Q.

20

21 i A .
22 Q.

23

24 A .
25

4

Q.

MR» KAPLAN: I think so, Your Honor.

THE (X)URT: 29 and 30, apparently.,

MR. KAPLAN: Answer to Interrogatory No. 29, Your

Honor, was '69 and '70.

iMr„ Bradshaw, the document that you handed me is a 

teacher salary schedule for '66--67, had beginning 

salary for a Bachelor’ s Degree of $4,000.00 and annual 

increments of $50.00 up to 10 years of service, is that

correct?

Yes. This is correct i f  the money is avai lab le .

I understand that. The extra duty got $900.00 with a 

maximum of $4,950.00, is that correct?

This is simply a figure which may be used or that amount 

could be given at the discretion of the Superintendent 

and recommendation made to the Board and their approval. 

Master's Degree had $350.00 more, is that correct, 

$4,350.00 commencing salary?

I believe th a t ’ s correct.

And diploma of advance study ca l ls  for $4,700.00, is 

that right?

That is true.

Superintendent and Principal were to have their salaries 

determined by the Board of Directors?

That is true.

A l l  r ight.  Now, in that school year '66-'67, did you

G L E N N  H P E R R I N  
O f f ic ia l  C o u r t  R e p o r t e r  

F ederal  B u il d in g  
EL  Do r a d o  A r k a n e a r  t » i m Ha.



T

2

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have a c e r t i f i e d  white teacher who earned less than any

black teacher?

A- I would have to look at the schedule.

Q- Please do.

No, s i r ,  I did not, but we did have some that drew the

same salary.

Q- Who were they?

A- Voletta Chavis and Mis. Davis each drew $4,000.00.

Q- Now, Voletta Chavis is white, is that right?

Bradshaw - Red irec t

1 0  A .

“  I Q .

13 A .

■*|j Q.

15

16 A .
17 I,

18 ii Q.

19

20

21

22

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That is true.

A n d  s h e  w a s  working o n  a n  emergency c e r t i f i c a t io n ,  not 

a  f u l l  c e r t i f i c a t io n ,  i s  t h a t  right?

Right.

And Mrs. Davis, Art ie  Davis, how was i t  that she only 

made $4,000.00? Was that her f i r s t  year?

I am not sure that Mrs. Davis was fu l ly  c e r t i f i e d  at 

that time.

N o w ,  s h e  h a d  h a d ,  h a d  s h e  n o t ,  several years i n  the

D i s  t r  i c  t ?

Y e s ,  she had b e e n  employed on a  substitute contract, 

blanket contract, whereby she worked for two or three 

y e a r s  before she ever obtained a degree from a co l lege .  

Do vou know approximately how many years she did have

I '
I l f

i n  t h e  D i s t r i c t ?  I s  i t  a b o u t  t h r e e ,  s i r ?

25 jj
_ _ _ _ | | _  A .  On e  s e c o n d .

G L E N N  H P E R R I N
O f f i c i a l  C o u r t  R i p o r t i r  

F e d e r a l  B u i l d i n g

__________ E L  D o r a d o ___ A r k a n s a s  7 _________________________ m



3radshaw - Red irec t
1 1 6

1 Q.

2 A.

3

4 Q.

5
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6 A.
i

7 ![

8 ! Q-
9 I A-

10 Q.

11 A.

12 Q.
13 A.

14

15 Q.
16 A.

17

18 1
1

Q.
19 A.

20 a

21 !

22

1
23

24 BY

25 Q.
ll-

Okay .

As of 1967-'68 year, Mrs. Davis had completed one year 

teaching experience in the Plum Bayou-Tucker D is tr ic t .  

Do you know whether that was her to ta l  experience or 

whether she had been in other d is tr ic ts?

I believe the Plum Bayou-Tucker School D is tr ic t  is the 

only d is t r i c t  she has served as a teacher.

Was your salary schedule changed at a l l  in 1967-'68? 

Yes, s i r ,  I think the salary schedule was amended.

A n d  d i d  i t  go up?

I be l ieve  so.

To what f igures, do you reca l l?

I cannot give you those figures without the schedule 

being in my presence.

And do you have that schedule?

i f  1 do not have i t  in this accumulation of materials, 

Mr. Starling does not have i t ,  I can get i t  for you.

And during the recess w i l l  you attempt to locate those?

Yes , sir  , I w i l l .

A l l  r igh t .

MR. KAPLAN: That's a l l  I have at the present time

Your Honor.

THE COURT.

I notice Robert J. Hall,  ’ 66-'67, $4,200.00, and Lois G

GLENN H PERRIN 
O f f i c i a l  C o u n t  R e p o r t e r  

F e d e r a l  B u i l d i n g



1

2 1 A .

3 Q.

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Thomas, $4,200.00. Are they both black?

Yes, s ir .

Does p la in t i f f  Lucreasia Evans s t i l l  work with the 

School D is tr ic t?

Yes, s i r ,  she is s t i l l  employed by Plum Bayou-Tucker 

School D is t r ic t .

Has she been on T i t l e  I since 1965?

Yes, s ir .

In other words, she was put on T i t l e  I program in 1965 

by your predecessor?

True.

And when did he pass away?

April  4th, 1967.

And she's been working--teaching for your school under 

this program ever since?

That is correct.

And is so now?
Yes, s i r .

THE COURT: Anything further, Mr. Starling?

MR. STARLING: No, s i r ,  Your Honor.

THE COURT: Anything further, Mr. Kaplan?

MR. KAPLAN: No, Your Honor.

THE COURT: You may stand aside.

(Witness excused.)

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

VI nnEinn



Direc tL i t t l e j  ohn

THt. COURT: The Court w i l l  now be in recess

ror the noon hour. 1 notice i t  is substantial­

ly past 12 o'clock, 1 don't know i f  we can get 

back by 1:30 or not, we w i l l  try .  If not, just 

as soon thereafter as we can. The Court w i l l  

now be in recess until that time.

8 (Whereupon,
9 thereupon,
10i:i heretofore,
li

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had, to-wit

12 'i
13 MR. KAPLAN: Dr. Littlejohn:
14

15

16

17

WALTER LITTLEJOHN.
called as a witness on behalf of the p la in t i f f s ,  being f i r s t  

duly sworn, testified as follows:
18

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DIRECT EXAMINATION
BY MR. KAPLAN:
Q.

MR. STARLING: Your Honor, if I may, at this time,

it's my-understanding that Mr. Kaplan is going to 

have two witnesses in this respect, and I make the 

objection to the fact that if it is the intention 

________  of these witnesses to testify as to what are the

G L E N N  H PERR IN  
O f f i c i a l  C o u n t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o  A r k a n r a s  7 i 7 » o / 7 k



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evaluation c r i t e r ia  u t i l i zed  was fa i r  or non- 

discriminatory or whether i t  was the best or 

proper c r i t e r ia  to be used or whether i t  was not 

the best, I object on, f i r s t ,  the grounds that 

starting this lawsuit the p la in t i f f s  have admitted 

that the c r i t e r ia  or evaluation c r i t e r ia  u t i l ized  

were fa i r  and non-discriminatory of and in i t s e l f ,  

that the only a llegation they are making is the 

c r i t e r ia  as applied to the various teachers were 

discriminatory. Second, I think that on many 

occasions perhaps this Court, I know the Eighth 

Circuit Court of Appeals has stated there is no 

proper c r i t e r ia  or d irect exactly the proper 

c r i t e r ia  to be u t i l i z ed  in such a case as this,

le john - D irec t

that experts across the country have disagreed as 

to what c r i t e r ia  is proper. And, th ird ly ,  i f  i t  

is the intention of these witnesses to t e s t i f y  as 

to the application of the c r i t e r ia  to the various 

teachers, then I object to their qua l i f ica t ion  to 

do so insofar as 1 doubt very seriously i f  they 

have ever been to the Plum Bayou School D is tr ic t  

No. 1, and, too, i f  they know anything concerning 

the facts of this case.

THE COURT: Well, of course, in the f i r s t

place the Court doesn’ t know what this witness

GLENN H PERRIN 
O f f ic ia l  C o u r t  R e p o r t e r  

F ed e r al  B u il d in g  
EL Do rad o__a r k _i m n



i s  going to t e s t i f y  to ,  thus far doesn 't  even

qua l i f ies  as an expert, can do so, why he can 

give opinions, i f  he can 't ,  then he cannot be 

giving any opinions regarding evaluation or 

anything else that might be involved.

Insofar as the other point that you raised 

about whether they have been to the school or 

not, I don't know that the Court is concerned 

about that one way or the other. We w i l l  just 

wait and see what the testimony is going to 

be.

MR. KAPLAN: Your Honor, before we do commence,

procedurally I would l ike to clear up one thing 

and that is I would l ike  to move for the admission

of P l a i n t i f f s ’ Exhibits No. 1 and 2 which I did not

do before.

THE COURT: What were P la in t i f f s '  Exhibits 1

and 2?

MR. KAPLAN: P la in t i f f s '  Exhibit No. 1 was the

evaluation form or the Principal,  Mr. Edwards; and 

No. 2 was a le t te r  of Mr. Bradshaw regarding 

interscholastic sporting a c t i v i t i e s .

THE COURT: Yes, they w i l l  be received for

the record.

know his name; and, second place, i f  he

GLENN H PERRIN 1

EL non  A __i a n u . i .  -

O f f i c i a l  C o u n t  R e p o r t e r

F ed e r al  B u il d in g



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BY MR„ KAPLAN:

Q- Mr. L i t t l e j o h n ,  p l e a s e  t e l l  us your name and address.
A. W a l t e r  L i t t l e j o h n ,  3 3 1 4  S o u t h  Main, Pine Bluff.
Q. W h a t  i s  y o u r  p r e s e n t  o c c u p a t i o n ,  D r .  Littlejohn?
A- S u p e r v i s o r  o f  S t u d e n t  T e a c h e r s ,  AM&N College, Pine Bluff.
Q- How l o n g  h a v e  y o u  h e l d  t h a t  p o s i t i o n ?

A .  F o u r  a n d  a  h a l f  y e a r s .

Q- B e f o r e  y o u  g o  i n t o  s o m e  o f  your duties in that capacity, 
w o u l d  y  i u  t e l l  u s  y o u r  e d u c a t i o n a l  background, where 
y o u  r e c e i v e d  y o u r  d e g r e e s ,  a n d  the employment that you 
h a v e  h a d  p r i o r  t o  AMAcN College?

A .  B a c h e l o r ' s  D e g r e e  i n  M a t h e m a t i c s ,  AM&N College; Master’s I 

D e g r e e  i n  E d u c a t i o n a l  A d m i n i s t r a t i o n  from the University
I

o f  A r k a n s a s ;  D o c t o r ' s  D e g r e e  in Secondary Education from j 

t h e  U n i v e r s i t y  o f  A r k a n s a s .  I  have been employed as a 
c l a s 8 r o o m t e a c h e r ,  school principal, public school 
s u p e r i n t e n d e n t ,  a n d  p r i o r  t o  coming--immediately prior 
t o  c o m i n g  t i  A r k a n s a s  AM&h, I was employed as Assistant 
P r o f e s s o r  o r  E d u c a t i o n a l  administration, Texas Southern 
U n i v e r s i t y  a t  H o u s t o n .

Q. How l o n g  d i d  y o u  h a v e  t h a t  p o s i t i o n ,  s i r ?

A .  One  y e a r .

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.An:  v o u r  1 u t i . e s ,  w o u l d  y o u  p l e a s e  t e l l  us what your 
d u t i e s  a r e  a L  p r e s e n t  a t  A r k a n s a s  AM&N College?
I h a v e  t h e  r e s p o n s i b i l i t y  o f  supervising our Student

GLENN H PERRIN 
O f f ic ia l  C o u r t  R eporter  

F ederal  B u il d in g
r  1 h O B l n n  A  D V  A k lA A A  "» A "n R A m



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Teachers in secondary education who are preparing to 

teach»

In that capacity as a supervisor of student teachers, 

do you have occasion to be involved with them and with 

school administrations throughout the State o f  Arkansas

on evaluation projects for teachers?

Yes.

Are you familiar with the l i te ra ture  in the f i e ld  of 

evaluation and with practices generally in evaluating 

public school personnel, teaching personnel?

Quite familiar with that c r i t e r ia ,  yes, s i r .

In addition to your academic experience with evaluation, 

were you also familiar with evaluation both as a high 

school principal and as a high school superintendent?

Yes, we went through the processes of evaluating teachers 

for the purpose of improvement of instruction in the 

schools I worked in, both as a principal and I had a 

part in i t  as a superintendent.

Dr. L it t le john, would you speak up just a l i t t l e  b i t  

louder so that we can a l l  hear you?

Yes. I said that we had--I had respons ib i l i t ies  in 

evaluation for the purpose of improvement of instruction 

both as the school principal and as a superintendent of 

the schools.

Thank you, s i r .  Are there some general techniques or

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g



guidelines that are accepted by evaluators, school 

systems, academicians, in regard to evaluation ot public 

school teachers?

Yes, there are. In particular, area that you are speaking

of now?

2. Yes, I am interested in guidelines, techniques of

c r i t e r ia  involved in evaluating teachers both in regard 

to their competency, retention, and improvement, a l l

three areas.

Yes, we tollow, in our supervisory program of student 

teachers, a set of c r i t e r ia  for this purpose. This 

c r i t e r ia  includes the areas of instruction in which the

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teacher is supposed to be competent in, involves the 

methods and procedures employed by the teacher in this 

process, and involves materials and how teachers use 

and make use of these materials in the process of

instructing their classes.

Now, in regard to a l l  of these factors, what procedure 

do you .ollow in evaluating teachers? How do you go 

about i t ,  just the pure physical act?

There are three individuals that are to ta l ly  involved 

in the evaluation process. As a col lege supervisor I 

am one of those persons, and the second person is the 

cooperating teacher that our student teachers are 

assigned to, and the third person is the student teacher

it

GLENN H PERRIN  
O f f i c i a l  C o u r t  R e p o r t s *  

F e d e r a l  B u i l d i n g

£1_IV4BAISF>_A_AJ



Litt le john - Direct 124

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himself, We--

I am sorry, I d idn 't  mean to interrupt you. Now,-- 

We use materials for evaluation, we have various printed 

materials for evaluation, and the f i r s t  process or the 

f i r s t  part of that process is that I go over with the 

student teacher these areas that we look for and we 

think that these are the things when done we l l  would 

constitute a good teacher. The cooperating teacher also 

has copies of these, and i t ' s  my respons ib i l i ty  to go 

over these with her, so a l l  three of us w i l l  know the 

things we are looking for in the student teacher in 

terms of teacher competency.

Dr. L it t le john , would you t e l l  us i f  a l l  of these factors 

which we are about to discuss and the method that you 

have just described to us is equally va l id  for a teacher 

already c e r t i f i e d  and in the classroom as we l l  as a

student teacher?

Most educators look at this procedure as one o f  the 

better procedures for evaluation, yes.

And in place of the co l lege  professor and the cooperating 

classroom teacher in the case of someone who is already 

in the classroom, who would you substitute?

The cooperating teacher would be the supervising 

principal at the high school; the student teacher would

be the teacher in the classroom; and my position is

OLENN H PERRIN 
Of f ic ia l  Co u nt  R t o n in n  

P kdcnal Bu ild ing ! jA



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similar to that of the superintendent of schools.

Q. Now, you told us that you yourself become involved in 

discussing a l l  of these various c r i t e r ia  with the 

individual. Is that a proper ro le  for anyone in an 

evaluation to take to actually ac t ive ly  discuss these 

c r i te r ia?

a . That is one of the main respons ib i l i t ies  of an

individual in this capacity to discuss the material 

before and even after  observation.

Q. Dr. L it t le john, I w i l l  hand you a document which has

been marked for iden t i f ica t ion  purposes as P la in t i f f s '  

Exhibit No. 3. Could you ident i fy  that for us and 

describe what i t  is?

a . Yes, this is a Confidential Report of the Student

Teacher, and this document here is f i l l e d  out by the 

cooperating teacher, that is the person that is with 

our student teacher each and every day that he is in

the classroom.

a. Now, I see this is a several page document with a number 

of items on i t .  Is the individual rated on a l l  of these

L i t t l e j o h n  - D irec t 123

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items ?

Each and every one of these items on here.

A l l  r igh t .  I hand you a document which has been marked 

as P la in t i f f s *  Exhibit No. 4. Would you t e l l  us what 

that is?
------------------- -------- -----------------------------------------------------------|—

GLENN H PERRIN
O f f i c i a l  C o u r t  R v o u t m  

P c o c m a l  B u i l d i n g  

EL P O W A P O  A « K A N « A «  7 I 7 » C



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A. This form we use as the student's se l f-appraisa l form. 

The student himself f i l l s  this particular form out, and

this is his opinion of how he himself rates or ranks as 

a teacher.

1 wil1 hand y°u a document that has been marked for 

iden t i f ica t ion  purposes as P la in t i f f s '  Exhibit No. 5, 

and would you t e l l  us what that is?

This again is another copy of the cooperating teacher's 

confidential report that the cooperating teacher f i l l s  

out on the student teacher that he has charge o f .

I A l l  r igh t .  And a document marked for iden t i f ica t ion  

as P l a in t i f f s '  Exhibit No. 6. Would you t e l l  us what 

that is?

This is a progress record that is f i l l e d  out jo in t l y  by 

the cooperating teacher and the student teacher. The 

reason tor the two people working on i t  so that they 

can get together as to how the student teacher f i t s  

each of these categories. An example is that the 

cooperating teacher nay decide on the progress record 

that the student teac her is only doing this much, the

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student teacher may think i t ' s  more, and there is an 

opportunity for discussion to point out the areas where 

I think I am or am not or where the cooperating teacher 

thinks that the student teacher is or is not doing this, 

so by jo in t ly  f i l l i n g  this out we can keep up with the

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

_________________________ EL DOltnn a » » . - . . .  -----



127

continued progress of the student teacher.

Q- Now, are a l l  of the factors and a l l  of the items on

those various lorms necessary to make a proper unbiased 

evaluation of any particular teacher?

A Yes, i t ' s  very important that the student has a s e l f -  

appraisal, that the student has an opportunity to 

discuss progress with the cooperating teacher and with 

the co l lege  supervisor for the purpose of f inding areas 

of strengths and weaknesses and making suggestions for 

improvement in these particular areas.

Q. How much time does anyone making such an evaluation 

whether for student teacher or for a teacher with an 

existing c e r t i f i c a t io n  have to spend and under what 

conditions must that time be spent to make any kind of 

a legitimate evaluation.

A Our cooperating teachers spend the entire 10 weeks of 

class period, that is ,  each class period every day, in 

making their confidential report. As a co l lege 

supervisor, 1 am with the teacher and the cooperating 

teacher, each individual student teacher and cooperating 

teacher, from f ive  to six times during the 10-week 

period, and this includes a fu l l  class period followed 

by--preceded by a conference and followed by a 

conference each time I am v is i t in g  there.

d What is toe purpose of the pre-cLass v i s i t  conference?

GLENN H PERRIN 
O f f ic ia l  C o u r t  R eporter  

F e d e r al  B u il d in g

L i t t l e j o h n  - D irec t



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A. Well,  we have student teachers in d i f fe ren t  areas, and 

as a supervising teacher, we f e e l  that the cooperating 

teacher has more expert ise  in each cooperating teacher's 

indiv idual area than I would, I wouldn't be fu l ly  

competent in both Mathematics, Social Science, and 

English, and this type thing so far as the subject 

matter area is concerned; therefore, i t ’ s necessary that 

I at f i r s t  get an opportunity to look at the student 

teacher 's  plan, lesson plan, for that day, discuss with 

him these things, the subject content that is going to 

be gone over with, the procedures and methods that the 

student teacher is going to employ in teaching these 

for that part icu lar  class period, and the materials that 

are going to be used and the student a c t i v i t i e s  or how 

the student w i l l  be involved in this method and proced­

ure, so I w i l l  have f u l l  knowledge prior to observing 

of what is going to go on.

The reason tor the conference afterwards is to get an 

understanding of where 1 may have misinterpreted the 

employment of  certa in  procedures that the student

teacher may use.

Q- Is i t  possible  for you, someone who has had experience 

in this f i e l d ,  to make an evaluation of a teacher's 

performance that is at a l l  fa i r  without knowing where he 

was going and what he was trying to do?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g



129L i t t l e j o h n  - D irec t

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No, not— it's almost impossible to do this for several 
reasons. For example, in an elementary class, the 
objective for that particular day, one aspect of the 
program may be to encourage students to openly express 
themselves, and if 1 don't know this, I may be in the 
classroom thinking that this is an opportunity for 
students to show their competence in a certain subject 
matter so I get a complete different picture of what 
the objective was and would probably indicate the 
student teacher wasn t doing her job. Now, if I knew 
prior to that what the objective was, the procedures 
and methods and contents, then this would be most 
helpful.
Dr. Littlejohn, I want to ask you a question directed 
specifically at existing teachers, teachers who have 
certification. How Important and what role should the 
evaluation given by the immediate supervisor be, either 
the immediate supervisor, or in the case we are dealing 
with, with the Principal?
That person plays probably the most important role. Our 
person in that respect is the cooperating teacher and 
that person is with the student teacher every day, each 
and every day, and this confidential report is a very 
valid part of our total evaluation of the student 
simply because of day-to-day contact with that

GLENN H PERRIN 
O f f i c i a l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7»o



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individual, so we place a lot of value on this.

Q. In the situation where there is an immediate Principal 

and an administrator either in the same facility or in 

an adjacent or adjoining facility, what kind of weight 
would you give to, as a person involved in this 

procedure, to the immediate Principal's evaluation and 

the evaluation of the remote administrator?

a. The immediate Principal's evaluation would probably 

constitute somewhat better than 70 percent of the 

value, total value; however, I certainly would add to 

that that in the areas that I, along with the Principal, 

did not agree on, whether it's above and below, I would 

have to have a conference with the Principal and we 

discuss why we don't do this, point out certain things, 

and the cooperating teacher--I mean the classroom 

teacher should be in on the conference, too, in terms 

of those three things.
Q. In an evaluation, either for the purposes of determining 

the teacher’s progress in his chosen profession or 
evaluation to determine whether or not a teacher should 

or should not be retained, is the teacher necessary for 

a complete and total evaluation to be a participant in 

this procedure?

a Yes, it's quite necessary, for this reason: If a

supervising Principal decides that this is the thing
GLENN M PERRIN

Of f ic ia l  Cou nt  Rbnontbn 
Fcokral Ru ilo in o

_______________________________________ El__CKMUIIO TITNO___________________________________________

L i t t l e j o h n  - D irec t



1

Litt le john - Direct

j| I you.^ren't doing well  or the teacher's

2 doing w e l l ,  then the teacher should know about this in

3 order to give an explanation of why he's using those

4 procedures and over a custom period of evaluation to

5 have an opportunity to improve in these particular

6 areas. In many secondary schools, and when I was a

7 Superintendent, the evaluation procedures used and the

8 report had to be signed by both the supervising Principal

9 and the teacher that was being evaluated, which gave me

10 as Superintendent the idea that what was said on i t

11 is agreeable by both persons.

12

1
Q- Dr. L it t le john , were you present during the testimony

13!I
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14 : | A. I was.

15 Q- During a l l  of i t?

“ j | A. Yes.

17 j i Q. Dr. L it t le john, 1 would l ike to ask you a hypothetical

18 j question and ask you for your opinion at i t s  conclusion.
19 Assume a Superintendent who evaluated a group of

20 teachers using the following f i v e  c r i t e r ia ,  "Teacher

21 ! j Competency", "A b i l i ty  to Maintain Classroom D isc ip l ine" ,

22 ; "Teacher-Pupil Relationship", "Teacher-Teacher Relation-

23 ship", and "Willingness to Cooperate with the Total

24 School Program". Assume further that this Superintendent

| i Jj
L has his o f f i c e  at a f a c i l i t y  eight miles remote from ~ “

!i 6 LC N N  H PERRIN J 
O f f i c i a l  C o u r t  R ep o r t er  M  t W  J 0 &  

F e d e r a l  B u il d in g  §
CL. Do r a d o  A r k a n s a s  titso V CJK.'



L i t t l e j o h n  - D irec t 132

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these teachers. And assume further that this Super intendm­

ent did not use for his evaluations at a l l  the 

evaluation of the immediate Principal,  and that the 

v is i ta t ions  to the classes were of approximate 15-minute 

duration for a period of one per month on the average, 

could that individual possibly give a fa i r  evaluation 

of that teacher‘ s performance?

I t ' s  my opinion that i t  would be almost impossible to 

give a fa ir  evaluation of the teacher's performance 

as an instructor with the limited amount o f  time spent 

in the classroom by that person and without the pre- and 

post-conferences with the teacher involved.

Dr. L it t le john, you heard some of the testimony this 

morning regarding dif ferences in evaluation between the 

immediate supervisor and the Superintendent. For 

example, with regard to Mrs. Lois Thomas, in "Discipline 

Within the Classroom". Her supervisor evaluated her 

with the highest possible grade, a No. 1, and her 

Superintendent evaluated her with a No„ 5, the worse 

possible evaluation. Now, le t  me add one factor.  The 

First Grade,that you also learned that she taught the 

First Grade. Can you form any conclusion as to the 

log ica l ,  any possible log ica l  explanation for a 

discrepancy of such degree?

Yes, I can, A person that teaches the F irst Grade w i l l

GLENN H PERRIN 
O f f i c i a l  Co u rt  Reporter

F e d e r a l  B u i l d i n g  

EL Dorado  A rk an sas  7i7so



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have a group o f  individuals of this age group, six years 

plus, six or seven years, this is a very active  group of 

young people and their attention span at this age is not 

more than 12 to 13 minutes, which means that i t ' s  almost 

impossible to get a young person at this age to concen­

trate on any one thing for any longer than 12 or 15 

minutes; therefore, toe a c t iv i t i e s  have to be varied.

In the process of varying the a c t i v i t i e s ,  the teacher 

w i l l  have students that w i l l  be moving around at this 

grade le v e l .  They may be moving around at the request 

of the teacher or at the permission of the teacher to 

involve themselves in the second a c t iv i t y  a fter  they have 

finished the f i r s t  one or when they get somewhat bored 

with the f i r s t  one. Now, a person that spends a greater 

part of his time in supervising or spends as much as an 

entire day with a teacher w i l l  see pract ica l ly  a l l  of 

the a c t iv i t i e s  i f  the teachers. That person w i l l  see a 

time when these students have--are concentrating for 12 

or 14 minutes, they w i l l  . êe a time when the a c t iv i t i e s  

w i l l  be more physical, and then they w i l l  see another 

concentrated time. A person spending a small period of 

time may come in at the very time that most of the 

ac t i v i t y  o f  moving around or moving to another ac t iv i ty  

or another lesson is being going on; so, therefore, a 

p e r s o n  s p e n d i n g  a lot of time may see the total program

GLENN H PERRIN 
O f f ic ia l  C o u r t  R eporter  

F ed e r al  B u il d in g  
EL Do r a d o  A r k a n s a s  71730

L i t t l e j o h n  - D irec t



whereas a person spending a short period of time may 
only see the activity or he may spend a short time- 
period o, time and only see the concentrated activity 
how these students are really down to work.
Is it unusual, then-I take it that it is not unusual, 
then, for First Graders-strike that. Is it also 
usual for some First Graders to be in that concentrated 
period when others are in that period where they are 
shifting their focus between one attention span and 
another, or is it common in the First Grade to have 
everybody doing the same thing at the same time?

No, on the contrary, you will have varied activities. 
Sometimes the First Grade teacher has as many as three 
to tour activities going on at the same time within the 
same classroom. This is one aspect of group work. One 
group of students may be scribing or coloring pictures 
or reading words, another group may be working in the 
Science corner or Science activities, another group may 
he over in the Library corner selecting library books, 
and if these varied activities are going on in the same 
classroom, you are going to have what would look to 
some people as confusion.

D r . uittlejohn, in your capacity as a teacher--student 
teacher evaluator and student teacher supervisor, do you 
work in both integrated and non-integrated situations?

GLENN H PERRIN 
O f f ic ia l  C o u r t  R eporter  

F ed e r al  B u il d in g
P I____H f l B i  r\/-t____A r-. ̂  ■ —___________ ( Q / ) ,



135
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Y e s ,  we  d o .  A t  p r e s e n t ,  a t  t h e  c u r r e n t  y e a r ,  w e  a r e  

w o r k i n g  m o r e  i n  i n t e g r a t e d  s i t u a t i o n s  t h a n  w e  h a v e  i n  

t h e  p a s t ,  b u t  w e  d o  h a v e  b o t h  t h i s  y e a r ,  a n d  I  h a v e  

w o r k e d  i n  t h e  l a s t  f o u r  y e a r s  i n  a l l  o f  t h o s e .

D r .  L i t t l e j o h n ,  i n  y o u r  e x p e r i e n c e ,  h a v e  y o u  h a d  a n y  

e x p e r i e n c e  d i r e c t l y  w i t h  i n s t i t u t e s  h a v i n g  t o  d o  w i t h  

o r  c u r r i c u l a  h a v i n g  t o  d o  w i t h  u n i f i c a t i o n  o f  s c h o o l s  

a n d  p r o b l e m s  a r i s i n g  o u t  o f  d e s e g r e g a t i o n ?

Y e s ,  L h a v e  s e r v e d  a s  c o n s u l t a n t  on o c c a s i o n s  f o r  t h e  

A t r a x  C e n t e r  l o c a t e d  a t  O u a c h i t a  U n i v e r s i t y  a t  

A r k a d e l p h i a  w h i c h  w e  i n v o l v e  o u r s e l v e s  i n  w o r k i n g  w i t h  

t e a c h e r s  w h o  a r e  c u r r e n t l y  u n i f i e d  a n d  t h o s e  w h o  a r e  

g o i n g  i n t o  u n i f i c a t i o n .

B a s e d  o n  y o u r  e x p e r i e n c e  a s  a n  a d m i n i s t r a t o r  a n d  a s  a n  

a c a d e m i c i a n  a n d  i n  t h e s e  i n s t i t u t e s  a n d  i n  y o u r  

c o n s u l t a n t  e x p e r i e n c e ,  d o  y o u  f i n d  t h a t  t h e r e  i s  a n y  

d i t t e r e n c e  i n  d i s c i p l i n e  w i t h i n  a  c l a s s r o o m  s i t u a t i o n  

b e t w e e n  t h e  b l a c k  t e a c h e r  a n d  t h e  w h i t e  t e a c h e r ?

O v e r a l l  t h e r e  i s - - i f  y o u  t a k e  t h e i r  o v e r a l l  p i c t u r e ,  

t h e r e  i s  b a s i c a l l y  n o  d i f f e r e n c e  b e t w e e n  t h e  t w o ,  i f  

i t ' s  t h e  o v e r a l l  p i c t u r e .  T h e r e  m a y  b e  a  c o n c e p t  o f  

w h a t  c o n s t i t u t e s  g o o d  d i s c i p l i n e  a n d  w h a t  d o e s  n o t  

c o n s t i t u t e  d i s c i p l i n e  d e p e n d i n g  o n  t h e  i n d i v i d u a l ' s  

i d e a s  o i  w h a t  i s  a n d  i s  n o t  g o o d  d i s c i p l i n e ,  s o ,  t h e r e ­

f o r e ,  y o u  ma y  h a v e  a w h i t e  h e r e  t h a t  b e l i e v e s  t h a t  t h i s

GLENN H P E R R I N  
O f f i c i a l  C o u r t  R eporter  

F e d e r a l  B u i l d i n g

FI Hob  a no A nk- i M L



Li t t l e j  ohn D irec t 136

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i s  g o o d  d i s c i p l i n e  a n d  a  b l a c k  t h a t  t h i n k s  i t  i s n ' t ,  

a n d  y i u  ma y  h a v e  j u s t  t h e  o p p o s i t e ,  t h e  s a m e  s i t u a t i o n ,  

a  b l a c k  w h o  t h i n k s  i t  i s  a n d  a  w h i t e  w h o  t h i n k s  i t  i s  

n o t .

S o  w h a t  y o u  a r e  s a y i n g  i s  t h a t  s t r i c t  o r  l a x  d i s c i p l i n e  

i s  n o t  a  f u n c t i o n  o f  r a c e  b u t  a  f u n c t i o n  o f  t h e  

t e a c h e r ' s  p e r s o n a l i t y ?

Y e s ,  i t ' s  a  f u n c t i o n  o f  o p i n i o n  o f  t h e  t e a c h e r  t e a c h i n g  

t h e  c l a s s  a n d  w h a t  c a n  b e  d o n e  w i t h  c e r t a i n  a c t i v i t i e s ,  

y e s ,  v e r y  d e f i n i t e l y  s o .

MR.  K A P L A N :  T h a t ' s  a l l .

G R O S S  E X A M I N A T I O N

MR. STARLING:

D r ,  L i t t l e j o h n ,  I  j u s t  h a v e  a  c o u p l e  o f  q u e s t i o n s  t o  

a s k  y o u .  F i r s t  o f  a l l ,  w i t h  r e f e r e n c e  t o  t h e  p r o c e d u r e  

w h i c h  y o u  a r e  u s i n g  i n  A r k a n s a s  A M & N , h o w  l o n g  d i d  i t  

t a k e  y o u  o r  y o u r  p r e d e c e s s o r s  t o  a c h i e v e  w h a t  y o u  h a v e  

n o w  i n  r e f e r e n c e  t o  t h a t  e v a l u a t i o n  p r o c e d u r e ?

Y o u  me a n  how l o n g  t o  a c h i e v e  t h e  e v a l u a t i o n  i n s t r u m e n t ?

21 ;j Q.

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N o ,  t o  c o m e  u p  w i t h  t h e  p r o c e d u r e  w h i c h  y o u  u s e  n o w .

I n  o t h e r  w o r d s ,  h o w l o n g  d i d  i t  t a k e  y o u  t o  c o m e  u p  w i t h  

t h e  v a r i o u s  c r i t e r i a  a n d  t h e  p r o c e d u r e  w h i c h  y o u  n o w  

a r e  t a l k i n g  a b o u t  u s i n g ,  t h e  c o o p e r a t i v e  t e a c h e r  p l a n  

a n d  a l l  o f  t h i s ,  how l o n g  d i d  i t  t a k e  y o u  a n d  y o u r

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

FI__Hod a no__Adve  mb a m



predecessors at Arkansas AM&N to come up with this

partic iar type ot procedure?

The--certain aspects of the procedures are discussed 

prior to a student teaching experience of student 

teachers. Now, many of these procedures that we use 

here have been used for a number of years by people who 

have worked at the inst itu t ion before I have.

1 1 see“ Let me ask i t  this way: In other words, is i t

possible to come up with a procedure l ike  you are talking

L i t t l e j o h n  - Cross

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about u t i l i z in g  in say a period o f  four months?

With the available information on methods and procedures 

of evaluating, this is highly possible with several 

people who are going to be involved in evaluation 

also involved in instruction of these items.

Now, I believe you t e s t i f i e d  that the procedure which 

you a l l  are u t i l i z in g  out there is one of the better 

procedures ?

In our opinion, yes.

Are there other procedures?

The colleges in Arkansas that have supervised student 

teaching programs, many oi them--most of them w i l l  use 

some of the same procedures that we have here. There 

are other procedures, but the main ingredients of these

procedures are also a part of those other procedures 

that are recognized as the better procedures in our

GLENN H PERRIN 
O ff ic ia l . C o u r t  R e p o r t e r  

F e d e r al  B u il d in g

li _  . _______ EL Do r ad o__A r k a n s a s  7 i7*n



L i t t l e j o h n  - Cross 138

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Lie 13 .

Then am I correct in saying that you are saying that 

your procedure is not the only procedure or not the only 

proper procedure that could ever be u t i l i z ed ,  is that

correct?

It  is our opinion that our procedure is--ranks among 

the better procedures used for supervising student 

teachers.

Dr. L it t le john, in reference to the hypothetical 

question which Mr. Kaplan asked you, assuming that I 

believe you had a school here, an elementary school 

here with a Head Teacher who was in daily  contact with 

them and a Superintendent who was located at another 

D is tr ic t - -o r  another area but came over and v is i ted  maybe 

15 minutes in the classroom, I believe Mr. Kaplan's 

question to you was could the evaluation o f  the teachers 

by the Superintendent based on his 15 minutes v i s i t s  to 

the classroom period ica l ly  be done in a f a i r  manner, 

and your answer was, I be l ieve ,  that i t  would be 

d i f f i c u l t  to get a truthful evaluation of the teacher.

Is that not a fa i r  statement?

This is primarily what l said, yes, s i r .

Well, assuming the same set of circumstances, could that 

Superintendent make his evaluation, although i t  may not 

be the best way to evaluate i t ,  on factors other than

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 * 0



139Litt le john - Cross ^ ^ 9

1 race?

2 1 h. Would you repeat that, sir?

3 Q. Well, in ither words, i f  the Superintendent came over,

4 as Mr, Kaplan stated, assuming that he—his o f f i c e  was

5 i at another school and they were in the D is t r ic t ,  and in

6
1

making his evaluation he came over to this school and

with 15 minutes v is i ta t ion  in the classroom over an

8 extended period of three years, in making his evaluation,

9 1 although i t  may not be the best method o f  evaluation,

10 could he make his evaluation based on anything— or could

11 he make his evaluation on other factors other than race?

12 He could make his evaluation on the factors that he has

13 1
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l is ted  without regard to race, yes, in my opinion.

" i MR. STARLING: 1 bel ieve tha t ’ s a l l .  Thank you.

15!

16 REDIRECT EXAMINATION

17 j BY MR. KAPLAN:

• Q- Dr. L it t le john, based on your knowledge of this area

19 and based on your testimonv--your presence in the

20 courtroom this morning, do you have an opinion as to

21 j whether the evaluation was based on factors including

22 race ?

23 THE COURT: I don’ t believe that to be a

24 proper question, Mr. Kaplan. 1 don't believe
(1

25 that this witness has attempted to quali fy  as

|l
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i!

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  t  

F e d e r a l  B u i l d i n g  B  
EL D o r a d o  A r k a n s a s  7 I 7 S 0  M  m a J *4%.



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an expert on the f i e ld  or rac ia l  problems.

MR. KAPLAN: Your Honor, I - -

THL COURT: You are invading the Court’ s

prerogative now from a l l  of the facts and 

testimony--

MR . KAPLAN : Your Honor , —

THE COURT: --that the Court is going to

decide this case on.

MR. KAPLAN: Your Honor, I am responding f i r s t l y  to

counsel's question and attempting to c la r i f y  his 

response and asking him not only could i t  have 

availed race, could i t  have included race.

THt COURT: You can ask him i f  under that

could i t  he made on the basis of race. He 

can answer-- 

Q. Could i t  a lso--

THE COURT: - - i t  in the a lternat ive .

Q. Could i t  also have been based on factors which included 

race, Mr.--Dr. L itt le john?

A. In my opinion, yes, i t  could have.

Q. Are the techniques that you have talked about generally 

well-known to adninistratirs in both this state and in 

education throughout the United States?

A It has been my experience and my involvement with both 

state, loca l ,  and national associations that deal with

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

L i t t l e j o h n  - R e i i r e c t





141L i t t l e j o h n  - Recross

7

this business of supervision, and these that we have 

l is ted  here are well-known among these organizations in 

their annual and semi-annual and national meetings, 

they are discussed. It  is quite readily available in 

the l i te ra ture  that is written in the area of super­

v is ion, also.

MR. KAPLAN: Thank you, Dr. L it t le john .

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RECROSS EXAMINATION

BY MR. STARLING:

One f ina l  question, Mr. L it t le john . In your experience 

in and around Arkansas with the various school d is t r ic ts  

and in the problem of unification of some o f  these 

school d is t r i c t s ,  how many school d is t r ic ts  do you know 

in the year 1968-’ 69 or the years 1969-‘ 70 u t i l i zed  the 

procedures and techniques which you have emphasized 

today?

I have not been concerned with this aspect of the 

u t i l i z a t io n  of the techniques for the purpose of 

deciding whether or not to keep a teacher or not to keep 

a teacher, our conversations deal with the evaluation 

for the purpose o f  improving the instruction; therefore,

I have not consulted with anyone that have used 

evaluation techniques for the purpose of deciding whether 

to keep or not keep a teacher.

GLENN H PERRIN  
O f f i c i a l  C o u r t  R k p o r t i n  

F e d e r a l  B u i l d i n g

rt nOBAHO A BE A MB A« 7 f 7*n 197,



142

!| MR. STARLING: Thank you, s i r .

2 THL COURT: Dr. L it t le john , just a minute,

3 please, s i r .
ii

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L i t t l e j o h n  - Court

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BY THE COURT:

Q. Dr. L it t le john , do you know i f  p o l i t i c a l  en t i t ie s ,  such 

as the State o f  Arkansas, Department of Education, or-- 

where did you say you come from, or did you say?

A. Pine Bluff is my home, I worked in Magnolia, Arkansas, 

in the public school system.

Q- I thought you said you were Superintendent of Schools 

somewhere?

A. That is r igh t ,  the Walker School D is tr ic t  No. 33, in 

Magnolia, Arkansas.

Q. Your experience has been en t ire ly  within this State,

then ?

A. No, I worked as Assistant Professor of Educational 

Administration in Texas at Houston.

Q. Well, I had some impression that you mentioned Houston 

and I assumed you had experience down there. But, so 

far as you know, has any state entity  or organization 

in connection with i ts  approved educational pol ic ies  

with reference to secondary education adopted any 

formula with reference to evaluation of teachers?

A. I i  I understand you correctly ,  s i r ,  you are wondering--

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n r a r  t i t r o



143

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Q- Well, has the state, either throu^i the state provided 

organization or either the--well ,  association of 

teachers, anyone who has respons ib i l i ty  in that f i e ld , I

approved and adopted any spec i f ic  c r i t e r ia  or formula 

for evaluating teachers?

A. No, no agency that c e r t i f i e s  school l ike  National Council 

of Teacher Educators or intake National Council of 

Teacher Association, none of these to ray knowledge has 

said sp ec i f i c a l ly  "We have this instrument developed 

and this is the instrument that"--

Q- Does the State of Arkansas, in any of i ts  educational 

f i e ld s ,  agencies, associations, or whatnot, have any 

approved c r i t e r ia  for secondary schools to follow?

A. No. Professional associations that work in these areas i
w i l l  recommend certain c r i t e r ia ,  but so far as approving 

i t  as the c r i t e r ia  to use, no, s i r .

Q- What is the purpose in your f i e  Id--which I am very much 

interested in, I had heard this before—what is the 

purpose of your educational programs in the area of 

co l lege  work of evaluating student teachers?

A. The primary purpose of our to ta l  evaluation process for 

student teachers is for the purpose of improvement of 

instruction. Here, through our evaluating processes, 

we find the various strengths and weaknesses of our 

student teachers. This gives us, along with the student j

GLENN H PERRIN 
O r r i c i A L  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

_________________________________________EL D o r a d o  A r k a n e a e  7 i 7 » o

L i t t l e j o h n  - Court



144

teacher, an opportunity to improve .̂.upon these areas of 

weaknesses and to continue strengthening the areas where 

they are strong when i t  comes to t^e to ta l  program of 

teacher competency.

Q. Well, is i t  ever used to compare the a b i l i t i e s  or the 

capab il i t ies  of either student teacher or teachers 

themselves insofar as you know?

A. Not teacher against teacher.

Q- That is what I am talking about.

A. No.

Q- Never used for that purpose.

A. Teacher against recommended procedures of teaching. So 

a l l  teachers are compared against these opinions of 

educators as recommended c r i t e r ia  which would indicate 

this person is doing a good job in the instructional 

program.

Q- Well, in doing th is, in your evaluations, do you arrive 

at a mark as to what they are ent it led  to as to how 

good or how bad they are?

A. We arrive at what we c a l l  recommendations based on our 

previous recommendations of people or student teachers 

who have done well in this area. I f  I may explain, we 

may write a summary recommendation for a teacher and 

indicate in our opinion and based on our work this 

teacher has the potential of becoming a master teacher,

GLENN H PERRIN 
O f f i c i a l  C o u r t  R k p o r t c r  

F e d e r a l  B u i l d i n g

___________________________________EL D o r a d o . A r k a n g a r  7 i 7 » o

L i t t l e j o h n  - Court



145L i t t l e j o h n  - Court
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quote, master teacher, that is one of the better 

teachers. Now, this is based on our follow-up program 

through our placement service at the co l lege  where we 

have recommended a person, a person has gone into an 

area, we have got feedback on the person, and that person 

has Line well ,  and he had some of the same qua l it ies  as 

the previous person did, so, therefore, i f  a student 

aide here shows some of the qua lit ies  that our research 

shows that students 1 0 , 1 2 , 14, and 16 have, we make the 

same recommendation and t e l l  the people who are employing 

him this is based on our recommendation and our previous 

experience.

But this is a l l  used for the improvement of the teaching 

techniques and the capab i l i t ie s  of the ind iv iduals ,— 

That's r ight .

--not for any comparative purposes of one against 

another?

No, no, not as far as we look at i t .  I imagine, and I 

did this when I was a Superintendent, I  would look at 

the recommendation before employing a person of the 

various people, the colleges ,  the previous employers, 

and people, and I compare recommendations for the purpose 

of employing, yes.

Oi course , that wouli be based on the practical

rea l izat L on - -
-------------- _

ii

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  h i m ~ 2 0 l  A .



146
L i t t l e j o h n  - Court

2 Q.

4  A .

5 i; q.

6

Yes, s ir .

--as to whether or not there were ample teachers 

ava i lab le  to employ, would i t  not?

Agreed, yes, s i r .

And i f  you couldn 't find teachers a va i lab le ,  then you 

wouldn't look too close at that, you are looking for  a 

teacher now.

8 ! A.

10

We would have to f i l l  i t  with what we have, yes, s i r .

THE COURT: Anything, gentlemen, in view of

these questions?

li

12 REDIRECT LXAMINATION

13

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BY MR. KAPLAN:

Q.

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Dr. L i t t l e jo h n ,  the c r i t e r i a ,  the methods that you 

described to us and described to His Honor in response 

his questions, would have--would they have equal

v a l id i t y  and would they be as necessary to a f a i r  

evaluation whether you were doing i t  to improve teacher 

performance or whether you were doing i t  fo r  the purpose 

oi comparison as to which teacher was perhaps better  

than another.'

Z2 e a .

23

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They would very d e f in i t e l y  have equal v a l i d i t y  or even 

more s o  for a person that is in an actual classroom

s i t u a t i o n  a s  a  teacher. The reason for  this is that we 

l o o k  a t  i n s t r u c t i o n  a s  an opportunity to teach children,

G L E N N  H PERRIN 
O f f ic ia l  C o u r t  R eporter  

F e d e r a l  B u i l d i n g  

E l ____D o r a d o ___ DA?



aau teachers should always be in a position to improve 

and continue to improve their methods. This procedure 

provides a valid  way in which this can be done when we 

u t i l i z e  the classroom teacher, the supervising principal 

and the top person responsible for evaluating for the 

purpose of improvement of instruction, yes.

And so they would have equal va l id i ty  i f  we were looking 

not only to see whether they had good instructional 

a b i l i t y  but whether we were wanting to compare one 

against the other?

Oh, yes. See, the l i te ra ture  in this area and many of 

the persons in education writ ing in this area recommend­

ing this l i te ra tu re ,  they are writing and the recommen­

dations are based on supervisory programs for public 

schools. We are using i t  for student teachers who 

eventually w i l l  go into public schools.

So you have auapted the common l i tera ture  to your 

spe' i f i c  purpose that c >mes from the actual classrooom 

s ituat ion?

This is true.

MR. STARLING: Nothing further, Your Honor.

THL COURT: Stand aside.

(Witness excused.)

MR. KAPLAN : Your Honor, we would move the

GLENN H PERRIN 
O f f i c i a l  C o u r t  R eporter  

F e d e r a l  B u i l d i n g

E L  D o r a d o  A i i f i i j . i t



Hester Direc t 148

a d m i s s i o n  o f  P l a i n t i f f s '  3  t h r o u g h  o .

T H E  C O U R T :  L e t  t h e m  b e  r e c e i v e d ,

MR „ K A P L A N :  M r .  H e s t e r :

NEYLAND HESTER.

c a l l e d  a s  a w i t n e s s  on b e h a l f  o f  t h e  p l a i n t i f f s ,  b e i n g  f i r s t  

d u l y  s w o r n ,  t e s t i f i e d  a s  f o l l o w s :

DIRECT EXAMINATION

BY MR. KAPLAN

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Q-

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T e l l  u s  y o u r  n a m e  a n d  a d d r e s s ,  p l e a s e .

My n a m e  i s  N e y l a n d  H e s t e r .  I  l i v e  a t  R o u t e  1  a t  

S h e r  i d a n .

W h a t  i s  y o u r  p r e s e n t  o c c u p a t i o n ,  M r .  H e s t e r ?

I  am a n  e d u c a t o r ,  I  am A s s i s t a n t  C h a n c e l l o r  a t  t h e  

U n i v e r s i t y  o f  A k a n s a s  a t  L i t t l e  R o c k .

How l o n g  h a v e  y o u  h e l d  t h a t  p o s i t i o n ?

I  h a v e  b e e n  t h e r e  e i g h t  y e a r s  w i t h  t h e  e x c e p t i o n  o f  

1 9 6 9  w h e n  I  w a s  o n  l e a v e  t o  O u a c h i t a  U n i v e r s i t y .  

W h a t  f u n c t i o n  d i d  y o u  s e r v e  a t  O u a c h i t a  U n i v e r s i t y ?  

I  w a s  i n  t h e  S c h o o l  o f  E d u c a t i o n  w i t h  t h e  A r k a n s a s

21 ! T e c h n i c a l  A s s i s t a n c e a n d  0

22 f  un d e  i  p r o j e c t .

23 Q. I s  c h a t k n o w n  a s  t h e T i t l e

24 t\. Y e s ,  f o r t h e  S t a t e .

25 Q. F o r  t h e S t a t e  o f  A r k a n s a s ?

GLENN H
-I—

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 9 0 5 J * l



y o u r' w o u l d  y o u  c e l l  u s ,  s i r ,  a  l i t t l e  b i t  a b o u t  

e d u c a t i o n a l  b a c k g r o u n d ,  w h e r e  y o u  r e c e i v e d  y o u r  d e g r e e s ,  

a n d  y o u r  e m p l o y m e n t  b a c k g r o u n d ?

1  a t t e n d e d  T e x a s  T e c h ,  R o o s e v e l t  U n i v e r s i t y ,  N o r t h w e s t e r n  

U n i v e r s i t y ,  a n d  S o u t h e r n  M e t h o d i s t  U n i v e r s i t y .  I  h a v e  

t h r e e  d e g r e e s  t n m  R o o s e v e l t  U n i v e r s i t y ,  a n d  my M a s t e r ' s

a n d  p r o f e s s i o n a l  d e g r e e  a r e  f r o m  S . M . U .

W h a t  d e g r e e  i s  t h a t ?

My M a s t e r ' s  a n d  T h e o l o g i c a l  D e g r e e  f r o m  S . M . U .

I  s e e .  A n d  h o w  l o n g - - w h a t  e x p e r i e n c e  h a v e  y o u  h a d  i n  

e m p l o y m e n t  i n  t h e  f i e l d  o f  e d u c a t i o n ?

P r i o r  t o  c o m i n g  t o  t h e  U n i v e r s i t y  a t  L i t t l e  R o c k  e i g h t  

y e a r s  a g o ,  l  w a s  o n  t h e  f a c u l t y  a t  S . M . U .  f o r  s i x  

y e a r s ,  a n d  p r i o r  t o  t h a t  1  w a s  a  M e t h o d i s t  M i n i s t e r .  I  

w o r k e d  i n  t h e  M e t h o d i s t  B o a r d  o f  E d u c a t i o n  i n  t h e  

N a t i  m a l  O f f i c e  i n  N a s h v i l l e .

W h a t  h a v e  b e e n  y o u r  d u t i e s  a n d  r e s p o n s i b i l i t i e s  s i n c e  

c o m i n g  t o  t h e  U n i v e r s i t y  o f  A r k a n s a s  a t  L i t t l e  R o c k  a n d  

i t s  p r e d e c e s s o r - -

L i t t l e  R o c k  U n i v e r s i t y .

- - L i t t l e  R o c k  U n i v e r s i t y ?

I  c a m e  t o  t h e  U n i v e r s i t y  e i g h t  y e a r s  a g o  a s  D i r e c t o r  o f  

D e v e l o p m e n t  a n d  1  h a v e  s e r v e d  a s  A s s i s t a n t  t o  t h e  

P r e s i l e n t ,  a n d  l o l l o w i n g  t h e  m e r g e r  o f  L i t t l e  R o c k

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a m a i  7 i 7 » o



Direc t 150Hester

Q.

A.

a

A.

Q.

A.

Q.

University with the University of Arkansas, our 

President's t i t l e  became Chancellor and I became 

Assistant to the Chancellor.

Have you had experience in particular with evaluation 

of teachers both as a teacher improvement technique and 

as a technique used to compare teacher sk i l ls  especia l ly  

in newly unitized school d is tr ic ts?

Yes, I have served as consultant to a number of school 

d is t r ic ts  in Arkansas with problems related to school 

desegregation and teacher evaluation, and during my 

year with Ouachita University with the College of 

Education I was related to a s ta f f  that was giving 

assistance in school desegregation problems over the 

State. Out of the State 's 214 b i- rac ia l  d is t r i c t s ,  we 

had some contact with about 1 0 0  of these.

You heard--were you present for the testimony this 

morning of the Superintendent of the Plum Bayou D istr ic t?  

Yes.

And were you present, also, for Dr. L i t t le john 's  

testimony?

Yes .

Do you have any opinions as to the teacher--strike that. 

Are there, in your experience, general guidelines and 

techniques used in making complete evaluation of teacher

pp-r sonne L in existing teachers?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

J iri rvvn



A. Yes, there are. These have been discussed some. They're 

generally accepted guidelines for making satis factory  

teacher evaluations. I think i t ' s  important that a l l  

of the teachers in a school and a l l  of the administrative 

sta ft  in a school who are to be involved in evaluation 

should s i t  down together f i r s t  and agree on goals and 

object ives, purposes, and then methods. This would 

involve in this particular case the 15 elementary 

teachers and the Superintendent and his administrative 

s ta f f .  Then following this agreement on goals and 

purposes, i t  seems to me that this group of people 

should agree on the instrument that everybody to be 

involved in any way should make some contribution to 

developing the instrument to be used. Now, this seems 

to be a rather simple elementary place to begin, but I 

th ink i t ' s bas i c .

Q- Is i t  basic both to the evaluation process and the 

unitization of a dual school d is tr ic t?

A. Yes. It indicates good fa ith ,  for one thing; i t

indicates willingness on the part of everyone involved 

to proceed with mutual respect for the other point of 

view. It would indicate that these goals and purposes 

that we have set for ourselves are mutually agreeable.

Q- Now, is the release of teachers, in your experience at 

the T i t l e  IV Center and in Education in L i t t l e  Rock,

GLENN H PERRIN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

~ ? t ) lK L  Dof i Ano__Ab b a ,



i;- t.be release o: teachers the only method in newly 

unitized d is t r ic ts  of consolidating facult ies?

No. we had, as a s ta f f  at the Atex Center at Ouachita 

University, relationship with school d is t r ic ts  that 

unitized sa t is fa c to r i ly  where no teachers were released. 

Through natural a t t r i t io n  teachers were kept unti l  

positions occurred and they were maintained on the 

facu lty .

A.

Q.

Now, is that system destructive in any way to your 

experience or any or the relationships within the 

d is t r i c t  or of the proper educational atmosphere in 

the d is t r ic t?

No, on the contrary i t ' s - - i t  shows an honest attempt to 

maintain good faith with the people who are part of 

the d i s t r i c t .

Mr. Hester, I would like to ask you a question. Assuming 

a Superintendent who used f iv e  factors for evaluation, 

"Teacher Competency", "Ab i l i ty  to Maintain Classroom 

D isc ip l ine" ,  "Teacher-Pupil Relationship", "Teacher- 

Teacher Relationship", "WiLlingness to Cooperate with 

the Total School Program", and assuming that Superintend­

ent was eight miles distant from the f a c i l i t y  and did 

not use as part of his evaluation the evaluation of the 

immediate supervisor and that v is ita t ions  to individual

classrooms in this school which happened to contain only
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

n  n n a i n n  a  . . . . . . .  . . . . .



Hester D i r e c t 153

1
ll

2

b l a c k  t e a c h e r s  l a s t e d  o n l y  1 3  m i n u t e s ,  d o  y o u ,  i n  y o u r

e x p e r i e n c e  a n d  i n  y o u r  o p i n i o n ,  f e e l  t h a t  t h i s  w a s  a

3 l a i r  e v a l u a t i o n ?

4 A. F r o m  my e x p e r i e n c e  i n  n e a r l y  a  h u n d r e d  s c h o o l  d i s t r i c t s

5 !: f a c i n g  i n t e g r a t i o n  d u r i n g  1 9 6 9  I  w o u l d  s a y  i t  w a s  n o t

6 f a i r  .

*  A C A n d  on w h a t  w o u l d  y o u  b a s e  t h a t  o p i n i o n ?

8 A. O h ,  s e v e r a l  t h i n g s .  1  i n d i c a t e d  e a r l i e r  I  t h i n k  t h e

9 i n s t r u m e n t  f o r  e v a l u a t i o n  a n d  a l l  o f  t h e  p e o p l e  t o  b e

10 i n v o l v e d  i n  t h e  e v a l u a t i o n  s h o u l d  b e  a  p a r t  o f  t h e

11 j p r o c e s s  a n d  s h o u l d  a g r e e  on g o a l s  a n d  p u r p o s e s  a s  w e l l

as  m e t h o d s .  T h e n  i t  w o u l d  s e e m  t o  m e ,  a n d  D r .  L i t t l e j o h n

13

14

c o v e r e d  s o m e  o f  t h i s ,  i t ' s  r e a l l y  h i s  f i e l d  a n d  n o t  

m i n e ,  b u t  I  h a v e  b e e n  i n v o l v e d  w i t h  s o m e  t e a c h e r
‘

15 e v a l u a t i o n  l o n g  e n o u g h  t o  r e a l i z e  t h a t  n o t  o n l y  m u s t

16
1

t h e s e  g o a l s  a n d  m e t h o d s  b e  a g r e e d  u p o n  b y  b o t h  p a r t i e s

17 b u t  t h e r e  s h o u l d  b e  a c i n f e r e n c e  b e t w e e n  e v a l u a t o r  a n d

)  18 t e a c h e r  p r i  or t o  t h e  v i s i t ,  t h e n  I  w o u l d  a s s u m e  t h e

19 e v a l u a t o r  w o u l d  h e  i n  t h e  c l a s s r o o m  b e f o r e  t h e  c l a s s

20 p e r i o d  b e g i n s  a n d  b e  s e a t e d  o v e r  t o  t h e  s i d e  o u t  o f  t h e

21 w a y  o f  . t h e  c h i l d r e n  , w o u l d  w a t c h ,  l i s t e n ,  a n d  p e r h a p s

22 m a k e  n o r t h s ,  c o m m i t  h i s  t h o u g h t s  t o  w r i t i n g ,  a n d  t h e n  a s

23 s o o n  a s  p o s s i b l e , p e r h a p s  t h a t  a f t e r n o o n ,  o r  v e r y

- i
24 s h o r t l y  , V ••}i s c u s s  h i s  n o t e s  a n d  h i s  t h o u g h t s  a n d  h i s

25 |

I
i

q u e s  t  i o h ' <  w i  t h  t h e  t e a c h e r  . T h e s e  s e e m  t o  b e  a g r e e d

G L E N N  H P E R R I N
O f f ic ia l  C o u r t  R e p o r t e r  ^

F ed e r al  B u il d in g  " “ J  M  .



x !
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Hes ter Rirec t

u p o n  b y  e d u c a t o r s  a c r o s s  t h e  c o u n t r y  a s  b e i n g  r a t h e r

m i n i m u m  p r o c e d u r e s .

MR.  K A P L A N :  T h a n k  y o u ,  D o c t o r .  Y o u r  w i t n e s s .

154

C R O S S  E X A M I N A T I O N

B Y  MR.  S T A R L I N G :

0. D r .  H e s t e r ,  w h e n  w e r e  y o u  w i t h  t h e  T i t l e  I V  O f f i c e  a t

O u a c h i t a .

A. I w a s  o n  l e a v e  from t h e  U n i v e r s i t y  i n  L i t t l e

R o c k .

Q.

A.

W h i l e  y o u  w e r e  a s s o c i a t e d  w i t h  t h e  T i t l e  I V  O f f i c e  i n  

O u a c h i t a ,  D r .  H e s t e r ,  d i d  t h a t  o f f i c e  p r o v i d e  s e t  

t e a c h e r  c r i t e r i a  f o r  t h e  e v a l u a t i o n  o r  c o m p a r i s o n  o f  

t e a c h e r s  w h o  w e r e  g o i n g  t o  b e  i n  t h e  s c h o o l  d i s t r i c t  

f i x i n g  t o  b e  u n i t i z e d ?

N o ,  w e  s i m p l y  u s e d  t h o s e  c r i t e r i a  t h a t  h a v e  b e e n  

d i s c u s s e d  h e r e  t o d a y  a s  b e i n g  c o m m o n l y  a c c e p t e d .

W h a t  c r i t e r i a  a r e  t h o s e  t h a t  w e  d e s c r i b e d ?

W e i l ,  s i n c e  t h e r e  h a v e  b e e n  n o  a g r e e d  u p o n  c r i t e r i a  b y  

e d u c a t o r s  n a t i o n a l l y ,  we  u s e  t h o s e  t h a t  a r e  a v a i l a b l e ,  

" T e a c h e r  C o m p e t e n c y " ,  " R e l a t i o n s h i p  w i t h  P u p i l s " ,  t h e s e  

t h a t  y o u  h a v e  d i s c u s s e d  t o d a y ,  a r e  l i m i t e d ,  t h e  

i n s t r u m e n t  i s  f a u l t y ,  h u t  a s  I  i n d i c a t e d ,  t h e  g r e a t e s t  

f a u l t  i s  n o t  i n  t h i s  i n s t r u m e n t  p r e c i s e l y  b u t  i n  t h e  

w a v  i t  w a s  u s e d .

G LE NN  H P E R R I N
O rr ic iA L  C o u r t  R eporter

F ed e r al  B u il d in g ~ ) ! r \  +



Q- Well, now, what do you mean “the way it was used"?
A. No conn only agreed upon goals and purposes, no pre-visit

conference.

Hester - Cross

Q-

A.

Q.

A.

Thank you. Let me ask you this, Dr. Hester: If Mr.
Bradshaw, the Superintendent, had held meetings with 
the teachers, both the white and the black teachers, 
and had told them that the problem was an evaluation 
of not just the black or the white but of all of the 
teachers and told them that this was the goal that he 
was attempting to come up with such an evaluation, 
possibly could they suggest some of these criteria, 
would you feel that then that instrument would be better 
or more fair?
1 heard M l, Bradshaw's answer this morning. It's not
simply saying to a group of teachers "I am going to do 
some evaluation and I would like your suggestions", it 
is more than that, to show good intent, to show good 
faith, would involve the teachers in perhaps a workshop 
or seminar or institute type program and develop such 
an instrument together. It's more than asking for 
suggestions for this instrument that I already have.
You testified that there were certain criteria while 
y o u  -were associated with the Title IV Office that you 
generally depended on. What are some of these criteria? 
These that you have mentioned that Mr, Bradshaw used.

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

E L  n n B A n n  A b i / a  a j g  a  ^ __— a — - - \ i l



Hester - Cross 156

2

3 A.

4

5 II a 

6

8

9 I

i o  A .

n :j Q.

12 ;l A.

13

!
14 1

|
15

|
16 I

11

17

19

||
20

I
,

21

22 Q.

23 1 A.

24 Q.

I n  o t h e r  w o r d s ,  t h e y  a r e  b a s i c a l l y  t h e  c r i t e r i a  w h i c h  

t h e  T i t l e  I V  O f f i c e  u t i l i z e d ?

T h a t ' s  c o r r e c t ,  t h e y  a r e  n o t - - a s  I  i n d i c a t e d ,  t h e y  a r e  

n o t  c o m p l e t e ,  b u t  t h e y  a r e  n o t  i n  t h e m s e l v e s  f a u l t y .  

W h i l e  y o u  w e r e  a t  t h e  T i t l e  I V  O f f i c e ,  M r .  H e s t e r ,  how  

m a n y  d i s t r i c t s ,  s c h o o l  d i s t r i c t s ,  i n  t h e  S t a t e  o f  

A r k a n s a s ,  w e r e  y o u  a w a r e  o f  t h a t  i n  t h e  y e a r s  l e t ' s  s a y  

1 9 o t ;  t h r o u g h  1 9  7 0  c r e a t e d  a n  e v a l u a t i o n  f o r m  t o  e v a l u a t e  

3 l l  o f  t h e  t e a c h e r s  w h o  h a d  t o  b e  c o m p a r e d ?

I  d o n ' t  k n o w  i n  p r e c i s e  n u m b e r .  S e v e r a l .

Do y o u  k n o w  t h e i r  n a m e ?

D u r i n g  t h e  y e a r  t h a t  1  w a s  a t  t h e  C e n t e r ,  a n d  I  w a s  o n  

l e a v e  t o  h e l p  i t  g e t  s t a r t e d ,  t h a t  w a s  i t s  f i r s t  y e a r ,  

w e  s t a r t e d  v n r k  i n  J a n u a r y ,  1 9 6 9 ,  t h e r e  w e r e  t h r e e  

p r o f e s s i o n a l  s t a f f ,  a n d  w e  h a d  d i f f e r e n t  a r e a s  o f  t h e  

S t a t e  i n  w h i c h  w e  w o r k e d .  T h e  D i r e c t o r  o f  t h e  C e n t e r ,  

D r .  W e a t h e r i n g t o n , w o r k e d  i n  t h i s  a r e a  a n d  v i s i t e d  M r .  

B r a d s h a w  i n  h i s  d i s t r i c t .  My r e s p o n s i b i l i t y  w a s  i n  t h e  

s o u t h e a s t  p a r t  o f  t h e  S t a t e .  T h e  d i s t r i c t  t h a t  d i d  t h i s  

e f f e c t i v e l y  w i t h  w h i c h  1  w o r k e d  w a s  D u m a s  S c h o o l  

D i s t r i c t .

N o w ,  d i d  t h e y  e v a l u a t e  a l l  o f  t h e  t e a c h e r s ?

N o .

Who d i d  t h e y  e v a l u a t e ?

T h e y  w e r e  e v a l u a t i n g  t e a c h e r  e f f e c t i v e n e s s  b u t  w i t h  a

G L E N N  H P E R R I N
O f f ic ia l  C o u r t  R eporter

F ed e r al  B u il d in g



'I

2

3

4

19

i l
20

2 1  |j

22

II
23

24
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25;!

it

d i f fe ren t  point of view, their problem was a d i f fe ren t

problem from this.

Q- Then we rea l ly  can't equate them with this problem, can

we?

p Your question was evaluating teachers and at that point 

i t  was the same, but it  was--their problem was not to 

hire or to release teachers, so i t  was a d i f fe ren t  goal. 

Q- Okay. When Mr. Kaplan asked you the hypothetical

question concerning Mr. Bradshaw having his o f f i c e  at 

the other school, Plum Bayou School, being eight miles 

apart and being able to v i s i t  the teacher classrooms 

at the kosenwaId-Tucker Llementary School, perhaps 15 

minutes on a v i s i t  over a three-year period, and using 

the r i t^ r ia  which you be lore you or have seen that Mr, 

Bradshaw u t i l i z ed ,  asked you i f  this could be done 

f a i r ly ,  and I believe y >ur a: swer was in most cases i t  

could not be done f a i r ly ,  is that correct?

Hester - Cross 157

That is correct.

Why do you say this?

As i indicated, the fault I find is not in the c r i t e r ia  

but in the way they were used, lack of involvement of 

teachers, which I find most serious. Teachers who are

to bt- evaluated should have some hand in Helping evolve 

the instrument for evaluation. There should be agreement 

on goals and purposes and methods. And then the
H-

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

F  L D n s in n  A oar A UE A •  i « 7  i x  ,



Hester - Oros:

10

n

12

13

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16 i

17 j|

18 ||

19

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Q.

A.

21

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evaluation periods, there would be no point in v is i t in g  

once a month £or three years for 15 minutes, i t  would 

be .much better to use the same amount of time and put 

i t  into one-hour v is i t s  and le t  i t  occur within a year. 

Satisfactory evaluation could be done within a semester, 

for instance, i f  i t  were done over a longer p e r -v is i t  

time, and then following that with a conference between 

evaluator and teacher. The fact of the matter is ,  I 

guess this is beside the point, the Superintendent is 

not the best evaluator.

Who is?

Another teacher. Most teachers are afraid o f  their 

Superintendents, and in an atmosphere of--and I say 

"a t r a i l " ,  you know the sense in which I mean it--good 

evaluation is not done in an atmosphere of apprehension 

or f e a r , and another teacher brought in from another 

school paid as a consultant for a day can do a much 

more e f fe c t i v e  job of evaluating. I think a l l  o f us 

who have been in a classroom have some apprehension or 

fear or maybe awe of the Superintendent.

Do you know--and I am asking kinda the Judge’ s question 

in this--do you know of any c r i t e r ia  which is put out 

by any state entity  or State Department of Education or 

bv the T i t l e  IV O ff ice ,  any c r i t e r ia  which is pinpointed 

tc be used in the evaluation and comparison of teachers

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

E l _  Dorado A t y j u

158



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which are raced with a reduction in teacher force due 

to the unitization of school d is tr ic ts?

A. No, sir.

MR. STARLING; I believe that 's  a l l .

Hester - Cross

REDIRECT EXAMINATION

BY

Q.

MR0 KAPLAN;

Mr. Hester, in response to Mr. S tar l ing 's  question you 

spoke about the c r i t e r ia  that Mr. Bradshaw spoke about 

as being the generally accepted c r i t e r ia .  I have 

handed you the documents marked P l a i n t i f f s ’ Exhibits J 

through 6 . Are you talking about c r i t e r ia  generally 

accepted just those broad categories or broken down in 

minute de ta i l  for each of those categories into a l l  of 

their constituent parts as exemplified in P la in t i f f s '  

Exhibits 3 through b?

i t '  necessary to break these down. When these were 

being discussed awhile ago, and I had never seen these 

before this moment, i t  bothered me that we kept talking 

about these four or f ive  areas without breaking them 

down, but the fact they are broken down shows them to 

be mu<-h more important.

â they I'.avi t v e same kind of va l id i ty  in just the broad 

aspect as they nave broker, down in minute deta i l  into 

many, many factors under each one of those?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R eporter 

F e d e r a l  B u i l d i n g  

EL D o r a d o  Arkamrar v i t «a



has L^r K e c r o s i 160

No, o f  course, i O t .

MR v KAPLAN: That's a l l .

RECROSb EXAM1NATION

3 1| BY MR. STARLING,

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Mr. Hester, one last question. When you speak about 

breaking these c r i t e r ia  down, which you say are the 

generally accepted c r i t e r ia  which Mr. Bradshaw u t i l i z ed ,  

for instance, under "Teacher Competency", break that 

down into what you might include in that.

In a sense, this tern covers everything we are talking 

about. I t  involves knowledge of the subject which one 

is supposed to be teaching and which he is c e r t i f i e d ;  

i t  involves personal things such as grooming and 

personal appearance; i t  involves relationships with 

pupils, the a b i l i t y  to give and take; i t  involves 

maintaining of irder; i t  involves the physical 

preparation of the classroom prior to the coming of the 

class; i t  involves the attitude of the teacher towards 

his profession and toward other people; i t  involves his 

relationship with other teachers.

What would you say, then--would you say that perhaps 

un er "Teacher Competency", i f  you were trying f )  break 

i t  down as to the c r i t e r ia  u t i l i z ed ,  that perhaps the-- 

maybe something l ike the a b i l i t y  to re la te  to the

GLENN H PERRIN
O f f ic ia l  C o u r t  R e p o r t * *

F e d e r a l  B u il d in g



dk*s ter Kecros s

student would be a factor?

A Yes.

Or maybe the preparation of the teacher, such as her

transcript or ce r t i f ica t ion?

These are involved.

Q- What would you say would be broken down aspect of

"Ab i l i ty  to Maintain Classroom Discipline"?

A The "Ab i l i ty  to Maintain Classroom D isc ip l ine" ,  I would 

place i t  under this whole area of "Teacher Competency".

Q. what would you say about "Teacher-Teacher Relationship"?

A I t ’ s very important matter. It also is related to the 

overall  picture.

Q. How would you break i t  down? What would be some of the 

factors under that that you would break i t  down into? 

Under "Teacher-Teacher Relationship", what would you 

break that down into?

Participation in such things as Parent Teachers' 

Association, attending meetings of the faculty in that 

particular school, attending meetings of the Arkansas 

Education Association, relationships with other teachers 

on a professional--

Q. Share oL materials or something l ike this?

A. Yes, on a local school oasis, yes.

You te s t i . i ed  ea r l ie r  that you heard Mr. Bradshaw’ s 

testimony, in reference to the c r i t e r ia  u t i l i z ed .  Did you

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 * 0



HRs ter Kecross

hear him t e s t i f y  to the fact that he broke each of these ] 

down and under the term "Teacher Competency" he broke 

that down " (a )  A b i l i ty  to Relate to the Student; (b) 

Preparati >n, which included the transcript, c e r t i f i c a t io n  

and training; (c )  F l e x ib i l i t y ;  (d) In i t ia t iv e "?

A Yes .
Q- How would you say those f i t  as far as breaking i t  down

is concerned?

A. They are acceptable, I would say they are very good.

MR. STARLING: Fine. Thank you.

I
REDIRECT EXAMINATION

BY MR. KAPLAN:
I

Q- Mr. Hester, I w i l l  hand you the Answer to Interrogatories 

propounded by p la in t i f f s  to defendant which contain the 

teacher evaluation form that Mr. Bradshaw t e s t i f i e d  that j 

he used and invite your attention to the evaluation of 

Mrs. Loi- Ann Thomas wherein she received a No. 2 in 

“Teacher Competency" and only one other "2", that in 

"Teacher-Pupil Relationship", and a l l  others two "4 's "  

and a "5" ,  and ask you i f ,  in your opinion, the evaluator 

was at all internally  consistent in giv ing her a " 2 " 

in “Teacher Competency", a f a i r ly  high rating, and 

basically "4s" and a "5" in three of the other areas?

A No, ! don't think this shows consistency. I think there

GLENN H PERRIN 
O f f i c i a l  C o u r t  R  C r o a t i a  

F c d c r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7t7*o 2. IX



Hester - Red irec t

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should be some other " 2 's " i f  this f i r s t  category 

"Teacher Competency" is ent it led  to a "2", these other 

things are related to "Teacher Competency".

And in accordance with your testimony before can rea l ly  

be sub-categorized underneath "Teacher Competency"?

Yes, that is what I am saying.

I invite  your attention, for example, to Mrs. Lucreasia 

Evans, who received a "1" in "Teacher Competency", but 

one "3", a "2", a “ 3", and a "4" in regard to "Cooperative 

with the Total School Program". Is that in i t s e l f

internally  consistent?

No, i t ' s  not consistent. "Teacher Competency" we seem 

to be using as a covering term and a " 1 " under i t  would
j

• j • lindicate some strengths in these other areas, too, that

are not indicated by " 2 ' s " ,  " 3 ' s " ,  and " 4 ' s " .

MR. KAPLAN: Thank you, s i r .

RECROSS EXAMINATION

-MR. STARLING:

.Mr. Hester, the only thing that confuses me is  the fact 

that you stated that these were the generally accepted 

c r i t e r ia  that you had experienced nr had experience with 

in the T i t l e  IV O f f ice .  Now, i f  these are the generally 

accepted c r i t e r ia  which Mr. Bradshaw u t i l i z ed ,  then 

certa inly I can see where they overlap, but i t  they are

GLENN H PERRIN 
O f f i c i a l  C o u r t  R epo rter  

F e d e r a l  B u il d in g  
EL Do r ad o  A r k a n r a i  7 1 7 3 0



Hester K ec r o s s
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the accepted c r i t e r ia ,  or generally accepted c r i t e r ia  

which you have experienced, then obviously they to some 

extent don't overlap ir that is the accepted c r i t e r ia  

which can he u t i l i zed  tor the evaluation of teachers, 

isn 't  that correct?

No, i see no inconsistency here, they do overlap,. You 

can't talk about the a b i l i t y  of a teacher to maintain 

d isc ip l ine  unrelated to his relationship with pupils, 

for instance. They are at the same time d is t inct  and 

separate hut they are d e f in i te ly  a part of the same 

th ing ,-- 

Well, I - -

--and you can't talk about a teacher 's--

No, 1 am not arguing that point, I am not—

--att itude,  they are related.

Weil, 1 agree that certa inly  they are re lated, but the

point being they can also be separated and broken down 

into each, so they can he i i s t in c t ,  too.

Within l im its ,

MR. STARLING: Fine. Thank you.

MR. KAPLAN: (Shakes head negatively)

THE COURT: You may stand aside.

(Witness excused.)

MR. KAPLAN : Mr. tdwards J

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 i 7 * o



Edwards Direc t

■ IK. AN CUR TIE EDWARDS .

called as a witness on behalf of the plaintiffs 
duly sworn, testified as follows;

being f i r s t

DIRECT EXAMINATION
BY MR . KAPLAN :

Q‘ r e i l  us ror the record, please, your name and address.

A My name is Jean Curtis Edwards, Route 1, Box 67,

S h e r r i l l .

Mr. Edwards, what is your present occupation?

A I am Coordinator Director of the Neighborhood Services 

System which is a component of the O ff ice  of Economic 

Opportunity here.

Were you ever employed as a teacher, Mr. Edwards?

Yes.

Q.

Q.

Q.

And in what school district and when?
I w a s  e m p l o y e d  as a teacher of Mathematics and Physical 

E d u c a t i o n  at S h e r r ill-Rosenwald School for two years, 

at Plum Bayou-Tucker School D is tr ic t  for seven years. 

W e r e  y o u  employed in Plum Bayou School D is tr ic t  

immediately prior to your resumption of duties as 

coordinator Director of Neighborhood Services System? 

Yes, 1 w a s .

F r o . : what year to what year did you serve, sir?

1 - e r v e  ! : r o r  J u l y ,  1 9 6 2 ,  t o  May 2 6 t h ,  1 9 6 9 .

A n u j l i u  you n a v e  m o r e  than o n e  capacity in which you

GL E NN  H PERRIN
O f f ic ia l  C o u r t  R epo rter

F e d e r al  B u il d in g
0  - >  /



Edwards - D irec t

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served ia that D is t r ic t?

Yes, I served as P r inc ipa l ,  a lso as parttime classroom 

teacher.

Approximately what percentage of your duties were 

devoted to your function as Pr inc ipa l  o f  that school?

I would say in the neighborhood of 30 percent.

And wnat were your duties and r e s p o n s ib i l i t i e s  as Head 

Teacher or Principal?

My duties as Head Teacher were to supervise the teachers 

and f i l l  out reports necessary for the D is t r i c t *

Did you have occasion during those years as Pr inc ipa l  

to evaluate your teachers?

Yea , i did.

Did you rake wr it ten  evaluation during that period o f

time?

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Yes .

And did you keep those?

Yes .

Were those ever ca l led  for  by any administrator in the 

D is t r ic t?  I speak oi "administratorM, I mean Superintend­

ent „

Q. Were they ava i iab ie had they been

A. Yes .

a Would you descr ibe for us the freq

G L E N N  H  PERRIN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

* 1 1 1C L  ■A A



Edwards - D irect 16

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classroom vis i tat ions  aid the method that you chose, 

that is,  what you would do when you got there and how

long your v i s i t s  were, and so forth.'’

. ror, tine t > time, unannounced, I would natural ly  have 

to v i s i t  classrooms for some reason, hut for s t r i c t l y  

tht purpose oi observing c lasses,  usually 1 would spend 

approximately one day per month in doing this and 

usually we would bring in a substitute teacher to work 

in my place while I was doing this*

How long would you spend in each class?

I would spend the entire class p e r io d , --

Did you ever have--

--normally was about 55 minutes*

Di 1 you have conferences with your teachers e i ther  

before or a lter to discuss what was going to take 

place and then what did take place?

I didn’t have a conference with the indiv idual teachers 

prior to observing the c lass,  but usually I would 

announce it in a s t a f f  meeting, and upon going into the 

classroom to observe the c lassroom I would always ask 

lor a copy ol the teacher's guidelines for  that day 

or teaching plan. Then a l t e r  the classroom v i s i t a t i o n ,  

the., i would nave conference with the teacher and we 

would discuss the area of weaknesses and strengths.

D iJ you ever discuss with the Superintendent of the

GLENN H PERRIN
O f f ic ia l  C o u n t  R epo rter

F e d e r al  B u il d in g ' J ? ' *



rewards j  1 r e c c
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D is t r i c t  any of vour opinions or f indings regarding 

teachers in the D is t r ic t?

Yes .

When ?

During the year of '68 -69 .

How frequently and when during that year?

We discussed the p o s s ib i l i t y  of teachers having to be 

terminated at the end or that school year, and I believe 

our f i r s t  conversation would have been about October 

oi 68, and then we discussed a c r i t e r ia  and the 

evaluation of teacher, la t e r ,  1 don't know exactly what

month i t  was, but I would say about the month of March,

'69.

Were the teachers themselves present in this conver­

sation?

N o .

How often ,  to the best of your r e c o l l e c t io n ,  was the 

Superintendent present tor evaluation purposes or any 

oLher purposes, and then t e l l  us which, during your 

last  two or three years in the D is t r i c t  at the Rosenwald

Schoo1?

Prior to '68- '  69, a l imited nunber of times. During 

68- *>), bas ica l ly  as he indicated this morning in his 

testimony, which was about mce per month, 15 to 20 

minutes per class period.

GLENN H P E R R IN  
O f f i c i a l  C o u r t  R eporter  

F e d e r a l  B u i l d i n g  

EL. Dorado A b k im b io  n-r«n



cdwards Direct.

Q. Did he ever discuss with you the evaluations or his 

opinions j f  what he had seen in any of the classes?

A Yes. On$some occasions, yes.

Did you ever have anything in writing regarding any of

that or ever put anything in writ ing ,  or did he, to your

know ledge?

1 think we both kept notes, and on one occasion I 

remember that we compared notes.

A l l  r ight.  in regara to what teacher?

A In regard to Mrs. Thomas once.

Q- Mrs. Lois Ann Thomas?

A. Yes.

Q- Te l l  us abaut that.

A. On this particular occasion, we both had observed a

classroom period, and he mentioned tha t- - I  believe she 

was at the board writing and a child started a 

Jis eur.uncc of some kind, in other words, he moved about, 

and she glanced back at him, and when she glanced back 

at him indicating that he should cease to do whatever 

he was doing, then he mentioned this, he referred to i t  

as brow-beating the child.

Q- What was your response?

A. I wouldn't consider i t  brow-beating, though I am gu ilty  

o! that, because this was one of the techniques that I 

ofinn u s e d  to control children. In other words, an

GI.ENN H PERRIN 
O rrio iAL  C o u r t  R k po rtkk



towards - d i r e c t

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indication by the eye that 1 was not pleased with what 

he was doing would almost always bring him under control. 

H a d  you e v e r  noticed or had you ever had any cr it ique 

of Mrs. Thomas or any other teacher in your school that 

they were not using the materials that had been given 

them, particular ly  the economy texts?

No, 1 don't have--I didn’ t have such cr i t ique .  In fact, 

we invited Mr. K i e f f e r , who was a representative of that 

company, down ior workshop, and afterward we called a l l  

o f the teachers together and complimented the teachers 

on their use of this material and f e l t  that they had 

done a  good job for the period of time that they had 

h a !  i t ,  b e c a u s e  the teachers themselves f e l t  that they 

were not doing an adequate job and this was our reason 

for invit ing him down there, and contrary to their 

b e l ie f  he f e l t  that they were doing a good job.

While we are talking about Mrs. Thomas, would you t e l l  

us something about her experience in the D is tr ic t  and 

your opinion and evaluation of her?

Mrs. Thomas, in my opinion, was a good teacher, and i t  

is indicated by the tact that not only was Mrs. Thomas 

employed as a i lassroom teacher but we used her also 

in teaching the Basic AduLt Education Class and we also 

recommended her for the Head Start Program because of 

her a b i l i t y  to establish rapport with young children.

1/0

GLENN H PERRIN 
O f f i c i a l . C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



Edwards J i r  ec L

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When you say “we", are you talking about the entire

administration of  the D is t r i c t ,  including the 

Superintendent?

Yes, out 1 am not speaking in terms o f  Mr, Bradshaw as 

such, now. At f i r s t ,  i t  was Mr. Elkins, I be l ieve ,  the 

f i r s t  Superintendent, that we recommended her for Head 

Star^ under Mr. Elkins; the second person was Mr. 

Anderson, and then the last time that she worked with 

the Head tart  Program, i t  was Mr. Bradshaw.

Was she always a F irs t  Grade teacher?

No. When we hired her, we hired her as a Third Grade

teacher.

Why was she teaching F irs t  Grade when she was f in a l ly  

released or not renewed?

A fte r  observing her, we f e l t  that she was one of our 

stronger teachers, and she had the a b i l i t y  to establish 

rapport with young children who had not had previous 

school experience, and a f t e r  a conference with Mr. 

Anderson, between Mr. Anderson and myself, we suggested 

that we would move Mrs. Thomas to the F irst Grade and 

Mrs. Kidd, who had taught in that capacity some 20-odd 

years, to the Third Grade.

Was this in recognit ion of Mrs. Thomas' special sk i l ls?

Yes, i t  was.

Now, in regard to Mr. Asive Thomas, did

G LE N N  H P E R R IN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 1 a

you have

! /t



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discussion with Mr. Bradshaw regarding him?

Yes.
And would you t e l l  us about those and when they took

place?
The discussion about Mr. Asive Thomas was possibly 

April of ’ 68, and the purpose of this discussion, Mr. 
Bradshaw had made Home Room v is i ta t ions  and he suggested 

that Mr. Asive Thomas was weak in the area of Social 

Science and he also suggested that Mrs. Kidd was weak 

in methods of presentation, and he asked me to make 

recommendations on it, and I did make recommendations 

to Mr. Bradshaw in le t te r  form and I  recommended that 

Mrs. Kidd and Mr. Thomas return and get additional hours 

in that area and that if they would agree to do this, 

that they would be retained in the School D is t r ic t .

Were you ever asked to ask e ither one of them whether 

they would be w i l l in g  to do that?

No, I d idn 't ,  but I went on the assumption that my 

recommendation would be accepted, and I asked them i f  

they would return, and they did.

21 j| Q. Did
22 ij

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A. Yes.

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23 ;j Q. Now ,

of the Rosenwald School and Mr. Bradshaw in 1969?

Yes.
GLENN H PERRIN  

O f f i c i a l  C o u r t  R epo r t er  
F e d e r a l  B u ild in g

E L  D n a i n n  A b v a n r a b  < r i t w 9 2

172



' v> a l <\ s - i) Lr ■? v .

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: r l i  Ub -appr Xi.-ately when that was anJ where it took 

-\ow, the particular tact or meeting that you arc na k  i ng

oention o t - -

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o k w e l l , wt were

7 ta lking ah <. i

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9 oncoming year,

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12 1 meeting.

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Is this the on'

14
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consequences oi

.. b e l i - v c  w e  - i i s c u c s e h  i t  at .aore than one time, 

.-vli right. At this neeting that you're ta lk i  ig about, 

•whot was said hy Mr. bradshaw and what was said by the 

tea-mers, including yourself,  to the best of your

17 wf a t was a i

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oming year that i t

up with a c r i t e r ia  to determine wĥ  t 

te.-jc. e rs woul 1 be d isn isse i.  At this point, one of the

GLENN H PERRIN
O f f i c i a l  C o u r t  R i r o r t u  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  t it io

i  J  .)



Edwards b i r e c t
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teachers aske i i f  it. - -

MR. STARLING: Your Honor, I am going to object to

what one of the teachers asked or what one o f  the

teachers said in the meeting as being hearsay.

MR. KAFLAN : Your honor,--

THt COURT. I understood Mr. Bradshaw was 

there talking with them.

’IK. STARLING: e l l  r ight.

Continue, Mr. Edwards.

And the question came out i f  a l l  of the teachers who 

would be. dismissed would be black teachers, and Mr. 

Bradshaw made the statement that i t  wouldn't be fa ir  to 

let  out white teachers who had been serving in this 

School d is t r i c t  and working at Plum Bayou and retain 

black teachers.

Oil he say anything else in that regard that you can

recall?

This is basically  i t .  There were more conversation to

it than this, yes.

Now, at that point in time when that conversation took 

place, had i t  already been announced that the Wright 

f a c i l i t y  at Wright, Arkansas , the Plum Bayou School, 

woui.i he the school where the unification would take 

place and that Kosenwald would not be used any more?

Yes, it was generally understood this would be the case.

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o  A r k a n s a s  7 « 7 s o



Edwards Dir ec

2

3

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Hi
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9 i, Q.

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21 jj Q.

22 A.

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24 A.

Had i t  in deed been announced to the faculty and to those 

present.

No.

In making your evaluati.ns which have been introduced 

here as i l a i n t i f f s 1 Exhibit I - - I  w i l l  show you that to 

refresh your recollectton--were you fa i r  and objective 

in those to the best :>i your a b i l i t y  as the Principal?

Yep , I was.

Were you present at any other time from the time you 

just described to us that Mr. Bradshaw made these 

remarks when he said anything else about unif icat ion of

the school system?

Beg your pardon, w i l l  you give me that again?

Yep. Were you present at any other time when Mr. 

Bradshaw made remarks about the unification of the 

school system, particularly  in regard to the retention

of teachers?

Not in a s ta f f  meeting as such. I be l ieve a discussion 

between Mr. Bradshaw, parents, and teachers came out 

one night in a School Board meeting.

Were you present at that meeting?

Ye s .

And lo yon reca l l  when that was?

No, I don't remember the exact date, but 

spring of '68.

GLENN H PERRIN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a w » a »  7 i t « o

i t  was the

1 2 /



Edwards Direc t 176

Q- T e l l  us what happened then.

A. I mean the spring of ’ 69.

Q. All r ight.  Before the school year '69-'70?

A. That' s r i g h t .

Q. Tell us what was said by the various participants at 

that time and where the meeting took place.

A. The meeting took place at the Plum Bayou School in the 

Library, 1 be l ieve ,  and basically  what was discussed at 

this meeting is the parent was concerned about what would 

happen to the teachers of the Rosenwald School, and 

during that meeting i t  was quite a b it  oi discussion 

that took place but basica l ly  i t  evolved around whether-- 

how many of the black teachers would be retained.

Q- Did Mr. Bradshaw say anything in that regard or any of

the members of the School Board, who are defendants here, 

say anything in that regard?

A. Yes. In fact ,  many persons say something in this

regard. I believe that basica l ly  what was said is that 

i f - -

Well, t e l l  us-- identi fy  foi us, please, because i t  is 

necessary to do so, who said what, by name,as best as 

you can reca l l  what they said. For example, do you 

reca l l  Mr. Bradshaw saying anything or any other member

of the School Board/

A 1 couldn’ t quote what was said by anyone at this meeting

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 i 7 » o



Edwards - D irec t 1 7 7

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3

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23 I A.

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other than one statement that was called into question 
hy Mr.--by Mr. Enid Tony at this meeting, and this 
statement was made by Mr. Clyde Archer. He referred 
to —

ts Mr. Archer a member of the Board?
Yes he is.
Tell us about that conversation between Mr. Tony and
Mr. Archer.
In the heat of the discussion, Mr. Archer referred to 
the black teachers as “Niggers" and Mr. Tony called 
his hand on it.
What else was said about black teachers, and how did the 
remark come up?
Well, the onliest other time that--this is not the same 
meeting--the onliest other time that we had a 
discussion concerning black and white teachers was in 

April of '68, in April of '68--no, April of '67. In 
April of '67 we discussed the equalization of teachers' 
salary.
Now, are you talking about vou and Mr. Archer?
Tba t ' s r ight .

All right.

It was--! haa asked the School Board if I could come and 
talk with them, and during this meeting we discussed 
the equalization of teachers' salary, and Mr. Archer at

G L E N N  H PERR IN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  b u i l d i n g  

E L  D o r a d o  A r k a n s a s  7 1 7 3 0



Edwards D irec t

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23 ! Q
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I

this meeting also referred to the teacher as "N iggers", 

and when I asked about bringing the teachers' salary 

up, he told me that he would hire--they would hire them 

for whatever they could get them for, and he used the 

agricultural situation to re fer  to and say that i f  1-- 

because ne knew I had farm background and experience, 

he said i t  I could go out and hire a person to drive a 

tractor for a certain amount, that I wouldn1t go over , 

and they had agreed to work for this amount, so that 

is what they would work f o r v

Now, just so that the record is c lear,  you are talking 

about a meeting in Apri l  of '67 where you were talking 

about equalizing black salaries to the white salaries? 

That ' s r i g h t .

And was it Mr. Archer's comment that he would hire 

blacks for whatever he could get them for?

That ' s r i g n t .

And is it  then that he used the epithet "Nigger", also? 

That's r ight.

And again in this meeting of Apr i l ,  '69, you are saying 

in conversation with Mr. Tony?

That ' s r igh t .

At that time, when he was talking with Mr. Tony, did he 

say anything about hiring or keeping black teachers as 

opposed to white teachers that you can reca l l?

GLENN H PERRIN  
O f f i c i a l  C o u r t  R i p o r t i r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  r i 7 s o 2 3 V



Edwards D irec t

No, I don't remember exactly what was said in this other ! 

than this.

Q Did you ever have any d isc ip l ine  problems at Rosenwald?

A. During the--

0 During the time that you were there.

During the seven years that I was there, I  d idn't have 

what I would consider serious d isc ip l ine  problems other 

than one, I had to expel one boy at one time.

Q- What was the general physical condition of the Rosenwald

School?

The general physical condition was i t  was run down and
I

inadequate teaching supplies and materials. Up unti l  

the T i t l e  I I  Program, some l ibrary materials was bought 

under this program, and we also had Hot Lunch Program ! 

during the last three years there, but prior to that 

tine we had not had a Hot Lunch Program, we had not had 

l ibrary t a c i l i t i e s .  In fact ,  we had one set of 

encyclopedias and tew other volumes, single-volume

books, that had been purchased by the Parent-Teachers'

As s o c  ia t i on.

J-.

Q.

Did you have a to i le t?

No, we had an outdoor t o i l e t  unti l  the last year. 

Indoor t o i l e t  was constructed during the last year 

Did you ask f >r improvements during your tenure as

Pr inc ipa 1.

G L E N N  H P E R R IN
O f f i c i a l  C o u r t  R epo rter  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  t i t u 2



Edwards - Direct

A

2 Q.

3

Yob , I did.

Jid you ever get them?

::o.

MR. KAPLAN; That'S a l l .

THl COURT; Just a minute. 

THE WITNESS; i am sorry.

Just a minute,

CRQS; EXAMINATION
9 BY MR. STARLING:
10 Q. Mr. Edwards,
11 I was going to
12 I believe you

1 together and
14 !i1 ! teachers woul
15 ||ji resolved?
16 j j Al. This is true.
1 7  1

, |
V* Mr. Bradshaw s

18 il be made among
19 among both the
20 A. When we discus

was just going to

21 Ra“s-> ari(̂ *n>sel->- 3no Mrs. Srair would make evaluations
22 oi our various compon-?nts and then that we would come
23 together -or a final ovaluation.
24 Q. evaluation o, all of che teachers?
25 ji fhat ‘ s right.

GLENN H PERRIN
O f f i c i a l  C o u r t  R c f o r t c r  

F i d i r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 17 10 7  7 /

180



ndwards - Cross

Q.

2 !; A.

5 !!

A.

Ibcit is both black, an i white teachers?

Right.

And 1 believe you t e s t i f i e d  that you had several meetings 

discussing how this evaluation of a l l  of the teachers 

would take e f fe c t  and the c r i t e r ia  to be u t i l i z ed ,  is

that correct?

Yes.

s ;l q.

9i;jj

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You fee l  that Mr. Bradshaw was concerned about this 

problem of evaluating the teachers?

Yes, in a limited way.

I ne was interested enough to hold meetings and come 

up with an evaluation of a l l  of the teachers, which he 

in j.rated t > you both black and white were going to be 

evaluated, why do you reckon, as you a l lege ,  that he 

made a statement that--at a meeting that he was not 

going t 1 retain any of the black teachers and le t  any 

of the white teachers out?

I beg your pardon?

A ter going to the trouble of explaining to you his 

purpose in evaluating a l l  of the teachers, both black 

an: white, and the c r i t e r ia  would have to be come up 

with, what do y iu feel in reference to the statement 

that you made that he stated, or that he stated at a 

School Board meeting or a meeting that he would not le t

any i f  the white teachers but was not going to retain

GLENN H PERRIN  
O f f i c i a l  C o u n t  R b f o n t k m  

F e d e r a l  B u i l d i n g  

EL D O N A D O .  A r k a n s a s  t i t s *

131



upwards Cross 182

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any ot the black teachers?

1 had no way of drawing this conclusion. The onliest 

thing that I can say in regard to this is that we did 

not follow through on the evaluation. In other words,

I did not take part or have input in the to ta l  

evaluation of the D is tr ic t  nor did the other Principals 

in the D is t r ic t .  In ather words, I simply ranked the 

teachers within my school system.

Mr. Edwards, anytime during this evaluation, the coining 

up with the c r i t e r ia ,  the meetings with you, the 

meetings with the teachers, did Mr. Bradshaw ever 

indicate to you that his evaluation would be based upon

race ?

Oh, no.

Di he ever state that to you?

No.

Did any member of the school Board ever state that this 

evaluation wiuld be based upon race?

No.

Then le t  ne ask you this question, maybe we can clear 

some things up. The rea l ly  only objection that you 

have to the evaluation was the fact that i t  was your 

understanding that once you had evaluated your teachers 

and once Mrs. B la ir,  the Head Teacher of the Elementary 

School at Plum Bayou, had evaluated her teachers, that

GLENN H PERKIN
O f f i c i a l  C o u r t  l U F O R r n  

F e d e r a l .  B u i l d i n g  

E L  Dorado A rk a n s a s  T1 7 RO 2 . 2 0  A



T

Edwards - Cross

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the two Head Teachers and Mr, Bradshaw would get together I 

and discuss and evaluate a l l  15 of the teachers and 

determine who would be retained?

That's r igh t .  In other words, my objection would be 

that a l l  persons who nad knowledge, working knowledge, 

of these teachers were not conferred with.

All r igh t .

In other words 

You fee l  that you--

--mv evaluation was not used at a l l .

You feel  that you knew the black teachers better than 

Mt. Bradshaw did in the every day performance?

That's r igh t.  i
I

I ' l l  agree, 1 think you probably did, also. But you 

also t e s t i f i e d  that Mr. Bradshaw never made any statement 

to you or made any indication to you that his evaluation 

would be based on race?

No.

Now, do you agree that the proper way to proceed 

with this evaluation was to come up with a c r i t e r ia  

and to evaluate a l l  15 teachers, both black and white, 

is that what you concede to be the proper way to do it? 

Since the School D is tr ic t  was to be unified and we had 

teachers both c e r t i f i e d  ir. elementary and secondary 

education and some of the teachers at the Rosenwald

GLENN H PERRIN  
O f f ic ia l  Co u rt  R eport! *

F e d e r a l  B u i l d i n g  

E L  D o r a d o  A r k a n s a s  t i t s a

183



184
Edwards - Cross

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25

School was holding secondary c e r t i f i c a t io n  but had been 

^orced t teach in elementary schools because of 
integration, 1 feel that the evaluation should have 

involved all teachers in the D is t r i c t , not just the 

elementary teachers even.

Well, now, in reference to that particular statement, 

which I wasn't aware of, le t  me ask you th is,  how long 

had it been since the elementary teachers at the 

Tucker-Rosenwald School had taught high school?

It nad been since the high school-- 
Four years, right?
--movec to Plum Bayou. No, three years.

Three years. So they really hadn't had any teaching 
experience in the high school level for a period of 
three years, is that correct?
This is true, other than junior high.

Now, going back to my or ig ina l  question, i f  Mr. Bradshaw 

was going to evaluate the elementary teachers, would

you concede that i t ' s  proper that he should have 

evaluated all 15 teachers, both black and white, rather 

than just evaluate the Negroes or just the whites or
however it may be?
Definitely .-,j.

Let me ask vou, Mr. Edwards, i f  1 may, what were the 

names ol the Negro teachers at the Tucker-Rosenwald

GLENN H PERRIN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

CL D o r a d o  A r k a n i a *  t i t i o



Edwards Cross

l j School, the elenentary teachers, when you made your

2 evaluation?

3 a . Mrs. Clark, Mrs. Davis, Mrs. Evans, Mrs. Gordon, Mrs.

4 Kidd, Mrs. Dora Thomas, and Mrs. Lois Ann Thomas.

5jl k Lrhai was the names of the elementary teachers at the

8 Plum Bayou Elementary School?
Ii

Mrs. Keith, Mrs. B la ir ,  Mrs. Moore, Mrs. Ramsey--I

5 believe that 's  a l l  I can name right now.
j

*!j a Was a W i l l i s  working there? Was she an elementary

io ji teacher?

n ij A. Yes.

12 I Q. And was--
i

A.13 Now> that 's  one name that I am familiar with, but I was

14 actually naming white teachers rather than the whole
IS s t a f f .

16 Q. Well, let me ask you i f  these were the names of the

17 teachers who were working at the Plum Bayou Elementary
18

1
School at the time of the evaluation. Mrs. Blair?

10 A. Yes.

20 Q. Mrs. Dye or Wall?

21 ! A. Jh-huh.

22 Q. Mrs. Ramsey?
!

23 A. Yes.

24 Q. Mrs. Rosen?
i
i
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39 A. Yes.

1

i
ii

GLENN H PERRIN
O f f ic ia l  Co u n t  R cpontsn 

P kdknal Ruiloim o  
I L  Dobapo_A i i h i i m h  _______ *7  * J t



Edwards - Cross

13 I Q-

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1
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Q. Mrs. W i l l i s

2 A . Yes.

3 Q. Mrs. Moore?

4 A. Yes.
ii

5 j i c . And Mrs. Kei
Ij

6 A. Right.

7 I Q. Now, at the

8 '! evaluation o

9 l i A. Uh -huh.

1 0
>j

Q. And you made
1

11 •i that correct

12 l| A. This is true

an

Do you know whether Mr. Bradshaw asked Mis, Blair, the 
Head Teacher of the Pluni Bayou Elementary School, to 
make an evaluation of her teachers?
No , I don 11 .

A l l  r ight. But it was your only objection to this whole 
thing which you have stated is the fact that after the 
evaluations were made by the individual Head Teachers 
that you then d i d n ‘ t  get together, you, Mrs. Blair, and 
Mr. Bradshaw, and s i t  down and determine who would be 
retained and who would not ,  is that not a correct 
s ta Lenient ?

This is true, because this is what had been indicated 

would happen.

GLENN H PERRIN  
O rr ic iA L  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 1 7 1 0

186

1  t l v  -



Edwards - Cros;

M Q-

5 ,

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Q.

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Let me just show you an enlargement of  a chart,  i t  is  

homemade and not the best in the world, and ask you i f  

tnese were the elementary teachers at the Plum Bayou

Elementary .school at the time you made your evaluation?

That is true.

And were these the elementary teachers at the Tucker- 

Rosenwal i School at the time you made your evaluation? 

That's r igh t .

Now, assuming you made your evaluation, which you did, 

assuming sirs. B la ir  made her evaluation of her teachers, 

and that you had gotten together with Mr. Bradshaw to 

determine which teachers would have stayed and which 

teachers would not have stayed a f t e r  the evaluation,

how would you have evaluated, l e t ' s  say, Mrs. Gordon

with Mrs. Moore?

fne part : ere is that I would not have evaluated them

a0ai. ist ,  you would have had the three persons making 

these evaluations. In other words, I could have ordered 

the strength and weaknesses of my teachers compared with 

Mrs. B la ir  and M.. Ramsey ordering the strength and 

weaknesses of th* i r  teachers and c o l l e c t i v e l y  with the 

knowledge that fir. Bradshaw had and that the three of 

us . ad, we could have come up with a better  evaluation 

than any oPe per:- in could have.

vlka) . How ;-idny tr  lpa have you made as Head Teacher of

GLENN M PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o  A h v a m b a b  t i t * /

187



Edwards - Cross
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the Tucker-PosenwaId School over to the Plum Bavou 

elementary behool ior the purpose of observing these 

teachers in the performance of the ir  duties?

1 hadn't made any s p e c i f i c a l l y  to observe them. Of 

course, I had made some tr ip s .

ilow many times had Mrs. B la ir ,  who was the Head Teacher

01 f iun bayou elementary School, come to your school, 

to Tucker-KosenwalJ Elementary School, :or the purpose 

o. i , taking pors ma 1 observation ol teacher performances 

in that school?

N on e .

Let s say, i t  we fo l low up ~*n your answer awhile ago, 

a f t e r  you have evaluated your te a c h e r s - - f i r s t  of a l l , - -  

s t r ik e  t a t ,  please, f i r s t  of a l l ,  could you have 

compared any of the teachers on this l i s t  with any of 

the teachers in that l i s t ?

Y<*s , 1 could nave. 1 could have compared them from the 

standpoint or number o: years experience, I could have 

compared then ron the standpoint of c e r t i f i c a t i o n  and 

from the ir  transcr ip ts .  These are things that 1 would 

nave had an ipportunits t > see, and 1 could have given 

input based in th is ,  an i then, not only that, hut from 

the standpoint of d is c ip l in e ,  the amount of pull that 

was established, i t  would have been a basis for 

discussion between Mrs. 3 ia i r ,  myself,  and Mrs. Ramsey.

GLENN H PERRIN 
O p i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n r a r  t i t s o



Q- in other w ■>; .s , are you saying then the only c r i t e r ia  

which would he u t i l i zed  in evaluating teachers are 

paper criteria.-'

A. No, I am not.

0- Are you saying--

A- ue f in i t e ly  not.

Q. Are you saying there are abstract qua lit ies  which a 

teacher must have to be a good teacher?

A. Oh, yes.

Then in evaluating or comparing the abstract qua l it ies  

ol ary "*f the teachers at the Plum Bayou Elementary 

School with the teachers at the Tucker-Rosenwald 

Elementary School, could you have compared those 

abstract qualit ies?

A. No, not without additional information.

Q. Did you evaluat c your ownself in your evaluation?

1 it. No, A. • i. 1 A A 1 w j

How t h e n , w e r e you going to include yourself in one o f

the 15 teachers who were going to be retained or not 

reta ined?

I had de l iberate ly  l e f t  myself out of the evaluation 

because Mr. Bradshaw and I had talked prior to that and 

he had offered me a position teaching middle-grade 

Mathematics. He had also decided at that time to hire 

a person who was not c e r t i f i e d  in any area as Principal

GLENN H PERRIN  
O f f i c i a l  C o u r t  R e p o r t e r

F e d e r a l  B u i l d i n g  * * * * * *  /  ^

EL D o r a d o  A r k a n s a s  7 < 7 s o  jT  L  i



Edwards Cross 190

ii
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o*c L̂ ,e school, and I had already set out to seek 

additional enployment and wouldn't be in the D is t r ic t ,  

so j. diin t tee l  that it  would even matter one way or 

the other, so 1 didn’ t include myself in the evaluation. 

Isn 't  i t  not true that Mr. Bradshaw made his evaluation 

of the teachers prior to your giving him your 

res ignat ion?

DiJ Mr. Bradshaw make his evaluation--

Did you- - f i r s t  of a l l ,  did you make your evaluation

prior to your g iving your resignation to Mr. Bradshaw?

Yes , I did.

And didn't Mr. Bradshaw make his evaluation of a l l  of 

the teachers prior to you g iving him your resignation? 

Possibly so. I believe I gave him my resignation in 

Apr i l .  i t  would have been about the same time.

1 see. Mr. Edwards, in other words, you did not evaluate! 

yourself in reference to the teachers at your school, 

right?

No, because that would have been a se l f-evaluation.

Then, in other words, you couldn't r ea l ly  have evaluated

yourself,  couli you?

No, I wouldn't have attempted to do that.

But, on the other hand, a l l  15 teachers needed to be

evaluated ?

This is true.

GLENN H PERRIN 
O f f i c i a l  C o u r t  R s p o r t k r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 S 0



Q. Who was the m ly  person who could rea l ly  look at a l l

1j teachers, Including Mrs. Bla ir ,  the Head Teacher, and 

you, and evaluate a l l  of them?

A Mr. Bradshaw would have been in the best position to 

evaluate me, but not necessarily in the best position 

to evaluate a l l  teachers.

Q. Well,  again, I ask you, how can you compare the abstract 

qua lit ies  of a teacher, of Mrs. Evans or Mrs. Clark, 

with any of the teachers over here who you have never 

observed in the performance of their classroom duties?

MR. KAPLAN: Your Honor, 1 think we have gone over

this several times already and getting a l i t t l e  

repet i t io u s .

MR. STARLING: A l l  r igh t ,  f ine.
i

Q. Let me ask you one f in a l  question, i f  you w i l l ,  concern­

ing th is ,  and that is ,  in the event that you and Mr. 

Bradshaw and Mrs. Blair had sat down and discussed these 

teachers together,  which is the rea l ly  only objection 

you have to what happened, is that correct?

This is true.

tdwards - Cross

Q. What i f  lrs. Blair had said Mrs. Moore is better than 

Mrs. Gordon, and you had said, "No, Mrs. Gordon is better 

than Mrs Moore", what would have been the f ina l  auditor

of that part icu lar  s ituation?

I think one of the things that 1 would use in comparison

GLENN H PERRIN
O f f ic ia l  C o u n t  R epo rter

F e d e r al  B u il d in g

EL Do r a d o . a r k a n r a r  t i 7 »o



Edwards - C oss

5 |i

9

10 I, 0-
II

11 l i
» ■  A.

13 I c.
14

15

16

17

18 II r, |l

is a fter  l looked at Mrs. B la ir 's  evaluation, I would

have used my teachers along with Mrs. B la ir 's  teacher 

and compare how she had compared the teachers that I 

did have s ome knowledge of and then 1 would compared my 

teacher. There is some teachers in this l i s t  of Mrs. 

B la ir 's  that I had experience with, and then based on 

my knowledge of those teachers and the teachers that I 

had evaluated and Mrs. B la ir 's  evaluation, I could have 

reached some type of evaluation.

But in the i in a l  analysis, Mr, Bradshaw would have been 

the man who had to make the decision?

Oh, yes, d e f in i te ly  he had to make the decision.

Alter the evaluation, Mr, Edwards, do you know the 

order in which these teachers, the result  of the 

evaluation ranked the teachers?

I couldn't remember just offhand, but I did get a chance

to see i t .  I have seen i t .

Can £ give you or show you an enlargement of the ranking

19 of the t e a c h e r s , and i wi L1 read them o f f ,  and you t e l l

20 me i .  this is correct to the best of your knowledge.

21 ,i No. 1 was Mrs. Mildred Blair.

22 A Uh-huh.

23 ' Q. No. 2 was Mrs. Janet Dye. No. 3 was Mrs. Robbie Keith.

24 No. 4 was Mr. Edwards. No. 3 was Mrs. Moore. No. 6 was

25 Mrs. W i l l is . No. 7, Mrs. Rosen. No. 8 was Mrs. Davis.

GLENN H PERRIN  
O ff ic ia l  C ount R eports*  

P bdkral B u ild ing  
EL Dorado  A rk ansas  t i t » o

192

* 5



Edvards Cross

*N,:°- , Mrs. .-.vans. No. 10 was Mrs. Clark.

Now, Chose were Che ten teachers who were retained and 

in Che order in which they were ranked a f te r  the

evaluation.

Oh-huh.

Is that true to the best of your knowledge?

That's r igh t .

And o; the l i v e  teachers who were not retained and the 

order and rank in which they were evaluated; No. 11, 

Mrs. Ramsey. No. 12, Mrs. Gordon. No. 13, Mrs.

Thomas, do. 14, Mrs. Dora Thomas. No. 15, Mrs.

Armenia Kidd.

Now, i t  you had had the opportunity to evaluate these 

teachers as you suggested that you should have had, and 

being your only object ion in this particular matter, 

how would you have ranked those teachers d i f fe r en t ly

than Mr. Bradshaw did?

.H<. KAPLAN: Your honor, I am going to object. We

have gone through that. He has already t e s t i f i ed  

to those addit ional .actors ne would have needed 

an! those conversations he would have had to engage 

m. He has already answered that question.

THE COURT; No, I don't think he has answered 

the s p ec i f i c  question. I t ’ s a proper question.

I w i l l  answer i t  in this way; I f  you note, Mrs. Althea

GLENN H PERRIN  
O f f i c i a l .  C o u r t  R c r o r t k r  

P socral. Bu ild in g  
EL D o r a d o  A r k a n g a *  7 1 7 s o 2 M &  *



Edwards - Cross

5 ii

7 i

23

24

25 Q.

194

Gorion, No. 12. Within my school I had ranked her No. 2, ! 

which means that she would have de f in i te ly  not f i t t ed  in 

that category ■- ith me having seven teachers in my school 

system. Let me point out Mrs. Lois Ann Thomas, who I 

ranked No. 4 } she would have not been in that lower f i v e .  

So as i t  was pointed out this morning, I had ranked Mrs. 

Evans as a stronger teacher, Mrs. Gordon second strongest, 

Mrs. Lois Thomas third strongest, Mrs. Maxine Clark 

fourth, Irs. Davis f i v e ,  Mrs. Dora Thomas s ix ,  and Mrs.
10 Kiddi seve a .

11 j a Well,
1

now M -c, . i O

12 Mr s . A r t i e Dav

13 - This Is t rue.

14 L How would you

15 ! wou Id you have

16 peopl e?

17
| L wouid have r
]18 1
:

Dav is h a r ed »n

18 class o o 0 , t h e

20
l!

Q- How- would you
II

21 i! r e fe r ence to y

22 : THE

attempt to rank himself, Mr. Starl ing.

•■IK. sTAPLINC: I w i l l  withdraw the question.

In reference to these bchool Board meetings, which you

GLENN H PERRIN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i m o

< •>  cC L  H f t B A r t r t  A  » w  a



Cros tEdwards

xi t e s t i f i ed  that, I be l ieve ,  Mr. Archer on two occasions

* use. tre -ptthet "N igger" , could he have used the term

3 "Nigri"?
4 No, he didn’ t .

ME. STARLING: 1 believe th a t ’ s a l l ,  your Honor.
i l

6
ilI

1  REDIRECT examination

8 ! BY MR. KAPLAN:

8 |j • tdwards, when did you find out about this non-

certx iod individual that was going to be hired to be

11 ! the ’r inc lpa l  o the consolidated, unified Plum Bayou
12 |

ii
School/ ;

i
13

Actually, I hadn’ t had anything o f f i c i a l  on i t ,  but,
14 we 11 1

ir every school d i s t r i c t ,  I guess, l ike  everywhere j
15 else intentions and plans for the next year get
16 out , and i knew that Mr. Ramsey and Mrs. Ramsey had

1
17 a lrea dy previously stated that they would not be with
18

1 the ochool D is tr ic t  another year early in the year, and--
19

! d- They had -aid that early in the year?

20 Yes ,
1

they ha i .

21 ! Q. Pr i or to March?

22 i’1 A. That ’ s r ight.
11

23

ji
Q. And prior  t ) both of the evaluations discussed here?

24 j
A i . That ’ s r igh t.

25
ME. STARLING: Your Honor, I object to that, 1

1
1 GLENN H PERRIN
I O f f i c i a l  C o u r t  R e p o r t e r

F e d e r a l  B u i l d i n g

i E l  n —-  ■ —  - - ....... ...................



Edwards - Red irec t
196

5 li

d a n  t R e l i e v e  that-- I  be l ieve in one thing what 

:"Ir“ r' ansey and Hrs. Ransey said would be hearsay, 

ani t h e  > t h e r  thing I don't believe there has been 

any testimony at a l l  concerning that fact.

KAPLAn: Well, he just t e s t i f i ed  to i t .  I w i l l
0

ji as!; him how he knows i t .  I don't think i t ' s

7 ji
inadmissible.

8 THE COURT: W e l l ,—

9
i| Q-
I

How d id  y  iu find out--
i

10 THE COURT: Of course, he said i t  was hearsay.

11 i

1
He said i t  was hearsay, M r. Kaplan. He said

12 l| "That's whet Mr. Ransey said". i
13 HR. KAPLAN: A l l  r ight.

1

14 Q. D id  you have a conversation with either M r. Ramsey or j
15 Mr. Bradshaw in  that regard?

16 A. With Mr. Ramsey and Mrs. Ramsey from time to time, 1
they

17 had discussed their plans for the coming year.

18! Q• A l l  r ight.  Now, in regard to the Head Teacher or
19

Principal at the Plun Bayou Bchool, I take i t  that there |
20 1 is such an individual, is  there not?

21 | c\. That's r i g h t .
j

22 Q. H a l b een  h is to r ica l ly  in  the D istr ic t?
||

23 h. That ’ s r ight.
i|

24

||
Q. Were you ever told that you were being considered for

25 1 that position? i

GLENN H PERRIN

1 Official Count Rbfontkn
F c o k r a l  B u i l d i n g

E l— D o r a d o  a  n»# *



No, like I mentioned, I had been told that--

THt COURT; Now, wait a minute, who told you? 

iHL 1TNESS : Mr. Bradshaw.

THE COURT: A l l  r igh t.

What did he t e l l  y 3u and \>;hen did he t e l l  you?

I t  would have been about March of '69.

And what did he t e l l  you?

He told ne that--he asked me would I consider taking the 

position to teach middle-grade Mathematics at Plum

Bayou.

Did he say anything at a l l  about any kind of adminis­

tra t ive  capacity that went with that?

No.

A l l  r igh t .  Now, in response to several of Mr. S tar l ing 's  

questions, you said that your basic objection to the 

evaluation method was that you did not partic ipate in 

i t ,  and oid you not also s ta te --o r ,  le t  me str ike that, 

and le t  me ask you, did Mr. Bradshaw say anything about 

not hiring blacks in preference to whites?

Only in the s ta f f  meeting that I had mentioned-- 

W e l l , —

--where he stated to the faculty at this meeting that 

he ! idn ' t think i t  would be fa i r  to dismiss white 

teachers who had been working in the Plum Bayou School 

over a number of years to replace them with black

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g



.1
i, iwn rd ■, - Red i r ec t

1 teachers iron Tosenwald School.

2 Q- is ow , in your evaluation o'" the unfairness of the

3 eva iuatl on method, or ijn your opinion of the un fa i rn ess ,
4 d o e s thi s remark also play a part?

5ji
J|

A. Yes , it does.

6

lj
7 1

MR. KAPLAN: That':3 a l l .

8 RECROSS EXAMINATION

BY MR. STARLING:

10 ( Q.

li ;

12 1

13

14

15

10

17 i

18

19

20

2i :

22

23

24

25

M r .  E d w a r d s , w h e n  I  a s k e d  y o u  e a r l i e r  h a d  M r .  B r a d s h a w  

e v e r  i n d i c a t e d  t o  y o u  i n  a n y  w a y  o r  m a d e  a n y  s t a t e m e n t s  

t o  y o u  t h a t  h i s  e v a l u a t i o n  w o u l d  b e  b a s e d  u p o n  r a c e ,

y o u  s t a t e d  ’‘ N o " .

Mo-. B r a d s h a w  d i d  n o t  t e l l  me s p e c i f i c a l l y  t h a t  h i s  

e v a l u a t i o n  w o u l d  b e  b a s e d  u p o n  r a c e .  A  t e a c h e r  i n  a n  

o p e n  s t a f i  m e e t i n g  a s k e d  M r .  B r a d s h a w  w h o  w o u l d  b e  l e t  

o u t  a n d  i f  i t  w o u l d  b e  a l l  b l a c k  t e a c h e r s ,  a n d  h e  

a n s w e r e d  h e r  b y  s a y i n g  t h a t  h e  d i d n ' t  t h i n k  t h a t  i t  w o u l d  

b e  l a i r  t o  d i s m i s s  t e a c h e r s  w h o  h a d  b e e n  a t  t h e  P l u m  

B a y o u  S c h o o l  a n d  g i v e n  t h e i r  s e r v i c e  t o  h i r e  b l a c k  

t e a c h e r s  ■ r o m  R o s e n w a l d .  T h i s  \was h i s  r e p l y  t o  t h e m .  

W e l l .  t h - T , ,  M r .  E d v a r d s ,  w h y  d i d  M r .  B r a d s h a w  g o  t o  a l l  

o i  t h e  t r o u t  l e  t o  c o r e  u p  w i t h  a n  e v a l u a t i o n  t e s t  a n d  

t e l l  y o u  t h a t  h e  w a s  g o i n g  t o  e v a l u a t e  a l l  1 5  o f  t h e  

t e a c h e r s ,  b o t h  b l a c k  a n d  w h i t e ,  i f  h e  a l r e a d y  s a i d  h e

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g



199Edwards - Recross

I1

5 .

10

11

12

13

14
!

15
i

16 II

17

18

19

20

21

22

23

24

25

w a s n ' t  g o i n g  t o  h i r e  o r  r e t a i n  t h e  Negro teachers;’

Hr  h a d  a l s o  s t a t e d  t h a t  a l l  teachers would be involved 

i n  t h e  e v a l u a t i o n ,  but that was not carried out, e ither.  

W e l l ,  the reason, I t h i n k ,  we have tr ied to demonstrate 

w h y  t h a t  w a s n ' t  c a r r i e d  out is because you were not 

k n o w l e d g e a b l e  i n  t h e  a r e a o f  the white teachers, there is 

n o  w a y  y o u  c o u l d  h a v e  e v a l u a t e d  them, the only person 

w h o  c o u l i  h a v e  e v a l u a t e d  the teachers as f a i r ly  as 

p o s s i b l e  w o u l d  h a v e  b e e n  M r .  Bradshaw, he is the only 

o n e  w h o  had,  k n o w l e d g e  o i  both sets of teachers, but the 

q u e s t i o n  I a r  asking y o u  i s ,  why did Mr. Bradshaw go to 

t h e  t r o u b l e  t o  c o m e  up w i t h  an evaluation test and 

e x p l a i n  t o  vou t h a t  h e  was going to evaluate a l l  15 

t e a c h e r s ,  b l a c k  an! white, i f  in fact he had made the 

s t a t e m e n t  t h a t  h e  was not going to retain any black 

t e a c h e r s  ?

Y o u  a s k i n g  . o r  a n  a n s w e r  o r  a n  o p i n i o n ?

I am a s k i n g  f o r  a n  a n s w e r .

I  w o u l d  h a v e  t o  g i v e  y o u  a n  o p i n i o n .  I f  you want me t o  

g i v e  y o u  a n  o p i n i o n ,  I  c a n  g i v e  t h a t .

Wa-  this a s t a f f  m e e t i n g  w h i c h  w a s  s t a f f  meeting o f  the 

P l a n  B a y o u  E l e m e n t a r y  s c h o o l  plus the Tucker-Rosenwald

E l e m e n t a r y  S c h o o l ?

N o ,  o n c e  monthly we w o u l d  have a workshop where teachers 

w o u l d  d e m o n s t r a t e  new methods or techniques to the s ta f f

GLENN H PERRIN 
O ff ic ia l  Cou nt  Rbpontkn 

Fkdcnal Bu ild in g
EL D o r a d o  A i h i m i a i  t i v i a



Recross
200

Edvards -

Q.

Q.

10

11

12 '!

131'
14 Ij
15

ia l |
I1

17 ji

18 ij
II

19
I

20

21 ji

22

23

24

25 i

A .

as a n  m s er v i c e  type of training program, and we would 

a l w a y s  invite Mr. Bradshaw in to these workshops, and

t h i s  w a s  at the end of one of said workshops.

At t h e  Tucker-Rosenwald School?

At t h e  Tucker-Rosenwald School.

And you lean to say that Mr. Bradshaw stood before a l l  

nine >egro teachers and told them, when they asked him 

what was gJing to happen to the faculty when there was 

a reduction in force took place due to unif icat ion, 

that none of the Negro teachers were going to be 

retained?

No, 1 did not say that Mr. Bradshaw said that. I say 

that Mr. Bradshaw say that i t  would not he fa i r  to

d i s m i s s  w h i t e  teachers from Plum Bayou School to 

r e p l a c e  t h e m  with black teachers from Rosenwald.

L e t  m e  a c k  y o u  t h i s ,  d i d  l i e  i n  t a c t  replace any white 

t e a c h e r s  w i t h  a  a l a c k  t e a c h e r  rrotn Tucker-Rosenwald

School?

No.

I showed you the evaluation form that Mr. Bradshaw 

m a d e  m t  a t  the end o f  that evaluation, how he ranked

those teachers , - -

LTh-huh .

- - a n ;  I -how you on that in a 1 evaluation ranking, Mrs. 

i - i t z a n e t h  Ramsey, who was ranked No. 11.

OUENN H PERRIN
O w e i a l  c o u r t  R eporter

PCOERAL •UILDINA



L ' Ivans Rtcross

M l  A U h - b u h .

2 : j  Q. I s  s h e  w h i t e  o r

3 A. S h e ’ s w h i t e ,  b u t

4 l e a v i n g  t h e  D i < t

5 : 0. H  ow ' o  y o u  K .n .o wr
« a.

7 1

8

9

17 i

18

10

20

2!

22

23

24

25

Mr. Bradshaw a wl Mr. kai. sey and I was at State Teachers’ 

College at Conway tan log administrative course, and 

Mr-. Ramsey a s  early as that knew that he would not b e ,— 

a. ! that was Ln 16 7 — that he would not be in the D is t r ic t ,

10 He w a s  b u i l d i n g  a home up at Beebe, and he had planned

li :| t o  l e a v e  p r i o r  t o  t h a t t i n e .

12 j. D i d  Mr. ka.nsey i e l i  Mr Bradshaw that Mi: s . Elizabeth

13 tj
R a m s e y  wa> g o i n g  t o  he r e s  i g n i n g ?

14; k - I c o u l d n ' t  say.

15 i! Q l W e l l ,  t h e  i ,  l o o k i n g  a t t h i s  evaluation, then, is i t  not

16 J true t h a t  M r s .  Ramsey was evaluated No. 11; thereiore,

she was i o t  o n e  o f  the teachers retained?

S h e  i s  e v a l u a t e d  N o .  1 1 .

h;. isi, t i t  true that Mrs, Clark, Mrs. Evans, Mrs.

D a v i s ,  Mr s . w i l l i s ,  M r .  r. car is are N e g r o  teachers 

w h o  c o u l u  c a v e  i n  .‘-act replace ' her on the evaluation? 

we o ’.ii-i ot r e p l a c e  s o m e t h i n g  that was leavLog anyway. 

Hov Jo y o u  k n o w  s h e  w v s  l e a v i n g ,  d i d  she t e l l  you she was 

r e. s  i g n i n g  •

Y e h  , s h e  i d .

GLENN H PERKIN  
Of f ic ia l  Co u nt  R o e a r n  

PCOKNAL BUILOIMO 
CL Dorado  A beaurar

I C f J &



towards - Recross

Wh e n  ?

Mi s . k ums e v - dine L 3 p i

to l  i c e  a n d  ;dr s . r.v ans

O c t  . O e r  o f t  that s h

Distr ic t  the next year

SX̂ LING* i believe t h a f s  a i l .  Thank you.

9 i n'

10

11

12

13

14

15

.REDIRECT EXAMINATION

MR. K A P L A N ;

Mr. Edvards, whaL is your response to Hr. Starling*

question.

Which one.

A. ii tht *- eat,o wny Hi . Bradshaw engaged in the 

evaluation anyway.

I f  I was*-

16

17 i

18

19

20

21 I!

22

23

24

25 |

MR, 2; TAR LING: I object, Your Honor, i f  i t ' s  going

t o  a >p i .o i o n . H> i s  n o t  one qua l i f ied  to g i v e  

an o p i n i o . .

VIK. KAf LAN: Your Honor, he asked the question. He

was ent it led  to answer i t

>IR“ 5^ L IN G :  I withdrew the question, too.

1R. *0AtEAN: Not that i  heard, Your Honor.

a Hi uOilRl; W e i ; ,  what question is this?

• fuU ^  - “ hy >ir. Bradshaw went through the 

evaluation even though he said that teachers would

OUENN H PCIVIVIN
Of f ic ia l  Co u nt

F io c n a l  S uiloim o

20,



towards ti rec l J03

22

23

24

25

n o t - -  l a c k  t e a c h e r *  w o u l d  a o t  h e - -

i . ! ±  C O U R T :  W e l l ,  we  h a v e  b e e n  g o i n g  t h r o u g h

thi . - ,  e v a l u a t i o n  a n d  t h e  r e a s o n  f o r  i t  a l l  d a y .  

x - 3  ' 1 1 s e e  t h a t  t h i s  w i t n e s s  n o w  c a n  g i v e  a n y  

>p i n  i n n s  a s  t o  w h y  M r .  B r a d s h a w  d i d  s o m e t h i n g  

a n y  m o r e  t h a n  M r .  B r a d s h a w  c a n  g i v e  o p i n i o n s

7 1
a s  w h y  h e  d i d  s o m e t h i n g  o n  h i s  o w n .

8 lj
w' hat  1  w o o l :  l i k e  t o  k n o w ,  w a s  1 9 6 8  a n d  ' 6 9

9 1 y o • :r  l a s  L y e a r  -

10 ;j THL
i

a IT N L S S : T h a t ' s  r i g h t ,  s i r .

11
;
J
|

IHr.  C O U R T :  A n d  t h e  y e a r  f o l l o w i n g  t h a t  w a s
1

12 |
w h e n  t h e y  h a d  t h i s  t e a c h e r  r e d u c t i o n ?

13
j THE i I T N L S S :  T h i s  i b  t r u e .

14 i
T HL  COURT:  T h e r e  w e r e  n o - - w e r e  t h e r e  a n y

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r e d u c t i o n s ,  s o  f a r  a s  y o u  k n o w ,  i n  h i g h  s c h o o l  i

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t e a c h e r s ,  N i n e  t h r o u g h  T w e l v e ?

|
17 THL I T N u o S .  N o t  t h a t  I  k n o w  o f ,  s i r ,  o t h e r  t h a n

18
1 •' ir . a m s e y .

19
THL ■COURT: d i d  t h e y  r e p l a c e  M r .  R a m s e y  w i t h

1
20

s  ome b od y  e l s e  ?

21 | THL W I T N E S S :  Y e s ,  t h e y  d i d .

THL COURT. who?

?Hh w1TNEHS : Mr. K1utts .

THL 10URT : 1 he/

"Hi iviTNLSS: Mr. Klutts , I believe,

G L E N N  H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n gPI firm A nr, A ■. . ... . i 2 5  9 n



ndwards Re ! i r e c t

1 TllE C O U R T :  K l u t t s ?

2 :
THE W I T N E S S :  U h - h u h .

3
THu C O U R T .  I s  h e  i n  t h e  h i g h  s c h o o l ?

4
THE W I T N E S S .  T l a t  s  r i g h t ,  s i r .

5|j
l! T}iE C O U R T :  A n d  h e  w a s  t h e  o n l y  .one t h a t  w a s

0
j!l

a H e l  t o  t h e  h i g h  s c h o o l  t e a c h e r s ?

7 It
THE W I T N E S S :  He w a s  a l r e a d y  i n  t h e  h i g h s c h o o l ,

Y o u r  H o n o r ,

THt. C O U R T :  w e l l ,  I  n o t i c e d  t h a t  h e  w a s  t h e r e

s o  I d i d n ' t  k n o w  h o w h e  c o u l d  h a v e  t a k e n  M r .

R a m s e y ' s  p l a c e .

THL . I T N R S b . i d r . R a m s e y  w a s  H e a d  T e a c h e r

THc. C O U R T .  rie w a s  w h a t ?

THi-- W I T N E S S :  He w a s  P r i n c i p a l  o f  t h e  P l u m  B a y o u

S c h o o l ,  a n d  M r .  K l u t t s  w a s  m o v e d  u p  t o  t a k e  h i s

p o s i t i o n .

THt. C O U R T :  O h ,  y o u  h a d  a P r i n c i p a l  o f  t h e

18
II s c h o o l . -

19
THE W I T N E S S :  T h a t ' s  r i g h t ,  o r  H e a d  T e a c h e r .

20
iHr.  I 0 U R T :  H e a d  T e a c h e r ?

21 !| THE W I T N E S S :  U h - h u h . P r i n c i p a l  w o u l d b e  a p e r s  o n ,

22 :| Y o u r H o n o r , w h o  d e v o t e s  m o r e  t h a n  oQ p e r c e n t o f  h i s

23 t  i n e t>> s u p e r v i s o r y  w o r k .

24
,i THE C O U R T :  U h - h u h .

25  ji

l
THE W I T N E S S :  H e a d  T e a c h e r  i s  a p e r s o n w h o  h a s  t h e

!
ii _

GLENN H PERRIN 
O f f i c i a l  C o u r t  Reporter 

F e d e r a l  B u i l d i n g * >  L r



205i Edwards
— i - - ------------------

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Redirect

responsib i l i ty  of a i’r inc ipa l  but more than 50 

percent n his time is spent teaching classroom.,

THE COURT. Oh, 1 see. Now, you resigned?

THE WITNESS: That's r igh t ,  s ir .

1HE COURT: Was that because you had a better

job to go to?

THE WITNESS: That was because that I f e l t  that I

was not being considered fa i r ly  tor the position 

that was becoming open in the other school.

THfc. COURT: Did you make that view known to Mr.

Bradshaw?

THE WITNESS: No, I d idn 't .

THE COURT; But you did write a le t te r  and 

tender your resignation?

THE WITNESS: That's r igh t,  s ir .

THE COURT: On the basis that you were going

to do whatc

THE WITNESS: That I was taking a job with the

Office  o: Economic Opportunity.

THE COURT: Economically speaking, was that

a better job than the one you had?

THE WITNESS: Yes, i t  was.

THE COURT: You had some incentive to go to

that, then;'

Yes

iLi

THE WITNESS:

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t s *  

F e d e r a l  B u i l d i n g



I'Ht COURT: Who e ls e  was i t  res igned besides

THE WITNESS: I i o n  t b e l i e v e  a n y  o t h e r  p e r s o n  o t h e r

than--that i s ,  i rorr t h e  s c h o o l  t h a t  1  w a s  w o r k i n g  

i n ,  r e s i g n e d .  A 1 m e n t i o n e d  b e f o r e ,  M r .  a n d  M r s .  

R a m s e y  r e s i g n e d  i r o m  t h e  P l u m  B a y o u .

T HL  C O U R T :  1  u n d e r s t o o d  t h e r e  w a s  a n o t h e r

o n e - - f r o m  e a r l i e r  t e s t i m o n y  I  u n d e r s t o o d  t h e r e  

w a s  a n o t h e r  m e  i r o m  t h e  E l e m e n t a r y  S c h o o l  a t  

R o s e n w a l d  t h a t  r e s i g n e d  b e s i d e s  y o u r s e l f .

THE I T N E S S : N o t  f r o m  my k n o w l e d g e .  M r s .  D o r a

T h o m a s  n a y  h a v e  r e s i g n e d ,  b u t  s h e  d i d  n o t  m a k e - -  

THL C O I T i T :  1  u n d e r s t o o d  s h e  w a s  n o t  o n e  o f  

them. T h e r e  w e r e  l e f t  t h r e e  t h a t  h a d  t o  b e  

a d v i s e d  t h a t  t h e y  w o u l d  n o t  b e  r e e m p l o y e d .  I n  

v / i ew o f  t h e  i a c t  t h a t  y o u  a n d  o n e  o t h e r  f r o m  

K o s e n w a l d  r e s i g n e d .  Y o u  d o n ' t  r e m e m b e r  w h o  

the o t h e r  o n e  w a s ;

THE W I T N E S S :  N o ,  I  d o n ' t ,  s i r .

T HE  C O U R T .  Y o u  n a y  s t a n d  a s i d e .

MR.  K A P L A N : Y o u r  H o n o r ,  I h a v e  o n e  b r i e f  a r e a  o f

i n q u i r y  b a s e d  in y o u r  q u e s t i o n s .

W e r e  y o u  i n  t h e  s c h o o l  s y s t e m  w h e n  t h e  h i g h  s c h o o l s  w e r e  

a n  i  f  i e d  

Y e s  , [ w a s t

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u il d in g  
EL Dor ado  A r k a n s a s  7 1 7 S 0



Edwards - Redirect.

i Q.

3  A .

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25

What happened to the black high school teachers at 

Rosenwald ?

The black high school teachers at RosenwaId--this is what 

1 brought out earl ier--due to the reduction of the 

lowering of the grades, the number of grades in the 

school, the high school teachers within the Rosenwald 

system, those who d i d  not resign that year, taught 

junior high school, and, well ,  I would say middle grades, 

l i v e  through eighth Grades.

Who w e r e  they? Yourself?

My s e l l ,  Mrs. Davis, and Mr. Robert Hall.

THE COURT: .Mr. who?

THE WITNESS: Robert Hall.

How about Mrs. Gordon?

M r s .  Gordon was teaching the Second Grade, she was 

t e a c h i n g  i n  the elementary le v e l .

I  s e e .  A n d  i i  i  a n y  r e s i g n ?  That taK.es care of three

18 ! teachers, y iu, Davis, and Hall.

1 9  A .
|! N o , Mr s  . W i l l is  was teaching English and the Librarian

20 there and she was moved to Plum Bayou.

21 ii Q. Anyone else cither resign or move to Plum Bayou?

2 2  ! A . That’ s a l l ,  there was only four teachers in the high

23 s c hoo1.

24 MR . KAPLAN: Okay.

THE COURT: Is that Althea W il l is?

G L E N N  H PERRIN 
O f f ic ia l  C o u r t  R e p o r t e r  

F ederal  B u il d in g  
EL Do r a d o  A r k a n s a s  7 i7so 1 L X

jo/



Edwards Reeross

THE WITNESS: That's r igh t .

THE. COURT; is she white or black?

THE WITNESS; S h e  i s  black.

RECRObS EXAMINATION

RY MR . STARLING:

Q. Mr. Edwards, in 1966-'67, when the Plum Bayou High

School was unitized, how many of the teachers at Tucker- 

Rosenwald were teaching high school at Tucker-Rosenwald 

prior to the unitization of the high school, '66-'67?

A. Four .

Q. And what happened to those four teachers upon 

un it iza t ion  in 1966-'67?

A. One resigned, a Mr. Charles Bell  resigned, Mrs. Althea 

W i l l i s  was transferred to the Plum Bayou school, I 

remained there as Principal of the school,  the same 

capacity that I had, the only thing I started to 

teaching .Mathematics from Five through Eighth Grade 

rather tnan high school Mathematics, and Mr. Robert Hall 

remained there as SociaL science teacher and he just 

taught on lower le ve l  where he had been teaching Seventh 

through Twelfth Grade Socia l  Studies, he started teaching 

FI. tbrougi Eighth Socia l  studies, and Mrs. Art ie  Davis 

remained there teaching English.

A l l  r igh t .  Then, in other words, when the Plum Bayou

GLENN H P E R R IN  
O f f i c i a l  Court R eporter 

F e d e r a l  B u i l d i n g  

EL D o r a d o  A rk ansas  7i7so



at toe T u c k e r -KosenwaId School who were teaching high

s c h o o l  s u b j e c t s , c o r r e c t '

T h i s  i s  t r u e .

Of those lour teacher?, one resigned,--

That's rights

- - t h a t  w a s  a M r ,  B e l l . '

T h a t ' s  r i g h t .

That l e f t  three. A Mrs. W il l is  was transferred from the

T u c k e r - K o s e n w a I d  H i g h  S c h o o l  over to the Plum Bayou 

H i g h  S c h o o l  w h i c h  w a s  unitized, right?

T h i s  i s  t r u e .

Then that l e t t  you and Mrs. Davis as high school teachers 

who remained at the Iueker-Rosenwald School which was

then c o n v e r t e d  into the Llementary school?

T h a t ' s  r i g h t ,  s i r .

J i  ; y o u  e v e r  t e l l  Mr. Bra )shaw w h e n  the Plum Bayou High 

S c c o o l  w a s  u n i t i z e d  t h a t  y o u  wanted a position over at

t h e  h i g h  s c h o o l ?

. 4 r . B r a d s h a w  w a 0 n o t  Superintendent at that time.

I s e e .  ) o  you Ceel that you should have been offered

a p o s i t i o n  o v e r  t h e r e  , t h e n ?

No, n o t  necessari ly .

Lr. oti e r  w o r d s ,  y o u  r e a l l y  h a v e  n o  complaint about not 

h'‘ L'g p u t  > v e r  at  t h e  i ' l u n  B a v o u  H i g h  school a t  that

GLENN H PERRIN 
O f f i c i a l  C o u r t  R i p o r t i *  

F e d e r a l  B u i l d i n g  

E L  D o r a d o  A r k a n s a s  7 1 7 3 0



E' !w a r d s Kecross
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t  i n e  i

I  am n o t O’op

f a c t  o f - - I 1o

t e s t i f y i n g tii.

d e c  i s  i o n , a n d

k n o w  l e d g e i n  :

p e r s o n s  w h o  w e r e  qual i f i ed i n  such areas to teach in 

high school and that these key persons should have been 

considered when positions became available in the high

school..

A l l  r i ght ,  tnen, let  me get this straight for mysel f ,  

and t hope tor the Court. then, in other words, when 

the Plun Bayou High School was unitized, two teachers--or 

one teacher was taken over there, one teacher resigned, 

an. Leit two teachers at the Elementary School at 

KcsenwaId-Tucker, r ight"  

h i t  .

T h e n  s o m e  t h r e e  years l a t e r  i t  was determined that the 

e l e m e n t a r y  s c h o o l s  w o o l ]  h e  unitized?

T h i s  i s  t r u e .

A n d  w h a t  d i r .  Bradshaw did in order to try to come up

w i t h  t h e  n u m b e r  or w h i c h  teachers he would have or

23 vjb.a t. l ea< her j he would retain, which teachers he would

24 n o t , tie took a l l o. the Rosenwald-Tucker teachers, which

1
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J  £ ‘ 'S i?  ̂- •* • ’ 1 i t_ tent ar y ,-.ub j ec ts ,
|lII GLENN H PERRIN

ji Official Court Rifoktu
ll Federal Building a >ri n n a .n n  -------- ---- ---------------------**E / /



2 1 1

1 , A. Uh-huh.

2 a  — and a l l  of the Plum Bayou Elementary teachers and put

3 them in a group to evaluate them?
'j

4 A. This is  true.

5jj a  Now, do you have any objections against that?

6 A- Yes.

Edwards - Recross

THE COURT: W ell, he has gone over that, Mr. 

S ta rlin g , I don’ t know why, unless you have 

something you want to bring out that hasn 't  

been.

MR. STARLING: W ell, Your H onor,--

THE COURT: You have been over i t  yo u rse lf,

th is is  twice, now; Mr. Kaplan has been over

MR. STARLING: Your Honor, I  guess the only thing

I am trying to bring out—we w i l l  certa in ly  

stipu late  that In the evaluation Mr. Bradshaw did 

not evaluate the high school teachers, he simply 

evaluated the Plum Bayou Elementary teachers and 

the Tucleer-RosenwaId Elementary teachers. We did  

not even consider evaluating any of the teachers, 

both white or black, with the high school teachers.

THE COURT: There is  no issue here about i t .

24 MR. STARLING: Then I am sorry I have taken the

25 Court's time, I thought there was an issue in that.

GLENN H PERRIN

■__i
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g 7Ll



Edwards -  Redirect
i—

i That's a l l ,  then, Your Honor,

THE COURT: Stand asIda.

MR. KAFLAN: Just one quick question, Your Honor,

REDIRECT EXAMIMATIflM

6 BY MR. KAPLAN:

7 a  Mrs. W il l is  did not go over to the high school, she went 

over to Plum Bayou— le f t  her high school position  to go 

to an elementary position , i s n 't  that correct?

This is  true.

THE COURT: You nay stand aside .

(Witness excused.)

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THE COURT: We w i l l  have a recess at this

tine fo r a few minutes.

(Whereupon, at 4:01 p.n.,  a short recess is  taken; 

thereupon, at 4:22 p .m ., the parties present as 

heretofore, the fo llow ing further proceedings are  

had, to -w lt : )

THE COURT: C a ll your next w itness.

MR. KAPLAN: Mr. Asive Th<

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

r i  HADirv/N

2 1 2



A. Thomas -  D iract

ASIYE THOMAS

ca lled  as a witness on behalf o f the p la in t i f f s ,  being f i r s t  

duly sworn, t e s t i f ie d  as fo llow s:

BY MR, KAPLAN:

ft T e ll us your name, p lease, and your address,

A Aslve Thomas, 616 North Magnolia, Pine B lu f f ,  

ft Mr. Thomas, what la your present occupation?

A Teacher-Coach in the Wabbeseka School D is t r ic t ,  Wabbeseka 

Arkansas.

ft Mr. Thomas, t e l l  us something about whore you received  

your education and your I n i t i a l  teaching experience.

A Arkansas AM6H C ollege, Pino B lu f f ,  I  received a B.S.

My f i r s t  teaching experience was in the Tucker-ftoaenwald 

School at Tucker, Arkansas, as a substitute  teacher fo r  

the semester o f— fo r the la s t  semester o f 1967 on a 

blanket contract I t  was.

ft Now, that was fo r the la s t  semester o f school year

’66-*67, is  that correct?

A True. R ight.

ft And that ended in June o f *67?

A That's r ig h t .

ft And when did you receive your c e rt if ic a t io n  from the 

State of Arkansas Department o f Education?

A i t  was sometime during the la t te r  part o f August of

DIRECT EXAMDUTIOM

GLENN H PERRIN 
O f f i c i a l  Court Reporter 

F e d e r a l  B u i l d i n g  

EL Dorado . A r k an sa s  y n a a



A. Thomas -  D irect 214

2 Q,

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1967 I received ay c e r t if ic a t io n  in Physical Education. 

And what did that allow  yea to teach under ce rt ifica tio n ?  

I  was allowed to teach la  the area o f Physical Education, 

with my minor being In General Science mid Socia l 

Studies, I  was ab le  to teach a t lea st  two c lasses of 

each without any hearing from the State Depertmmt In 

Socia l Studies and General Science.

Now, where did you teach a fte r  your in i t i a l  teaching 

experience? I take I t  that Is  while you were s t i l l  In 

school, Is  that correct?

True.

Your f i r s t  f u l l  year In education as a teacher, where 

were you employed?

At the Tucker-Roseoweld School in Tucker, Arkansas. 

And that was fo r  *67-*68 school year?

True.

What did you teach at that time?

I  was teaching Health, Science, Socia l Studies, P.E.

I  think that was a l l .

Do you r e c a l l  how many c lasses of each you were teach­

ing?

V e i l ,  at f i r s t  I  was teaching— 1 think— we had a seven- 

day period, i  was teaching a l l  day fo r seven hours 

u n t il they got a teacher aide In there before  long and 

she l i f t e d  me of one c la s s , one Socia l Studies c la ss ,
_i—

GLENN H PERRIN
O f f i c i a l  C o u r t  r b »ortcr 

F k d c r a l  B u i l d i n g

EL Don a no aoeam eae 7 7 a



II
215

end I had s ix , so I  was o f f  fo r one period that year 

a fte r  th is aide came an, but I  was teaching seven

periods.

A. Thomas -  D irect

4 a  Do y**1 what subjects you were teaching in those
11

5 j! seven periods?

6: *■ Yes, i t  was Socia l Studias along with General Science 

and Health and Physical Education, which was a 

8 combination o f the two.

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W ell, were you teaching more than one hour o f Socia l 

Science?

Yes.

How many?

Oh, I  think i t  was about— I be lieve  two.

And bow many Science courses were you teaching?

Oh, about two. what was happening, I  think, two hours 

F ifth -S ix th  Grade, I b e lieve , 1 am not fo r su re, but i t  

was two o f Socia l Studies, two Science, I  think, and 

Health would cone in , I think, on the o f f  days with 

Science, I  think, something lik e  that.

A l l  r ig h t . Did you teach that entire  year, Mr. Thearns? 

Yes, I d id .

During the course o f that year, did Mr. Sradshew 

an appearance in your classroom?

Yes, he did .

How many times?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g

Cl * ____________

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Oh, I would say— I can re c a l l  r igh t now maybe two or 

three, but I can re c a ll  two.

Approximately what duration, how long were these sessions 

when he came into your class?

W ell, I remember the f i r s t  time i t  was not too long.

Then he came in again when I was fin ish ing  up a Health 

c la s s , he came in an the fin ish in g  up of a Health c la ss ,  

and he ashed me— he brought the Geography book and 

asked me "When do you teach th is? " I said the next 

period. He said  "Okay". So the next period he came back 

in  and got in the beck of the room, I  think, end he s i t  

for awhile and le f t  out. And th a t 's  a l l  1 can r e c a l l ,  

the la s t  time I  can r e c a l l  him coming in my

c la s s .
I

When you say "a good w hile" that he sat there, are you 

talk ing about 20 minutes, 30 minutes?

Yes, he s i t  about that long, I think.

And when you said he ju st sat there a short time the 

f i r s t  time—

W ell, what happened the f i r s t  time he came in , actually  

he came through and d idn 't  stay anytime hardly, ju st a 

l i t t l e  w h ile, then moved on out.

A l l  r igh t .  Did you ever discuss any evaluations with  

Mr. Bradshaw of your teaching cap ab ilit ie s?
I

No, not r igh t then, but at the end of the school year,
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r

F e d e r a l  B u i l d i n g  ^  I

PI Hno i  nn A pi/ * _________________________#  ■ ..a 

Thomas -  D irect



217

now, he came in end told ate that since I wee not 

certifie<i in Socle l Studies that ay contract would not 

be renewed, and I asked a question “What about Physical 

Education?* since I was c e r t if ie d  there. He sa id , w e ll,  

they was going to discontinue lik e  they had done, I

A. Thomas -  D irect

think, in the past and they would not have i t  in the 

curriculum the coming year, so a fte r  he sa id  that I 

went along with i t  because i f  he d id n 't  have i t ,  I  could 

not teach i t  i f  I was not accepted on the Socia l Science 

contract, so I went along with i t  for awhile u n til the

u

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community somewhat wanted Physical Education, so this is  

when I applied fo r some help, wanted someone to help me 

as fa r  as getting a position  i f  i t  was p oss ib le .

Who did you go to fo r help?

The A .T .A . I  wrote Mr. Patterson o f the A .T .A . at that 

time and asked him for any aid  he could give me in 

coming back there or even find ing a job anyplace because 

I  needed employment, I had a fam ily, and he came down. 

A ll  r igh t. Now, at the time that Mr. Bradshaw spoke to 

you about being weak in Social Studies, had you already  

spoken to, or did you subsequent to that**

Now, be never- -  

I am norry, go Ahead.

He never did t e l l  me I was weak in that.

*

a What did he say?

GLENN H PERRIN !1
O f f i c i a l  C o u r t  R e p o r t e r

O't2  Lj F e d e r a l  B u i l d i n g



Th -  D iract

Nothing. Ha d id n 't » * I  can 't reaaaber h ia saying any* 

thing about ha would not— sinca I  was not c a r t if ia d  in  

that, I think, that ha would not ranow ay contract. 

This is  what ha to ld  na.

I see. Did you aver have a convaraatian with Nr. 

Edwards—

Yes.

— about Socia l Studies —

Yes.

- -o r  more hours?

Yes.

And when did that taka place?

W ell, ac tu a lly , Mr. Edwards s i t  la  ay c lass  severa l 

times, I think. In fa c t , eur doors ware adjacent, 

neighboring doors there, he s i t  in  ay c la ss  severa l 

times, and ha mentioned--we11, the way i t  happened, I  

asked Mr. Edwards whan was we going to  receive  our new 

contracts, th is is  the way I  asked h ia , I  w i l l  mover 

forget i t .  He sa id , "W ell, I  don 't knew fa r  sure i f  

a l l  o f the teachers w i l l  receive one", lik e  that. 1 

sa id , "W e ll, who is  going to t e l l  as 1 am fire d ? ", lik e  

that, somewhat jok ing . W e ll, he d i f e ’ t come out stra igh t  

and t e l l  ae, a^d I  sa id , "Mr. Edwards, I  want to know", 

and th a t 's  when he to ld  ae Mr. Bradshaw sa id  I  was 

weak, incompetent, or semething in that nature, o f

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  t i t .

ii

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A. Thomas -  D iract 219

Socia l Studlas, so I  would not fears a camtract, aad ha 

to ld  a s , 1 think, to construct a la t t s r  asking tha Board 

i f  I was w il l in g  to go to school ta upgrsds th is  waak- 

noss, so they say, th is  incompetence, to ra in sta ts  na 

for another yaar. 1 don 't know what happened,

a  Did you w rits  a la ttsr?

A Well, Mr. Edwards did th is , I  think, ha typod i t  and

sent i t  to tha Board, bacausa th is  is  h is raesnnandatisn

that i f  I  would do th is , and X was w il l in g  to  da i t  i f  

thay would g lva  na sons type—  

a Did you actu a lly  e n ro ll in  any in stitu tion?

A Oh, yas, I  want—what was happening, I  was needing soon

hours in  education to be completely c e r t i f ie d  as fa r  as 

deficiency on education, and I  picked up a l l  my 

education being ab le  to teach two c lasses o f Socia l 

Studias and two o f General Science. This g iro  ms a 

double minor with a c e r t if ic a t io n  in Physical Education 

that I  was q u a lif ie d  to teach anywhere and teach two 

subjects in any graded school, i t  doesn 't matter, w ith ­

out a hearing from tha State Department, 

a  And when did you do that? Was i t  a fte r  the school year? 

A  Mo, sir—w a ll ,  yes, a fte r  tha school year of *67-'6B, 

yes, sir.

& And at what in stitu tion  did you do this?

A  Arkansas AMSD, Pine B lu f f .

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n r a r  t i t i o



A -  D irect

2 JL

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A

And did you accomplish that taak r ig h t  that next a 

Y « « ,  a i r ,  I  d id .

And you conpleted your dutiea , than?

Yea, a i r ,  I d id .

Or your requ lranents, then?

Yea, a i r .

A l l  r ig h t . A fter you were not reh ired , were you ab le  to  

get another poaition?

W ell, Mr. Kaplan, I went everywhere, I  cheeked the 

neighboring d la t r le ta  and everywhere, but before  that I  

aaked fo r a le t te r  o f recaanaadatlan thinking that would 

be aona help. Mr. Edwarda gave ne one, I  c a lled  out to 

Mr. Bradshaw to get one, and he to ld  ne he would 

tine out o f hia d a lly  occupation and gat ne one, but 1 

never d id , try ing  to seek help that way to find  

enploynent, but I  never did receive anything fran  b in .

So f in a l ly  I  got a job in Brinkley •Marianna High School 

in Brinkley, Arkansas.

Did that requ ire  coanutlng fo r you?

Yea, i t  d id . I went through a tough taak, because at 

that tine sty kid was very s ick , ay w ife  was—

How far was i t  fro a  your hone, air?

83 miles one way, 166 a lia s  round t r ip .

Did you have to drive  that?

2 2 0

Yea, a i r ,  and what was tough, I  was coaching a basketba ll

GLENN H PERRIN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 i 7 i n n t



I

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team up there, and a fte r  the gaae I  would have to drive  

hone, before I get hone i t  was sunrise, time to go back 

again , because the kid was s ick .

How much had you made in sa lary  your la s t  year la  the 

Plum Bayou D istr ic t?

Actually , I made, I think i t  was $4,300.00, but the 

way that came about, they d id n 't  pay me a l l  o f ay money 

during the f i r s t  semester I worked there, because 1 was 

working on a day-by-day base, and at the end o f the 

school year they d id n 't  pay me a l l  o f my money. Then 1 

counted up with Nr. H a ll, who was Acting P rin c ip a l, and 

1 found out they was s t i l l  owing ms about $75.00, and 

they d id n 't  want to pay me, but in ta lk ing and 

communicating with the County Supervisor, I  was ab le  to 

get this added on the $4,300.00 contract the next year. 

I see. Now, how much did you make at Brinkley? Now, 

l e t 's  not consider what other expenses you may have had 

Incident to your employment.

Basic contract, i t  was $5,650.00.

A l l  r ig h t . And how long did you teach in Brinkley?

One year.

What did you teach there, what subjects?

General Science and Physical Education.

Did you a lso  coach there?

Yes, s i r ,  I was coaching. Head Basketball, Assistant

Thomas -  D irect

GLENN H PERRIN 
O f f i c i a l  C o u r t  R i p o r t i r  

F e d e r a l .  B u i l d i n g  

EL D o r a d o  A r k a w r a r  t i t r b



2 2 2
A. Thomas -  D irect

1 !| Football Coach, junior high court:*, and Haad Baskatball,

2 senior high courts.
3 a

4 A.

5 j! a

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Now, that took cara of school y e a r --

•68~'69.

— '68-'69?

Yas, s i r .

Now, where wore you in '69-'70?

Wabbeseka.

A l l  r ig h t . And are you a lso  there this year?

Yes, I aut beck now.

A l l  r ig h t . Your base sa la ry , including coach ing duties, 

in 1968— 1 am so rry— '69-• 70 at Wabbeseka was how much? 

Coach and pay?

Coach and pay.

Coach and pay in the Wabbeseka School D is t r ic t  that 

year the black coach did not receive any pay for 

coaching, that year was hired in there fo r classroom  

teacher, and you coached on your own time and work i t

out the way you see f i t .

Well, what did you make that year?

Oh, $5,000.00*

$5,000.00?

Yes, air.

A ll  r ig h t . Now, at any time since the school year

1967-'68. has any o f f i c i a l  of the Plum Bayou-Tucker

Gl ENN H PERRIN
O f f i c i a l  C o u r t  R c f o r t c r  

Fe o t R A L  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 m 5  7  O'A.



oneSchool D is t r ic t ,  that i s ,  e ither Superintendent 

members of Board of D irectors, asked you et e l l  about 

your requ irin g--you r acquiring any add itional hours to 

be able to teach a l l  of the subjects necessary in their

A. Thorn** - D irect

A.

a

curriculum?

Since the dism issal?  

Yes.

A

a
a

a

A

Ho, sir.

Or p rio r to the dism issal?

Wo on* remark* that came up when severa l o f the parents 

end the concerned people eround the community was very 

upset when they heard that I had been terminated. 

Several representatives went out and talked to ifr. 

Bradshaw and I th in k --d ire c t , I  got th is one from tbe—  

d irect from one of the representative# that he aay 

a fte r  I asked fo r th is help end Mr. Pattersen came in 

end talked, he would not have me hack under no 

circumstances then.

Mr. Thomas, in your capacity as tha coech in another 

d is t r ic t  the next school year, ,6 8 -,69, did you angage

in competitive sports with Plum Bayou?

No, d id n 't ,  i t  was a long ways o f f  and most 

superintendencs would not le t  a bus go as much as 80 

a lia s  for baskatba ll because most schools has e 

basketba ll in the neighboring area, but in fo o tb a ll they

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o , A r k a n s a s  7 1 7 3 0 I ' i o



A. Thomas - Direct
1 !

i 224

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»  '  A.

would le t  us go as much as 50 a l io s ,  so wo was 83 a lio s  

away, some 90 a lio s ,  I guess, from Plua Bayou, so we 

could not— ccd I  did not try to play then.

Did you knew whether or not the next year they did 

engage—

Oh, yes, 1 ca lled  several of the basketba ll gnaws, I 

think about two o f the basketba ll games in Kagland.

8 ! 0
1

And who was the Coach?

9
i

A. Mr. McConnell.

10 a A r e  you q u a lif ie d  to b e a basketba ll coach?

11 J L F u lly .

12 a Have you, indeed, coached basketba ll fo r any

13 J L Yes, I  was lucky enough or bleaaed enough to

14 State Championship la  Junior Beys la s t  year

15 Vabbeseka.

16 m .  KAFLAM: That's a l l .

17

18

19 BY m .  STARLIHG:

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i a Mr. Thoaas, 1 shew you a mm m

21 i A Sir?

2 2 a 1 as going to show you a traaac rlp t h e re ,—

1
AO A A ll  r ig h t .

24 ji a — and ask you i f  you can id en tify  that?
j

25 i J L Yes, th a t 's  u lna.

GLENN H PERRIN 
O m c u L  C o u r t  r e t o u t i k  

F u d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a n s a s  7 1 7 3 0



225A. ThoMs -  Cross 

i j Q. That your transcript?

2 1! A Yes.

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MR, STARLING: I  w i l l  ask Mr, Kaplan I f  ha has any

ohjaction,

MR, KAPLAN: Arc you introducing it?

MR. STARLING: Uh-huh.

M l. KAPLAN: Hub-uh.

>•., STARLING: Mark th is for id en t ific a t io n , p lease,

ma'am.

I mould lik e  to introduce i t  in evidence, Your 

Honor.

THE COURT: Without objection i t  w i l l  bo

received.

MR, KAPLAN: What is  the number?

MR. STARLING: No. 3.

Mr. Thomas, on your tran scrip t, which is  Introduced as 

Defendants' Exhibit No. 3, i t  states that your major is  

Community Recreation and underneath that i t  has "Nan- 

Teaching".

Uh-huh.

What does that Man?

W ell, that should Man ju st what i t  says u n t il you have 

actu a lly  been c e r t if ie d  by the State Department, you 

cannot teach i t  u n t il you got your c e r t if ic a t io n .

And i t  says your minor is  "Coaching"?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n b a ,  t i t . 2m ^



2 2 6
A. Thomas -  Cross

j L - ------------------------------- ------------------------

H *.

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3

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Actually , tha minor wiild ha, If count tha hours,

I hava about 16— 18 in General Sclanca, about 18 in 

Socia l Studies, not a c e r t if ic a t io n  but a minor in those 

f ie ld s .

Why does your transcript only say a minor in  "Coaching"? 

I f  you check tha records of tha o f f ic e ,  they put i t  on 

there, that is  a l l  i t  i s ,  a matter of not on there, but 

i t ' s  on there as far as the requirements i f  you want to 

count the hours.

What does— perhaps maybe you bettor explain  to me, 1 

an confused, what is  major in  "Community Recreation, 

Non-Teaching" mean?

Actually  Just what i t  say. See, th is is  the way i t  

goes, in any f ie ld  you have "Teaching" and "Mon-Teaching". 

According to coaching, d irect coaching, educational 

hours are lim ited , meaning maybe my hours wore somewhat 

short and I had enough q u a lif ic a t io n  to fin ish  and get 

a B.S. Degree and I could s ta rt  teaching, so th is  is  one 

reason my education hours was very lim ited , but I  could 

coach and teach P.E. and work on my defic iency , which 

was education.

A l l  r ig h t . Now, when you say work on your defic iency , 

what you are actu a lly  ta lk ing about working on is  

coming up with a degree?

No, I have a B.S. Degree.

:i

GLENN H PERRIN
O f f i c i a l  C o u r t  R i p o r t u  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 3 0



227A.

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A ll  r ig h t . Then, what you « r a  ta lk ing about is  coming 

up with c e rt if ic a t io n  in education which allows you to 

teach PeE» and coaching?

No, 1 can teach two of Socia l Studies without s hearing 

back on any school d is t r ic t ,  two of General Science 

without any hearing, and a l l  o f the P.E. courses that 

the curriculum in the State w i l l  a llow  any person to 

teach.

How long can you teach th is two hours of Socia l Studies 

without a ce rtifica tio n ?

According to Mrs. Case. I got th is c le a r , she says as 

long as 1 want to as long as I am not teaching over two. 

When you were hired at Tuckar-Rosenvald by the Pirns 

Bayou School D is tr ic t  to teach at Tucker-EossowsId 

School, you were hired as a Socia l Studies teacher, 

correct?

Thomas -  Cross

W ell, I was teaching— what year you mean, when I f i r s t  

came on, what contract?

When you were h ired , in 1966-'67.

Oh, actua lly  I was teaching everything, Math, English, 

you ju st  name i t ,  everything am the blanket c e r t i f ic a te ,  

everything. I had Math, English , Seventh and Eighth 

Grade English , Seventh and Eighth Grade Math. I don 't  

know where that came from.

Were you a lso  hired to teach Socia l Studies?

GLENN H PERRIN
O e ; * * c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o  A r k a n s a s  7 t 7 * o



A. Thomas - Cross 2 2 8

2 1; a
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I don 't know that was In that p articu lar position .

Did you teach Socia l Studies?

Let me see, * « *  Social Studies in that? I t  could have 

been, but I can remember my English course so often , 

and my Math courses, I  was teaching a f u l l  load o f a 

seven-day period, could have been a Socia l Studies.

You don 't know whether you taught Social Studies?

Let me see, 1 can 't  remember whether i t  was Social 

Studies that year or not, but I  know one th ing, I  was 

teaching two English , Eighth and Seventh Orade Math, 

cou ldn 't have been over one or two Socia l Studies, i f  

any.

Do you remember haw many hours of Socia l Studies you 

taught the year o f - -  

No, I don 't.

A l l  r ig h t . Thank you. Were you hired as a P0E. 

instructor at the Tucker-Rosenwald School?

W ell, I cam through Mr. Anderson, at that tine he was 

l iv in g , I was r e a l ly  rep lacing Mr. Keith, I  be lieve  was 

his name, or Heath, or something, and I  took his  

position , so I don 't know what was an h i s - -  

Did they hav« an organised P.E.?

W ell, 1 worked hard to get organised P.E. program out

there.

Did they have one when you were hired?

GLENN H PERRIN
O f f i c i a l  C o u k t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7t7»o



I 'h n m a*

N o .  I  h o y  h o d  h t i t f t  . H I I  ( N o t * .  I  d « * « ’ (  k t i M M  w h a t  1 1

ot£***i*<*d t , t ,  \jx juot at tttcttstt txoMfk did you allow 
then gaaMs, et cetera?

W all, a c tu a lly , at P.E. tine we had an hour, I  think,

out together, so I  worked hard showing thaw gases, yes. 

Were you hired as a coach at the Tucker-Rosenwald 

School?

W ell, a c tu a lly ,— no, I don’ t know, I  can 't  even r e c a l l  

the blanket c e r t i f ic a te ,  I t  d id n 't  have such things as 

that on I t ,  because I was not c e r t i f ie d ,  i t  d id n 't  hove 

"coach" on there, and 1 r e a l ly  replaced th is  nan, I  

can 't resenber a l l  o f the courses he was teaching, but 

P.E. was Involved.

Organised P.E.?

W ell, i t  should have been, but i t  was not.

In other words, was there a period set a s id e -*

Yes, i t  was.

- -c a lle d  Physical Education?

Yes, i t  was.

Are you sure of that?

Yes, s i r .

Under oath, are you sure of that?

i

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where a l l  c lasses fron Five through Eight I  think was

GLENN H PERRIN
O f f i c i a l  C o u r t  R t p o m i i  

B u i l d i n g

EL D o r a d o  A r k a n s a i  7 i 7 s o



A. ThoMs -  Cross 230

i A

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.

Let me see. I t 's  beer s long t l s s e tw*t I  mm not 

positive  on i t  now a l l  the way, bat I  did work an that 

la s t  period. I was oat there with then.

What organised a th le tic  a c t iv it ie s  did they have at the 

Tucker-koscmwald School?

When I f i r s t  got there?

Uh-huh.

Organised?

(Hods heed a ffirm ativ e ly )

Nothing, r e a l ly .

So you r e a l ly  wasn 't a coach, were you?

W ell, that is  what they was h irin g  fo r .  they needed a 

coach, and the m ,  as I  sa id , that was working was not 

c e r t i f i e d , did not have the q u a lif ic a t io n , I  w i l l  pat 

i t  th is way, neyhe he was c e r t i f ie d ,  did net have the 

q u a lif ic a t io n  to construct a com petitive, a r e e l  

Physical Education program.

Mr. Thomas, in the year 196b-'67, when you were hired by 

the School D is t r ic t ,  did the Tucker-EoeemwaId School 

have organized competitive a th letics?

Organised, no.

Then there was no need fo r a coach, la  that correct?  

V e il ,  i t  should have been.

V e i l ,  I  am not asking you whet i t  should have been, I  

an asking you was there a need fo r it?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R epo rter  

F e d e r a l  B u ild in g  
EL Do r a d o . A r k a n s a s  7 I7 SO



A. 

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Th -  Cross

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W ell, the need fo r It, according to—

In other words, did they have organised competitive 

sp o rts , ®id If they did not, them they don 't need e 

coach, is  that correct?

I w i l l  say th is , in going there, I played games. It  

was not actu a lly  play games, I got teams, I  hooked 

schools, I tra v e lle d , and played competitive sports.

Did you do th is on your own?

W ell, ac tu a lly , through the a id  of the P rin c ipa l there 

we did th is and we worked hard. I  asked him ahewt this  

and he was very concerned about i t .

In other words, these were not competitive games put 

up by the D is t r ic t  or anything, ju s t  something that yen 

wanted to do?

W ell, a c tu a lly , I  d id n 't  have any po licy  book an the 

D is t r ic t ,  a l l  I  had was a blanket contract, and r e a lly  I  

d idn 't get that, because I  don 't know what happened to 

that a fte r  going back try ing to look i t  up. The

231

19 Princ ipa l at that time, I  think, was 1 * . H a ll, and he
20 worked hard, he wanted the program, but lik e  I sa id , the |

2! I man did net construct one.
i

72 ! a Okay, ro we had no competitive a th le tic s  a t that time?

— *>
i

JL Teat, we played teams, we played schools.
1

24 1 a Were you paid as a coach?

25 A No, a c tu a lly ,— long story behind i t ,  whom I  was f i r s t
GLENN H PERRIN 

O f f ic ia l  C o u r t  R epo rter  
F e d e r a l  B u ild in g  

EL Do r a d o . A r k a n s a s  7 1 7 1 0



hired out there the P rinc ipa l to ld  ssj ha was going to 

pay me one thing and the Superintendent came down and 

said  he was going to pay me $10.00 a day. I say, -No, 

a i r , -  I say, “with my education", I  say, " I  would go 

somewhere e lse  and get a much better jo b " .  So Mr* 

Anderson say, "W ell, I am not supposed to do th is , but 

what I do with most o f my blanket teachers get $10.00 

a day, I w i l l  pay you $15.00 ju s t  to stay here to work-, 

so 1 d id .

10 ji Q. Were you paid as coaching and fo r coaching at the

11 Tucker-RosenwaId School?

12ji *• W ell, ac tu a lly , I d id n 't  have a contract proving what I

A. Thomas -  Cross

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18

a
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was doing, being paid for*

What team did you coach?

What team did I  coach? I coached the jun ior high team 

at Tucker-Rosanwald. We played s o ft b a l l ,  which i t  was 

a spring sport, we had a track setup, we run track, so 

I  coached the jun ior high school*

Were these teams set up by the School D is t r ic t ,  was th is  

part of their program?

W ell, I  did not see any po licy  book, I  don’ t know what 

they had in their po licy  book*

Oka*. At the rime you taught Socia l Studies 1966-1967, 

were you c e r t if ie d  in the area o f Socia l Studies?

Now, you say *66-'67, now, I  may have been teaching as

GLENN H PERRIN
O f f ic ia l  C o u r t  R ep o r t er  

F e d e r a l  B u il d in g  
EL Do rado . A rkansas  tissj



!|
4 , a
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51! K
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7 l| A.

•I o

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. Thomas -  Cross

ona class ta ' M “ '67, 11 have bean such

®ore* I w a * not because I had not received ay degree 

until that voeear.

So the amswar is ,  you were not cartifiad?

Eight.

Than you ware rehired tha yaar 1967-‘68?

W all, i t  was a hard matter tha way I  was reh lred .

W ell, le t  ne ask you th is , wara yaw c a r t if ia d  in Socia l 

Studies whan you ware hired in  tha school yaar 1967-'68? 

S i r , 1 said  I was not c e r t if ie d  but I  haws a ainor there 

meaning I  can teach two courses. As long as you have a 

minor in various f ie ld s  you can teach two courses in  

that f ie ld  without a hearing from tha State Department 

back to the D is t r ic t .  This is  free  the C ertifica tio n  

O ffic e , Mrs. Casa.

Let no ju s t  get you to answer ny question. Were you

c e r t if ie d  in  the f ie ld  o f Socia l S tu d ies ,—

I say no.

-1967- *68?

No, s i r .

Are you c e r t if ie d  in  the f ie ld  o f Socia l Studies now?
I

Could X*»no, I an not.

Fin*; that s a l l  I wanted. Who was your counterpart as 

a Socia l Studies teacher and a P.E. teacher in the Plum 

Bayou High School in tha yaar 1967-'68?

GLENN H PERRIN
Of f i c i a l  C o u r t  R e p o r t * *  

F e d e r a l  B u ild in g  
EL Do rad o  A r k a n i a i  7 i7 >o



I a .  i n s  -  cross 234

41| a

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23 ;l a
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Truth fu lly  speaking, that is  something— that is  something 

I  don 't know. I was not fam ilia r with the s t a f f  out 

there, but — I don 't know.

Do you r e c a l l  whether his n w i  was Nr. Hunter Douglas?

Like I  say, I don 't knew. 1 never did knew those people 

out there. Conmuaicatian was not tee g reat, so I  d id n 't  

know.

Do you knew whether or net a Nr. Hunter Douglas was 

released  at the saws tine you were?

No, 1 d id n 't ,  a l l  I knew is  that 1 was re leased . That's  

a l l  1 know, that I  was re leaaed , I  never did knew.

Do they have--d o  you know whether or not they have a 

P .E . , Just a P.E. course, and they h ire  a teacher to 

instruct that course at the P lus Bayou High School in 

the year 1967-'68?

1967-'68? A ctua lly , 1 have— I don 't knew about P .E ., 

but they have a person who was teaching P.K. and Socia l 

Studies, we cosnMnlcate good together, Mr. McConnell and 

me were working in the system together, yes, he taught 

various P.E . courses and Socia l Studies.

He taught Socia l Studies and P.E.?

Right.
!

Then, in other words, you are saying that they dsn 't  

Just have a P .E . course that a teacher can teach and 

that is  a l l  at the Plum Bayou High School?

GLENN H. PERRIN
Of f i c i a l  C o u n t  R epo r t er  

F e d e r a l  B u il d in g  
e l  Do r a d o . A r k a n sa s  7i7so



I 235A. Thoau -  Cross 

ij A True.

2 ft A l l  r ig h t .

3 A But this is  the exception here-*

4 ft No. that is  e l l  I  wonted.

5lj a  A l l  r ig h t .
I!

6 ft Do you know whether Mr. McConnell, who was hired in the 

year ’68 -'69 , to teach Socia l Studies and P . I , , at the

8 Plus Bayou High School, was c e r t if ie d  in  the area of

9 i Socia l Studies?

10 A.

11 ft

12 A

13 ft

14
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15 ft

Do I knar it?

Yes.

Yes.

He was c e rt ified ?

Uh-huh.

Do you know whether he was c e r t if ie d  to teach P.E.?

16

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A 

ft

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Uh-huh. 

He was?

Yes.

Do you know what happened to Mr. McConnell?

Yes, s i r ,  ho cane down to Wabbeseka and I was temporarily  

terminated down there.

Why were you terminated down there?

W e ll> they said  T it le  1 money had played out, or 

something, I  don 't know.

Did you bring a su it  fo r that, tee?

GLENN H PERRIN  
O f f ic ia l  C o u r t  R epo r ter  

F e d e r a l  B u ild in g  
EL Do r a d o . A r k a n s a s  7 t7 »o



—

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Cress 236

JL

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Yes, m  are c

think that prebleo is  « m  with* I  

short w h ile , 2 « M  re instated  as tho 6th o f  

through tho consideration o f tho Beard who Is  

r o s l  good togothor i s  VSbbeeeha moo.

Do you know, o f to r Hr. McConnell lo f t ,  

McConnell's p lace os tho Soc ia l Studies cod P . I  

a t tho Pina Bayoo High School?

Yes, I  know, because l  to ld  tho yoong one to  go 

ho had a pooslb la  chameo to got that Job, 

r a c ia l  b lack  down there I  know ha should hove 

chance to got that jo b , i s —

Was ha a black  non?

Yeah, ho was a b lack  ana, 1 know him, 1 to ld  him

i t .

• l  
fo r a

o f the 

a good

a  1 take i t  that the Plan Bayou Blgh School d id n 't  h ire  

him, did they?

A. W e ll, they wouldn 't have h ired  b in  because they d id n 't  

know anything about him i f  I  hadn 't to ld  b ln .  

a  Did they h ire  hin?

jl Oh, yeah, they h ired b in , without any c e r t if ic a t io n ,  

a  Lot no ask you sonathlng a ls o . You stated  in  your 

testi****/ that In 1967-'6S while you wore working at 

Plun Bayou— X noon— excuse no— a t  Tucker-*■  a sane Id  

School, your base sa la ry  was $6,300.00, right?__________

G LENN H. PE K ftlN
Of f ic ia l  Co u nt  m o r a  

f ib k n a l  S u il m n s  
EL Do kado . A r k an sa s  t it s o

m



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A. Thauss -  Cross

A Right.

a  Moo, you varo 1st go , sc your contrast wos oot rsnswod

s t  tho and o f tho *47-*A4 yasr, i s  thst tw o?

A Trus.

a  Than you to s t lf lo 4  thst in 1 H I  sod 1949 school yssr 

you oant to k&nkloy?

A R ight.

a  And thst your s s ls ry  thors oos $5,454.00?

A Trus.

a  Why did you lssoa Rrlnkloy?

A V o l l ,  I  t o l l  you, uhsn you hs*s o t e l l y ,  oaucsrasd shout 

your fo u lly ,  sny parson w i l l  sssspt slooo to hsns I f  tho 

position  boss—  s v s l ls b ls ,  so ths position  4 U  St 

Wshhossks sad X dooido X would Oooopt s  out in  psy to

eous clooo to  ny fo u lly ,  so uhlsh o sp ls las  i t o o l f .  

a  F ins. Hsu, you a ls o  to s t if io d  thst in  tho school  yosc 

1949*1970 you uses saployod s t  hsh h issh i, is  thst

eorrset?

A *69-*70, r ig h t .

a And what uss youat  s s ls ry  thsro , $5,400.00?

A Right.

a Are you saployod s t  WShhosohs s t  th is  tins?

A TOO , 1  OA'ri*

a And sro you p lussing an hoing saployod thsro

A Oh, yos, «o  sro war king good.

SLBNN H. PBM tlN
O m ciAL  Count u n unti  

F n n M .  I u iu m n .
EL Do n a  do . A nkannan  t itn o

i



234;

& S o , in  o th e r  w o rd s , s in c e  ye a  vest** t e r m n a t e d  i n

1967-*68, At the and o f that school year, what you have 

dene the oast two school yoaro is  have your pay increased 

some— f i r s t  t ic s ,  $1,600.00— w e ll,  excuse aa— about 

$1,300.00, and the second tiaae, you s t i l l  had a pay
i

increase o f $700.00, right?

A E ight.

Q. Kay I  ask you whet your damages are? 

a  M r .  S ta rlin g , I have su ffered  hum iliation and various
|

things 1 have gone through these years, the pay would
I
I

not— the money did not value ao much as I  have goao !

through, i t ' s  the only place 1 could find  a Job. See,

I tr ied  everywhere, app lications everywhere, hut I  was 

unable to find  employment, and every men baa got to find  

a job .

O Do you want your Job back at Plum Bayou Sigh School?

A No, s i r ,  I  d on 't . No, a i r ,  not under the circumstances 

now.

a  Teaching at Habbeseka, are you touching Socia l Studies?

k. A ctua lly , I was booked to teach two Socia l Studies

courses, but since Mrs. Sanders, the— she was terminated 

also, she has a major in Socia l Studies, I  think they 

worked her in thoee c lasses and 1 work in  tha Science 

and Physical Education and Coach, 

a  Are you teaching Socia l Studiaa thoro now?

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo r ter  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n g a e  7 1 7 * 0

A. Thauas -  Cross



236A« Thcmm - Cross 
A No, nut now.

ft Were you at the start in g  of th is school year?

A Lot ne sea, s ta rt  o f the school y e a r ,—

ft That is  in September.

A No, I vas teaching Science,

ft Were you teaching Socia l Studies in  the school year

'69-'70?

A '69**70? No, Science. We had plenty o f zsejors there,

I  was q u a lif ie d  to .

ft Since 1966*'67 and 1967-*66 whan you were re leased  fre a  

the P lus Bayou School D is t r ic t ,  have you received any** 

have you worked on your c e r t if ic a t io n  fear Socia l 

Studias or Ganoral Science?

a  No, because I  have an aaount I  can teach two subjects  

and that is  a plenty in that miner f ie ld ,  

ft In other words, you are Just going to continue—

A W ell, that depend®, th is p ro fessional teaching is  so ,

I don 't knew, I  don 't knew, s i r ,  

ft Have you gone to school in the senator tine?

A Oh, yes, Tes, 1 lik e  education and socio logy, I  havo 

taken socio logy, yes, 1 havo.

ft In reference to Genoral Science and Socia l Studias end 

c e rt if ic a t io n  fo r those two sub jects, where did you go 

to school in the suneertine end whet courses have you 

taken in reference to your c e r t if ic a t io n  fo r thoee two

GLENN H PERRIN
O f f ic ia l . C o u r t  R epo rter  

F e d e r a l  Bu il d in g  
EL Do r a d o . A r k a n s a s  7 i 7 »o



A. Thosiag -  Cross

subjects'/
2*0

2 A

3

10

Well, the courses I needed to certify, according to Mre. 
Case, was European History, and the last two >u w s r » it 

was not offered in a nina«woek course so 1 could not 

take It unless I stop working and go during the first 

seaester or second semester, so 1 was not able—  

unfortunately I an not able to do that, not at the 
present tine.

STARLIKG: That's all, Your Honor*

R S P m C T  BXASQnATIQM
12

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BY K£. KAPLAN:

a  There has boon considerable discussion , Jfir. Thowas, 

about what subjects you can and cannot Coach. Mew, 

a fte r  your tenure with the P lus Bayou School D is t r ic t ,  

you te s t i f ie d  that in that aw a re  o f 1963 you went to 

Arkansas AM6M and took some add itional courses, is  that 

correct?

A Yes, s i r .

& Hew, those courses, what did they enable you to teach 

with f u l l  c e r t if ic a t io n  so that the D is t r ic t  would not 

be penalised in any way for your touching those subjects?

A That omanor would enable ns to got tay defic iency in

education to teach any Physical Education, north Central 

*A" rated , or what have you, along with two courses in

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d eral  B u il d in g  
EL Do r a d o . A r k a n s a s  r t 7*o



241
A.

1

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S o c i a l  S c ie n c e  i ttd ox Q m ttS c < L «s iic < t#

So that I f  you wore to teach la  eay d is t r ic t —

True.

•irtso iM r it *a  your d is t r ic t  aos oc whether It  wo® PXaa 

Bayou, that very east ter® you could have taught toe 

Science courses, —

True,

— tv® Socia l Studios courses,—

True.

— and ss meay ?.s. courses as yew needed?

Right.

r ®S*fd te  the §5,600.00 you aeda a t  Brink ley,

Did i t  cost you any nancy te  trave l there?

W ell, l  drove fo r  16 weeks, 83 ©11©© ora© way, 166 a lio s ,

I  thlalt, fro® oy hose, 166 a lio s  a day.

Mo® fa r was I t  fro a  your hesso to the P lus Bsyou D istr ic t?  

W ell, I  haven 't exactly chocked I t ,  X haven’t  gone Chet 

way too aaich, I  would say 20 to 25 a l i a s ,  aayke.

Between 20 and 25?

One w«y, I b e lie v e , yes.

A H  r ig h t . How fa r  is  I t  fro© your hcesc to the 

Wabbeseka School D istrict?

(Hi, 1 be lieve  i t ' s  about 13 or 19 a l le s .

And would the distance between Plan Bayou your 

house bo ©ppreaclaately the sans, aaybo ju s t  & l i t t l e  b it

G LENN H PERRIN
O f f i c i a l  C o u r t  R ep o r t er  

F ed er al. B u il d in g  
EL Do r a d o . A r k a n s a s  7 17 3 0

Tfccs&A® -  Redirect



A.

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2 ! A. 

a a

5  j j  A .

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81! A.

10

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15

T s k o s i & &  - Redirect 

laager?

Wabbeceke end Plum Bayou?

TIm  distance between year hence and Plwn Bayou and yots 

houo® Webbeseka.

I  be lieve  Habbesoka is  a l i t t l e  c lo se r , l  b e lie v e , nee. 

A l l  s igh t* Did you hove any other ospoosos In ccnneetlsn  

with your teaching la  Brinkley?

Oh, gee, I t o l l  you what happened, I  was wanting to atay 

up there, but, lik e  I aay, the rent waa so high, the 

place I  rented waa about $95*00 a aanth, and, lik e  X 

say, 7 was l iv in g  there and ay fam ily down here, oo 

r e a l ly  I cou ldn 't nako I t  that way*

A l l  r igh t*  Did you liv e  there fo r awhile?

Tea, X tr ied  liv in g  there fo r about— X think I t  was 

about two or three weeks.

242

16 ft Okay.

17 II A.

19

20 ft

22

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24 >

ft

But the main Issue was when the baby had taken sick , 

and, Ilk a  I  say, the w ife  bed to work a ls o , and X had 

to coae back and try  to give  her cone a id , toe.

Are the courses that you took in the summer oo t-M f  

Defendants' Exhibit Mo. 3, that la ,  tha summer of 196S?

Do they appear on there?
|

Oh, no, th is la  the year that I  received th is  when I  

got ay B .S.

A l l  r ig h t . The date of tren acrlp t, September 22, 1967.

GLENN H. PERRIN
O f f ic ia l  C o u n t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  717*0



A* Thomas -  Redirect 243

2 i A

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1

When w a s that?

W sll, th is u u 6 have boon vbost) X g u sn  ( X btou^ic i t  

out to the P rin c ip a l, X guess, and guess th is is  the 

date Ue had to have th is .

You had ju st  received your—

W ell, I  received «y  c e rt if ic a t io n  before tbea, because 

I  was c e r t i f ie d  in  August.

A l l  r ig h t . But the extra courses that you took ,—

They are not there.

— they do not eppecr here?

No, s i r ,  they ere not there.

Ml. KAPLAN: F ine. That's a l l .

Your sa lary  a t Vabheseka s t i l l  the seas?

No, s i r ,  i t  has gone up.

What is  it?

X think he gave as the Coach's r a is e ,  X think he was 

making $570.00, $77.00 more, so they made the adjus 

on that as the 4th of January, i t  baa gone up, s i x t y  

three, X b e lie v e .

$6,300.00?

Yes, a i r ,  $6,300.00, I  think i t  i s ,  new.

That’ s only since the 4th o f January o f th is year?

Yes, that i s  when I was re instated  to go back, se  they

GLENN H PERRIN 
O f f ic ia l  C o u n t  R epo rter  

F e d eral  B u il d in g  
EL Do r a d o . A r k a n s a s  717*0 2.99



A. Tfaoaas - Court

l' did, yes, sir.
2 Q, Were you teaching at

3 1970-•/!?

A Yes, sir.

3 ji aJj I n was it  then?

6 Aif It was $5,800.00.

7 l| THE COURT:

8i have seam i

9 ! MR, KAPLAN: (Si

10 jlll
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112 ! THE COURT:

13

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Id

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o questions?

(VltaMi excused,)

or would you p re fer to w ait u n t il  tomorrow? 

i® . KAPIAH: At tho Court's p leasure, but 1 would

prefer to wait u n t il to— row i f  a t a l l  p oss ib le . 

Your Honor,

THE COURT: Very w e ll ,  then* Hew many sacs

witnesses do you have?

MR. KAPLAN: Your Honor, I  feev© three more

w itnesses, one fa i r ly  b r ie f  and two approximately 

the same time as Mr. Thomas, about 30 or 40 minutes 

long.

THE COURT: Do you knew how stay  witnesses

you are going to hove, Mr. Sterling?

STARLING: Your Honor, 1 em going to hove about

GLENN H PERRIN
O f f i c i a l  C o u r t  Rapoftmt 

F e d e r a l  B u il d in g  
E L  Do r ad o  A r k a n s a s  7 i t »o

$ t o 4



245

thrae or four. i*ire Bradsnew, of course, wxii be 

She lengthiest, which will coke appr exists tely an 

hour end a half, the rest of thesa will be about 
20 minutes apiece«

THE OOORT: We w i l l  be in recess u n til

tomorrow morning at 9:30.

(Whereupon, at 5:00 p.m ., February 8, 1971, a 

recess is  taken u n til 9:30 a .m ., February 9, 1971.)

GLENN H PERRIN
O f f ic ia l  C o u r t  R e p o r t s*  

F e d e r a l  B u ild in g  
E L  Do r a d o , a r k a n s a *  7 17 3 0



Evans - Direct 2^«

Now, at 9:26 a.rn*, on chit 9th day of February, 

1971, the parties present as heretofore, the following 
proceedings are had, to-wit:

THE COURT: You nay proceed, gentlemen.

MR. KAPLAN: Mrs. Evans:

9 I LUCREAS1A EVANS.
10l called as a witness on behalf of the plaintiffs, being first 
11 duly sworn, testified as follows:

121 DIRECT EXAMINATION

13

1 4  ji
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BY MR. KAPLAN:

O Tell us your full name and address, please.

A I an Lucroasia Alexander Evans of Tucker, Arkansas. 

Q> Mrs. Evans, what is your present occupation?
17 |

18

A

a

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Remedial teacher in the Plum Bayou-Tucker District.

How long have you been employed by that District, Mrs. 
Evans?

, IITwenty-eight years.

Save you been a classroom teacher all during that time? 
Yes, I have.

And hoe Aong have you had certification as a claseroea 

teacher?

1 have had certification as a classroom teacher the time __________________________________ _ I
GLENN H PERRIN  

O f f ic ia l  C o u r t  R epo r ter  
F e d e r a l  B u ild in g  

EL Do r a d o . A r k a n s a s  7 1 7 3 0



Evans - D i r e c t

i|| of my teacher log— teaching.
21 0. For all 28 years?

3 A. Yes.
i j

4 & What grades have you taught during that period of cists? 

51 A Fourth through the Sixth Grades.
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And as a Remedial Reading instructor, what grades are
i

you responsible for?
Reading only.

In what grades?

Well, Fourth through the Sixth Grades.

When you were a claserooa teacher, did you also teach in 
those grades?

Yes, I did.

When were you nedo a Roaedial Reading Instructor?

The tarn of 1966 end '67a
I!How did that coaa about?
II

I was asked by the Superintendont, Mr. Anderson, and the 

Principal, Jean C. Edwards, at that tisas to work in this 
capacity, because at that time we did not have cnyeoe 

that would— that they thought or felt like would ba 

able to handle the job, because it wea quite a bit of
♦

paperwork to be done with it and orientation for the
job.

24 j i  ai j
25 ij

Did you ever receive eny spec ia l tra in ing  fo r that 

position?

GLENN H PERRIN
O f f i c i a l  C o u r t  Reroute*  

F e d e r a l  B u ild in g  
EL Do r ad o  A r k a n s a s  7 17 * 0



243
i  .

Evans - Direct 
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a

Nothing but the required subjects chat were leading up 
to my degree in elementary education.

Where did you receive your degree? I  think I  overlooked 

that.

Arkansas AMfiti C o llege , Pine B lu f f ,  Arkansas.

Since the time that you have assumed your duties as a 

Remedial Reading in stru c tress , have you asked fo r any 

spec ia l training?

9 A Yes, I have.

10 l! a And whom did you consult with or ask?

11 ! A I  asked the Superintendent, Mr. James K. Bradshaw.
12 a

1
On more than one occasion or ju s t  one occasion?

13

*• Yes, I  d id .

14
i ft How many times?

15 A Oh, I  asked him about three times. 1

16 a When was the la s t  such time?

17 j A I  asked him the year that we u n ified , the la s t  time was

18 when we went in to u n ifica tion  of the schools •

19 a A l l  r ig h t . Have you had the— a l l  of the supplies that
1

20 you were supposed to have during your course at the

2 ! Tucke\- School before you mowed over?
I

22 A No, I d id n 't .
'

23 a What were you lacking?
1

24 |j A I lacked qu ite  a few machines, lik e  aud io -v isua l

25 j machines, and some books fo r Reading, the workbooks.

! OLENN H PERRIN
Of f i c i a l  C o u r t  R v o m m  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a w a i  7 17 * 0 &



Evans -  D irect 249

(2 Are you familiar with the Economy cext?

A Yes, I am,

a  Did you always have enough o f thoee?

A Ho, at the time when we startod In the prograa, 1 d id n 't .

Q Were a l l  of the teachors equipped with Economy textbooks?

A 1 understand that they were.

a  But you don 't have any personal knowledge of that?

A Ho, 1 don 't.

a  1 see. Mrs. Evans, did you ever serve as Health 

Coordinator at the Tucker-Roeeawald School?

A Yea, I  d id . 

a  Hew long?

A The whole time 1 was at Tucker School, 

a  What vere your duties and re sp o n s ib ilit ie s  as Health 

Coordinator?

A Testing fo r eyos and fo r hearing and carrying the 

children to the hoalth c lin ic s  which was located in  

Pine B lu f f ,  Arkansas, for shots and heaping the f i le s  

on their health records.

a  Did you do that a l l  during the course e f  your tenure 

at the Roseuwald School?

A Yes, I d id .

G Right up to the very le e t  year?

A Yes.

a  Did you ever receive any payment at a l l  fo r that?

GLENN H PERRIN
O f f i c i a l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n r a e  7 179 0



Evans -  D irect

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No, I didn’t.
Did you ever--were you ever consulted or asked to be 

the HeeLth Coordinator once un ification  took place?

No, I was not coked.

A l l  r ig h t . Were you aware o f anyone e lse  while you were 

s t i l l  at the Tucker School, were you aware o f anyone 

e lse  who served in the capacity of Health Coordinator?

Yes.

Who was that individual?

Mrs. Robbie Keith.

How were you oede aware of her capacity as Health 

Coordinator?

Through contacts with the nurse f ro *  the Pine Q lu ff

c l in ic s - -

A l l  r ig h t .
I

— and P rin c ip a l—

1 am sorry .

— and the P rin c ipa l of our school.

And who was Mr. Edwards?

Jean C. Edwards.

Did Mrs. Keith ever c o m  over to the Roseawald School?

I never did see her there.
i

During tne cine that you served as Health Coordinator 

at the Rosonwald School, did you take car© o f a l l  ot 

the health a c t iv it ie s  et that school?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i 7 *o



Evans -  Direct: 251
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A Yes, I d id .

Q. Did that Include anything having to do with T it le  I?

A. W ell, yes, i t  d id .

& And what aspects o f T it le  I  did i t  deal with or whet

way?

& I was told by the Superintendent that g lasses could be 

secured a fte r  so long and maybe dental work, and, of 

course, I went to work to have them tested fo r that. 1 

ran tne machines and tasted the ch ildren , but there was 

no fo llow -up as fa r  as I knew.

ft W e ll ,—
iI

A- Several received g lasses but not a l l  that needed them.

ft Now, did you carry children to doctors, to d en tists , 

and to eye doctors?
I

A. 1 carried  them to the Health C lin ic  over here, but 1 

never carried  one to a den tist.

ft I see . But that Health C lin ic  is  in Pine S lu ff?

A- Yes , i t  is .

ft I see. And did you ever receive any compensation at a l l  

fo r that?

A No, I d id n 't .

ft Were you ever to ld  in any way that you were under

consideration or that there was a Health Coordinator 

paid job availab le?

A No, I wasn't to ld  that one was being paid for but there

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

F ederal. B u ild in g  
EL Do r a d o . A r k a n s a s  7 17 3 0



252Evans -  D irect

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was one serving in the capacity—

A l l  r igh t .

--b y  the school.

In your capacity as Health Coordinator, did you maintain 

a l l  of the records for a l l  o f the ch ildren , also?

Yes, I d id . They were kept in the f i l e  a t the Tucker-  

Rosenwald School.

In the course o f keeping those records, wee i t  over 

necessary for you to consult with anyone in the 

adm inistration of the Plum Bayou-Tucker School D istrict?  

Yes, i t  was.

With whom?

W ell, i t  was necessary— should have been necessary, I  

would nave consulted with the Superintendent.

W ell, did you?

No, I d id n 't  have any conversation with hits about i t  

at a l l .

Did you keep those records—were they ava ila b le  to 

anyone who wanted to inspect them?

They were av a ila b le  to anyone that might want to see 

them. They were kept in the f i l e  cabinet in the 

P r in c ip a l 's  O ffic e .

Was th is a program that you institu ted  on your am  or 

was i t  actu a lly  part of the echoel program?

It was a part of the school program.

GLENN H PERRIN  
O f f ic ia l  C o u r t  R epo r t er  

F e d e r al  B u il d in g  
EL Do r a d o  A r k a n s a s  7 t7so



Evans -  D irect

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A

A ll  r ig h t . Mr*. Evans, were you present during any 

neeting* or workshops at which un ification  was discussed  

with the Rooonwald teachers by the Superintendent?

Ye*, I was.

Tell u* when that we*.

It was March, the year before we un ified  with Plus* Bayou

School.

So that would have been March, 1969?

March, *68-*69 tern, yea.

A l l  r ig h t . So i t  wa* March o f the *68-'69—

Ye*.

--sch oo l tern , that would have node i t  March o f 1969, 

is  that correct?

Right.

A l l  r ig h t . Where did the meeting take place?

It  tcok place in the Reading Roon, ny roon, classroom. 

Who wss there?

A l l  of the facu lty . In fa c t , i t  had been a workshop 

conducted by Mr*. Armenia Kidd, and a fte r  the workshop 

was ove r--

Did the workshop have anything to do with un ification?

No, i t  d id n 't .

A l l  r ig h t . T e ll  us what happened a fte r  the workshop, 

then.

A fter the workshop, Mr. Edwerds asked fo r comments from

GLENN H PERRIN  
Of f i c i a l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n g a e  7 17 * 0



254

1 the Superintendent, and th at 's  when we were to ld  that

2 the school would be noved to P lus Bayou end that a l l

3 "N igger" teachers would not be used car carried  over

4 !i there.

5 ii & Was that the word that was used?
li
j

6 A. Yes, i t  was.

7 | MR. STARLING: Your Honor,—

& | a  Who used it?

9 A. Superintendent, Mr. Bradshaw.
I

10 MR. STARLING: — the witness said  "we were to ld " .

11 Did Mr. Bradshaw t e l l  her or sons of the teachers

12  ̂ c o ll  her? I f  1 nay, I would lik e  to have i t

13 | c la r i f ie d  as to who to ld  or who said  that.

14 j THE COURT: She said  Superintendent—

15 THE WITNESS: Yes.

16 THE COURT: --and the Superintendent is  Mr.

17 li Bradshaw.
j

18 ;| MR. STARLING: A l l  r ig h t , I  an so rry , I  d idn 't  hear

Evans -  D irect

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her say "Superintendent".

Q> Anything e lse  said  during the course o f that aaeting  

by Mr. Bradshaw about un ification?

A. At that nesting, no, because when that statesMnt was 

nade a l l  teachers becaan very upset with bin  c a llin g
j

then "Nigger teachers* and the nesting ju s t  broke up, 

and the teachers refused to go back to work. They would

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo r ter  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i 7 so



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coae to work but they ware not coaching the ch ildren .

So I t  was ca lled  to tty attention—

a  Who ca lled  i t  to your attention?

a. The facu lty , a l l  o f the teachers except the P rinc ipa l

was not aware, he knew nothing was happening, because 

every nam ing each teacher would cone to ay claesreen  

and the discussion would s t a r t .  So I  sa id , "We a ren 't  

doing anything but hurting our students not teaching". 

They sa id , "W e ll, we w i l l  not go back to work because 

we are not s a t is f ie d  with h la  c a llin g  us ' l i g g e r s '" ,  

and at that tin s I  consulted the P rinc ipa l fo r a 

conference with Mr. Bradshaw because he hadn't been back 

in about two weeks, and he agreed fo r one, and f in a lly  

he cane over, and I  went into the o f f ic e  and we talked  

fo r about an hour and a h a l f ,  I  guess.

a  What was said  at that tine?

A. And I asked h la  then*-1 to ld  h la  the grievances that the 

teachers had. He wanted to know why, and 1 to ld  h la  i t  

was on teachers ' grievances, and 1 to ld  h la  why, because 

of the word that he used was "H iggor*.

Q. Uh-huh.

A. So i t  went on as fa r  as th is  point, I  asked h la  oven 

about the c r it e r ia  would he have in se lection  o f h is  

teachers. I a lso  asked h la  at that tine would sen io rity  

have anything to do with teachers being retained , and

GLENN H PERRIN  
Of f ic ia l  Co u rt  R p o r m  

F sdkral Bu ild in g  
EL Do rad o . A rk an sa s  7*7*0

Evan* - Dir e c t



256Evans -  D irect

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he sa id , "No“ . I  sa id , "W eil, what acout T it la  I money,

I  am on T it  la  !?• And ha sa id , "W all, i f  T it le  I oeacy 

goes o f f ,  you might jv e t  not have a Job". So natu ra lly  

I  wee concerned, I  noadad a Job, And I  sa id  th is , "W all, 

I  would lik e  to know why, i f  my work hasn 't boon dona 

w a ll enough to be retained , what could I  do?" And I  

* * ld »  "Nr, Anderson made th is promise to me, that I  

could go back to the classroom ", which was the Sixth  

Grade, and I  gave my Sixth Grade work up fo r Mrs, A rtie  

Davis. With my supervision , ha agreed to h ire  her on 

a substitute  basis  the f i r s t  year she was there because 

she was not c e r t i f ie d ,  and, o f  course, 1 did  go in and 

supervise her roam and carry  on the work o f  testing  the 

whole school the re s t  o f the year.

Now, getting back to your conversation with Mr,

Bradshaw—

So, back to Mr, Bradshaw, he says i f  N r. Anderson did 

not put i t  in paper, i t  was not any good.

Did you ta lk  about the re s t  o f the teachers with him 

and what would happen to the root of the black teachers? 

Yes, 1 d id .
(

And what was sa id  by you and what was sa id  by him?

He said that he would not nood a l l  of the black  

teachers— a l l  of the "Nigger teachers".

Did he say i t  again?

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 it s o



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Yes, repeated, and h#*Muyd4 iu*i d id n 't  caste wxuh

the r o i l ,  but he did say "S igner• aa p la in  as 1 could 

say i t .  But he said naybe ho did a a is tsk s  whoir

we had the conference and ho said  the word "n igge r", 

but he d id n 't  say r o l l ,  he wasn 't used to saying that, 

he cou ldn 't say I t ,  what did wo wish to bo c a lle d .

Did you have any other nestings with h ia  a fte r  the 

meeting in Mr. Jean C. Edwards' o ffice?

Yes, on one occasion.

Where was that?

In Mr. Edwards' o f f ic e  when he was about to say what 

teachers would be retained and what would not be.

How did that nesting cone about? Haw were you present? 

He ca lled  us in  one by one. He would c a l l  one in and 

then t e l l  that one to t e l l  the next one to cone In .

And at that tine were you to ld  that you would be 

retained?

Yes , I was •

A l l  r ig h t . How, were you present at another meeting 

that was a public  nesting where Mr. Bradshaw and perhaps 

some of the School Board members were present?

I was present at the very f i r s t  nesting that the parents 

asked to cone over.

Where did that nesting take place?

At the Plum Bayou School In the L ib rary .

GLENN H PERRIN  
O f f ic ia l . C o u n t  R epo r t er  

F e d e r a l  B u ild in g  
EL Do r a d o . A r k a n s a s  7 17 3 0 3 ^ 3

t

25



1 & Was that in the Wrigat comunj.iy?
2 A. Yes, in the Wright coaeamity.

3 C. All right. And who was present?

4 A It was around 50 parents there end all teachers fre©
51! Tucker School.

e 0 How about officials of the School District?

7 A They were present.

8 i 0 All members of the School Board?

91| A Yes.

0 Was Mr, Bradshaw present?
A Yes, he was.

O Was there any conversation at that ties about— specific* 

ally about retention of black teachers once unification 
was achieved?

A Yes, It was.

Q> Tell u« what was said then.

A One of the patrons, Enoch Tony, Enoch Tony, asked 

the question what would become of cur students— of our 

teachers, and he said, *1 will not fixe a white teacher 
for a 'Nigger' teacher 

& Was that Kru Bradshaw again?
A Yea.

0- All r igh t.

A And it was about to get into a— I naan the meeting woo 

getting in a high pitch seeaingly, there were 50 people

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

F ed e r al  B u il d in g  
E l  Do rad o  A r k a n s a s  7 1 7 3 0

Evans -  Diracc



Evans -  D irect
259

or more present in the Negro race , an*, o f course, Sir.

Tony gestured, he got up, he stood up on his fe e t , and 

he said, "Hold it. Did you say ’Nigger’?* And, of 

course, tha neeting was quickly brought to a close. I 

did not attend the last nesting that the parents west 

over.

a I see,

A. No teachers, as far as I know, attended.

a mvo you ever bean told by— since Mr. Bradshaw took over 

as Superintendent, that if Title I funds were unavailab le , 

that you would be replaced ea the Minimus Foundation 

salary schedule?

A. No, I haven't.
!

£> Was the first you heard of it yesterday?

A. Yes, that was ay first tine of hearing it.
ft Since unification, have you ever been consulted or asked 

about the Health Coordinator position?
A. No, I haven't.

Q. Have you served as the Health Coordinator cr any way
j

performed any of those duties since unification?
A. No, 1 haven ■t

>&. KAPLAN: That's s l l

GLENN H PERRIN
Of f i c i a l  C o u r t  R epo rter  

F e d e r a l  B u ild in g  
EL Do r a d o . A r k a n s a s  7 17 * 0



Evans -  Cross 260

CROSS SXAMljfcUTIOfr

BY MR. STARLING:

a M rs. Evans, while you w ere at the Tucker-Rooeos&ld School 

and say you were acting as Health Coordinator, who 

assigned you to that job?

6 A. The P rinc ipa l and the Super in tendent <>

7 a Who was the P rinc ipa l and Superintendent?

8 A. Mr. Jean C. Edwards was there, I  served under him, I
9 served under four P rin c ipa ls , namely, Mr. C. 1Si. G arrett,

10 deceased ,--

11 a
i

Let me ask you th is , I can save--what Superintendent

12 assigned you to the job of Health Coordinator at the
13 Tucker-Rosenwald School?

14
i

A. Mr. Charles E lk ins.
j

15 a And when was that? 1

16 A. Oh, I don 't remember the year he was there, I can 't
17 remember that righ t now, I don 't r e c a l l .

18 a How many years was it  before Mr. Bradshaw can»?

19 A. Hew many years before?
■

20 a Uh-huh.

21 A. Then Mr. E lk in s ' tenure, which was before Mr. Bradshaw

22 and Mr. Anderson.

23 a How many years would you say before Mr. Bradshaw?

24 A. O h, l  guasa 15 or 20 years. |

25 a That you w ere--

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

F e d e r a l  B u ild in g  
EL Do r a d o . A r k a n s a s  7 i7 »o



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Evans -  Cross

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I served la  thac capacity.

But you ware not paid fo r i t ,  right?

I have never received one peony fo r i t .

Did yea ever ask Nr, Elkins o r—

Yes, I have. I t  was In the po licy  that any extra duty 

that a teacher performed, they would be paid fo r .

Did you ever ask Mr. Bradshaw?

For money fo r—

Yes.

--H ealth  Coordinator? I  had no need to ask bin  whoa I  

w asn 't— I w asn 't assigned i t  by Mr. Bradshaw, He knew 

that I was doing i t .

Hew do you know that he knew?

He knew because he would cane over cad t e l l  ae to rxa  

the te s ts . The machine was brought over by the nurse 

fron the Health Department,

Mow, you t e l l  as that you maintained—

And the nan fron  the State Department, I  don 't reom bar 

his name now, cane down to help.

While Mr. Bradshaw was Superintendent, you never asked 

him for money fo r being Health Coordinator, correct?

I never asked Mr. Bradshaw?

Right.

No, but the po licy  book says th is , that any extra

duties that the teachers perform, they w i l l  be paid fo r

GLENN H PERRIN  
O f f ic ia l  C o u r t  R epo rter  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7 s o

1



2 6 2Evans - Cross
I — -
1 it. Was chat extra duty?

2 a  W ell, what I am asking you, how did Mr, Bradshaw know

3 that you ware Health Coordinator i f  ha d idn ’ t assign you

4 that job and you never asked bin to pay fo r  it?

5 |j a. Because I had the f i le s  to keep, I signed the records

6 that was sent over.

7 1 a  I  be lieve  you te s t i f ie d  that you m inteined  records, is

8 that not correct?
,|

9 | A. l  beg your pardon?
!

10 d 1 be lieve  you te s t i f ie d  that you maintained records?

11 j A. I d id .

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A.

But 1 a lso  be lieve  you te o t lf le d  that you never did  

consult with Mr, Bradshaw shout these records, is  that

correct?

They were there in the f i l e  in the P r in c ip a l 's  O ffic e .

Did you ever consult with Vs. Bradshaw about the 

records?

In what way?
I

W ell, you indicated that i t  was your--that the records 

were there end you should consult with the Superintend- ! 

ent but you never did consult with Mr, Bredahaw.

I didn’ t  have any chsncs to do i t .

What no you mean?

I d idn ’t havs the opportunity to ask bin  to look at the 

f i l e s  because he knew what was lacking over et

GLENN H PERRIN 
O f f ic ia l  C o u r t  R sro rtkr  

F e d e r a l  B u ild in g  
EL Do r a d o . A r k a n s a s  7 i7S o



26:
Evans -  Croat

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Tuckar-Rotenwala School. I felt like he had che 

knowledge to know, because he said  g lasses could be 

bought through T it le  I .

W ell, Mrs. Evans, the only thing I  on concerned about, is  

i f  Mr. Bradshaw had no way o f knowing, since you did net 

consult hin about the records, you newer asked h ie  that 

you be paid, and he did not assign  you t*v* job of 

Health Coordinator, the only thing that is  concerning 

ae , how did he know that you were Health Coordinator?

Is there a w ritten  po licy  in the D is t r ic t  or was there 

sons piece of paper that you signed waking you Health 

Coordinator?

I  signed the f i l e s  of a l l  records of the health  

c e rt if ic a te s  or whatever you eight c a l l  thaw—

Did you ever show—

— for the children at Tucker-Rosanwald School. Whoever 

a report had to go into the State Departaunt or T it le  I ,

I fixed  i t  and signed i t  and gave i t  to  the Superintend­

ent with ay nawe signed an i t .

What did you sign your nawe as?

Lucreasla A. Evans.

Health Coordinator?

Yes, I d id .

Have you got any o f those records with your snd

Health Coordinator on then?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 * 0



Evans -  Cross

1 ; A. They are in the file cabinet. I didn't keep any of the

2 f i l e s  that was brought over frost Tucker School. They

3 are in h is o f f ic e ,  I suppose. They were in the

4 P r in c ip a l 's  O ffic e  at the time, and I d id n 't  keep them

5 I in my room.
II

<V d But you never consulted with Mr. Bradshaw—

7i| A. Ho. 1, I d id n 't  have a f i l in g  cabinet in my room at that

8 |j time.
■Iii

8 a  But you never consulted with Mr. Bradshaw about the 

0  l i  records o r— did you ever show him any o f the records

11

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that you sent to the State Health Department with your 

name on it?

No, I  d id n 't .

Mrs. Svans, when the schools ware u n lt lsed , did you ask 

Mr. Bradshaw could you be compared with Mrs. Robbie 

Keith fo r the job as Health Coordinator?

No, I d id n 't  ask him that. The o ffe r  was not M de.

No Negro teacher holds any adadn lstratlve o ff ic e  over at 

Plum Bayou. I  wasn 't asked, but he knew that I  was 

serving, and I  f e l t  l ik e —

How did he know that you were serving in the o f f i c i a l  

capacity of Health Coordinator? Is i t  not— is  i t  a

T it le  I job?

I to ld  you he knew it  because the records that I  kept 

and because o f the papers that had to be sent in to

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7 »o



L65

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Evans - Cross

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T it le  I .

Is i t  a T it le  I  job?

I don 't know that i t 's  a T it le  I  jo b . I  would lik e  to 

know.

Do you know whether Mrs. Robbie Keith, who is  the Health 

Coordinator, worked under T it le  I funds?

She's paid out of T it le  I  funds, I  understand.

Then why d id n 't  you ever go to Mr. Bradshaw and say,

"Mr. Bradshaw, Mrs. Keith is  being paid out o f T it le  I  

funds"?

I was a fra id  to ask him.

Oh, I see. And when you--whcn the schools were 

un itized , you never asked Mr. Bradshaw could you be 

compared with Mrs. Keith fo r the job o f Health  

Coordinator?

No, I d id n 't ,  because, as I  sa id , I  was a fra id  to ask 

Mr. Bradshaw, because the statement was made in the 

f i r s t  meeting we had in the workshop that h is o f f ic e  

would not be used to run in and out, s p e c if ic a lly  fo r  

business only.

W ell, do you consider that business?

Yes, I would consider i t  business, but i f  you are not 

going to get the proper answer, you wouldn't want to be 

embarrassed.

25 a W ell, bow do you know you wouldn't have got the proper

GLENN H PERRIN
O f f i c i a l  C o u r t  Reporter A  i 

F e d e r a l  B u i l d i n g  jL J  r 
EL D o r a d o . A r k a n r a *  7i7*o Ji L^, | jj

i



26<
Evans -  Cross

Xij answer?

2 A W ell, beforehand, I hadn't*

3 a
i

When had ycuorer been in there beforehand?

4 A I have been in  his o f f ic e  once since the school was over
5 l there.

6 ! a
1

And at that one tine you d id n 't  get the proper answer?

7 A I wasn 't talk ing concerning Health Coordinator. I  wasn 't

8 talk ing as the Haalth Coordinator.

9 0i
Lot dwj ask you th is , is  there--you don 't hove a contract

XO or anything that says--when you o r ig in a lly  signed up

IX with Mr. Elkins sene 20 years ago, did you sign a
1

12
|

contract that said  you were the T it le  I Health 1

13 | Coordinator?
1i

14 A We d idn ’ t have T it le  1 in  that school at that t in s .

15 a A l l  r ig h t , le t  ne aak you, did you—

16 A T it le  I  cone in  tho D is tr ic t  in '66 and '67. !

17 a  A l l  r ig h t , when i t  cams in the D is t r ic t  in '66 end *67,

18 did you t e l l  Mr, Breda hew, car Mr. Anderson et that tine

19 that you were Health Coordinator at Tucker-Eeaenwald,

20 and, therefore , oince T it le  I was in and there was a

21 job fo r T it le  I Health Coordinator, that you wanted that

22 job?

23 A. x have never been to ld — I have never seen any figu re s ,

24 I have never bean on a committee, which I waa advised

25 , that I should have been on since I  was working under

G L E N N  H  P E R R I N

O f f i c i a l  C o u r t  R e p o r t * *  m

F e d e r a l  B u i l d i n g  J
E L  D o r a d o . A r k a n s a s  7 i 7 s o



Evan* -  Cross

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chat title, from the State Department, that 1 should 
have bean considered**

W ell, now,**

— as one o f the people that would have coca thing to say 

about how the money would be spent,**

W e ll ,—

--bu t I  was never—

Just answer ay question, Mrs. Evens. Did you ever t o l l  

Mr. Anderson when T it le  I  cane into e ffe c t  and Robbto 

Keith was the T it le  I Health Coordinator, that you 

wanted a lso  to com  under T it le  I?

At that tine I  did not know that Mrs. Keith was the 

Health Coordinator fo r P lus Bayou.

Did Hr. Edwards— you t a l l  cas that Mr. Edwards was one 

of tha ones that appointed you Health Coordinator at 

Tucker-ftosanwaId School. D idn 't he knew that T it le  I  

funds ware av a ila b le  fo r Health Coordinator?

I f  he knew i t ,  I  d id n 't  know i t ,  he d id n 't  t a l l  sas.

Okay. And—

He might have had the knowledge o f goat o f these 

that I d id n 't  have, being tha P rin c ip a l.

Since u n it la stio n , have you ever asked Mr. Bradshew 

could you be the Health Coordinator or coopered with  

Mrs. Keith?

Jt^had in mind to ask him at one time, but I waa a fra id .

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n r a e  7 1 7 3 0

2 6



& Were you afraid he was going to h it  you?

A No, I  wasn 't a fra id  of a blow, no, a physical bios*, no, 

a  Mrs. Evans, you were put on the T it le  I  p ay ro ll as a 

Remedial Reading teacher p rio r to Mr, Bradshaw coming, 

is  that correct?

A. Under Mr, Anderson, *66 and '67, January, 

a  Whan he asked you— I be lieve  you stated that Mr, Edwards 

and Mr. Anderson asked you to take that job?

A. Yes.

a  Did you object a t that time?

A W ell, yes, I  d id .

& What did Mr. Edwards say?

A I sa id , "1 am not prepared, spec ia l s k i l l ,  fo r this

program, why?" And we went along with the conversation  

in th is way, I asked Mr. Anderson in the presence of 

Mr, Edwards, " I f  I  am placed in th is position  and you 

see that I  cannot do the work, I  cannot perform, w i l l  

you please le t  me go back to the classroom?" And he 

sa id , "Yes", The answer was "Yes", 

d What did Mr. Edwards say at th is time?

A What did Mr. Edwards say?

d Uh-huh.

A He was the one who was s it t in g  in et the desk the

morning that I arrived  back from St. Louis, M issouri, 

and be sa id , " I  was about to forge your nase", and £

G L E N N  H P ER R IN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a n s a s  7 * 7 3 0

Evans -  Cross



Evans - Cross
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M td - U  And n . . . i d  h . . . .  .bout to g .c

these papers ready fo r T it le  I  money.

Did Mr. Edwards —

I was brought into the D is t r ic t ,—

Did Mr. Edwards —

-a n d  at that time, I .a id ,  -W e ll, I haven't app lied ,

I did not sign the s l ip  that you sent around".

Then Mr. Edwards was the one that b a s ic a lly  reconended  

you for the T it le  I Job?

Yes.

Are you .ey ing that Mr. E d w rJ . d t .c r l . in a t .d  « Se ln ,t  

you fo r doing that?

No, I am not saying that he discrim inated against me 

for doing that, but at that t in s  he wanted soaeone that 

could do the paperwork and do the te stin g , which I had 

a l i t t l e  knowledge of doing.

So you accepted the job?
i

Yes, I  accepted i t ,  with th is understanding, that I  would 

go back to tha classroom i f  I  d id n 't  perform lik e  a 

Remedial teacher should do.

Were you s t i l l  the T it le  I teacher-now , what year was j

this?

’66-'57 , January.

Are you s t i l l  the T it le  I teacher?

Yes, I am.

GLENN H P E R R IN
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o  A r k a n s a s  717,0



a How much money do you make a* T id e  I teacher chi* 

year?

A. I got a ra is e  o f $200.00. That was a blanket ra ise  

that the whole school got.

Q How ouch is  your salary?

A. $6,200.00.

O Is n ’t i t  true that over the period o f tine that you

have been the T it le  I teacher that you have received a 

ra ise  in excess in your basic  sa lary  frees the regu lar  

pay ro ll o f over $2,000.00?

A. Yes, it is true, but I don’ t receive a stipend— I don’t 

receive a bonus as other teachers under the Minimal 

Foundation.

0 While you have been there, Mrs. Edwards— Mrs. Evans, 

excuse me,—

A. Yes.

tt --under the T it le  I program, have you ever te ld  Mr. 

Bradshaw that you wanted to get out from under the 

T it le  I program?

A. W ell, I to ld  him I wanted to be— I wanted to go to

school, get some more s k i l l s ,  which I  thought I  needed.

O Wait a minute, now, I am going to get to that in ju s t  e 

second. Have you ever to ld  Mr. Bradshaw that you did  

not want to stay under the T it le  I?

A. No, I haven’t to ld  him that I  d idn ’t want to stay under

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 * 0

Evans -  Cross



271

I t ,  no, I haven 't,

a  How does he know, then, that anything la  wrong with you 

being under the T it le  I program?
|

A. Because of conversation we have had.

Ml. KAPLAN: Object, Tour Honor.

MR.. STARLING: I w i l l  withdraw the question,

tt Do you know whether or not there are any white teachers 

under the T it le  I  program?
.

; a  Not as I  know o f .  I  haven 't ever seen anything from
I

T it le  I except ny check every month, 

a  I f  I asked you, between the years 1965 and 1970, whether 

you knew that there were fiv e  white teachers under the 

T it le  I  program and three Negro teachers under the 

T it le  I  program, would you say that th a t 's  a true fact?

A w i l l  you state  that again , please?

O Between the years 1965 and 1970, i f  1 gave you the

figu res that there were fiv e  white teachers under the i
T it le  I  program, as you a re , with a contract having the 

same language, " i f  funds are a v a ila b le " , and three Negro 

teachers, would you say that th a t 's  a true fact?

Ml. KAPLAN: Tour Honor, I  am going to ob ject.

The witness is  not competent to answer the question. 

The Superintendent has already t e s t i f ie d  to these 

fa c ts .

THE COURT: W ell, i f  she knows, she can

OLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a n s a s  7 1 7 3 0

Evans -  Cross



te s t i fy  whether that is  true os* not. I  see 

nothing wrong about that. The Superintendent 

did te s t i fy  that, but I  think i t ' s  appropriate

Evans -  Cross

4

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question. I f  you know whether or not there 

have been these indiv iduals since 1965 on 

the prograa under T it le  I .  I f  she don 't know, 

she can say so.

Yes, I do know that they have been.

How do you fe e l  that their position  is  any d iffe ren t  

from your position?

In what way, did you say?

In the respect that you are a lle g in g  that the D is tr ic t  

has discrim inated against you fo r placing you on the 

T it le  I  prograa and asking your tenure as a teacher 

subject to " i f  funds are a v a ila b le * .

As i t  was stated yesterday, some of these programs were 

put into T it le  I had to be pulled  out. I  uaders tend 

they were not to be under T it le  I  in the f i r s t  p lace. 

W e ll,—

I understand that T it le  I money was supposed to be used 

for deprived children .
i

How was your position  under the T it le  I  prograa any 

d iffe ren t  frou the fiv e  white teachers who are under the 

T it le  I  prograa?

Pardon toe, say that again, p lease.
—  _ —— ——— ——— — —————— ———j-

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 i t s o



273
Evans - Cross

i, a

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Why is  your position  under the T it le  2 program say more 

detrimental to you than the white teachers under the 

T it le  I program?

Because of the teaching load— the teaching that I  have 

to do, and I wasn 't prepared, I  wasn 't given any 

particu la r s k i l l s .

Are any o f the—

I Just had to taka the book that was given to me—

Mrs. Evans, sra  any spec ia l s k i l ls  required to be a 

teacher under the T it le  I program?

I should think i t  should be.

No, not what you th ink ,—

Yes, there e re .

— is  there? Have you been--has the government required  

you to take any sp sc ia l courses or sk ills?

The government?

Yes.

No, they haven't required me to take any, but I  went to 

the State Department of Education under Mrs. Case, 1 had 

an interview with Mrs. Case, and she said  aa o f— and 

Mrs. Hubbard, which is  over the Reading program, the 

State of Arkansas, that In due time teachers would have 

to be c e r t if ie d  in Remedial Reading.

"In  due time”. When was "due time"? When is  "due time"? 

Oh, less than two years. About two years.

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 t 7 » o



Evans -  Cross

i !  & 

2

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19

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W ell, in other words, r igh t now there are no spec ia l 

s k i l ls  required under the T it le  I  program to he a 

teacher—

W e ll ,—

— other than an elementary or secondary ce rt ifica tio n ?  

W ell, I  have that, I  have my c e rt if ic a t io n  fo r  elementary 

education.

Now, you say that— you stated that you asked Mr.

Bradshaw, I  take i t ,  to le t  you go to school to get sons 

spec ia l tra in ing  in th is area at the expense of tho 

D is t r ic t ,  is  that correct?

I asked fo r workshop or anything that I  night get through 

a stipend even, not from the D is t r ic t 's  neney altogether 

but ju s t  stipend.

Stipend from where?

From anyplace. You understand what a stipend is?

Yes, I do.

Send peoples to school on a p articu lar s k i l l ,  and I 

understand they are a v a ila b le .

Mr. Bradshaw to ld  you that the D is tr ic t  did not have a 

policy of defraying expenses fe r  teachers to acquire  

extra s k i l ls ,  right?

Yes.

Mrs. Evans, do you know any teacher, white or black, 

who has ever been allowed to get add itional s k i l ls  at

GLENN H PERRIN

F e d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a n s a s  7 i 7 s o

O f f i c i a l  C o u r t  R k f o r t k r



Evans -  Cross

i|j the expense of the District by District runes?
2!l a. No, I d o n 't .

3 a

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W ell, then, why is  i t  that you are being d iacriainated  

against?

I wanted a stipend, I ju s t  asked fo r a stipend or attend 

a workshop that other teachers had attended—

At the expense o f the D istrict?

--and I  was denied.

At the expense of the D istrict?

W ell, I am hoping that I wouldn't have been discrim inated  

aga in st, but I  asked the question, a l l  I  could do was 

receive the answer, which was •No".

Hr. Bradshaw answered you that the D is t r ic t  had a policy  

that they would not defray expenses fo r teachers to get 

add itional s k i l l s ,  is  that correct?

Pardon me, say that once more.

Is i t  not true that Mr. Bradshaw told you when you 

him for expense money that in fact the D is tr ic t  had a 

policy that they would not defray the expenses of a 

teacher to acquire add itional sk ills?

He d id n 't  quote that they d id n 't  have a p o licy , he ju s t  

said they d id n 't  have any money.

Then, I ask you again, do you know of any teacher, white 

or b lack , that has ever had her expenses defrayed by the

D istrict?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



Evans - Cross 276

1 A. No, I don’ t .  My answer was “No*,

2 a A l l  r ig h t . Now, at the meeting with the Tucker-Koeenwald

3 teachers where you a lle ge  that Mr. Erodehow made the

4 statement before these teachers "No 'N igge rs ' w i l l be

5 i used when the schools are u n ified " —

6 A. He said not a l l  o f the "N igger" teachers would be

7| needed, that is  what 1 sa id .

8 i a A l l  "N igger" teachers would not be needed, is  that what

9 he said?

10
■

I *• Yes.

11 MR, KAPLAN: No, Your Honor, that is  not what the

12 witness sa id . The witness said  "not a l l " . |

13 THE WITNESS: Not a l l . 1
14 a Not a l l  o f the "N igger" teachers — 1
15 A. Right.

16 a —w i l l  be used?

17 A. I said "not".

18 a And he said th is before a facu lty  meeting?

19 K Faculty only, facu lty  of Negro teachers. ■

20 a Was Mr. Edwards in the room?

21 * : A. Yes, the P rinc ipa l was there, a l l  teachers.
l

22 a Mrs. Evans, Mr. Edwards, I b e lieve , t e s t i f ie d — le t me
|i

23 ask you th is , are you sure th a t 's  what he sa id , he

24
Ij

used the word "Niggers"?

25
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A. I understood him to say "N igger", and one teacher, Dora

|
il
Ij

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  t * 7 s o



Thomas, called his nand co that, *£id you say  'Nigger'?" 
And th at 's  why we stopped working.

Evans - Cross
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25

Let me ask you th is , why do you reckon Mr. Edwards 

te s t if ie d  that he said  he would not le t  out any of the 

white teachers to reta in  any o f the black teachers?

KAPLAN: Objection, Your Honor, he is  asking

this witness fo r a conclusion o f what another 

witness said and fo r an opinion.

THE COURT: I think th a t 's  r ig h t , Mr. S ta r lin g , j

i t  i s n 't  her to speculate on why he said  

sonething. You can ask what was sa id  and done. 

Let we ask i t  th is way, Mro. Evans. Mr. Edwards— you
i

were present when Mr. Edwards t e s t i f ie d ,  is  that 

correct?

A ll  facu lty  neabars were present.

Yesterday you were present when Mr. Edwards te stified?

I thought you said the workshop. Yes, I  was present 

yesterday.

Mr. Edwards te s t i f ie d  that Mr. Bradshaw stated that he 

was not going to le t  out white teachers to re ta in  black  

teachers. Now, did you hear Mr. Bradshaw cay that, too?

At th is p articu lar neeting?

Uh-huh.

No, I d id n 't .

Then, in other words, Mr. Bradshaw sa id , or at least you

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



276

allege chat he said either "hoc all 'Niggers* will be 
2 used" —

Evans - Cross

3 A.
4 a

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a

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Yes*

That’ s what he sa id . Okay. Why do you rectum, Mrs.

Evans, that Mr. Bradshaw— o r , io i t  not true that Mr. 

Bradshaw, when the evaluation period f i r s t  started  or 

when th is natter o f un ification  f i r s t  cane up, Mr.

Bradshaw recomnended that a l l  teachers, black and white, 

be given an objective test which would be administered
j

by the National Testing Service and graded by the 

National Testing Service, is  that not true?
I

State that once more, p lease.

Is n 't  i t  true that when the problem of un ifica tion  f i r s t  

arose, Mr. Bradshaw recommended that a l l  teachers, both 

black and white, in the elementary schools would be
i

given an objective  test which would be graded by 

National Testing Service and administered by National 

Testing Service?

Yes, i t  was stated.
i

And is n 't  i t  true that Mr. Bradshaw said that the ten 

highest grades would be retained and the fiv e  lowest 

grades or f iv e  lowest graded teachers would not be

retained/

I did not hear the figu res ca lled  as such, no. I did 

not hear any figu res . He said a l l  teachers would take

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n e a e  717so



Evans -  Cross 2 7 9

2 I 0

3

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th is te st .

Mr. Bradshaw had e a r l i e r  co ld  you that th e re  were 15 

teach ers  and on ly  10 would be r e ta in e d , i s  th a t  co rrec t?

He d id  not quote any f ig u r e s  o f  how many teach ers  would  

be r e ta in e d , he sa id  he would not need " a l l  'N i g g e r ' 

te a c h e rs " , and I  was in c luded  in  th at group because I  

worked a t  the Rosenwald Sch oo l.

My q u estio n  i s ,  i f  Mr. Bradohaw had g iven  an o b je c t iv e  

w r it te n  t e s t  which had been ad sd n ia te red  by a N a t io n a l  

T estin g  S e rv ic e  and graded by the same, then the h igh est  

number o f teach ers  graded  on th a t t e s t  would have 

stayed  and the low est number, w hatever th at number nay 

have been , would not have been r e t a in e d , then he r e a l l y  

c o u ld n 't  have s a id  th at "not a l l  'N ig g e r ' teach ers  

would have been u se d "; in  o ther w ords, i t  would have 

been p re t ty  nuch determ ined by who scored  what g ra d e ,  

i s  th at not co rrec t?

I  am not understand ing  your q u e s t io n , now, I  am s o r ry .

MX0 KAPLAN: Your Honor, I  th ink  th at the qu estion

poses an argum ent- -  

THE WITNESS: Uh-huh.

MR. KAPLAN: - - t o  the w itn ess  and asks fo r  a

conclusion to an argum entative q u e s t io n , and I  

th ink  i t ' s  in p e rm ls s ib le .

THE COURT: W e l l ,  I  th ink  both  p a r t ie s

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a n s a s  7 i 7 > o

______________________________________________________________________1_



understand wnat is intended.
0- Why was -  -

THE COURT: Mr. S t a r l in g , as the Court under-

stands i t ,  is  trying to ask her to explain i f  

determination is  going to be aside froa  th is  

tM t  re fe rred  to , why would such a statement 

have been made, and I  think that would be a 

proper in terrogation .

ft In other words,— I w i l l  try  to phrase i t  as properly as 

the Court d id— in other words, i f  th is ob jective  test  

was going to be u t i liz e d  and simply the highest grades 

would be retained and the lowest grades would not, what 

was the reason for th is type o f statement or what would 

be the need fo r th is type o f ntareswmt to be made?

A- To the best o f ay knowledge, th is statement was oade 

a fte r  the conference at Tucker-Rosenwald School. To 

the best of ay knowledge, i t  was. We were informed 

afterwards. I don’ t r e c a l l .

ft Now, you spoke about the Board meeting which was held 

sometime in March in which I be lieve  Mr. Tony—

A. Enoch Tony.

ft — asked what would become o f our teachers when the 

schools were u n it iz e d ,- -

A. Y es.

ft --and you stated that Mr. Bradshaw said that he was not

OLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n e a e  7 i7»o

Evans -  Cross



il
1 ij going to f i r e  any white teacher* for any “Nrgger

2 1 teachers"?

3 A Yes.

4 ft And was th is Board M atin g  attended by the pub lic , both

Evan* -  Cro&s

5 l!

A

ft

A

6 A
I

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8

N  ft

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21 j| Q .

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241! A

25 !

white and black alike?

There were no whites except the Board stMfcers, a l l  

Negroes, and the teachers frosi Tucker School, but no 

patrons from over at Wright coanunity.

I f  you think about that p articu lar Board neeting, Mrs. 

Evans, i s n 't  i t  true that the question Mr. Tony asked 

was would Mr. Bradshaw h ire  any blacks to take the job  

of cooks or bus drivers?

Beg your pardon?

Is n 't  that what Mr. Tony asked at that Board M ating?  

Not to my knowledge. He asked what would happen to the 

teachers at Tucker School i f  they take the school. I f  

they took the school, what would happen to the teachers. 

And Mr. Bradshaw stated that he was not going to f i r e  

any white teacher fo r a "N igger" teacher?

Yes.

Was Mr. Edwards present at that—

Yes, he was present.

-•a t  that M eting?

Yes, he was. A l l  o f the teachers at Tucker School were 

present.

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a w a *  7 1 7 s o



ij| a But Mr. Edwards didn’t testify to that statoia&at 
2 yes torday, did he?

a A. I am not try ing to prove his point.

4 ft Were you here in the courtroom yesterday?

5 A. Yes, I was here.
i

® • KAPLAN: Your Honor, I  am going to object to

th is lin e  of questioning as to what another witness

8 may have said  or may not hove sa id . This witness

9  i j  is  not bound by what any witness other thanI
0 i h erse lf sa id .

Evans -  Cross

1
n 'ii|
12

13

14 a
15

19 11

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THE COURT: The Court heard what the other

witnesses sa id .

THE WITNESS: That's r ig h t .

Mrs. Evans, when Mr. Bradshaw node the evaluation of the 

15 elementary teachers, you were one o f the teachers 

retained , were you not?

Yes, I was.

And Mr. Bradshaw a lso  stated that when he made the

evaluation that he was not going to evaluate the teachers 

in reference to their grades or subjects that they 

taught but in reference to their o ve ra ll a b i l i t y ,  is  

that not true, that he would evaluate in reference to 

their o ve ra ll teaching a b ility ?

W ell, yes, I an sure— I hope he d id .

And i f  you were retained In the evaluation , how la i t

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r al  B u il d in g  
EL D o r a d o  A r k a n s a s  7 i 7 » o H i

I



Evan* * Cross 283

1 r||
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that you could o« damaged by being on the T it le  I  

pay ro ll for i f  in face funds were not av a ila b le  you were 

s t i l l  evaluated as one o f the top ten teachers?

In the evaluation that was done at Tucker School, 1 was 

rated No. 1. I  f e l l  to No. 9. One teacher with less  

teaching experience than I  had, a n o n -c e rt if ie d , was 

rated over me.

W ell, le t  sae ju s t  ask you, though,—

Rating doesn 't mean anything, I  guess.

— regard less of where Mr. Edwards ranked you in his 

evaluation, you were retained by Mr. Bradshaw on his 

evaluation?

Yes, I was retained .

And Mr. Bradshaw made his evaluation on the basis  o f  

your o v e ra ll a b i l i t y ,  not the fac t that you wore a 

Remedial Reading teacher, and since you were retained  

in the evaluation , how are you damaged?

How am I damaged?

By the fact that you are under the T it le  I  payroll?

Ml. KAPLAN: Your Honor, I  think th is is  a

conclusion fo r the Court and not th is w itness.

THE COURT: The Court has been Crying to find

that out, too, Mr. Kaplan, and would hope that 

sooner or la te r  something w i l l  come out.

NR. KAPLAN: Your Honor, th is witness has already

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 i t » o



Evans -  Cross

te s t i f ie d  that yesterday was the f i r s t  time she 

was ever to ld  that i f  T it le  1 finds were not 

a v a ila b le , then she would be placed on Minimum 

Foundation, and she lias already te s t i f ie d  here this  

morning that she was told  by Mr. Bradshaw that i f  

T it le  I  funds were unavailab le , then she would not 

be placed on Minimum Foundation, and that yesterday 

was the f i r s t  tine she was ever to ld  anything to 

the contrary.

THE COURT: W ell, the Court hasn 't hoard her

te s t i fy  to that, Mr, Kaplan,

Ml. KAPLAN: W ell, begging the Court's pardon, I

be lieve  that is  what she did te s t i fy .

THE COURT: W ell, the Court d id n 't  hear i t

that way, and i f  you want to in terrogate her

about i t ,  you may do so. The Court hasn 't  

heard any such rsauries made by Mr. Bradshaw 

coming from th is w itness.

Do you have any further questions, Mr,

Starling?

Ml. STARLING: 1 be lieve  th a t 's  a l l  r igh t  now,

Your Honor.

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



265

/ ... ■ j

E v a n s  - R e d i r e c t

REDIRECT EXAMTMA^Yfttl

2 BY Ml. KAPLAN:

3 Q. Mrs. Evans, did you have a conversation with Mr. Bradshaw

4 about what would happen as an Instructress i f  T it le  I

5 funds were not available?

6 A Yes, I d id .;l

7 !| Q. When was that?

8i A That was conference that I  had with him in the o ff ic e  

9 ij at Tucker-RosenwaId School.

10 i| a

11 A.

12 \ 0.

13

14

15

16

17 ||

18 

19

A

a

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21 || 

22

24

Was Mr. Edwards present?

No, Mr. Edwards was not present at that weeting.

A l l  r ig h t . What did he t e l l  you,—

He was in the bu ild ing  but not in  the o f f ic e .

What did you say and what did he say?

F ir s t ,  I talked with him about teachers' grievances 

a fte r  he was over to the workshop and a l l  teachers had 

refused to work for two weeks or aare? no one was 

working, ju s t  coning to work, and I  to ld  h ia—

THE COURT: What year was th is , Mrs. Evans?

THE WITNESS: '6 * - '6 9 .

THE COURT: Pardon?

THE WITNESS: *68-'69.

THE COURT: In March, *69?

THE WITNESS: Yes, March, *68-'69. March o f '69.

Il

25 Yes.

GLENN H PERRIN
Of f i c i a l  C o u r t  Rp o r u h  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 1 7 , 0

'

____________ I



" tvans -  R ed irect" 26b

1 ! a

4 A.

6 i ajj

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21 . a

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A l l  r ig h t . Now, what was said  about your p^ i c < m t oa 

T it le  I  and the u n av a ila b ility — the p o s s ib il it y  o f the 

u n av a ila b ility  o f funds?

W ell, i f  i t  was cut o f f ,  I cou ldn 't return to my c la s s ­

room as a regu lar classroom teacher.

Who said  that?

The Superintendent, Hr. Bradshaw.

Did he t e l l  you that d irectly?

Yes.
I

And what did you say to that?

W ell, I thought i t  was a l i t t l e  u n ju st, and I  begged
|

for him to consider me as such because of my teaching 

experience and the work that I  had done at Tucker- 

Rosenwald School.

Now, in your job  as Health Coordinator, I  would lik e  to  

place that a l i t t l e  b it  more c le a r ly  in perspective to 

the to ta l school program. Were you requ ired , in your 

capacity as Health Coordinator, to sign  various items
:I

for the school system?

Yes.

What kinds of things?

I signed forma to be sent in  to T it le  I  fo r services
j

that they had received from med ic a l and fo r g lasses and 

what have you lik e  that.
I.

Would these forms have to go to the Superintendent's

GLENN H PERRIN 
O f f i c i a l .  Count R eporter 

F e d e r a l  B u i l d i n g  

EL Dorado . A rk ansas  7t7so



£.v j u i s  -  aeaurect ' zo/
!

1 O ffic e ?

2 A. Y es .

3 a Nov, m s  th ere  e  te s t in g  program  th at the sch oo l system

4 had?

!
5 ; A. W e l l ,  they brough t in  the C a l i fo r n ia  Achievement Test

6 and i t  was adm in istered  by am to  the whole sch oo l a t

7 Tucker.

8 a As H ealth  C oord inator?

9 A. No, that was f o r  Residing.

10 a No, I  am ta lk in g  about h e a lth  t e s t in g .

11 A. Oh, y e s , we had to  t e s t  them every  yea r fo r  eyes and

12 h e a r in g , v i s io n .

13 a Nov, would you re c e iv e  n o t ic e  o f  th is  from the

14 a d m in is tra t io n  as  to  when th is  had to  be dame?

15 A. They would send a machine over and s a id  who sen t i t  and

IS th at was i t .

17 a A l l  r i g h t .  And i t  would be sen t to  you?

18 A. Y es .

19 a A l l  r i g h t .  And was that d u rin g  Mr. Bradshaw ’ s tenure

20 as w e l l - -

21 A. Yes.

22 a - - a s  Superintendent?

23 A. Y es . I  d id  i t  the l a s t  year I  was th e re .

24 a Did the b la c k  teach ers  a t  Tucker-Rosenwald ever have any

25 caum m lcatian  w ith  the w h ite  teach ers  a t  the F lu e  Bayou

GLENN H PERRIN 
O f f i c i a l  C o u r t  R k p o r t k r  

F k d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n r a *  7 i 7 s e



£.v«mt> - Keaxrect ---  --
_  11---------------------------------------- --------------
ij School before the unification?
2 a . We had one workshop

3 | ft When was that?

23b

4 A.

9 jlI
7!

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9 a

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12 jl

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1

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— ** far as I  know. That was the suaner, August, I  

believe  I t  was, Dr. Weatherford from Arkadelphie cams 

up from Atex.

And was that the summer r igh t  before un ification?

Yes.

Now, before that one meeting at which black and white 

teachers were present, In your 28 years o f tenure with  

this D is t r ic t ,  was there ever any smthod or way o f  

communicating with the white teachers?

Mr. Anderson started  to having meetings with a l l  of the 

facu lty  from Tucker and from Wright, or from Plum Bayou, 

meeting, but i t  d id n 't  work out, i t  was ju s t  thrown out 

of the window.

How many meetings did you have?

I remember attending two.

A ll  r ig h t . Did you ever have occasion or the opportunity 

then to find out what programs were a v a ila b le  at the 

Wright School or what teachers, rather, were being paid 

for what function?

State that again , p lease.

Did you ever have an opportunity to find  out i f  Mrs.

Keith was being paid for Health Coordinator?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R o o m  a n  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 * 0



fclvans - R e d i r e c t 289

X | A.

2 a
6 A

4 i
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i
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6 a
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)  8 a
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1
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12
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17 a
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> ”
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22

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25 A.

vv\

Yes, I  d id.

When?

The le s t  year Chet I  wee e t  Tucker-koscnw eld  S ch oo l.

Did you ever have an oppo rtu n ity  to  b e fo re  then?

No, I  d id n 't .

How d id  you f in d  out?

Through the C oord in ato r fo r  T i t l e  I .

From the State?

S ta te  D epartaen t.

A l l  r i g h t .  You spoke not too  long ago about your 

s a la r y  as the T i t l e  I  teach er cad mentioned th a t  you 

d id  not r e c e iv e  a bonus. Would you t e l l  us wha£ th at  

means?

The bon us, as I  un derstand , i s  f e r  teach ers  th a t e re  on 

Minimum Foundation . I f  th e re  i s  any money l e f t  in  th a t  

p a r t i c u la r - - i n  t h a t - -

Fund?

•• fu n d , i t  w i l l  have to  be d is t r ib u t e d  e q u a lly  among 

the teach ers  th a t  a re  on Minimum Foundation .

A l l  r i g h t .  So th a t—•

I t  cannot be re tu rn ed  to  the S ta te  Departm ent, I  under-  

s tand .

No budgeted Minimum Foundation money i s  l e f t ,  i s  th at  

r i g h t ,  i t  e l l  i s  expended?

That i s  what I  understand , to  my know ledge.

GLENN H. PERRIN 
Of f ic ia l  Co u r t  R p o k t r  

Federal Bu ild in o  
EL Do rad o . A r k an sa s  t it s o

_______________________________________________________________l



fcvans -  Keairect

2 ;|

3 A

4 a

5 II
A.

6 a

7
ij

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9 !|

10
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11 A.
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J L

And i f  there is  moaey l e f t ,  teacneru get a bonus at the 

end of the year, is that correct?

The ones that are not on T it le  I .

A l l  r igh t*

Yes*

Have you ever received any kind of a bonus at the end 

of the year?

I received one when I was on Minimum Foundation and 

$62.67 fo r September to January o f *6 6 -'6 7 ,—

A l l  r ig h t .

and Mrs. A rtie  Davis took over the Sixth Grade as a 

substitute  teacher.

A l l  r ig h t . So you received your h a lf year**

Yes.

— as a Minimum Foundation teacher fo r that h a lf  year?

Right.

Since that time, January of 1967t have you ever received  

any bonus at a ll?

No, I  haven 't.

Now, in response to one o f Mr. S ta r lin g 's  questions, you 

said that--and he was ta lk ing about the teacher 

examination proposed by Mr. Bradshaw and asking you about 

— an opinion about something— you said  that a statement 

was made a ft e r .  Would you t e l l  us which statement was 

made a fte r  what?

OLCNN H PERRIN
Official. Co u r t  E p o w  

F id c r a l  Bu ild in g  
Do rad o . A rk an sa s  t i t m

I



£.v«ui» -  n e a i r e c c

M j  * ■
2 I Q,

3 A.

6 ft

8 ft

9 || A.

10 n

11 il A

12
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ft

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BY

19
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23 ft

24, A

25 ft

After we were called “Nigger* teacherfi­
fth -huh.

— and that a l l  “N igger" teachers would not be hired  

over there, he decided he would give a test to see who
I

would not be.
i

So i t  was a f t e r —

That was my understanding.

It  was a fte r  those remarks—

Yes.

--th a t  the teachers then remarks were made?

Yes.

I see.

That would be one o f h is c r it e r ia  or one o f his ways of 

elim ination o f teachers.

®  • KAPLAN; Thank you, Mrs. Evans •

MR. STARLING:

Mrs. Evans, in your conference with Mr. Bradshaw, what 

did Mr. Bradshaw say in reference to i f  funds become 

unavailable?

What did he say? 

T it le  I funds, yes.

I

Whether or not I would be reta ined—

Yes.

GLENN H. PERRIN 
O f f ic ia l  Cou nt  R eporter 

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--as a classroom teacher? He said, "No".
He just seta—

Wouldn’t have to be, because I asked would seniority
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Kean anything, I had bean there 28 years,—
Did he say—

— he said, "No".

Did he say that there is a possibility that if Title I 

funds became unavailable, that you night not be retained i 

as a classroom teacher?
10 j: *• Yes.
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He said there ia a possibility of it?
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i jl He said 1 would not be, could not be retained, no.

13 a He said you could not?
14 A.| 1 might not go back to the classroom*
15 a You might not?
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Ii k.i 1 asked the question if I could go back to the classroom j
17 i if Title I money was cut off,—
18 a Did he say-- |
19 IL —  if it was not available.

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20 a Did he say "you cannot" or did he say -you might not*?
21 A. He said, "No, it doesn't mean that you wsuld go back to
22 the classroom bacause of seniority, it muims nothing**
23 1 ft Well, what I am— I guess I am trying to gat at, did fee
24 say, in essence, that if Title I funds w ere unavailable,

556 that you would not be allowed to be a classroom toookor
GLENN H PERRIN  * A A

O f f ic ia l  C o u r t  R t 'o ir r E i  
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1 j any more?

2 A Yes, I wouldn't nave any jo b ,

3 Q. Okay. I s n 't  I t  a true fact that in his evaluation  he

4 ranked you No. 9 and you were in fact retained?
Ii

3|j A. A fter th is meeting, yes.
i|

6 a  And i t *8 a lso  true that he ranked you or evaluated you

7 on the basis of your o ve ra ll a b i l i t y  and not the fact  

that you were a Remedial Reading teacher, correct?

9 a. W ell, I don 't understand your question.

10 a  W ell, you answered awhile ago when I  cross-examined

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I don't understand what you--what you are try ing t o - - I - «  

state  your question again , p lease .

W ell, I asked you the question awhile ago, when Mr. 

Bradshaw evaluated you, he evaluated you in reference to  

a l l  the teachers in reference to their o ve ra ll a b i l i t y .

I  was in hopes that he would.

Then I f  he retained you in h is evaluation , then 

obviously your o v e ra ll a b i l i t y  aa a teacher is  better  

than a l l  o f the ones that he did not re ta in , and, 

therefore , you would be ab le  to teach in the classroom  

in the event T it le  I  funds became unavailable?

MR. KAPLAN: Your Honor, again , counsel is  arguing

with th is  witness end asking for conclusions of 

this witness bsssd on what somebody e lse  may think.

GLENN H. PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

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THE COURT: Well, X don't aaaw why you wjLii to

keep going over it, Mr. Sterling.

MR. STARLING: A l l  r ig h t , s i r .

THE COURT: She hes to ld  about i t ,  end so have

you, and on end on. It  seems lik e  to me the 

question on the pert o f both of you is  moot 

so fa r  because two years have passed.

MR. STARLING: A l l  r ig h t , s i r .

Two other th ings, Mrs. Evens. You say that you loomed 

that Mrs. Keith was a Health Coordinator in March of

1969?

Pardon?

D idn 't you say that you learned that Mrs. Keith was the 

Health Coordinator under the T it le  I funds?

Yes, through the State Department, from the T it le  1 

Coordinator.

A fter you learned that, did you ask Mr. Bradshaw to let 
you be compared with Mrs. Keith?

No, 1 d id n 't  ask Mr. Bradshaw.

Do you know whether or not any o f the white teachers 

under the T it le  I  fund received a bonus that the teachers 

on the regu lar p ay ro ll received?

Do I know what? State that again .

Do you know whether or not any o f the white teachers 

under the T it le  I  p ay ro ll received the benus which yea

GLENN H PERRIN
O f f i c i a l  C o u r t  R ep o r t er  

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testified about that the teachers oe the regu la r pay ro ll 

received?

I f  you understood me, I d id n 't  say that T it le  I  people 

received a bonus.

W ell, I know that. The regu lar pay ro ll people received  

the bonus.

Yes, they d id , under M inim a Foundation, they d id .

Do you know whether or not any o f the white teachers 

who were under the T it le  I  program received that bonus, 

also?

I don 't have any knowledge of that. I  have never seen 

any records or f i l e s  or anything.

THE COURT: Stand aside .

(Witness excused.)

MR. KAPLAN: Mrs. Tta

10IS THOMAS.

ca lled  as a witness on behalf o f the p la in t i f f s ,  being f i r s t  

duly sworn, t e s t i f ie d  as fo llow s:

DIRECT EXAMINATION

BY MR. KAPLAN:

O Mrs. Thomas, t e l l  us your f u l l  name and address, p lease. 

A My name is  Lois Thomas and I  l iv e  at 616 North Magnolia,



2%

1\ Q. Mrs. Thomas, are you che w ife  of the gentleman who

2 te s t i f ie d  here yesterday, Mr. Asive Thomas?

3 A. Yes, I am.
)|

4 I a  Hrs« Thomas, have you ever held a position  in  the Tucker-
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Rosenwald School D is t r ic t— I am so rry— in the Plum Bayou-
i l

6|j Tucker School D istr ic t?

7 a . Yes, I  have, I  taught there fa r  f iv e  years.

8 a  A l l  r ig h t . Where did you receive  your education, Mrs.

X. Thomas -  D irect

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Thomas?

W ell, I fin ished  my elementary and high school at  

Rosenwald School at Tucker. 1 have a 3 .S . Degree in 

elementary education from AMttl C ollege, Pine B lu f f .

Are you a lso  c e r t if ie d  to teach in  public schools in the i 

State of Arkansas?
|

Yes, I  am.

And what kind of c e r t if ic a t io n  do you hold?
i

I  have elementary c e r t i f ic a te .

When did you f i r s t  begin teaching at the Tucker-Bosenwald

School?
j

I  began teaching there the year 1964.
I

For school year '64-*65?

Yes, I  d id .
I

And was that r igh t a fte r  your graduation?

Yes, i t  was.

And did you teach— that was the f i r s t  position  you

Q L IN N  H P E R R IN  
Of f ic ia l  Co u rt  Reporter 

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held

Yes.

— as a graduate teacher?

Yes, i t  was.

And did you continue to teach in  the ThckarHRosenweld 

School D is t r ic t  for soma period o f time a fte r  that?

Yes, I  d id .

Was i t  always at the Tucker-ftosanwaId School that you 

taught?

W ell, yes, other than teaching Head S ta rt , i t  was.

I  see. What grade did you f i r s t  begin teaching?

I  f i r s t  begin teaching Third Grade, I  taught there for
i

two years.

And then what grade did you teach?
i

W ell, I  was moved to the F ir s t  Grade to , I  was to ld , to  

strengthen the elementary department.

Who to ld  you that?

My P rin c ip a l, Mr. Edwards.
|

And what year was that in?

Oh, that was the year 1966-'67, I  b e lieve .
I

A l l  r ig h t . That f i r s t  year, 196b-'67, i t ' s  been 

te s t i f ie d  was a lso  fo r some short period o f time Mr. 

Bradshaws f i r s t  year as Superintendent. Did he ever 

come into your classroom during that year?

No, he d id n 't .

GLENN H PERRIN  
Of f i c i a l  C o u r t  R rportkr  

F k d c ra l  B u il d in g  
EL Do r a d o . A r k a n s a s  t i 7 so



ijl q. The next year, 1967-'68, did he ever coaie into your
||

2 |i classroom?|| .  j
3  a  No, he d id n 't .

i j
4i a  During the en tire  yeer?

5j| A. No, he d id n 't .

6 Q. Are you sure of that?

7 |j A. Yes , I  am.

- l . ' xnomas -~Dixw?t— ~ ~  ~ | 29H

s j a  A l l  r ig h t . Did Mr. Edwards evar come into your c la s s -  

9 J room?

A Yes, he did .

n a  And did he ever engage in any kind of evaluation with

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you during that year?

Yes, he d id .

Did he discuss i t  with you?

Yes, he d id . j

And did he give you anything in  writing?

W ell, no, not in w rit in g . He had notes that he, you
I

know, when he c a lled  me into the o f f ic e ,  that he 

discussed with me.

Did he, in  any adverse way, was ha c r i t ic a l  o f your
I

performance as a classroom teacher in the F ir s t  Grade 

at that school?

W ell, not r e a l ly .  He gave me som e--well, he had a few 

c rit ic ism s, but net very many, no.

I  see. What kind of things did he say to you, do you

GLENN H. PERRIN  
Of f ic ia l  Co u rt  R efowtrR 

P kdkral Bu ild in g  
EL Do rad o . A r k an sa s  t it s o



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remember?

A. W e l l ,  I  can remember one, chat was discussing my

b u l le t in  b o a rd , I  b e l ie v e ,  and he to ld  me th a t  1 shou ld  

p ro bab ly  be a l i t t l e  mere o o n c re te , you know, on u s in g  

m a te r ia ls  fo r  my b u l l e t in  bo a rd .

Q. And d id  you accept h is suggestions —

A. Yes, I  d id .

Q. --and a lte r  the method that you had bean using?

A. Y es , I  d id .

Q. A l l  r ig h t . During the year 1968-*69, was that your 

la s t  year in the D is t r ic t ,  Mrs. Thomas?

A. Y es , i t  w as.

a  A l l  r i g h t .  How many tim es or d id  Mr. Bradshaw ever c o m  

in to  your c lassroom  th a t  year?

A. W e l l ,  I  can remember on ly  tw ice  th at he came in  to

o b se rv e , but he came through once, I  th in k , d u rin g  the  

Christm as Season to  d e l iv e r  a  bonus th at the teach ers  

had g o tten .

Q. How much was th a t  bonus?

A. W e l l ,  I  c a n 't  remember now, bu t i t  was between seven ty -  

f iv e  and a hundred d o l l a r s ,  I  g u e s s , I  c a n 't  remember 

the exact amount.
i

Q. A l l  r i g h t .  Now, th a t would be one tim e, and you say  

th at there  a re  a t  le a s t  two o ther tim es th a t  he casw

in?

GLENN H PERRIN
Of f ic ia l  Co u rt  R eporter

Federal Bu ild in g  
EL Do rad o . A rk an sa s  717*0



L. Tnooas -  Direct 300

1 A. Yes, that he did come in .

2 a  A l l  r ig h t . How long did he stay then?

3 a. W e ll, the f i r s t  tine  he cane in , I  guess he stayed fo r

4 about 15 n inutes.

5 i a  Did you give hin a lesson plan?
j

6 A No, I  d idn ’ t g ive  hin one, he d id n 't  ask.

7 ! a  Did he ever ta lk  to you e ith er before or a fte r  the c lass

8 about h is v is it?

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No, he d id n 't .

The second tine that he cane, can you renenber approxi­

mately when i t  was?

Yes, i t  was during the spring o f '69, I  guess around 

March or A p r i l .

How long did ha stay at that tine?

W ell, between 15 and 20 minutes.

Did he ever ta lk  to you a t a l l  about anything that he 

had observed in  the classroom?

No, he d id n 't .

Did he ever ask you fo r any lesson plan or tests or

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anything lik e  that?

No—w e ll ,  he asked fo r a book that I  was using.

What book was that?

He wanted to see the Reading Economy book that we were

using, and he wanted to see i t .

Were you, in  your c la s s , using the Economy Series?

OUENN H. PKRRIN
Of f ic ia l  Co u rt  R v o r m  

P cdkral Bu ild in g  
XL Do rad o . A rk ansas  t i 7*o



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mamas - uXXSCC

Yes, I was.

Were you using any other supplementary awaterial?

Not on—no, I w asn 't.

Did e ither Mr, Bradshaw or Mr, Edwards ever discuss with  

you any d isc ip lin a ry  problem  in your classroom?

No, they haven 't.

In your evaluation , Mrs. Thomas, as a classroom teacher, 

did you have a d isc ip lin e  problem in your classroom?

No, I  d id n 't .
i

Did you attend a workshop at the Pitas Bayou-Tucker School 

D is t r ic t  at the Tucker-Roseawald School concerning

un ification?

Yes, I  d id .

Now, was the workshop i t s e l f  about un ification?

No, i t  w asn 't.

Was Mr. Bradshaw present?

Yes, he was.

Approximately when, to the best o f your re co lle c t io n ,  

did th is take place?

W ell, i t  was in  the spring o f *69, I  can 't remember the j 

month r igh t now, but i t  was—

Who was present?

A l l  of the teachers at the Tucker-RoeearnsId School and 

Mr. Bradshaw.

Can you t e l l  us what was sa id  by the var io u s— to the_______

GLENN H PERRIN  
Of f ic ia l  Co u nt  R votrm i  

Federal Bu ild in o  
EL Do rad o . A rkansan  7i7*o



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best of your recollection, by the various participles 
in those two--in that meeting?

A. W ell, a fte r  Mrs* Kidd had fin ished  her workshop, w e ll,  

we discussed—w e ll,  th is is  when he to ld  us that we 

would be un ified  end that a l l  o f the teachers would not 

be needed. He did say—w e ll ,  someone did ask him, you 

know, i f  a l l  o f tha black teachers at Rosenwald would be 

used, and he said  that he would not get r id  of one of 

his white teachers to h ire  a "N igger" teacher.

jj <1 N - i -g -g -e - r?
11
j| A. That's r ig h t , yes.
i|

;j a  Did you hear him say that?

A. Yes, I d id .

& What e lse  was said  by tha various partic ipants in that 

meeting?

A. W ell, one o f the teachers asked him i f  he said  "Iligger".

W ell, he denied i t  that he did say i t .  

a  Who was that teachar who asked him?

A. Mrs. Thomas, Dora Thomas.

Q. la she re la ted  to you?

A No, she 's not.

a  A l l  r ig h t . What a lse  was said?

A W ell, we went on and we wanted to know seme of the

c r it e r ia  and he asked us to make a l i s t  o f some of the

c r it e r ia  that we thought that ha should use

GLENN H PERRIN 
O f f ic ia l  Co u rt  R eporter 

F ederal Bu ild ing  
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And did you? Did the teachers do that?

Yes, we d id , we turned i t  in to Hr. Edwards. I don't 

know i f  he picked i t  up or not, I  don 't know.

A l l  r ig h t . Were you present et another meeting at which 

teachers were present at which u n ifica tion  was discussed? 

Yes, at the Plum Bayou School.

In the Wright community?

Yes, i t  was one night at a Board meeting.

Were there any white people there?

W ell, the Board members were.

Were there any other white people there?

No, there wasn' t .

And do you remember approximately when that was in  

re la t io n  to the meeting you Just to ld  us about?

W ell, i t  was a fte r  th is meeting, in the same y ea r ,—

A l l  r ig h t .

—  '69.

T e ll us what was said at that time.

W ell, when we walked in , 1 think they were r e a l ly  

surprised to see us, because as we walked in they ju st  

stopped ta lk ing  and looked, and we came in and sat 

down, and then the discussion went on, and Mr. Tony 

asked what would happen to the black teachers at 

Rosenwald.

What was said?

GLENN H PERRIN
Of f i c i a l  C o u r t  R ep o r t er  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 1 7 * 0



uxrect-■mamas - 304
W ell, he said —

Who is  "he*?

Mr. Bradshaw.

Uh-huh.

--made che stateswnt chat none of the white teachers 

would be re leased  to h ire  a "N igger* teacher, and th a t 's  

when Mr. Tony ca lled  his hand and said  that we don 't  

use that term any more.

Anything e lse  said?

W ell, no, not very much, because th a t 's  when— they 

dismissed the meeting and we were a l l  gone, l e f t .
I

Did Mr. Archer say anything at that time?
|

I  don 't remember. 1 can 't remember righ t now.

In addition to your regu lar classroom duties , you spoke 

about Head S ta rt. Would you t e l l  us when you began in  

that program and how you actu a lly  secured your employ­

ment in that program?

W ell, I began teaching Head S tart the second year that 

I started teaching school at Tucker, and I — Nr. Edwards 

recommended me to th is jo b .
|

Did you teach i t  continuously as long as you were in
I

the D istr ic t?
I

No, I  d id n 't .  I  taught i t  fo r two years stra igh t and 

then I think Mrs. Evans taught i t  fo r a year and then 

I  taught i t  the next year.

GLENN H PERRIN
Of f ic ia l  Co u rt  R epo r im  

Federal Bu ilo in o  
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Was Chat your iasc year?
IThat was my lasc  year, yes*

Did you teach the suaner a fte r  your contract was not
i

renewed?

Yes, I was— yes, I  d id .

What age children  were you dealing with?
I

W ell, s ix -y e a r -o ld  ch ildren , f iv e -y e a r -o ld , sons*

Were they ju s t  about ready to go to the F ir s t  Grade?

Ready to go to the F irs t  Grade, yes.

Was that a program that was operated Jo in tly  by O.E.O. 

and the School D istr ic t? I

Yes, it was.

A fter your employment, Mrs. Thomea, a fte r  your c o n t r a c t -  

w e ll,  l e t 's  back up fo r Just a moment. In that la s t  

year, was your contract renewed, '63-*69?

No.

Was i t  renewed fo r '69-'70?

No, i t  w asn 't. No.

How did you discover that your contract was not going 

to be renewed?

Mr. Bradshaw ca lled  me into the o f f ic e  and—

Whose o ff ic e  did he c a l l  you in?

Mr„ Edwards' o f f ic e ,  and he a lso  ca lled  Mr. Edwards in  

on che conversation, and he to ld  ns that according to  

the c r it e r ia  that he had and according to the way he had

GLENN H. PERRIN
O f f ic ia l  Co u rt  R eporter 

F ederal Bu ild in g  
EL Do rad o . A rkaneae  t it e o

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rated the teachers, that &oa& o f the other teachers. ^*4 

rated higher than I d id , and he to ld  me that he was 

sorry that 1 was one o f the ones he was going to hove to 

le t  go, and that is  when I to ld  him that 1 had expected 

th is decision  from him. I  to ld  him that 1 w asn 't a t a l l  

su rprised , you know, to hear him say th is .

Was anything e lse  said?

No, i t  w asn 't.

Why did you t e l l  him that you were not surprised?

W ell, r e a l ly ,  I  guess, because the year before  that he 

had le t  my husband go, and fo r  some reason I  thought, 

you know, that th is was one o f tho reasons that he was 

going to le t  me go. I  ju s t  hed th is  fe e lin g , I  don 't  

know why, no one hed to ld  me th is .

At the time that he spoke to you about tho ra tin g  and 

that some of the other teachers had ratad higher eham 

you, did you eve r--d id  ha show you a copy o f tho 

rating?
j

No, he d id n 't .
I

Or the evaluation?

No, he d id n 't .

Did he show you anything?
I

No.

A fter your employment was concluded at the Plum Bayou- 

Tucker School D is t r ic t ,  did you look and soek other

G LENN H PERR IN
Of f ic ia l  Co u rt  R v o r m  

F i m r a l  Bu ild ing  
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employment?

Yes, I d id .

Where?

I  tried  « t  Townsend, Perk, Pine B lu ff  School D is t r ic t ,

I  tr ied  at Wabbeseke, S tu ttgart, England, a l l  places 

around.

When you say you t r ie d , did you actu a lly  put in  

applications?

Yes, I  d id . And I  talked to the P rinc ipa ls  at England, 

there were some positions open, but a fte r  the 

Superintendent found I  had f i le d  a su it  against Plum 

Bayou, the P rin c ipa l to ld  as that the Superintendent 

to ld  him that he cou ldn 't h ire  as because I  had a su it  

in against the D is t r ic t .

Did you actu a lly  get any kind o f employment?

W ell, not u n t il November of that year.

And was your employment in teaching?

No, i t  w asn 't.

What was it in?

I am working as a N utrition  Aid fo r the Extension 

Service.

Is that for the Arkansas-*

Yes, i t  i s .

--Extension Service?

Yes, i t  i s .

OLENN H. PERRIN
Of f ic ia l  Co u rt  R rportsr 

F kdcral Bu ilo in o  
EL. Do rad o . A rk an sa s  t it s o



i.. rnomas - Direct 306

11| C, Are you s t i l l  employed in chat capacity?

2 A Yes, 1 am.

3 Q. Do you s t i l l  hold c e rt ifica tio n ?

4 A Yes, I do,

5 jj  a  Does that job pay as touch as teaching?

61! A Oh, no. No.

7 i! a  But you s t i l l  want to be employed as a teacher? 

8| a  Yes, I  would.

10

Ml. KAPLAN: That’ s a l l .

ii CROSS EXAMINATION

BY MR. STARLING:

Q. Mrs. Thomas, you t e s t i f ie d  that Mr. Bradshaw, during the 

year8--th e  en tire  years 1966-'67, '6 7 -'6 8 , newer came 

into your classroom, is  that correct?  

a  That's true.

a  Were you present yesterday when Mr. Edwards te stified ?  

a  Yes, I  was present.

a  Do you r e c a l l  that Mr. Edwards t e s t i f ie d  that Mr. 

Bradshaw would make tr ip s  around to the classrooms?

2 1  | j A He probably went to the other classroosis, but he d id n 't  

come to my classroom.

a  Why do you reckon he d id n 't  came to your classroom?

A I  don 't know.

a  Did you ever see him go to any other classroom?

GLENN H PERRIN  
Of f ic ia l  Co u nt  Rp o k t o i  

Federal Bu ild in o  
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J». No, I  d idr**t , not or* c h e  a id *  w aere we w ere .

a In the m eeting Chet you had, Mr. Bradshaw suggested  that  

the Negro teach ers  come up w ith  some o f the c r i t e r i a  

which would be used fo r  the e v a lu a t io n  fans?

A. Yes.

O And the N egro  teach ers  d id  c o m  up w ith  sons o f  the  

c r i t e r i a ,  i s  th a t co rrec t?

A. Y es , we d id .

a  Did Mr. Bradshaw recommend to  you or to  a l l  o f  the Negro j 

teach ers  th a t  i t  was h is  id ea  th a t  the f a i r e s t  way to  

do th is  th in g  was to  g iv e  a com p lete ly  o b je c t iv e  t e s t ,  

one based  upon a N a t io n a l T e s t in g  S e rv ic e , who would  

adm in iste r and grade  the te st?

a. Y es , he to ld  us th a t  he had planned to  g iv e  the M i l l e r 's  

Analogy T e s t ,  y e s .

a  And whet d id  the Negro  teach ers  do when he made chat 

recommendation?

A. W e ll ,  we to ld  him th at we d id n ’ t  th in k  th a t  t h is  was a 

f a i r  way t o ,  you know, to  s e le c t  te a c h e rs .

Q. Why?

A. W e ll ,  we d o n 't  f e e l  th at you can s e le c t  a teach er through! 

a s tan d a rd ised  t e s t  o f  th is  k in d .
|

a  In  o th er w o rd s , you f e e l  th a t  th e re  a re  a b s t r a c t

q u a l i t i e s  in  a  teach er which need to  be judged  based  

on c lassroom  perform ance?

GLENN H PERRIN  
Of f ic ia l  Co u r t  Reporter 

Federal. Bu ild in g  
EL Do rad o . A rk an sas  7 it s ©



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That's tru e ; th a t 's  true.

Do you think that— did Mr. Bradshaw, in fa c t , give th is  

objective  test a fte r  the Negro teachers had objected to 

it?

No, he d id n 't . A fte r—v e i l ,  a fte r  ve had scheduled a 

meeting with the County Superintendent, ve talked with  

the County Superintendent about th is te s t .

Did you t e l l  him you d idn 't  vent that kind o f a teat?

Yes, we did.

THE COURT: What was the teat?

THE WITNESS: M i l le r 's  Analogy Test*

THE COURT: M i l le r 's  Analogy Test?

THE WITNESS: That's true.

And I be lieve  a l l  o f the Negro teachers went to the 

County Superintendent's O ffice?

Yes, we d id .

And Mr. Bradshaw did not give that te s t , is  that correct?  

No, he d id n 't .

Do you know why he d id n 't  give it?

No, I don’t .

Instead, he gave or made up an evaluation test based

22
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upon some o f the c r it e r ia  which the Negro teachers had 

suggested, is  that correct?

W ell, some of them, yes, but one he d id n 't ,  and that 

was "Teacher Tenure".

GLENN H PERRIN
Of f ic ia l  Co u rt  R eporter 

F ederal Bu ild in g  
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a Mrs. Thomas, you stated that Mr. Evans said that— excuse 

me, I am so rry— you stated that Hr. Bradshaw stated in 

th is teacher workshop that he would not get r id  of a 

white teacher fo r a "N igger* teacher, Is  that correct?

A. That' s tru e , yes •

a  Do you know a fte r  the evaluation fo ra , or do you taow 

now once the evaluation was aade, who were the teachers 

that were retained and who were the teachers that were 

dismissed?

A. Yes, I think so, yes.

a  Let me show you an enlargement of that evaluation , 

show you the ranking of the teachers. No. 1 teacher 

ranked was Mrs. B la ir ;  No. 2 was Janet Dye; No. 3 was 

Robbie Keith; No. 4 was Mr. Edwards; No. 5 was Mrs. 

Moore; No. 6 was Mrs. W i l l i s ;  No. 7 was Mrs. Rosen;

No. 8, Mrs. Davis; No. 9, Mrs. Evans; No. 10, Mrs.

C lark. Those were the ten teachers in the order of 

their ranking that were reta ined . And the f iv e  teachers 

that were not reta ined : No. 11, Mrs. Ramsey; No. 12,

Mrs. Gordon; No. 13, Mrs. Thomas; No. 14, Mrs. Dora 

Thomas; No. 15, Mrs. Armenia Kidd.

Now, is  i t  not true that— is  Mrs. Ramsey a white person 

on a black person?

A. She's white.

0. Then somewhere in th is group o f peop le , whether i t  be

GLENN H PERRIN
Of f ic ia l  Court R v o R m  

F kdkmal Bu ild ing  
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black or white caanot be cold— Mrs. Raajsey, a whitw 
teacher, was in fact not reta ined , is  that correct?  

W ell, lik e  was stated be fo re , I  had heard that ttrs. 

Ramsey was leaving in the f i r s t  p lace.

Do you know whether Mr. Bradshaw knew that before he 

made th is evaluation?

I don 't know, but I  am sure he d id .

W ell, you are sure he did?

W ell, if everybody e lse  knew i t ,  I  am sure he knew i t ,

too.

Do you know when Mrs. Ramsey gave Mr. Bradshaw her 

resignation?

No, 1 don 't .

Now, looking at these people, where do you say you 

should have been ranked?

W ell, I cou ldn 't say where I  should have been ranked, 

but I know I  should have been ranked higher the

way he ranked me.

Why?

Why?

Uh-huh.

My P rinc ipa l ranked ms higher than th is . I  think I  

should have been ranked higher than soam o f those— some 

of the others. I  was ranked higher than MTs.—

L e t 's  s ta r t . What about Maxine Clark? Do you fe e l you

GLENN H PERRIN
Of f ic ia l  Co u rt  Reporter 

Pkdkral Bu ild in g  
EL Do rad o . A rk ansas  t «? so

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have better abstract qualities as a te&cher aac more 
qualified?

W ell, I am not going to impersonate anybody, but I  think 

that I — some o f ay a b i l i t ie s  are higher than some of the 

ones that is  on there.

W ell, l e t 's  s ta rt  with them and t e l l  a s .

W ell, I  don 't want to name anyone lik e  that, but I do 

know sons o f those th a t 's  on there that I  rank higher 

than they do.

Mrs. Thomas, you made the a lle ga tio n  that th is School 

D is t r ic t ,  Mr. Bradshaw and th is School D is t r ic t ,  have 

discrim inated against you in th is evaluation .

Yes, they have.

Then was i t  Maxine Clark that you fe e l you were better  

teacher than, o ve ra ll a b ility ?

* .  KAPLAN: Tour Honor, I  think again I  am going

to object to the question as arguing with this  

witness and asking her questions that she can 't  

possib ly  answer without argument, conclusions, 

that are inadm issible.

MR. STARLING: Tour Honor, s me either e along the

lin e  we have got to get to the question in th is  

case, and that is  whether or not Mr. Bradshaw 

discrim inated against th is  woman or not. I f  she 

has a lleged  they d id , then somehow she has got to

GLENN H PERRIN  
Of f ic ia l  Co u rt  R efofte*

F k d c r a l  B u il d in g  
S I- Do r a d o  A r k a n s a s  717SO



1 |j show the abilities and qualities that she caa say
2'i he did discriminate against.

1 THE COURT: W ell, Mr. S ta r lin g , i f  there is

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ju st  d iscrim ination, that is  not included in 

the Issues involved here, got to be ra c ia l  

discrim ination i f  th is  Complaint on th is  

consideration provides fo r any r e l i e f .  The 

record speaks fo r i t s e l f ,  I  don 't think that 

e ither you or she can change that.

Mrs. Thomas, do you know whether Mrs. B la ir  i s  a white

woman, white or black?

I know she 's white.

How about Janet Dye?

She's white.

Robbie Keith?

Yes, she 's white.

Jean Edwards?

He's black.

Juanita Moore?

She's white.

Althea W illis?

She'8 black.

Nancy Rosen?

She'8 white.

A rtie  Davis?

GLENN H. PERRIN
Of f ic ia l  Co u nt  R w o ntcn  

F kdcnal Bu ild ino  
EL Donad o . A r k a w a *  t it n o

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Thomas -  Cross 

She's black.

Lucreasia Evans?

She's black.

Maxine Clark?

She’s black, too.

How many black teachers were retained and how many white 

teachers were retained?

W ell, there is  fiv e  black teachers and s ix  white.

W ell, we only have 10 people, i f  there are f iv e  black  

teachers —

That's r ig h t—wait a minute— fiv e  black and f iv e  white. 

Retained were f iv e  black teachers and fiv e  white 

teachers?
jI

That's true.

And those teachers not retained were one white and four 

black?

Uh-huh.

Do you know whether Mrs. Armenia Kidd is  a p la in t i f f  in 

th is lawsuit?
i
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No, she 's not.

What about Mrs. Dora Thomas?

No.

How about Althea Gordon?
I

Mrs. Gordon is  working.

When Mrs. Ramsey and Mr. Edwards resigned a fte r  the

GLENN H PERRIN 
Of f i c i a l  C o u n t  R nfontkn 

F e d e r a l  B u il d in g
EL DONADO. ANNLANSA* 71730



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evaluation, what happened to the teacher si a t that 

point, do you know?

No, I don’ t .

A l l  r ig h t . F ine, Do you fe e l that there is  any fa i r  

way that Mr. Bradshaw could have evaluated the teachers 

than that which he did?

I don 't know what way he could have. I  aa sure there 

is  a better way that he could have evaluated the 

teachers than what he d id .

MR. STARLING: I be lieve  th a t 's  a l l ,  Your Honor.

THE COURT: You may stand aside .

(Witness excused.)

MR. KAPLAN: Mrs. Woods:

CORINE WOODS.

17

18

ca lled  as a witness on behalf of the p la in t i f f s ,  being f i r s t  

duly sworn, te s t i f ie d  as fo llow s:

19 DIRECT EXAMINATION

20 BY MR

21 !| a

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. KAPLAN:

Mrs. Woods, t e l l  us your nastt and address, p lease. 

I am Corine Woods from Tucker, Arkansas.

Mrs. Woods, would you speak up ju st a l i t t l e  b it?  

Corine Woods, Tucker, Arkansas.

Mrs. Woods, sre  you a p la in t i f f  in th is lawsuit?

GLENN H PERRIN  
Of f ic ia l  Co u rt  R sportkr 

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A (Nods head a ffirm a tiv e ly )

Q. And do you have children in this Plum Bayou-Tucker School 

Distr ict?

A  Yes, I do.

Q. Do they attend the Plum Bayou School?

A Yes, they do.

Q. Mrs. Woods, are you on any committee fo r T it le  I o f the 

Elementary Secondary School Act?

A  Yes, 1 was on the Advisory Committee at one time.

&  Do you know—

A  I never been n o tified  that I wasn 't cm i t .

0- Were you ever ca lled  to a meeting of that committee?

A  Yes.

a  Were you ever shown a budget?

A  No.

a When were you ca lled  to your f i r s t  such meeting and how 

many meetings were you ca lled  to?

A I was called to two. That was righ t a fte r  the unitary 

system.

Q. I am sorry?

A  Right a fte r  the unitary system. I don 't remember the 

month.

a  When were you n o t ifie d , a time, were you n o tified  that 

you were on the T it le  I Committee?

A  it was in 1968-'69, I  b e lieve .

GLENN H. PERRIN  
Of f ic ia l  Co u rt  Reporter 

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The school year?
Yes.

At that time were your children s t i l l  going to the 

Tucker School?

Yes.

I  see. Were you ever consulted in any way about the 

formulation of the T it le  I  plan?

No.

Did you ever know or were you ever told during fchese 

meetings what teachers received what payment fo r  

T it le  I?

No. W e--I never did see figu re s . The only thing, we 

would come in and be seated and the Superintendent, Mr. 

Bradshaw, would read o f f  the amount o f money end how 

much was spent for th is and how much would be spent for 

that.

MR. STARLING: Your Honor, i f  I may, I  am going to

object because 1 be lieve  this testimony Is  

irre levan t and immaterial and there is  nothing 

alleged  in the Complaint whatsoever to the e ffe c t

that there has been any Improper use o f T it le  I  

funds or that Mrs. Woods was denied access to see 

where the T it le  I funds were spent. There is  

nothing whatsoever In the Complaint concerning 

T it le  I funds except one instance which we mutually

GLENN H PERRIN
Of f ic ia l  Co u rt  R eporter 

Federal Bu ild ino  
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settled prior to the lawsuit. I am completely at 

a loss as to what any a llega tion  along th is line 
contains or concerns.

THE COURT: W ell, did you se tt le  the question

of Mrs. Evans?

MR. STARLING: A l l  r ig h t , s i r .

O How inany meetings were you ca lled  to?

A Two.

a  How many other people were at those meetings?

A Four. There was s ix .

Q- Six people? Was that the en tire  committee?

A Yes.

a How many black people and how many white people were on 

that committee?

A I t  was two. S ix of us with exception o f Mr. Bradshaw.

O And two black people and four white people?

A That's r ig h t .

0- Who was the other black person?

A Mrs. L izz ie  Evans, who is  a dishwasher at Plum Bayou, 

and she is  liv in g  in another d is t r ic t ,  

a I see. She liv e s  in another school d is tr ic t?

A Yes.

& Was she at that time liv in g  in another school d is tr ic t?  

A Yes.

Q. When was the la s t  meeting you were ca lled  to?

GLENN H PERRIN
O f f ic ia l  Co u rt  R eporter 

Federal Bu ild ing  
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7 vooar -  D irect ' I 320

ij A. In '68.

2!j 0- Since that time have you e ither been n o tifie d  o f another 

3 meeting or of your no longer serving on the committee?

41 A. No, I haven 't.

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Mrs. Woods, were you present at a meeting in the Wright

6
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community involving parents of the black children?

7i' A. Yes, I was.

8H
:! 0- When was that?

9 A.
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It  was in March o f— prio r to the u n ifica tio n . I
10 i  a And who was present and where was the meeting? 1
11 A. About 50 Negroes, Negro parents. i
12

! a Where was the meeting? iii
13 A. Plum Bayou L ibrary .

14 a A l l  r ig h t . Did you attend more than one meeting over

15 there?

16 A.
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Yes.
I

17 a How many?

18 A.
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Two.
1

19 a Were there any white people-other than the School Board

20 members, were there any white people there?

21 | A. No.

22 1 a The f i r s t  such meeting?

23 A. No.
1,

24 a At the f i r s t  such meeting, were the teachers present?
1

25 j A. Yes, they were.

1! GLENN H PERRIN J 
Of f ic ia l  Co u rt  R eporter /„ 

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a Were they present at the second meeting?

A. No, they w e re n 't .

Q. T e l l  us whet you r e c a l l  happened a t  the f i r s t  m eeting  

f i r s t .

A. At the f i r s t  m eeting—

Q. And who s a id  w hat. Id e n t i fy  everyone.

A Mr. Bradshaw s a id  th at he would not f i r e  w h ite  teachers  

to  h ire  "N ig g e r s " ,  and Mr. Tony c a l le d  h is  hand.
I

a  And what happened? What e ls e  was sa id?
I

A W e l l ,  we got r i l e d  up, and the m eeting was d ism issed , 

a  How soon a f t e r  th at was the second meeting?

A  I  b e l ie v e  i t  was the next month.

Q. Who was p resen t a t  that meeting?

A  Nothing but the paren ts  and the Board members, 

a  Was Mr. Bradshaw p resen t a t  th a t time?

A  Y e s , he w as . i

a  T e l l  us what was sa id  by the v a r io u s  p a r t ic ip a n t s  in  th at  

m eeting.
I

A W e ll ,  i t  was in  that m eeting th a t Mr. A rcher made the  

remark th at he would n o t—

MR. STARLING: Excuse me, I  d id n 't  hear the name.

THE WITNESS: A rch e r. C lyde A rch e r.

a. --m ade the remark th a t  he would not f i r e  a w h ite  teacher  

to h ir e  a "N ig g e r " ,  and M rs. Thomas c a l le d  h is  hand, 

a  Which M rs. Thomas?

GLENN H PERRIN  
O f f i c i a l  C o u r t  R ep o r t er  

F e d e r a l  B u ild in o  
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Mrs. Laura Thocias, Mr. Asive Thomas' mother. She is  not 

present.

I  see. Did you hear that remark?

Yes, I heard i t .

What e lse  did you hear at that meeting? Can you r e c a l l  

anything else?

Got a l l  r i le d  up and i t  was dismissed and went homo.

MR. KAPLAN: That's a l l .

CROSS EXAMINATION

. STARLING:

I ju s t  got a couple of questions to ask you, Mrs.

Woods, i f  you would. In th is f i r s t  meeting at the Plum 

Bayou L ib rary , th is was a regu lar scheduled Board 

meeting?

A Yes, i t  was a regu lar scheduled Board cieeting.

0 And the press was present?

A I beg your pardon?

G Was the press present?

A The press?

0- Uh-huh.

A I f  i t  was, I d id n 't  know i t .

Q. Do you have the date of th is meeting?

A I  don 't have the exact date, but It  was p rio r to the 

un ification  of the two schools.

GLENN H. PERRIN  
O f f ic ia l  Co u rt  Reporter 

Federal Bu ild ing  
EL Do rado . A rk an sa s  7 i7 »o *



wooes - cross

1
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a Prior to un ification?

2 ! A. I f  you know what I mean, be fo re .

3 a Before the actual unification?

4
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A. (Nods head a ffirm ativ e ly )

5 a Would you say i t  was around—

6 A. It  was in March.

7
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! a In March?

8 A. Right, s i r .

9 i ^ Do you know whether or not the press attended the public

10
i Board meetings? When I say "the p ress", I  am talking

11
i about the Pine B lu ff Commercial o f the Gazette •

12 A. I don 't know.

13

°
Now, who e lse  was present at th is meeting besides the

14 Board members and Mr. Bradshaw?

15 A. At which meeting, now?
1

16 a At the f i r s t  meeting.

17 i A. The teachers.
i

18 a Just the teachers?

19 A. The Plum Bayou teach ers••a ll of the teachers at the

20 Rosenwald School, and the— about 30 patrons.

21 a Black and white patrons?

22 A. Wasn't any white there.

23 a No white people at th is meeting?

24 A. Except the Board members.

25 a And th is was in March. Did they take minutes of that

323

GLENN H PERRIN
Official Court R ep o r t er  

Federal Building  
EL Dorado . A rkansas 7i7so



~ w o o o s c r o s s '
- i | - - ............ .. —
1

1 meeting?
2 A. I  d o n ' t  know. I  d on ' t  know whether they d id or n o t.

3 a How d id  you know the m eeting was go ing  to  be held?

4 A. I t  was in  the p aper.

5 ai]
P u b lic iz e d  in  the paper?

6 A. Yes.

7 a Now, a t  t h i s  second m eeting, who was p re se n t - •where wee

8 th is  m eeting and when was it?

9 ! A- I t  was in  the L ib ra ry  about a month l a t e r .

10 a Plum Bayou L ib ra ry ?

11 A. Yes.

12 a And i t  was approx im ate ly  in  A p r i l ,  then?

13 A. Yes. '

14 a Was th is  a Board m eeting, a lso ?

15 A. Y e s , i t  was.

16 a How d id  you know about th is  meeting?

17 A. I t  was p u b lish e d .

18 a I t  was p u b l ic iz e d .  Do you know whether any members o f

19 the p ress  were p resen t a t  th a t aweting?

20 A. I  d on ' t  know.

21 a Now, Mr. Bradshaw, I  take i t ,  a t  th is  meeting d i d n ' t

22 make the statem ent which he had been accused o f  making

23 in  the other meeting?

24 A. Mr. Archer s a i d  th a t .
1

25 a And who is  Mr. Archer?

GLENN H PERRIN  
O f f i c i a l  C o u r t  R epo r ter  

F e d e r a l  B u il d in g  
EL Do r ad o  A r k a n s a s  7i7so



-wc«<nr^ci?bi¥

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One of the Board members.

One of the Board members. And was th is In response to 

a question that he made that statement?

Yes, i t  was— I mean i t  had arose about how was the 

teachers being— said  how was the teachers going to be 

le t  out or reta ined .

As a p la in t i f f  in th is law su it, Mrs. Woods, what are 

you a lle g in g  is  discrim inatory against you?

til. KAPLAN: Your Honor, I think that is  not a

proper question to ask th is w itness. The Complaint 

speaks for i t s e l f .  She speaks as a member of a 

c la ss , th is is  a c lass action of parents and 

students in the D is tr ic t  a lle g in g  r a c ia l  

discrim ination on severa l grounds including facu lty  

members. 1 think i t ' s  not a proper question fo r  

her and ob ject.

MR.

THE COURT: W ell, o f course, she 's  not

representing the facu lty  as a c la s s , Mr. 

Kaplan, she 's representing the ch ildren , some 

of her own ch ildren , as a c la s s , and 

discrim ination, r a c ia l  d iscrim ination, is  

alleged  against her children  and a l l  of these 

in a sim ilar c la s s , and Mr. S ta rlin g  has a 

r igh t  to ask her about i t .

STARLING: I have no further questions, Your

GLENN H PERRIN 
Of f ic ia l  Co u rt  Ra 

Federal B u il d in g  
EL Do rad o . A rk ansas  7 i7so



Honor.

THE COURT: Anything fu rth e r?

MR. KAPLAN: No, Your Honor. P la in t i f f s  w i l l  reat

at th la tin e .

THE COURT: You may stand aside , Mrs. Woods.

(Witness excused.)

THE COURT: The Court w i l l  have a few minutes'

recess .

(Whereupon, at 10:58 a .n . ,  a short recess is  taken; 

thereupon, at 11:15 a .a . ,  the parties present as 

hereto fore, the fo llow ing  further proceedings are
I

had, to -w it : )

i
MR. STARLING: Your Honor,-*

THE COURT: C a ll your f i r s t  w itness.

MR. STARLING: - - a t  th is tine the defendants, under
[

Rule 41 (b ) o f the Federal Rules, would lik e  to 

move th is Court to dismiss the Complaints with  

reference to the fo llow ing a lle ga t io n s : (1 ) Those j
a llegation s on which no proof has been offered  as 

set forth  in the Complaint, which includes the 

p la in t i f f  Woods' a llega tio n  concerning discrim ination  

against her ch ildren , which no testimony has been

GLENN H. PERRIN
Of f i c i a l  C o u r t  R epo r ter  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 17 9 0



327

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offered  by her on that point. (2 ) Againsc Hrs. 

Evans, the a llegation s by Mrs. Evans that the 

placing her upon T it le  I  pay ro ll has discrim inated  

against her by making " i f  funds were a v a ila b le "  

inso far as she has not lo s t  any employment and has 

only gained monetarily by th is process. (3 ) As to 

Mr. Asive Thomas, (1 ) because he was not 

discrim inated against, and, (2 ) because there has 

been no r e l i e f  shown i f  the Court should determine 

he was discrim inated aga in st, because he has only 

increased his monetary standing since his 

termination at Tucker-Plum Bayou School D is t r ic t ,  

and, too, he does not want his job back at the 

Plum Bayou School D is t r ic t .  And, f in a l ly ,  I  ask 

the Court to dismiss the Complaint with reference  

to the a lle ga tio n  of Mrs. Lois Thomas, because Mrs. 

Thomas has not in any way proven the case that she 

has been discrim inated against in  reference to the 

evaluation of the teachers, she has not shown this  

Court in any way or any evidence been offered  in 

any way how she is  more q u a lif ie d  than any of the 

teachers that were retained by the D is t r ic t .

MR. KAPLAN: Your Honor, our response is  b r ie f  and

that is  that defendants' motion exh ib its profound 

misconception of the status of the law in th is

G L E N N  H P E R R IN  
O f f i c i a l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
E L  Do r a d o . A r k a n s a s  t i 7 so



328

area. The status of the law basically la  three 

cases In this c ir c u it ,  Saqth Va NorriUoo. Hancv v. 

S£.Yl«¥ CPMR^Y» «nd Jackson v . Wheatley School 

D is t r ic t , indicates that the burden la  r e a l ly  not 

upon the p la in t i f f ,  the burden rests  an the 

defendants. A l l  the p la in t i f f s  have to show is  

discrim ination in the fac t that black teachers were 

not reh ired  or in some way had teacher tenure or 

teacher status diminished, demoted, degraded in any 
way. Then the burden is  upon the defendants to 

show that whatever happened to those teachers was 

not discrim inatory. I think that th a t 's  very c lea r i 

in the la te s t  teachings of this c irc u it  in  Jackson 

v « Wheatley and was equally  c lea r in  Hancv v .

Sevier Countv. We have showed that black teachers 

were not reh ired , including Mrs. Lois Ann Thomas; 

that a black man was not even considered fo r the 

position  of Coach, P.E. in structor, or c a l l  i t  what 

you w i l l ,  the fac t remains that the man taught four 

sections o f P.E. and was the Coach. We have shown 

that Mr8• Evans was not to ld  u n til yesterday that 

she would be placed on Minimum Foundation i f  there 

was an eventuality of removal of T it le  I funds.

We have shown that she was never even considered 

fo r a paying position , one that she had served in

G L E N N  H P E R R IN
Of f i c i a l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
E L  Do r a d o . A r k a n s a s  71 73 0



araasnaw -  D irect 329

for many, many, many years, that of Health 

Coordinator, which carries  an add itional stipend  

in excess o f $500.00. I think that profound 

misconception of the status of the law prevents this  

Court from granting that motion to dism iss.

THE COIRT: The Court w i l l  reserve judgment.

You may c a l l  your f i r s t  w itness.

MR. STARLING: At th is time, Your Honor, I c a l l  Mr.

James K. Bradshaw.

111!
12 :|

JAMES K. BRADSHAW.

ca lled  aa a witness on behalf of the defendants, having been 

previously duly sworn, te s t i f ie d  as fo llow s:

DIRECT EXAMINATION

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BY m ,  STARLING:

O Now, Mr. Bradshaw, a llega tion s 24 and 25 of the p la in *  

t i f f s '  Complaint they have a lle ged : "In  terminating

p la in t i f f  Lois Thomas and severa l other teachers at 

Rosenwald School, the defendants reduced the to ta l 

facu lty  by elim inating only black teachers."

Mr. Bradshaw, in reference to that a lle ga t io n , 1 ask 

you, when did you begin to seriously  consider the fact 

of un ifica tion  and the problems which are inherent in 

that fact?

A. In 1966-'67, the year 1 became Superintendent.

G L E N N  H P E R R IN  
O f f i c i a l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
EL Do r ad o  A r k a n s a s  7 i 7 so

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Q. What did you see as one of the aajcc problem  In

reference to the u n ifica tion  of the School D istrict?

A. W ell, a fte r  a thorough study, I re a lised  that upon 

u n ifica tion  of the school that th is would asean a 

necessary reduction in teacher force and a certain  

number of teachers would have to be re leased .

a  When did you s ta rt  taking a ffirm ative  steps in the 

preparation o f th is problem of reduction o f teacher 

force?

A. That was in 1968-'69, I be lieve  i t  was.

Q. This the f a l l  or spring or when?
|

A. In the f a l l .  I was in contact with the D is t r ic t  lega l

counsel and asked for their advice on how best to fa i r ly
I

and le g a lly  solve the problem of teacher reduction.

(1 Being aware of the problem and acting upon your attorney1 s 

advice, what did you do as a so lution  to th is  problem?

A. W ell, I  rea lized  that I had to come up with some method 

whereby I could f a i r ly  and ob jective ly  evaluate a l l  

13 teachers, elementary teachers.

a  And in what way did you go about obtaining th is  method 

of fa i r ly  evaluating the teachers at the elementary 

schools?

A. By reading and studying, and I  had ideas on th is matter 

of my own.

Bradshaw -  D irect

Q. Did you talk with any person in any state representative



331
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capacity concerned with school districts?

a. Well, I had some discussions with Mr. Turner, who is the 

County School Supervisor, on several occasions.

a Did you discuss the problem of evaluation of the

teachers in the elementary schools with Mr. Turner?
A. Yes, I certainly did, on several occasions.

a How many times did you visit with Mr. Turner concerning 
this subject?

A. I would say approximately three or four times.

Q. And would these be lengthy meetings or short or what?
A. Yes, I talked with him at length on this matter.

a Mr. Bradshaw, now, was this prior, your meetings with

Mr. Turner and your preparation for the problem of 

the reduction in teacher force, was this prior to 

unification of the elementary schools?
A. Yes, it was.

a When were the elementary schools unified?

A- I believe the decision was made at a Board meeting on

March 28, 1969, that the two elementary schools would be 
unified commencing with the school term ’69-*70.

O Now, upon receiving official notification of the

elementary schools that they would be unified at the 

beginning of the school term 1969-'70 and that a 

reduction in teacher force was necessary, did you go 

about informing the teacher faculty that this fact was
GLENN H PERRIN 

O f f ic ia l  C o u r t  R c p o r t u  
F e d e r al  B u il d in g  

E L Do r a d o  A r k a n s a s  71730

Bradshaw -  D irect



o r a a s n a w  - Di r e c t 332

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inevitable?

Yes, sir, in April. I believe it was in April I held 

a meeting with Mr. Edwards and the teachers over at 

Tucker-RosenwaId School and informed them that upon 

unification of the schools that this would mean a 

reduction in staff and that a certain number of teachers 
would be released.

How many teachers did you have at that time at the two 

elementary schools, both the Tucker-RosenwaId and the 
Plum Bayou Elementary Schools?

At that particular time we had eight teachers at Tucker- 
Rosenwald School and seven at the Plum Bayou Elementary 
School.

So a total of 13 elementary teachers?

That is correct.

Now, how many teachers did you determine it would be 

necessary--or it would have--it would be necessary to 

retain after the unification of the schools?

It was felt that 10 teachers would be needed.

Now, did you also hold similar meetings at the Plum 

Bayou Elementary School to explain to the white teachers 

what was coming in reference to unification?

Yes, I held a meeting with the elementary teachers end 

explained the same thing, that upon unification of the 

schools that this would mean a necessary reduction in
GLENN H PERRIN 

O f f ic ia l  C o u r t  R epo r t er  
F e d e r al  B u il d in g  

EL Do r a d o . A r k a n s a s  7 i7 so



staff and chat only ten teachers would be a M d d d .

Ci Mr. Bradshaw, at cnese meetings you had with the

teachers at the Plum Bayou Elementary School and the 

Tucker-RosenwaId Elementary School, did you mention to 

these teachers that you were attempting to devise soc© 
type of evaluation form?

A. Yes, sir, at several of the meetings I met with the 

teachers and told them that we would need to come up 

with some method whereby we could fairly and objectively 

evaluate our teachers and that I needed any suggestion 
that they might have.

Q- Did, in fact, any of the teachers at eitber of the 

schools give you any suggestions in reference to the 
evaluation form?

a. Yes, sir, at one particular meeting that I recall, I

believe it was over at the Tucker-RosenwaId Elementary 
School, I asked for certain criteria that could be 

used and they actually did suggest criteria which they 
felt could be used and would be fair.

Q. And did you, in fact, use any of these suggestions or 
criteria in your evaluation form?

A. Yes, sir. In fact, several of those that they mentioned 

appear on the form which was finally approved.

a Did you also meet with the white elementary teachers in  

reference to the criteria which would be used on the
GLENN H PERRIN 

O f f i c i a l  C o u r t  R epo r t er  
F e d e r a l  B u ild in q  

EL Do r a d o . A r k a n s a s  7 17 3 0



Bradshaw -  D irect 334

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evaluation form?

a. Yes, s ir ,  I  d id .

a Mr. Bradshaw, after meeting with the teachers in the

various schools concerning the unification and reduction 

in teacher force and the criteria to be suggested and 

utilized, what did you do at that point?

A. Well, after the various meetings 1 took the suggestions 

and comments of the teachers along with my ideas and 

came up with a rough copy of the evaluation facia which 
I hoped could be used.

Did you discuss this evaluation form or show it to Mr*

B. E. Turner, the County School Supervisor?

A. Yes, sir, I did. In fact, I kept in contact with Mr. 

Turner throughout this period of time. After I came 

up with the rough copy of the evaluation form, I did 

visit with Mr. Turner.

Cl What did you and Mr. Turner do in reference to this 
form?

a. Well, we took each criteria which was listed and

discussed the pro's and con's of each, what each meonf, 
and what should be included in each criteria.

a Did Mr. Turner approve the rough form as it was 
presented to him by you?

A. Yes, sir, he did. In fact, Mr. Turner felt like this

was one of the finest evaluation forms that he had seen

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r a l  B u il d in g  
EL Do rad o  A r k a n s a s  7 17 S 0



Oi. o u o a a i v j j l i  e c  L

ijj developed.

2I! a After CO(ninS up with the completed rough draft of the 
a evaluation form which had been discussed with Mr.

Turner, did you visit with the teachers at the Tucker- 

5 jj Rosenwald and the Plum Bayou Elementary Schools to

discuss the evaluation form and criteria with thee?
7 j A. Well, I did not specifically lay the form down and say
8 "This is it", but the criteria was discussed on several
8 i| occasions and they were all pretty well notified that

10 the criteria would be used cm the evaluation form.
11 i ^ Mr. Bradshaw, did any of the teachers of the Tucker -
12 Rosenwald Elementary School have any objections to the
13

1 final form as it was devised?
14

i A There was no objections to the criteria.
15 a Did you submit this form to the School Board at its
16 regular meeting for consideration and approval of the
17 form? |
18 A. Yes, sir, I believe I submitted this criteria April the
18 14th, 1969, at the regular Board meeting.

i
20 a And did, in fact, the School Board at that meeting
21 j April 14th, 1969, approve the form as was devised?
22

1
A. Yes, sir, they did.

23 ' a Was this a public School Board meeting regularly
1

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A. It was.
GLENN H PERRIN 

Of f i c i a l  C o u r t  R epo rter  
F e d e r a l  B u il d in g  

t L  Do r a d o . A r k a n s a s  7 t7 so



21 || A.

And was it open to the public?
Yes, sir,

Did anyone at the School Board meeting objecc to the 

criteria on the evaluation form which you utilized or 
which had been approved by the Board?

No, sir, there was no objections.

Mr. Bradshaw, how long did it take you, including the 

various meetings which you had with the various 

teachers at both Plum Bayou and Tucker-Rosenwald and 

discussions with Mr. Turner and other persons 

concerning evaluation, to coaae up with this particular
. I

form?

I spent over a year attempting to come up with an
i

evaluation form which I felt would be fair to all 15 
teachers.

I
(Whereupon, a document is shown to counsel for the 
plaintiffs.)

Mr. Bradshaw, I show you a document entitled "Criteria 

For Teachers", and could you identify that as the
I

evaluation form which you devised?
Yes, sir, that is it.

22
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f1® • STARLINGi 1 would like to have it marked for 
identification and entered into evidence, Your
Honu*..

THE COURT: Let it be received.
GLENN H PERRIN 

O f f i c i a l  C o u r t  R epo r ter  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  7 1 7 * 0



Q. Mr. Bradshaw, prior to the School Board's decision of 

April 14th, 1969, to approve the evaluation form which 

you had come up with, had you ever previously suggested 

another type or another method of evaluating the 15 

teachers involved?

A Yes, sir, I had,

Q. And what was that?
A Well, when I was in contact with the District's legal 

advice I was advised to come up with some objective 

method in evaluating the teachers, and I felt like the 

written objective test was the fairest and would most 

certainly be the easiest solution, just simply to have 

all 15 teachers take this written objective test, one 

which would have been prepared by National Testing 

Service and graded by National Testing Service, thereby 

the 10 teachers scoring the highest would be retained
I

and the five lowest would not have been retained.

a Did you utilize this type of test?

A No, s ir ,  I  did not.
I

Q. Why?
A. Because of the objections on the part of the Negro 

teachers at the Tucker-RosenmaId School.
I

a What were their objections based on? What did they say 

to you?
A Well, they simply went to Mr. Turner’s office en masse

GLENN H PERRIN
O f f i c i a l  C o u r t  R kfo rtkr  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 I7 so

ijraasnaw - D i r e c t  337



Bradshaw - D irect 33fc

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and protested to the use of such— of the written teat. 

Indeed, they wanted another method used.

Did you a lso  discuss this type of ob jective  test with 

the white teachers at the Plum Bayou School?

Yes, I certa in ly  d id .

What was their reaction?

I t  suited them and they were w il l in g  to take the te s t .  

Did you, in fa c t , give th is type of test?

9j| A.

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No, s i r ,  I did not.

What was your reason for not g iv ing the test?

W ell, I wanted to come up with something which I  could 

f a i r ly  and ob jective ly  evaluate every 13 teachers in the j 

D is t r ic t  as f a i r ly  and ob jective ly  to the best o f my
i

a b i l i t y .

Did any of the Negro teachers suggest that you, in fa c t , ; 

u t i l iz e  the type of c r it e r ia  or form which you la te r  

came up with?

Yes, they did .

When did you s ta rt  actua lly  evaluating the elementary
|

teachers in reference to the evaluation form which has 

been approved and submitted into evidence?

My evaluation was not started u n til a fte r  the 14th of 

A p ril meeting, which the Board approved the c r it e r ia ,  

and then my evaluation was made in reference to the 

approved evaluation form.

GLENN H PERRIN 
O f f i c i a l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  7 1 7 * 0



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& Did you ask Mr. Edwards, the Head Teacher at Tucker- 

Rosenwald, and Mrs. Blair, the Head Teacher at Plum 

Bayou, to make their own independent evaluations of 

their teachers and give them to you?

A. Yes , sir, I did.

a And did, in fact, they give you their evaluations?
A. Yes, they did.

Q. Were they cm the forms, or were they evaluation*<«were 

their teachers evaluated with reference to the form 

that was approved by the School Board?

A. No, sir, I did not ask Mr. Edwards or Mrs. Blair to maka 

their evaluations on the form which had been approved by 

the Board, I simply asked them, if they would, just 

think about the abilities and qualities of the teachers 

which they had and give me their thinking as far as 

their teachers were concerned.

a Did you utilize either Mr. Edwards' evaluation of his

teachers or Mrs. Blair's, the Head Teacher at the white 

Plum Bayou School?

A. As I testified yesterday, I did not utilize these

evaluations. I did look at them, but I did not use 

them on my evaluation.

a Why did you not utilize their evaluations, Mr. Bradshaw,

of their own teachers?

A. Well, Mr. Starling, at first 1 thought this was the best
GLENN H PERRIN

O f f i c i a l  C o u r t  R epo r ter  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  7 17 3 0

araasnaw -  D irect



l u r a a s n a w  - Di r e c t 340

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way, but then I changed my  mind in that I  f e l t  l ik e — 1 

f e l t  l ik e  th a t th is  would not be p u tt in g  as g re a t  a 

burden on me, and then I changed my mind and I  decided  

I  would not use th e ir  e v a lu a t io n  forma fo r  these  

re a so n s : F i r s t ,  1 am the Superin tendent o f  Plum Bayou-

Tucker School D i s t r i c t ,  and i t  i s  my u lt im a te  

r e s p o n s ib i l i t y  fo r  d e c is io n s  such as t h i s ,  and I  was 

w i l l i n g  to  take the blame fo r  those teach ers  who would  

not be r e -c o n tra c te d  w ith . N ex t , Mr. Edwards o r M rs.

B la i r  on ly  eva lu a ted  th e ir  teach ers  in  th e ir  s ch o o l,  

and I  d id  not f e e l  l ik e  Mr. Edwards or M rs. B la i r  cou ld  

i n t e l l i g e n t ly  dec ide  which teach e rs  to  be re ta in e d  

and which ones not be re ta in e d  in  that they d id  not know 

the a b i l i t i e s  or c a p a b i l i t i e s  or q u a l i t i e s  o f  the 

teach ers  in  the other s c h o o l. Only I  was in  a p o s it io n  

to know th a t ,  and i t  was my r e s p o n s ib i l i t y  to  make the  

e v a lu a t io n  and make recomeiendation to  the Board , so  1 

d id .  And one o ther reason  was t h i s :  That Mr. Edwards
I

or Mrs. B la i r  was not inc luded  in  the e v a lu a t io n , they  

cou ld  not have o b je c t iv e ly  eva lu a ted  them selves in
I

re fe re n c e  to  the other te a c h e rs , and th is  had to  be done, 

and on ly  I  was in  a p o s it io n  to  do th a t .
I

Mr. Bradshaw , when the School Board voted  an March the 

28th, 1969, to  u n it iz e  the e l emen ta ry sch oo ls  

v o lu n t a r i ly ,  how many elem entary  teach ers  w ere  there  a t

GLENN H PERRIN 
Of f i c i a l  C o u r t  R epo r t er  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  t it s o



iiraasnaw -  D irect 341
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the Tucker-Rosenwald and Plum Bayou Eiwuienciiry Schools? 
At that time we had eight Negro teachers at the Tucker- 

Rosenwald Elementary School; we had seven teachers at 

the Plum Bayou Elementary School, which was six white 
and one Negro.

Now, I believe you testified that the determination was 

made that of those 15 elementary teachers, only 10 would 

be needed after the unitisation of the schools, is that 
correct?

Yes, sir, that is correct.

Have there ever been any objections to the fact that 
only 10 of the 15 teachers would be needed?

No, sir, there was no objections.

In determining which teachers would be retained and in 

utilizing the evaluation form which had been approved 

by the Board, did you just compare the abilities, the 

overall teaching abilities and qualities of the Negro 
teachers?

No, sir, I did not, I took both the teachers from the 

Tucker-Rosenwald Elementary School, the teachers at the 

Plum Bayou Elementary School, and put them together and 

evaluated them in reference— all 15 in reference to the 

criteria which is listed on the evaluation form.

Mr. Bradshaw, I show you an enlargement that I have 

prepared entitled "Plum Bayou Elementary School and
GLENN H PERRIN 

O f f i c i a l  C o u n t  R epo r t er  
F e d e r a l  B u il d in g  

E L  Do r a d o . A r k a n s a s  7 1 7 so



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DL dU K U A W  -  u irecc 342

Tucker-RosenwaId Elementary School, 1968-1969* ana on 

that enlargement drawing I have lis ted  those teachers 

who were teaching at the Plum Bayou Elementary School 

In the school year '6 8 -'6 9 , and their names are B la ir ,  

Dye, Ramsey, Rosen, W i l l i s ,  Moore, and Keith, and at the 

Tucker-Rosenwald Elementary School, Edwards, Evans, 

Clark, Davis, Gordon, Thomas--that is  Lois Thomas, Dora 

Thomas, and Kidd.

Now, 1 ask you i f  these are the teachers that were 

teaching at the various elementary schools p rio r to the 

evaluation?

A. Those a re  the teachers.

Q. A n d  I  ask you, when you made your e v a lu a t io n , d id  you 

ju s t  e v a lu a te  those te a c h e rs * -

A. No, s i r ,  I  d id n 't .

Q. - -o r  did you evaluate a l l  teachers?

a . No, s i r ,  1 put a l l  13 teachers together.

& Mr. Bradshaw, I  a lso  have an enlargement of the

Defendants' Exhibit No. 4, which is  the evaluation form 

which you u t i liz e d , and I ask you i f  that enlargement 

represents the Defendants' Exhibit No. 4, which i s ,  in  

fa c t , toe evaluation form?

A. Yes, i t  does.

0- Mr. Bradshaw, would you explain  the various c r it e r ia  

u t iliz e d  in that form?

GLENN H PERRIN
Of f ic ia l  Co u rt  R eporter 

F ederal Bu ild ing  
EL Do rad o . A rk an sas  7i7»o



U i a u a u a w  — U l i e C C 343

A. Yes. We used “Teecfter Competency", "Ability to jiaxncain 

Classroom Discipline", "Teacher-Teacher Relationship", 

■Teacher-Pupil Relationship", "Cooperation with Total 

School Program".

0- What about "Number of Years Teaching Experience"?

A Mr. Starling, I did not look at teaching experience 

unless the other factors resulted in a tie.

& Mr. Bradshaw, how did you come up with this or names, 
is there any reason?

A There is no reasoning for it, I simply thought of the 

teachers we had in the District and wrote their names
I

down.

a Are these all 13 elementary teachers, including both 

black and white?

A Yes, they are.

0> Mr. Bradshaw, what is "Teacher Competency" or how is it 

broken down?
A Well, under "Teacher Competency", we have broken this 

down as the ability to relate, in other words, the 

teacher's ability to relate to the students, and we 

also listed under there preparation, which would take 

into consideration the academic training, naturally, 

which we would have to look at the transcript and 

certification.

a What about "Ability to Maintain Classroom Discipline"?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R ep o r t er  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  7 I7 SO



Bradshaw - D irect 344

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Under this we listed ability to have control in the 

classroom to the point where there is mutual respect 
between the students and students and the teacher. Also 
under this we listed that an atmosphere conducive to a 

learning situation should exist in the classroom.

"Teacher-Pupil Relationship®?

Yes, under this I have listed that a teacher should have 

warmth and love for each student in her class or ones 

in which she is working with.

And, finally, "Cooperation with the Total School 

Program"?
Under this one we listed, you might say, cooperation, 

teachers with the teachers, teachers with the 

Superintendent and the Board of Education in trying to 

meet the objectives of the School District.
Now, Mr. Bradshaw, would you explain--first of all, 

when you evaluated the teachers, did you evaluate them 

in reference to the grades or subjects which they
I

taught?
No, sir, 1 did not. I simply evaluated the teachers on 

their overall ability.

Why?
Because in the elementary schools, teachers are supposed 

to be able to teach all of the required courses.
i

Mr. Bradshaw, would you explain to the Court the method
_____________ — ---------- --------------------------  - ........ . * ' —

GLENN H PERRIN 
O f f i c i a l  C o u r t  R ep o r t er  

F e d e r a l  B u il d in s  
EL Do r a d o . A r k a n i a i  717 so



1

Bradshaw -  D irect

o f scoring that you u t il iz e d  in coming up with the

*'! A.

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evaluation?

Yes, sir, I  used a score of -1“ to "5“ , "1" representing 

the high score, the "5" the lowest, and the teachers 
coining up with the lowest number of points would be 
ranked as the highest teacher.

And when you went down the list evaluating these 

teachers, you would put in here what, from your 

personal observation, what you felt each teacher-- 

Yes, I took each criteria and rated the teacher with a 

score of “1“ to *5“ on each of the criteria used.
Did you to ta l them a fte r  that?

After I had gone through each teacher, I then totalled 
the teacher’s points.

Mr. Bradshaw, did you know the abilities or capabilities 

or the abilities for classroom performance of each of 

the teachers involved in this evaluation?
I

Well, I feel like I was the only one in the District 

that could do this in reference to all 15 teachers.

Did this knowledge come from classroom visits or 
personal observations?

Yes, this was based upon classroom visitations and 

observations and my knowledge of the teachers over a 
three-year period of time.

How often would you, or did you have a policy of
GLENN H PERRIN

Of f i c i a l  C o u r t  R ep o r t er  
F e d e r a l  B u il d in g  

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v is it in g  each teacher’ s classroom both at ?lua. Bayou and 

Tucker-Ros enwald?

A. Y e s , I  c e r t a in ly  d id .

Q. How often or how frequent were these v is it s  with  

reference to the Tucker-Rosenwald School?

A As I  previously t e s t i f ie d ,  I  did try to v i s i t  the c la s s ­

room at least once a month for observation.

a  Mr. Bradshaw, Mrs. Thomas te s t i f ie d  that you did not 

v is i t  her classroom, Lois Thomas, at a l l  during the 

years 1966-’ 67 or ,6 7 -,68. I  ask you, did you v is i t  

Mrs. Thomas' classroom?

A. I most certa in ly  d id , I  was in every classroom in the 

Plum Bayou-Tucker School D is t r ic t .

a  How often during the years '6 6 -'6 7 , '6 7 -'6 8 , would you 

say you v is ite d  Mrs. Thomas' classroom for observations 

o f her teaching performance?

A In *67-'68?

a  '6 6 - ’67 and '6 7 -'6 8 .

A. I imagine I was in her class on *66-'67 year maybe a

couple o f times because I only took over a fte r  A p r il the 

4th, but in the *67-'68 year, I  am s a t is f ie d  that I  was 

in her classroom probably eight times.

a  Mr. Bradshaw, did you pay sim ilar v is it s  to the Plum 

Bayou Elementary white school a t that time?

A Yes, I certa in ly  d id .__________________
G L E N N  H P E R R IN  

O f f ic ia l  C o u r t  R epo rter  
F e d e r al  B u il d in g  

E L Do r a d o  A r k a n s a s  t i t » o

B r a d s h a w  - D i r e c t



n r d u s n a w  - Direct 347

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Did Mr. Edwards, the head Teacher at the Tucker-Rosenwald 

School, make sim ilar v is it s  to the Plum Bayou Elementary 

School tor observation of teacher performance?

No, s ir ,  he did not.

Did he ever?

He did not come to the school to make personal 

observations within the classrooms.

Did Mrs. B la ir , the Head Teacher o f the Plum Bayou 

Elementary School, ever go to the Tucker-Rosenwald 

Elementary School for the purpose o f personally observing 

teacher performance of those teachers?

To my knowledge, Mrs. B la ir never did v i s i t  the Tucker- 

Rosenwald Elementary School for th is purpose.

Who was the only person in the D is tr ic t  who had the 

opportunity to observe the teacher performance o f a l l  

o f the teachers, elementary teachers, in the D is tr ic t?

I was the only one that had th is opportunity.

Mr. Bradshaw, once you had made your evaluation o f the 

teachers, can you name the rank o f the 10 teachers or 

name the 10 teachers and rank which were retained and 

the f iv e  teachers which were not retained?

Yes, s ir ,  I  think 1 can g ive those to you. I  b e lieve  

Mrs. Blair was retained as No. 1; No. 2, a Janet Dye— 

Janet Dye W all; No. 3, i t  was Mrs. Robbie Keith; No. 4,

Mr. Jean Edwards; No. 5, Mrs. Juanita Moore; No. 6, Mrs.

GLENN H PERRIN 
O fficial Count Reporter 

Federal build ing  
CL Dorado A rkansa*  t i 7»o



Altftea W ill is ;  No. 7, Mrs. Nancy Rosen; No. 8, Mrs.

A rtie  Davis; No. 9, Mrs. Lucreasia Jivans; No. 10, Mrs.

Maxine Clark.

a  Now, Mr. Bradshaw, w h a t — who were the five teachers who 

were not retained in the order of their rank?

A Would you repeat that, please, sir?

U Who were the five teachers who were not retained in the 

order of their rank?

A  I believe that was Mrs. Ramsey, M rs. Gordon, Mrs. Lois 

Thomas, Mrs. Dora Thomas, and M rs. Kidd, 

a I am going to show you an enlargement drawing which 1 

have made of the rankings of the teachers after the 

evaluation and ask you if it fairly represents what you 

have just stated in reference to the teachers retained 

and not retained?

A  Yes, sir, it does,

a  Now, is Mrs. Blair white or black?

A  Mrs. Blair is white,

a  She is white?

A  Yes, sir.

a  And Mrs. Dye?

A  Mrs. Dye is white,

a  S h e ‘s white?

A  Correct,

a  Mrs. Keith?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R ep o r t er  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  7i7ao

B r a d s h a w  - Direct 348



Bradshaw -  D irect 349

1i A.I White.

2 a And Mr, Edwards?
3 A. Black.
4 a He is Negro, right?
5 A. (Nods head affirmatively)
6

a
Mrs. Moore?

7I A. White.
8 Q.1 She's white. Mrs. Willis?
9 A. Black.
10 a Mrs. Rosen?
11 A. White.
12 a Mrs. Davis?
13

1 *
Black.

14
a Mrs. Evans?

IS A. Black.
18 a And Mrs. Clark?
17 A. Black.
18 a Now, after this evaluation of the 13 teachers, Mr.
19 Bradshaw, how many Negro teachers were retained?
20 A. Five.
21 1 a And how many white teachers were retained?
22 A. Five.
123 a And how many black teachers were not retained?

24 A. There were four.
25 a Who are they?

GLENN H PERRIN 
O f f i c i a l  C o u r t  R ip o r t ik  

F e d e r a l  B u il d in g  
E L  Do r ad o  A r k a n s a s  7 i 7 so



o r a usnaw - D i r e c t 350

i1II
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Mrs. Gordon, Mrs. Tnctuas --Mr s . Dora Thomas, ar.d Mrs.

Lois Ann Thomas, and Mrs. Kidd.

And how many white teachers were not retained?

One.

And who is that?

Elizabeth Ramsey.
Mr. Bradshaw, when you made the evaluation, did you know 

that Mrs. Ramsey was going to resign?
No, sir, I did not.

When did she give you her resignation?

It was after this evaluation had been made.

When you made the evaluation, did you know that Mr. 

Edwards was going to resign?

No, sir, I did not.

When did he give you his resignation?

It was after this evaluation had been made.

Now, when Mr. Edwards resigned and Mrs. Ramsey resigned, 

did you go out and hire additional white teachers to 

fill those positions?

No, sir, I did not.

What did you do?

Mrs. Gordon moved up—

Into No. 10?
--into No. 10 position. Mrs. Lois Thomas moved up into 

11th position, Dora Thomas to 12, and Mrs. Kidd to No.
GLENN H PERRIN

O f f i c i a l  C o u r t  R epo rter  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  7 t7 »o



1/ M.X. tV , t 351

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13.
Is iMrs. Gordon a plaintiff in this lawsuit?

No, sir, she is not.

Is Mrs. Dora Thomas a plaintiff in this lawsuit?

No, sir, she is not.

Is Mrs, Armenia Kidd a plaintiff in this lawsuit?

No, sir, she is not.

Mrs. Lois Ann Thomas, of the five teachers not retained, 

is the only plaintiff in this lawsuit, is that correct? 

That is true.

Now, did you submit the list of teachers wh o  you 

recommended to be retained and those not to be retained 

to the School Board?

Yes, sir, I did and made recommendations that they be 

reemployed and those three that were the lowest rank 

would not be re-contracted with for the upcoming school 

year.

At that meeting--was this a public School Board meeting? 

Y e s , s i r , it w a s .

And was it, in fact,--how was it made public, was there 

a publication in the paper?

Yes, sir, we give notice to the news media.

Were there any objections made to the manner in which 

this evaluation was made or the outcome at that public 

School Board meeting?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R epo rter  
F ed er a l. B u il d in g  

EL Do r a d o  A r k a n s a s  7 17 * 0



U  1 1  C L  t 352
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No, s i r ,  chert were no objections.

When you made your recommendation to the School Board 

concerning those teachers who would be retained and those 

teachers who would not be retained, was there any state­

ment by any member of the School Board or by yourself

concerning the race of any of the teachers retained or 

not retained?

No, sir, there was none.

Did they, in fact, approve your recommendation?

Y e s > 8 i r , the teachers were employed for the upcoming 

school year.

Mr. Bradshaw, throughout this period that you were 

revising this evaluation form, that you were actually
|

evaluating the teachers, and after that, and during the 

meetings which you had with the Negro teachers and the 

Negro faculty members relating to the unification of the j 

schools and the evaluation form, did you ever make any 

statement that you would not dismiss any white teachers 

to hire black teachers in reference to your evaluation?

No, sir, I have never made such a statement. In fact, 

if I had made such a statement such as that, then there 

would have been no need of going to all the trouble to 

come up with an evaluation form. There has been no 

statement made on my part of that nature.

Well, did you, in fact, dismiss one of the white

GLENN H PERRIN 
O f f i c i a l  C o u r t  R epo rter  

F e d e r a l  B u il d in g  
EL Do r ad o  A r k a n s a s  7 i7 s o



a r a a s n a w  - Direct 353

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teachers, or that was not retained?

Mrs. Ramsey was not reemployea.

At anytime during this evaluation period or prior to it 

or during the unification of the schools or at anytime 

have you made any statement to the Board, to the School 

Board, or to the patrons of the District, or to any of 
the members of the faculty, both black and white, that 

your evaluation would be based upon race?

No, sir, I have not. We realized that problems that has 

arisen in teacher reduction when schools were unified, 

and this is one thing that we were trying to do is come 
up with a method whereby we could fairly do this and 

avoid any court action, because we realize that it's 

time consuming and most certainly expensive, and our

District had done everything up, including our teacher 

selection, as we had been directed to do so by Health, 

Education and Welfare„
Mr. Bradshaw, as Superintendent of the District and the 

person to whom responsibility of deciding which teachers 

would be retained and which teachers would not be 
retained, what were your aims and goals in reference to 
the evaluation of these 15 elementary teachers?

Would you repeat that, please, sir?
Since you were the Superintendent of the School District 

and basically it was your responsibility to determine
GLENN H PERRIN 

O f f i c i a l  C o u r t  R epo r t er  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  717SO



a r a u s n a w  - Direct 354
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wnich teachers would be retained and which teachers would 

not be retained, what was your ideals and goals in 

reference to the evaluation of the 15 elementary 

teachers?

Well, really, on the rejection of this written objective 

test on the request by the Negro teachers, I spent some 

time in diligent search trying to come up with an 

evaluation form which I felt actually would be fair and 

would take in certain qualities which are necessary, 

and I talked to different people, I read on this topic,

I utilized suggestions by the teachers themselves, and 
1 actually did come up with the evaluation or the 
criteria which was approved by the Board and by the 

majority o f the teachers, and I actually used these or

applied them to every one of the teachers in a fair and 

as objectively as 1 possibly could using my own personal 

observation, judgments, classroom visitations, and 

knowledge of the teachers based over three-year period 

of time in an attempt to come up with what I felt the 

most capable teachers that we presently had, and it's 
possible that I have made some mistakes, but if so, 

these mistakes are based on my own objective judgments. 

Mr. Bradshaw, have you ever been in a School Board 

meeting at anytime when Mr. Archer, a School Board 

member, or any of the other School Board members,
GLENN H PERRIN 

O f f i c i a l  C o u r t  R ep o r t er  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  7 1 7 3 0



355
nxrausnaw - Direct

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particularly during the perioo of evaluation and 

un^ ^ ca*-s‘on process, where they made any statement to 

the effect that their ideals or their goals or the 

District's aims were that they were not going to dismiss 

any white teachers to hire any "Nigger" teachers?

Mr. Starling, I feel that my Board members realized what 

the situation was and there has never been such a 

statement made in any Board meeting which I was in 
attendance.

Mr. Bradshaw, in reference to Mrs. Lucreasia Evans, 

have you ever told Mrs. Evans that, in reference to her 
being on the Title I payroll, that if funds became 

unavailable, that she would not be able to work in the 
classroom?

Mr. Starling, I have never told Mrs. Evans that if 

Title I funds was cut off, that she was out, never.
Was Mrs. Evans one of the teachers retained in your 
evaluation?

Yes , sir, she was.

And was she evaluated on her overall ability?
That is correct.

And if Title I funds became unavailable, would she be 
retained by the District?

Yes, because she was evaluated as— on her overall 

ability she ranked in the top 10, and she would have
GLENN H PERRIN 

O f f i c i a l  C o u r t  R epo rt er  
F e d e r a l  B u il d in g  

E L  Dor ado  A r k a n s a s  7 1 7 * 0

“T



o * . o u a i u i w  ■ »  u u e c c l 356

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been u t iliz e d  in the regular school program.

Did you assign Mrs. Evans the job o f health Coordinator 

at the Tucker«Rosenwald School?

No, sir, I certainly did not, and I did not know that 

she considered herself as the Health Coordinator. I 

assumed chat this is probably a responsibility that Mr. 

Edwards had given to Mrs. Evans because from time to 

time the Principals do request teachers to assist in 

some of these various responsibilities.

Did Mrs. Evans ever tell you that she was the Health 

Coordinator?

No, sir, she did not.

Did Mrs. Evans ever request that you pay her for her 

duties as Health Coordinator?

No, s ir ,  she did not.

Did Mrs. Evans ever request that you compare her or 
request that you give her the opportunity to be a 

Health Coordinator in the place of Mrs. Robbie Keith? 
No, sir, she did not.

How long has Mrs. Keith been the Health Coordinator at 
the Plum Bayou Elementary School?

It's my understanding that Mrs. Keith was placed under 

the Title I program as Health Coordinator during Mr. 

Anderson’s administration back in 1965-’66 school year. 

Is this something you are contracted for?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R epo rter  
F e d e r a l  B u il d in g  

EL Dor ado  A r k a n s a s  7 1 7 3 0



Bradshaw - D irect- i 357

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Yes, there is a contract on this.

And the name of her official capacity under that contract 
is "Health Coordinator"?

Title I Coordinator, that is correct.

Do any of the white teachers on Title I or under the 

Title I program receive the regular payroll bonus at the 
end of the year?

If the Court would permit me, I would like to elaborate 

on this bonus business. Mr. Starling, what this bonus 

amounts to is this: We have certain laws which state

that we must expend X-number of dollars from the 

Minimum Foundation Aid on teachers' salaries, and from 

time to time districts do fail to contract a sum of 

money that will satisfy that particular law, and upon 

audit of our books the State Department will give us 

notice that our District must pay, in the form of a 

bonus, to the teachers under the regular program money 

in the amount of the underpayment, that is what it 

amounts to. Title I teachers do not participate in this 
bonus.

I might state this: We have followed this particular
practice as far as Title 1, every time there is a pay 

increase for the regular teachers, then there is a pay 

increase for Title I teachers that is on contract.

Did Mrs. Evans receive this pay increase?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R epo r ter  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  7 1 7 * 0



358- DiT»uan»¥r-— urrcctr "— r

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A. Yes, sir, she has.
& Who is the highest paid elementary teacher in the Plum 

Bayou School?

A. In the Elementary School? 

a Yes.

A. At the present time, Mrs. Evans is the highest paid

elementary teacher that we have in the District other 
than the Head Teacher.

0. Mr. Bradshaw, in reference to Asive Thomas, now, I

believe— when was he employed at the Tucker-RosenwaId
School?

A. I believe I testified yesterday that Mr. Thomas was 

employed January 26th or January 28th of 1966.
i

Q. And what was he employed to do?

A. He was employed as a Social Study teacher.

Q. Do you have Physical Education or coaching duties at

the elementary school at Tucker-RosenwaId?
!

A. As I testified yesterday, we do not have an organised

Physical Education program or coaching on the elementary 
level, no, sir.

0- So he was hired to teach Social Studies?
A. Yes, sir.

0- Now, who was the--at this time who was the Social

Studies teacher or Physical Ed teacher at the Plum Bayou

High School?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n o  

EL D o r a d o . A r k a n r a r  7 1 7 * 0



oiouauow - uirect 359

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Was this *66- ’67? We had a Mr. Hunter Douglaa.
And what was tie hired to do?
Mr. Douglas was employed to work as a Social Study 
teacher and Physical Education.

Then at the high school do you hire just a man for 
Physical Ed?

No, sir, we do not.

Do you hire a man just to coach?

No, sir, we do not.

What do you hire him as?

We hire them as a Social Study teacher and Physical 
Education.

What were the reasons that you did not renew Mr. Asive 
Thomas' contract in 1968— '67-'68? j

The reason I testified to yesterday was that Mr. Thomas 

was weak as far as providing instruction in the area of 
Social Studies, he was not fully certified in this 

area, and as--on my personal observation, actually, he 

did not show a great interest in Social Studies, I 

think he was primarily interested in Physical Education, 

but the reason I did not recommend that he be reemployed 

by the District was because he was weak in the area of 

providing instruction to the boys and girls of our 

District in the area of Social Studies.

Now, at the same time that you did not renew Mr. Thomas'
GLENN H PERRIN

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



contract, what did you do in reference to Hunter Dcu^Liua i 

who was occupying basically the same position in the 

Plum Bayou High School as Mr. Thomas was in the Tucker- 
Rosenwald Elementary School? 

a. Mr. Douglas was released for the same reason. Mr.

Douglas was weak in the area of Social Studies as far

u i a u a u a w  -  U i r e C C

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as providing instruction, he was not certified, there­

fore, I made recommendation to the Board that his 
contract not be renewed.
Was he white?

Yes, sir, he was.

So, in other words, both Mr. Douglas and Mr. Thomas, 

both had their contracts not renewed at the end of the

'67-*68 year, one was white and one was black, is that 
correct?

That is correct.

And who did you hire for the job of Social Studies

teacher and Physical Ed teacher at the Plum Bayou High 
School for the year '68-'69?

A Mr. Bruce McConnell was employed by the District for 
that position.

Was Mr. Me Connell--did he— after employing him, did he 

appear to teach Social Studies in a competent sianner?
Yes, sir, he did.

Wasjie certified in both Physical Ed and Social Studies?
GLENN H PERRIN 

O f f ic ia l  C o u r t  R epo rter  
F e d e r al  B u il d in g  

EL Do r a d o . A r k a n s a s  7 i 7 » o



A-* **■ V.V- W
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Yes, sir, he was fully certified in Social Studies aad 
Physical Education.

And I believe you testified yesterday that Hr. McConnell 
left in 1970, is that correct?

At Che end of the '69-'70 school year, y e s , he submitted 
his resignation.

And was it a white man that you hired for that job after 
that?

No, sir, I did not.
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Who did

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14 i A. Yes, sir
15 MR.
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THE COURT: Well, 1 think probably under the

circumstances we better— it's a little after 

the 12 o ’clock time, we better recess for the 

noon hour, and I wonder if we could try to 
come back about 1:15—

CAPLAN: Yes, Your Honor,

THE COURT: --or just as soon thereafter as
you can.

GLENN H PERRIN 
Of f ic ia l  Court R eporter 

Federal Bu ild ing  
EL Do rad o . A rk ansas  71730



theYou may stand aside, Mr. Bradshaw,
Court will be in recess until approximately 
1:15.

(Whereupon, at 12:03 p.m., the noon recess i, taken 

thereupon, at 1:18 p.m., the parties present as

heretofore, the following further proceedings are 
had, to-wit:)

MR. STARLING: Your Honor, if I may, at this time,

I have one witness who I am only going to ask one 

basic question of and she needs to get back, and 

may I step out of turn and call her very briefly,
I only have one question to ask of her.

MR. KAPLAN: I have no objection, Your Honor.

THE COIRT: Well, with the agreement of Kr.

Kaplan, why Mr. Bradshaw will step aside, of |
course, and bring this party on for the 
limited purpose.

MR. STARLING: Mrs. Gordon!

G L E N N  H P ER R IN  
O r r i c i A L  C o u r t  R epo rter  

F e d e r a l  B u i l d i n g  

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ww*. - ui r e c c
36

2

5 ,,

ALTHEA GORDflM,

called as a witness on behalf of the defendants, being fir8t 
duly sworn, testified as follows:

DIRECT EXAMTN.Tynu

BY MR. STARLING:
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Would you state your na.se and address, please, ma'am? 
Althea L. Gordon.

Where do you live, Mrs. Gordon?
Route 1, Box 231, Sherrill.

How are you employed or where do you work?
Plum Bayou Elementary School.

THE COCRT: Will you talk a little louder,
please, Mrs. Gordon?

Plum Bayou Elementary School.

During the school year 1968- 'fid aiay i,0° o9, did you work at the
Tucker-Rosenwald Elementary School?
Yes, I did.

Are you aware of the evaluation which Mr. Bradshaw made

in reference to the teachers of the elementary schools,
did you know that he was making an evaluation?
I think so.

When-were you ever present at any of the meetings where 
Mr. Bradshaw was with the Negro teachers of Tucker- 
Rosenwald School?

Yes, I was.
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t * *  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 * 0 V/%



vjoxuuii - ux r e c c 364

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0. I am only going to you one more question Mrs. 
Gordon, and as I told you, all I wane is Che truth, 
not asking you to take sides one way or the other. Did 
you ever hear Mr. Bradshaw in any of those meetings ever 
state that he was not going to fire any white teachers 
to hire any "Nigger"?

A. "Nigger"? I don’t think so, I don't recall hearing 
"Nigger".

<1 Did you ever hear him say he was not going to fire any 

white teachers to hire any white— I mean any black or 
any "Nigger" teacher?

A. No.

MR. STARLING: All right, that's all, Your Honor.

THE COURT: Just a minute.

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CROSS EXAMINATION
BY MR. KAPLAN:

Q. Mrs. Gordon, how long were you a teacher in the District? 
A Let me see, now. Four years at Plum Bayou--I mean

Tucker-RosenwaId, and this is my second year at Plum 
Bayou.

Q. What subjects did you teach at Tucker-Rosenwald?
A Second Grade.

0- All of the time that you were there?

A Yes.
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 i 7 » o



vjuiuvmi - or os s ! 365

a At the time that you came chare, did you have a 

certification in elementary scnool education?

A Yes.

Q. Did you also have a certification in high school 

Home Economics?

A Well, they had to be turned in to the State Department, 

see, they wouldn't allow me to have two certificates 

at once.

Q. I see. But you did at one time possess that?

A Yes.

Q. All right. Were you present at a workshop that Mr.

Bradshaw addressed--were you present in a workshop given 

by Mrs. Kidd at the Tucker School?

A Yes.

Q. All right. At the end of that workshop, did Mr.

Bradshaw make some remarks to the teachers?

A I think so. I think he talked, but I don*t--(interrupts

self)

Q. Do you remember?

A No, I don't remember just what it was about.

0 Do you remember him saying anything at that meeting, or 

do you even remember him being there?

A He was there.

Q. Do you remember anything that he said?

A No.__________________________________
GLENN H PERRIN 

O f f ic ia l  Co u rt  R eporter 
F ederal Bu ild ing  

EL Do rado . A rk an sas  7 i7 »o



366

1 0. Do you remember wnat the subject matter waa chat he
2 spoke about?
3 A. No.

4' 0- Do you remember anything at all about the meeting,

5ij either what happened before he got there or what happened
ll

6 1| after he got there?

7 !j A. Well, I don't know exactly what Mrs. Kidd's subject was

8 !| that day.

9 |j Q. All right. Do you remember that it was a workshop?
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It was.

All right. But you don't remember what she said?
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No, I can't recall offhand.

Did Mr. Bradshaw participate in the workshop in any way?

I don't think so. I think just after she finished what 

she had to say, I think he made a few comments, but I 

don't know exactly what they were.

Do you remember even what the subject matter of his 

comments were?

No, I don't, I am sorry.

Were you present at a meeting in the Wright School when 

either Mr. Bradshaw or anyone from the School Board

ever said anything about unification?

Yes.

Do you recall when that was?

No, not exactly. It was early spring, I think.
GLENN H PERRIN 

O F F I C I A L  C O U R T  R V O K T W  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7t7»o



u o x ;u u n  -  cross 36?

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In 1969, Mrs. Gordon?

I chink.

Do you remember who was there? Were there any white 

people there?

I really don’t know, maybe a few.

Other than the School Board?

I really don't know.

Who else was there besides yourself?

Most of the teachers from Tucker-RosenwaId.

Anyone else?

Some of the parents.

Do you recall what anyone said during that meeting?

No. They probably were there to discuss the unification
—  I mean--yeah, unifying the school,-- 

Do you remember why—

--unitary system.

I am sorry, I didn't mean to interrupt you.

—  the unitary system.
Do you remember what the purpose of the meeting was, 

why the parents wanted to be there?

That is what I said, I think they were discussing going 
into the unitary— working on the unitary system then. 

Mrs. Gordon, do you recall then at that time being upset 

about black teachers not being retained?

Yes „
GLENN H PERRIN 

O f f ic ia l  Court R eporter 
Federal Bu ild ing  

EL Do rad o . A rkansas  717*0



c o r a o n  - cross

i a W ere  yo u  a ls o  u p s e t  a b o u t th a t ?

2 A. Well, I was concerned because--
3 a I knew you were concerned.
4 A. — I was earning my living.

5 I' a I see. And was that one of tha reasons why you went
li

6 to that meeting in Wright?
7 11 A. Yes.
8 a Do you recall Mr. Tony, Enoch Tony, being there?

9 A. Yes.
10

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a Do you recall any conversation--do you know who Mr.

11 1 Enoch Tony is?
12 A. Yes, I do.

1
13 a Who is he?
14 A. Well, I only know that he is a  resident of Tucker—

15 a Right.
16 A. --community, and I had one of his boys in my class.
17 a And at that time did he still have children in the
18 public schools?
19 i A. Yes.
20

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21 1 A- Yes.
22 l! a And do you--
23 A. He had a child, I don't know about children «• m 9

24
i| Q. I am sorry.

25 A. — but I know he had this one child that was in my
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t * *  

F e d e r a l  B u i l d i n o  

EL D o r a d o . A r k a n s a s  7 1 7 b o



V jU i  UUI1 L.TOSS 369

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classroom.
Okay. All right. Now, do you recall his having a 
conversation with any member of the School Board or the 

Superintendent about the retention of black teachers?

No, I don't remember any conversation.

Perhaps "conversation" is a bad choice of words. Do 

you remember him making some remark to either Mr.
Archer or to Mr. Bradshaw?

1 don't know as I do. 1 don't know as I do.

Do you remember anything about what was said at the 

meeting by anyone who was there?

No, I can't recall.
Don't remember anything?

No, I don't.

And is it also your testimony that you don't remember
i

anything that was said at the meeting that Mr. Bradshaw 
came over to at the Rosenwald School?

That's right.

All right. Is it your testimony that you don't remember 

whether he said "Nigger" or whether he didn't say 

"Nigger"?
22

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MR. STARLING: Your Honor, I object to that. Mrs.

Gordon has testified to the fact that— on direct 

examination the question was asked did she remember 

whether or not Mr. Bradshaw had ever indicated or
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7i7So



\J Wt Vvi. &
370

made any statement in reference to the fact that 
white teachers would not be fired for the purpose 
of hiring "Nigger" teachers, and Mrs. Gordon said 

no, she did not, and I think that is sufficient 
answer.

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THE COURT: Well, I think he has a right to

cross-examine her about it, Mr. Starling.
It is proper, you may proceed.

Do you remember the question, Mrs. Gordon?
That you--

That I asked, yeah.

If I remember--if I recall anything that Mr. Bradshaw 
said during the meeting?

Do you recall whether he did or didn't say it? Do you 
recall anything at all about that remark?
No, sir, I don't.

All right. Could he have said it and you just don't 
remember?

I don't know.

You don't know?
21 11 A. I don ' t.

Z2 a  Could it have been said, the same remark been made and 

23 you don’t remember about the meeting in Wright?
24 A.
25

Well, I just don't remember hearing anything like that. 

I don’t say that it wasn't said, but I don't remember
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n i a i  7 i 7 » o



u o x u o n  - cross 371
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hearing it.

You don’t say that it wasn't said?

I couldn't say that, but I don't remember, I didn't 
hear anything like it.

I see. Were you present for the whole meeting?
I was present.

Do you remember him saying anything at all about retain­
ing white teachers?

Yes.

All right. Now, do you remember Mrs. Evans saying 

something about seniority? Do you remember her asking 

a question about seniority in the District?

I think— 1 think 1 do. I think I remember something of
that.

All right. What do you remember of that?

Well, I don't know how it was worded, I couldn't say 

that I could quote her words, I don't know just how 
she worded it.

Well, to the best of your recollection, Mrs. Gordon, tell | 

us what you remember.

All I remember that something of the sort was brought 
up, something with reference to that was brought up, 
but, now, how it was worded, I don’t know.

Now, you also say you remember something about the 

retention, his saying--Mr. Bradshaw saying something
GLENN H PERRIN 

O f f ic ia l  Co u k t  R epo rter  
F e d e r al  B u il d in g  

EL D o r a d o  A r k a n s a s  7 1 7 9 0



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about the retention of teachers. Whet do you rtmerr-r 
about that?
Well, I remember hearing Mr. Bradshaw said that if you 

were qualified, you would be considered.

Did he ever show you anything that looked like this 

teacher evaluation chart?

No, I don’t remember seeing anything like that.

Did he ever show you a list of criteria that he was going 

to use to evaluate teachers, “Teacher Competency", 

"Ability to Maintain Classroom Discipline", "Teacher- 

Teacher Relationship", "Teacher-Pupil Relationship", 

■Cooperative with the Total School Program", did you 

ever see anything like that?

It seems to me as if we had something similar to that 

the morning that he had called us one by one into the

office.
I see. And did you see it for the first time at that 

time?
I don't know. I might have seen it before, but I don't 

recall.
At the time you were called into the office, were you 

told that you were discharged or were you told that you 

were being retained?

I was told that I was being retained.

Were you shown how you faired on the evaluation?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n q  

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v j U i  u  l u i  -  L I U 8 S 373

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No, I wasn't.
Were you told chat you were one of those teachers who 
was originally scheduled to be discharged?
No.

Were you told that it was only because Mrs. Elizabeth 
Ramsey--

MR. STARLING: Your Honor, I am going to object,

because on my direct examination I did not get into 
the evaluation that was actually utilized, and I 

think that Mr. Kaplan is going outside of the scope 

of direct examination.

THE COURT: I think it's proper cross

examination.

Were you told that it was only because Mrs. Elizabeth 

Ramsey was leaving the system that you were allowed to 

remain in the system?
No, I wasn't told anything of the sort.

Mrs. Gordon, did you know who Mrs. Ramsey was?

Yes.
Did you know whether or not she was leaving the system?

No, I didn’t.

What grade do you teach now, Mrs. Gordon?

Fifth.

Have you taught that since being in the system?

Yes.
GLENN H PERRIN

O f f i c i a l  C o u r t  R e p o r t e r  

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Gordon - Cross __________________ __________
C Were you asked co suggest any criteria for uhe retention

of teachers or the evaluation of teachers/
A. It seems to me that we gathered — I can’t be sure, out it 

seems to me that we gathered and were allowed to 

contribute, I don't know.

Q. Did you contribute?
A. Seems to me. I don't know, I can't be sure about that, 

but it just seems to me that we did, several things, 
you know, I might have it confused, but it seems to me

that we did, I am not sure.
a During 1968-'69, how many times did Mr. Bradshaw come 

into your class?

13 II A.
14

15 0-
16 A.
17

Oh, I don't know. I didn't think of counting them, but 

he was there rather regularly, I thought.

How many times would you say?

You mean for two years?
Well, let's take the last year that —

18!! A. The total of the two years?

19
(j a

No, let's take the last year first,

20 | A. Maybe about four, perhaps, I don i

21 1! Q. About four times?

22 A. Perhaps, I don’t know.

23 Q. How long did he stay each time?

24 A. Not too long.

25 | a Ten, 15 minutes? Twenty minutes?
1
1 GLENN H PERRIN 

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1 A. Perhaps.
2 a Any longer than that?
3 A. I shouldn't think so.
4 a How about the year before that, how long was he there?
i]

5 i How often was he there and how long did he stay?
6 A. Oh, about the same, perhaps.
7 a About the same?
a i| A. Uh -huh.

9,j a During 19--the first year that he became Superintendent:,
10 !i! ' 66-’67, did he come by your class then?
n ,i

II A-.1
Yes.

12 1 a How many times?
13| A* Maybe about three, I am not sure,
14

!
! a Do you remember what month he became Superintendent?

15 A No.
ia

1
MR. KAPLAN: That's all.

17 MR. STARLING: 1 have nothing further, Your Honor
18 THE COURT: You may stand aside. Have you
19 concluded with this witness?
20 MR. STARLING: Yes, Your Honor.
21 THE COURT: Have you concluded?
22 MR. KAPLAN: Oh, yes. Your Honor.
23 THE COURT: She may be excused, Mr. Starling
2* (Witness excused
25

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1 THE COURT: You may come back co Che witness
2 stand, Mr. Bradshaw.
3

4 JAMES K. BRADSHAW,
5 having been temporarily excused from the stand, resumed the

6 stand and testified further, as follows:
7 :| CROSS EXAMINATION

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BY MRo KAPLAN:

Q. Mr. Bradshaw, before you became Superintendent, had the 
District any plans at all for unification?

A Yes, there had been plans.

Q. And was Mr. Anderson involved in those, your predecessor? i

A Yes, sir, he was.

Q. Did those plans contemplate Che unification of the 

elementary school?
A I am satisfied they did, because we knew that we must 

come to a unified school, sure.

0. All right. You testified on direct examination you saw 

as a prime problem of unification the necessity of 

reducing the total teacher force, is that correct?

A. I testiried that we needed to have reduced the 

elementary, correct.
a Are you familiar with the attrition method of reduction?

A I beg your pardon?
Q. Are you familiar with the attrition method of reduction?

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A. Would you define chat, please, sir?
Q. I am asking you if you are familiar with ic. Do you

know what it means? Do you know what "attrition- means?
A. I am not so sure that I can give you the definition.

Q. Are you familiar with other school districts that have

reduced their faculty by the natural retirement, natural 

dropping out of teachers, the natural leaving by a 
teacher from the district?

A. Yes, sir, I do know that some districts have had teachers 

that retired and as a result have reduced their faculty.

Q. All right. And have you, in your experience in this 

District, known to have resignations, retirements, 

leaving the District for one reason or another?
A. Yes, we have had teachers to leave the District from 

time to time.

0- Of the 13 teachers that you evaluated, was any not

qualified to be a teacher in the public schools of the 

Plum Bayou District?

A. What do you mean, now, "not qualified"?

0- Well, was there anyone who was not qualified to be a 
teacher?

A. I might say that we have had teachers teaching with 
maybe a deficiency, yes.

a Of the 13 people on Mr. Starling's enlargement here, 

beginning No. 1, Mildred Blair, No. 15, Armenia Kidd,
GLENN H PERRIN

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I

any one of tflea not qualified co oe a public scnocl 
elementary teacher?

There is not a one on there not qualified at the present 

time to be an elementary teacher.

How about at that time?

At that particular time they were qualified but perhaps 

we may have one that was not fully certified.

Who was that?

Well, we have a Mrs. Janet Dye that has a full degree 

that has a high school certificate.
High school certificate?

That is correct.

And at that time she didn’t have any certificate, isn’t 

that right?
I beg your pardon, she has had the full certificate.

No, at that time, 1968-'69.
She did have a certificate.

She did have?

Yes, sir.
High school certificate?

Right.

Anyone else?
To my knowledge, all had certificates.

All had high school— 1 am sorry-elementary certificates? 

No, Mr. Edwards, I believe, held a high school
GLENN H PERRIN

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certificate.
Anyone else?
I believe I can say with some accuracy chat Che remaining 
had elementary certificates.

Let’s talk about Mr. Edwards for a moment. When you 

evaluated and put these people on this list, did you 

consider Mr. Edwards for a position in the elementary

school?

Yes, I certainly did.

I see. Did you ever consider him for a position in the 

high school?

Well, had he been retained, I am satisfied that I 

probably would have put him in the area of Math in the
I

elementary school and parttiae in the high school.

I see. At the time that you were considering this and 
going through this appraisal, you had a man in the 

high school who was not certified, isn’t that right, who 

was teaching Math?
I beg your pardon, this man had 30-something hours in 

Math, 40-something in Chemistry. As far as being 
qualified to teach Math, he was fully certified in the 

area of Math. His only deficiency was this: That he

did not have the required number of hours in education 

which he was working for to eliminate and has done it.

He had an emergency certification, didn’t he?
GLENN H PERRIN

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That is correct, because he did not htve the education
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hours which are requirede

Mr. Bradshaw, an emergency certification is not a full 

certification and would require you to have a warning 

or an advice from the State Department, isn't that right? 
That is if they fail to go back and pick up six 

additional hours between school terms.

But, let's get right at the issue, Mr. James Henry 

Klutts did not have a certification at that time, did 

he, he had an emergency certificate?
I will agree with you on that.

And he didn't finish his regular— and acquire his 

regular certification until this year, did he?

That's right. We have many teachers in our District 

that has worked under the same situation.

I see. Mr. Edwards was, however, a former Principal in 
your District, is that right?

He did serve as the Head Teacher.

Fully certified?

As far as the school administration, 1 do not know.

Fully certified at least as much as Mr. Klutts but had 
a regular high school certification?

MR. STARLING: Your Honor, I object on the grounds

that Mr. Edwards is not the plaintiff in this 

lawsuit, not alleged that he has been discriminated
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against by not being awarded the opportunity to be 
compared with a high school te&cner.

THE COURT: What is the purpose of this line or

questioning about Mr. Edwards, Mr. Kaplan?

MR. KAPLAN: Your Honor, it is simply to show

discrimination against black school teachers-- 
THE COURT: Well,--

MR. KAPLAN: --that are named plaintiffs.

THE COURT: --Mr. Edwards said on the

witness stand that he had no such claim, so 
the objection is sustained.

MR. KAPLAN: Your Honor, I would, if the Court

please, wish to make this statement: We make

claims of discrimination against black teachers.
In order to show discrimination against black 

teachers, it is necessary for us to show 

discrimination even against those who may not be 
claiming actively in a lawsuit-- 

THE COURT: Well,--

MR. KAPLAN: — some discrimination.

THE COURT: Well, that is not a class action,
Mr. Kaplan.

MR. KAPLAN: We don't seek relief for them, Your
Honor.

THE COURT: Well, the Court has ruled on it.
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MR. KAPLAN: Please note our exceptions.
THE COURT: Well, your exceptions are noted.

At the time of the evaluation, sir, you had people

teaching in high school who were not fully certified 

and people teaching in elementary school who were not 

fully certified for elementary school, is that correct? 

Yes, that is correct, and this is something that we have 

to contend with since being a small school it is rather 

difficult at times to get a fully certified personnel 
which we would like to have.

Now, you have told us that everyone on this list of the 

15 people were qualified to be teachers in the Arkansas 

Public Schools and in the Plum Bayou District, is that 
right?

As far as on paper they do hold a certificate.
Well, where Miss Dye was not certified, you did have 
several people down here who were certified and 

qualified, didn't you, even in that small District?

I will say that these people on the bottom did hold 
certificates.

They were fully certified to teach in the elementary 

schools, is that right?

That is correct.

And you had someone way up here in No. 2 who was not 

even certified, is that right?
GLENN H PERRIN

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I say that she did not hold an eiec^entary certificate. 
That's what I thought.

But other qualities which she possessed would over-rank 

that one little slip of paper which is issued by the 
State Department of Education.

Let s talk about "that one little slip of paper". Does 

it have any meaning at all, "that one little slip of 
paper"?

Yes, it indicates that they have been in school and 

obtained a number of hours and--a number of hours in 

education; therefore, the State Department will certify 
them as teachers.

Is it an idle gesture on their part just to show 

someone had matriculated for a given number of hours? 

No, they are required to get a certain number of 
courses to be certified.

Well, the State has set minimum standards-- 
True.

— for people to teach in the public schools, haven't 
they?

True.

And they say that the minimum standard for a qualified 

teacher in the elementary schools in the State of 

Arkansas is an elementary certification, don't they?
That is correct.

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
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And you kept 

was?
someone who was noc when you had someone who

Mr. Kaplan, in the past, we have employed people with 

only 60 hour, of work, and we have permitted these 

people to work until they obtained 136 hour, end 

qualified. We have people sitting in this room that has 
worked for the District with a 60-hour certificate.
And frequently at that time, at times when such was

Che case, you didn’t have anybody else, you had to have 
someone, isn’t that right?

As I repeated, it’s very difficult at times to get a 
fully certified teacher with the capabilities of

performing like we would like for them to do in the 
classroom.

Mr. Bradshaw, you had someone, didn't you, in Lois Ann
Thomas?

I repeat, she was certified.

And you had someone in Dora Thomas, didn’t you?
She did hold a certificate.

And you had someone in Armenia Kidd, didn't you?
She did hold a certificate.

You had three people from which to choose, didn’t you, 

who had met all of the requirements that the State of 

Arkansas says are minimum requirements for teaching in 

the Arkansas public elementary system? Didn’t you have
GLENN H PERRIN 

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2 A.

3 a

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those three people?
I believe I answered that, yes, sir.
Who made the decision, Mr. Bradshaw, to reduce the 
teacher force?

Again, that was a decision of the Superintendent with 
the approval of the Board.

Now, when you say "the Superintendent-, you mean you?
8 A. Yes, sir.
9 1 a When did you make that decision?

10 A. ihac decision was based on a study or a survey which I
11 made in the school year '68-'69.
12 a At the time, did you consider any alternative to a
13 reduction in force?
14 A. I beg your pardon?
15 a Did you consider any alternatives to a reduction in
16 force?
17 A. Yes, I realized that there would be a necessary
18 reduction.
19 i a No, did you consider any alternative method of unifies-
20 tion of faculty other than reduction in force?
21 A. Mr. Kaplan, we are a rather small school with a low 1

22 enrollment and it would have been not feasible to
23 retain all 13 elementary teachers because our class

1

24 size is actually below what the State would like for it
1251—  Ir to be.

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  a t  J 

F e d e r a l  B u i l d i n g  ' M r  (fc; 
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G- It would not have been feasible for you co carry them?
A. No, sir, it would not.

& I see. Would it have been unfeasible because of money?
A That is one thing, and then space.

Q. Didn’t you have enough money to keep paying them?
A. I beg your pardon?
a Didn’t you have enough money to keep paying them?
A. Yes.

a You could have kept on paying all 15 even if all 15 had 
stayed, couldn't you?

A. Yes, we could have.

a And you have been operating at a substantial surplus 
each year, haven't you?

A. I will repeat, that we have been able here in the past 

few years by being conservative and by being--receiving 

an increase in tax collections, increase in Minimum

B r a d s h a w  - Cross

Foundation Aid, we have been fortunate to build up a 
little surplus of funds, yes, sir.

a I see. Did you consider, in the school year '68-'69, 

in preparation for unification, any alternative method 

of unification of faculty other than reduction in force?
A The only thing that I knew that we could do.

Q. Just yes or no, did you consider any alternative method?
A. No.

Q Mr. Bradshaw, have you ever made an evaluation of any
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teacher or the Plum Bayou District before 19c8-'69?
I beg your pardon?

Had you ever made any evaluation, critical evaluation--by 
"critical" I don't mean necessarily bad points, I mean 

critical for both good and bad purposes--of any teacher 
in the Plum Bayou District before '68-'69?

Well, yes, I had been visiting the classrooms, but as 

far as using a particular form and evaluating this 

teacher and putting these things on file, we just did 
not.

Now, you said this morning that you visited classrooms 
approximately once a month. Is that still your 
testimony?

Yes, sir, it is.

How many times would that make during the year?
On the average of nine months.

Didn't you tell me on deposition five or six times a 
year?

I don’t recall.

MR. KAPLAN: You have a copy?

MR. STARLING: Yes.

I believe that perhaps was our first meeting, was it
not?

I show you a deposition in this case, deposition of 

James K. Bradshaw, Lois Thomas v. The Board of
GLENN H PERRIN

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Education of Plum Bayou District, and ask you to read to 
yourself the bottom of Page II and the top of Page 12. 

(Complies with request) In this deposition I did state 
up to six times or six different occasions. I might 

elaborate on that. As Mr. Edwards testified yesterday, 

that I was in the school on several different occasions 

but not necessarily for going in and making personal
8 observations in the classroom.
9 a Well, that is what I am asking you, I am asking you about

10 the times that you spent evaluating your teaching staff,
11 and didn't you tell me on deposition "I would say that
12 I had spent probably anywhere from 15 to 20 minutes on
13 a particular visit within a classroom on four or five
14 or six different occasions"?

1

15 A. That is correct.
16 Q. Is that still true?
17 ; A. At that particular time, like 1 say, I did not keep a
18 '

i record of the times I visited these classrooms, but I
19 say I visited approximately once a month. It could have
20 1 been less. I have not kept a record of these
21 visitations.
22 a  Well, four times a month (sic) would be less than half
23 of nine times, is that right? Which was it? What is
24 the best of your present recollection about how many
25 times you went to a classroom for evaluation purposes?

GLENN H PERRIN
1 O f f i c i a l  C o u r t  R e p o r t e r  1 i fit i f

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25

I would say still approximately once a month.
About nine times?

Approximately nine times.

Now, when did you visit your legal counsel concerning 

how to go about your plan of reduction in force?

I think perhaps I was in contact with the legal counsel 

in the fall of 1968-'69 school year and asked him on how 
best and fairly to solve the problem of teacher 
reduction.

Now, was it his suggestion to have objective criteria 
or was it yours?

Well, yes, he advised that we needed to come up with 
something, some method whereby we could fairly and 

objectively evaluate all 15 elementary teachers, that 
is correct.

Now, was that the first time that you thought about 
actually using the criteria that later appear on 
Defendants' Exhibit No. 4?

I had given thought to some type of evaluation before­
hand.

Did you do any reading?
Yes, I did.

What did you read?

Well, we have different educational publications. We 

have Math books— not Math books but textbooks as far as
GLENN H PERRIN

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school adminis eracion, for Principals, administrators, 

that usually devote a chapter to evaluation.

What book?

I cannot give you the name of a book.

Can you give me the title of any book that you read?

I was enrolled in a course which we called "Organization 

in Secondary Schools". I also was enrolled in a course 

at State College of Arkansas concerning "Secondary 

Principals" which dealt not into great depth on the 

topic of evaluation, but several publications.

Can you name one that you read in preparation for this 
task?

Even our A.E.A. Journal from time to time carries 

articles on evaluation. Even our Arkansas School Board 

Journal will have an article on evaluation, the 

importance and probably some of the things that should 
go into it.

Did you read any texts? Any authorities?

Offhand, I cannot give you the name of a particular 

textbook.

Can you give me the name of any author of any article 
that you read?
No, sir, I can't.

When did you meet with Mr. Edwards?

I beg your pardon?
GLENN H PERRIN

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When did you meet with Hr. Edwards about the unification 

and the reduction in force?

A Well, this was after the decision that the Board had 

made, I believe it was in— March 28th, 1969, that the 

two elementary schools would definitely be unitized, 

and it was, I believe, in the month of April that I 

held my meeting with Mr. Edwards and the teachers at the 
Tucker-Rosenwald School,—  

j 0- At that time —

j A. — and I explained to them at that particular time upon

unification of the elementary schools that we would have 
to have a reduction in the number of teachers that we 

had in the elementary school, that at the present time 
we had 15 and I felt like we only needed 10 to carry on 

the program which I had given thought to for the upcoming 
school year in the elementary school.

a Now, No. 10 that appears, was that your determination, 
also, your sole determination?

A. Yes , it was.

0- You looked over the number of children and the nuu&er

of faculty people and you decided you could handle your 

whole program with 10 people, is that right?

A. I think I have already given testimony on this topic,

that we had students in classrooms, they were classified 

as Fifth or Sixth Graders and actually functioning on
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Second and Third Grade level,—

That is not my question, now, my question is, you are 
the one who made the determination?

I am trying to justify why I selected 10 teachers, if 
you will permit me.
Sure, go ahead.

--and I felt one of the ways to probably help solve our 

problem since understanding that these people were not 

functioning at the level in which they were placed, to 

put these people on the level where they could actually 

function, and by doing this, we would need more than 
six elementary teachers,—
Okay.

— and this is what we did. I decided that 10 teachers 

would permit us to break these people up or get them 

out of the Sixth Grade room and put them on a level 

where they could perform, because this had been one of 

the problems in the past year, we put people in the 
Sixth Grade room, we fed them Sixth Grade material 

which they could not digest, therefore, they continued 
to get farther and farther behind.

Now, at the time that the Board made its decision on 
March 26th, had you had in your mind how you were going 

to accomplish this reduction, the method you were going
to use?

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1 A. I beg your pardon?

2 ■! G Had you had in your mind the method you were going to
3
1

use?
4

1 A- As I have already testified, I had some ideas of my own
5 on this thing.
6 ! Q. Now, you had already talked to counsel, is that right?
7 A. Yes, and was advised that a method would need to be
8 used.
9 G All right. Now, was that method--had you fixed your
10 mind at that time on the National Teachers' Exam?
11 A. No, sir, I had not.
12 G And you hadn't fixed your mind on any particular
13 criteria, either, is that right?
14 A. No, sir, I had not.

Of the criteria you finally came up with— let's go over 

them— which ones were suggested by the Rosenwald faculty? 

I cannot pinpoint the ones which those people mentioned.

I think Mr. Edwards testified and others have testified 

that we did hold several meetings over there which 

criteria was the--was the topic of discussion, and 

several teachers did mention certain criteria which they 
felt could be used and would be fair.

Was it before or after March 26th that you talked to 

Mr. Turner, the County School Superintendent?
I

I was in contact with Mr. Turner throughout this period
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or rime, ana I talked to him on different occasions, 

and on what date, I cannot give you a specific dace.

Was it before or after that you showed him the form?
I beg your pardon?

Before or after March 26th that you showed him the form?
I don't recall.

You don’t remember?

No, sir, 1 do not.

Did you show him the form in the manner it was introduced 

here with all of the numbers put in or did you show him 
the blank one?

Mr. Turner was presented a rough copy of the form which 
I proposed to use.

No numbers filled in?
No, sir.

At the time that you submitted the form to the School 

Board, were any of the teachers notified that the form 
would be submitted then?

As far as me announcing to the teachers, "All right, 

teachers, I am going to submit the evaluation form to 

the Board for their rejection or approval", no, I did 
not make this announcement.

Do you know if any teacher ever saw this form?

As far as seeing the form, I will say no, but they did 

know what criteria was going to be used because it was
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discussed aiany times.

And did they know cne "1" througn “5" scoring system 
you were going to use?

Whether or not I told them I would score them with a 
"1" or "5", I don’t recall.

At the time that you submitted the completed list, 

which had Nos. 1 through 15 on it, did you tell any 

teachers at that time that the reduction in force scheme 
was going to be presented to the Board?
I beg your pardon?

At the time that you presented the "1" through "1 5 " 

ranking to the Board you testified about earlier, did 

you tell any of the teachers at that time that your 

rankings were going to be submitted to the Board?

I simply stated to the teachers that I would make my 
recommendations to the Board.

Did you tell them at which meeting that it was going to
be?

No.

At the time that you submitted it to the Board, was 
Mrs. Ramsey’s name still on it?
I beg your pardon?

At the time that you submitted the "1" through "15" 

listing, was Mrs. Ramsey's name still on it?

Mrs. Ramsey had already notified me that she would not
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be with the District before this was submitted.
•

2 a How about Mr. Edvards?
3 i A- Mr. Edwards also informed me.
4 a Did you ever have a conversation with Mr. Edwards about
5 | his leaving the District?
6 A. No, I did not have— I beg your pardon, at one time Mr.
7 J Edwards asked me for leave to attend some kind of
8 meeting or conference. This was months before the school
9 was closed down.

10 a I am sorry, I am not talking about that.
11 A. I don’t know what you- -

12 a I am talking about his retiring from the District. Did
13 he ever tell you he was going to be leaving the
14 District?
15 A. He did not.
16 G Never did?
17 1 A. Not until this evaluation had been made.
18 ! G Did he ever give you a reason?
19 A. No, sir, he did not.
20 a Now, when you did your evaluation, it is your testimony
21 you evaluated only those people who were then teaching
22 in the elementary school, is that right?

23 A. That ts what I have testified to, that I evaluated the
24

25
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15 elementary teachers.

And you didn’t consider, then, even those who might have
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h e l d  high school certification for any position in the 
high school, or vice versa, is chat right?
At that time, I did not.

And you did not ever, in this evaluation, contemplate 
any of the high school people— the high school had 
already been unified, is that right?

Yes, we were unified in 1966-'67, and at that particular 

time there was no need for reduction in staff in the 
* 6 8 - ' 6 9  school year.

right. Let's look at this teacher composition, 

the racial composition of your faculty, starting in the 

year 1963-'66, and let's see what we ended up with the 
first year of full unification.

I only have *67-'68, *68-'69.

Would the data concerning local school districts help
you any?

Probably so.

All right. In 1966--I am sorry, in 1963-'66, what was 

the total number of your black teachers, can you tell
us?

Nine.

Was anyone teaching on Title I that year?

'63-'66? That is the year that Mrs. Evans was placed 
on Title I, I believe sometime in January.

All right. And then how many white teachers did you
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1 have?

2 A. Thirteen.

3 Q. Thirteen white and nine black?
4 j A. That is true.

5 |J Q. All right. Now, in '66-’67, the first year of your

unification of the high school, how many black and
7 j how many white?

8 j A. What year are you calling for?

s j Q- ’66-’67.
10 A. Here we are. In 1967--

j
11 j a No, ' 66- '67.

12 A. In '66-*67, we had 11 Negro teachers and 13 white.

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a

And in 1967-*68?

We had 10 Negro teachers, 13 white.

And in '68-'69?

We had 10 Negro teachers and 13 white.

And the first full year of total integration, what did 
you have?

We had six Negro teachers, 12 whites.

So from the time of 1966 to 1970, '69-*70, from '66-'67 

to '69-'70, your black teachers fell from 11 to six 

and your whites from 13 to 12, is that right?
That is true.

Do you ever recall Mr. Edwards talking to you about 

equalization of the differences in the money paid to
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black teachers and to white teachers?
399

I d o n ’t recall a conversation on tnat matter.

Never?

No, sir, I do not.

Did your District have a policy of paying black teachers 
less than white, or a practice?

To my understanding, when I became Superintendent, the 

salaries had been pretty well equalized, and since I 

have been the Superintendent in that District, I will 

assure you of one thing, that both groups of teachers 
have received the same increase.
How many--

A black teacher, if they get $300.00, then the white 

gets $500.00. This is the way I have operated, and no 
teacher can tell you any different.

Now, at the time that you took over, it was still black 

teachers who were making less than white teachers for 
the same job, isn't that right?

We can look at the records and determine that. Yes.

And at anytime since that period of time, other than 

the fact that the raises have been the same, was anything 

done to bring the lower level teacher up to the higher 

level white teacher?

Well, this is the problem on that, Mr. Kaplan. Assuming 

that one teacher is making $4,000.00 and this teacher
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over here is making $4,200.00, the State Departaent giv>__ 
a n a t  grant of $500.00, each teacher is entitled to a 

$500.00 raise, and anytime a grant is given, a flat 

grant like that, then you cannot close that gap.

There is nothing to prevent the District itself from 

spending its own money to close that gap, is there?
If the money is available.

I see. Now, how long did Mrs. Blair spend with you 

when she told you about her feelings, her evaluation 
of the teachers in her school?

This was probably an hour conversation between Mrs. Blair 
and myself.

How long did you spend reading Mr. Edwards' evaluation?

I did not take probably over 30 or 40 minutes —
I see.

--to study it.

Did you ever call him and ask him about any of the 

intangibles in that form, what he used to say that Mrs. 

Thomas deserves a "1" here but a ■2" here or whatever 
it may be?

I believe I testified that I did look at his form and 

did not use it; therefore, I did not call Mr. Edwards. 
Now, it’s my understanding you gave three reasons for 

your personally assuming this duty of ranking the 

teachers. That was, you had responsibility anyway, is
GLENN H PERRIN

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that correct?

The Board delegates me this responsibility, tnis is one 

responsibility that I must assume, making recommendation 
to the Board of Education for the teachers to be

employed to provide the educational instructions for the 
boys and girls.

Who— before the school year '67— or, ,68-,69, who was 
the one who made all of the recommendations for hiring 

and firing of teachers at the Rosenwald School?
' 6 8 - ' 6 9 ?

Before that time. Wasn't the black Principal the one 

who almost always made all of the recommendations 

whether someone was hired or fired or retained or not 
retained?

I think the records will show that I made the 

recommendations to the Board as to who to be retained 
and who released.

But isn't it true, sir, that you relied almost exclusive­
ly on the black Principal's recommendation?

I will make this statement, that I did discuss it with 

Mr. Edwards, but I was under no obligation to use the 

recommendation that he made to me, because it was my 
responsibility to the Board of Education.

From your knowledge of Arkansas school districts and 

practices, hasn't it been the practice that the black
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Principal always made the recommendations for his 

school and that his recommendations were nearly always 
followed?

I would say in some cases they may be followed; in 

others, the person in the top position will assume the 
responsibility.

You also said that each Head Teacher evaluated only the 

teachers in their own school and didn't know the others, 
is that right?
That is correct.

I see. And, lastly, that Mr. Edwards and Mrs. Blair 

were not included in the evaluation, that only you 
could do that?

They were not included in their own evaluation.

They did not give you a self-appraisal, is that correct? 
That is correct.

I see. Now, in the various criteria, on your direct 

examination you said that under “Teacher Competence* 
came two basic heads, “Ability to Relate to the 

Students" and the "Teacher's Preparation*?
Right.

Both academic training and certification, is that
right?

That is correct.

I see. Now, when you considered academic training, did
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you consider the institution that someone wer.t to?
A I certainly did not.

Q. You considered only their transcript, is that right?

A. I reviewed their transcript, which I had a copy on file,

i Q. All right. Did you have Lois Thomas' transcript?
A Yes, I did.

0- Do you still have it?
i
A At the present time, I do not have.

j Q. Do you recall what her grade point was?
I! A. I will, if she has no objections, tell you that she has 

approximately 22 C's, some D's, and an F on that 

transcript. I cannot tell you what her GPA is at this 
time.

Q. I am sorry, you couldn't tell me what?

A. I cannot tell you what her grade point average is.

Q- All right. You did say she had some A's, is that
I

correct?
!

A I think, perhaps she had some A's, B's, and several C's, 
some D's, and perhaps an F.

a I hand you a document which is a notarized certification
I

and ask you if you are familiar with that?

A I would say that this would be considered as an average
transcript.

Q. As an average transcript?

A Yes, sir.
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Okay. And that is, at that time Miss Garrett, now Mrs. 
Thomas, transcript, is that correct?

That is correct.

And she was certified at that time?
I beg your pardon?

And she was certified at that time?

I believe I testified to that, yes.

All right. How, her ability to relate to students, was 
there some deficiency in that?

Well, my personal observation, I find that she did not 

have the ability that some of the other 15 teachers had.

In giving them their number for that "Teacher Competency", 

did you rank them against the other?

No, sir, I did not. I think I testified that I 

evaluated these 15 teachers in reference to the 
criteria.

1 see. But not against each other. Now, you gave her a 

"2" in that— well, I will give you the thing so you can 

refresh your recollection. You gave her a "2" putting 

all of those factors together, is that right?
Yes, sir, that is correct.

I see. Now, what were the component parts of 

"Discipline", the next category, "Ability to Maintain 

Classroom Discipline"?

Yes, "Ability to Maintain Classroom Discipline", I took
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in there consideration of the teacher's ability to 

primarily have control in the classroom to where there 

was mutual respect between the students and the 
students and the teacher.

Q- All right. Anything else?

A. And I also took into consideration there that an

atmosphere which would be conducive to a learning 

situation should prevail in the classroom.

Q. Now, would you say that "Teacher Competency" as a

subject was an overall general classification of how a 
teacher performs his function, his or hers?

A. Would you repeat the question?

Q. Yes. Would you say that the category "Teacher

Competency" was a general category of how a teacher 

performs their function as a teacher, how they performed 

in their profession, which included things like "Can 

you teach a kid something because it's too noisy in the 

class", "Can the supervisor talk to this person and have 
the person listen", things like that?

A. Yes, I think all of these things could be taken into 
consideration.

Q. And would you--

A. Like I mentioned that preparation would also have to be 

considered under "Teacher Competency".

Q. I see. Would you say that in some way all of the other
GLENN H PERRIN 

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chings that you have here, "Ability to Maintain 

Discipline", "Teacher-Teacher Relationship", Teacher- 
Pupil Relationship", and "Cooperation with the Total

School Program", are in some way really functions of 

the teacher1s total performance, his total "Teacher 
Competency"?

Yes, I would say all of these things would relate to 

that in one--reference to "Teacher Competency".

I see. Now, on cross examination, talking about this 

enlarged list with Mrs. Blair at the top and Mrs, Kidd 

at No. 15 position, you talked about retaining black
i

and white teachers and not retaining Mrs. Ramsey, Mrs. 

Gordon, Thomas, Thomas, and Kidd. Actually, what 

happened was, by the time you went to the School Board 

the only elementary school teachers let go were black, 

isn't that right, the non-retained teaciers were black? 
Yes, that is true, because there had been two people 

that had informed me that they would not seek reemploy­

ment with the District for the upcoming school year.

Do you know where Mr. Ramsey is now? Mr. Ramsey.

I believe Mr. Ramsey is in Jacksonville, Arkansas.
Do you know where he has his home?
Yes, Ido.

Where?

In Beebe, Arkansas.
GLENN H PERRIN

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G. And during his last year in the District, wasn’t he

building that hotae? Did you know he was building that 
home?

A. He had the home built prior to that year.

a And didn't he, at one point in that year, tell you and

several others in the District in your presence that 

he thought that that year was going to be his last year?
A He did not tell me.

Q. Never did?

A No, sir, he did not.

Q. Now, at the time that you assumed your duties as

Superintendent, or very shortly thereafter, did you have 

any occasion at all to become involved in the health 

problems of the District, children being tested, eyes, 
ears, things like that?

A. Yes.

Q. Is that a service provided by your School District?

a. No, sir. No, sir, it is not. This is a service which 
is provided by the County Health Center.

Q. And did the County Health Center provide for the 

testing of both black and white children?

A Yes, these people had the equipment, and by making an 

appointment with those, those people would bring the 

equipment out and usually volunteer people would come in 

from the community, such as PTA mothers, would come in
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and actually do the testing, yes, sir.
I

2 a

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What does Mrs. Keith do tor her $540.00?

Mrs. Keith acts as a Coordinator and she was in contact 

with the Health Center setting up dates for these 

people to bring the equipment out and primarily to get 

the machines into the school and then let the parents 

corae in and administer the screening of vision and 

he a r i n g .

Do you know whether she had anything at all to do with 

any of those aspects at the Rosenwald School?

I am satisfied that she was in contact with the Health 

Center to see to it that they did bring the machines 

o u t .

Do you know if she did?

In fact, I know she did.

Do you know who was the person who carried those 

children to the Health Center when they had to be 

carried to the Health Center?

I do not know.

Are you saying, Mr. Bradshaw, that you did not know that 

Mrs. Evans was serving in the capacity of Health

Coordinator?

So help me, I did not know it.

Did you ever have to sign a form for the State on who

25 was receiving Title I?

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2 5

I am the one responsible for any forms or letters to be 
sent in or reports to the Federal Division of 

Education in Little Rock, Arkansas.

I am not talking about the responsibility,
I am the one--

— who took the responsibility at the local school?

I am the one that submits the form. I am the only 

bonded individual; therefore, I am responsible for any 
funds that are expended.

Not funds. Not funds. Reports.

Reports. I am still responsible for the reports that 
are to be submitted.

Mrs. Evans never signed the reports?

She is not responsible for submitting any report to the 
State Department of Education.

That is not what I asked. She never signed the report?
I don't know that she did or not.
You don't know?

No, sir, I do not.

Do you know who maintained all of the health records 

for the children at the Tucker School?

I do know this, that the State law requires that health 

records be maintained, which is usually a responsibility 

of each classroom teacher. Now, whether or not Mr. 

Edwards appointed Mrs. Evans for this position, 1 don't
GLENN H PERRIN

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know. It is a State law that we maintain health records 
on our boys and girls, usually it is the responsibility 
of the classroom teachers to do this, 

a Who did it at Tucker--I mean at Plum Bayou?

a. I believe each teacher did help keep these records up.

Q. Did you ever look at the records at Tucker?
A. No, I did not.

Q. Do you know where they were kept?

A. I am assuming they were--that they were kept in Hr.

E d w a r d s ’ office on file.

0- Isn't it a fact, Mr. Bradshaw, that with the exception 

of one black teacher aide, all non-teaching Title I 

remunerative positions were held by white people?

A. I think that is correct.

Q. Secretaries?

a. Yes , I do have one secretary that draws partial pay from 

the Title I funds because she is responsible for keeping 

books in regard to Title I.

Q. Bookkeepers?

A. She is the one. Secretary-Bookkeeper.

Q. The Health Coordinator?

A. She is considered a parttime Health Coordinator, yes. 

a All right. You have one teacher aide who was black at

one time, is that correct?

A I think that is true.
GLENN H PERRIN 

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Who was that?

At the present time I c a n ’t call her name.

Odessa Davis, is that the one?

That is true.

All right. Social Worker, white?

Yes.

That was Mrs. Bradshaw, your wife?

That is correct.

The Special Secretary, Mrs. Archer, white?

This is one which I had reference to as S e c r e t a r y  

Bookkeeper for financial accounting for the Title I 

program.

So anyone who has drawn any Title I money, with 

exception of one teacher aide, in a non-teaching 

position, has been white, is that right?

That is correct.

How about your bus drivers?

Bus drivers, we have five bus drivers.

How many blacks?

We have two.

Two blacks?

That is correct.

How about last year?

Last year?

Uh-huh.

GLENN H PERRIN
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We only had one.
Out of five?

That is true.

Now, of the children who get bussed in your District, 
what percentage--

MR. STARLING: Your Honor, I am going to object to

this line of questioning. It is, in fact, outside 

of the scope of direct examination which I examined 
Mr. Bradshaw on. I don't remember any situation 

where I talked about bus problem or bus drivers or 

the non-administrative teaching positions with 
reference to black versus white.

THE COURT: Well, it's alleged in the Complaint
Mr. Starling.

m.a STARLING: Yes, sir.

Of the children who get bussed in your District--let's 
talk just very briefly for one second about the way the 

District lies. The Plum Bayou School is in the Wright 

community, is that right?

That is true.

The Wright community is almost totally white?

Surrounding area, yes.

All right. Eight miles down the road live all of the 

black children, is that right?
In recent years that has developed to be the most densely

G L IN N  H PERRIN
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populated part of our School District, true.

And probably a good 95 percenc of the black children 

live right there in that one little Tucker community, 
is that right?

I would say approximately 35 percent live there.
Thirty-five?

Probably 35 to 40 percent.

Of the children who get bussed in your District, what 

percentage are black and what percentage are white? 

Well, I think I reported that we have approximately 

90 percent black, 10 percent white, and we transport 

approximately 98 percent or 99 percent of our boys and 
girls, black and white.

At the time of these bonuses, what have they averaged 
in the last several years?

I don’t have those figures with cae. I would say on the 
average of anywhere from $50.00 Co $150.00 or maybe 

$200.00, whatever the audit report shows that has been 

an underpayment in teacher salary, we simply count up 

the number of teachers which the District has employed 
and then we pay this to those teachers that was 
teaching in that particular year.

Now, that figure, that bonus figure, is not included 

in the teacher salary figure in the interrogatories, is
that correct?

GLENN H PERRIN
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Bradshaw - Cross
A. I beg your pardon?

a  That bonus figure, that is not included in the teacher 

salary figures in the interrogatories, is that correct?

A. Somewhere it would be showed in the expenditure of the 
School District.

Q. But not in what you have listed as the salaries for the 

various personnel in the District, is that right?
A. (No response)

Q- In Answers to Interrogatories you have appended

■Salaries of Teaching Personnel" for *66-'67 all of thd 

way through *69-'70. Do those bonuses figure in there?
A. No, they do not*.

Q. All right. Now, there is an allegation in the Complaint, 

Mr. Bradshaw, regarding the manual that the District has, 

"Principles, Policies, and Objectives". Are you 
familiar with that manual?

A Yes , sir , I am.

Q. Please direct your attention, sir, to Page 6 of that
manua1.

A. Give me one second.

a Certainly.

A. I think I have a copy.

MR. STARLING: Your Honor, again I am going to

object to this line of questioning in that it was 

not covered on direct examination. If Mr. Kaplan
GLENN H PERRIN

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wants to bring up and prove the allegations, the
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time to do it was in his case in chief, ana I feel 

he is going far outside of the scope of direct 
examination.

THE COURT: Well, Mr. Starling, this is a

matter of equity which the Court is consider­

ing and it is a part of the overall question, 
and I think it's appropriate.

MR. STARLING: Okay.

Do you have a copy now, Mr. Bradshaw?
Yes, I do have.

All right. Thank you. The matters at the top of 

Page 6 regarding the composition of the Board of 

Directors of the Plum Bayou-Tucker School District, do 

you recall how that matter got inserted in here, whose 

direction it was?

I would say this matter probably came into existence 

20, 25, or 30 years ago.

In the tenure that you have had as Superintendent, has 
that matter ever been considered for a change by the
Board?

This has not been discussed.

Has there ever been, indeed, any more than one black 

School Board member?

We have had several to seek election to the Board but
GLENN H PERRIN

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were d efeated.

Now, the Tucker community is now an ail-black community, 

is it not?

No, sir, it is not*

Any white children come from over there?

Whether or not we have any white children residing 

within the Tucker community, I don't know.

Wright community, is that all white?

I would say no at the present time because we have had 

a couple of Negro families to move in.

Now, in your 15 years or so tenure in the District, 
although the schools were segregated at one time, 

could you tell us whether or not the racial composition 

of the District itself--I am talking about the number of 

students in the District--has always been majority 
black?

No, sir, it has not.

How long has it been majority black?

I would say probably in the last eight to ten years it 

has become majority black.
And how long has it been the rather lopsided percentage 

that you have told us about today, approximately 90-10 

black?

That was only here in the past year or so.

Let's talk for just a moment again about Asive Thomas.
GLENN H PERRIN

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When Mr. McConnell began teaching for you, sir, cell u- 

how many Social Studies courses he uaght.

The first year he was teaching two Social Study course . 
And what did he do the rest of his tiiue?

He devoted it to Physical Education.

At the time he was Social Studies teacher for two 

courses, you had another Social Studies teacher, also, 

is that right?

That is true.

Is there anything to prevent, after Mr.--after Mr.

Thomas acquired his summer of 1968 hours at Arkansas 

AM&N College, after his graduation, and after his 

certification, was there anything to prevent him from 

teaching one or two hours in Social Studies?

Let me restate--

Can you answer yes or no?

Let me restate some of the testimony which I have 

previously given.

Can you answer that question yes or no?

Frankly, the reason that he was let off is because—

Can you tell me yes or no to that question?

He would still not have been certified.
i

That's right. That’s not the answer to the question,
:though. Yes or no? Was there anything that would have 

been injurious or harmful to the District as far as the
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State Board of Education is concerned?

As far as my concern, with two hour addition in Social 

Study, he would still not have been able to provide the 

type instruction in Social Studies that would have been 
desired in a Social Study room.

That's not exactly what 1 am asking you, Mr. Bradshaw. 

What I am asking you is, as far as the State Board of 

Education is concerned, could he have taught two hours 

without any kind of criticism of the District? Isn’t 
that right?

He may have.

That is correct, he may have done that. So that without 

the District suffering any consequence at all, he could 

have done, with the certification that he had, exactly 

what Mr. Bruce McConnell did in 1968-*69, isn’t that 
right?

I am saying that Mr. McConnell was —

Wait a minute, just answer the question. Couldn't he 
have done in '68-*69 exactly what Mr. McConnell did 

without the District suffering any ill consequences 
from the State Board of Education?

The students would have suffered.

Oh, no, no, no, without the District suffering from the 

State Board of Education any ill consequences.

Well, the State Department might have permitted him.
GLENN H PERRIN 

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They would have permitted him, w o u l d n ’t they?

Perhaps.

Well, isn't the answer "Yes"?

Actually, I d o n ’t know the law on that at the present 

time.

To the best of your knowledge, the answer is "Yes", 

i s n ’t that right?

It may he possible.
I

That's right. Now, even while he could have been doing 

that without the District suffering, the District had 

Mr. Klutts, who was emergency certified, isn't that

right?

This was in--
i

Just a minute. i
--in the area of education hours.

Wait a minute. While he could have been doing this
i

without any ill consequences to the District, the
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District had an emergency certified man in Mr. Klutts,

didn't they?

I think I have testified to that, yes, sir.

And he's white, isn't that right?

Yes , he w a s .

They had Mrs. Dye, or who by that time had become Mrs. i
Wall, she wasn't properly certified for what she was 

doing, was she?
GLENN H PERRIN 

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1 ;• A. T h a t  i s  c o r r e c t ,  I  h a v e  t e s t i f i e d  t o  c h a t .

2 u  S h e  w a s  w n i t e ?

3 A. R i g h t .

4 Q. Now, you had some other people, too, didn't you, who
il5 also that year didn't have any proper certification?
j

6 A. Y e s ,  sir, I h a d  Mr. Hunter Douglas.'I
7 Q. Mr. Hunter Douglas. That was the year before. Let's

8 ! talk about the year--

9 A .  The same year that I had Mr. Thomas.

10 Q. Oh, no, no, no.

11 MR. STARLING: Let him answer the question, please,
12 Your Honor.

13; MR. KAPLAN: Well, I would like him to answer the

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THE COURT: Well, will you let him answer the

question, Mr. Kaplan? You asked a question 

and he starts to answer and then you interrupt 

him as though you are going to do the 

testifying. Let him testify and you ask the 

questions.

Yes, sir, I did have Mr. Thomas who was not fully 

certified in Social Studies. 1 did have Mr. Hunter 

Douglas in that same year who was not fully certified. 

Neither was providing the type of instruction in 

Social Studies that 1 felt like our boys and girls were
GLENN H PERRIN

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entitled to receive; therefore, upon those findings, I 

did not recommend to the Board for their re-contract.

a That’s not what I am asking you, sir. What I am asking 

you about is school year 1968-’69. Now, can you get 
that in your mind?

A 1968-'69, yes, sir.

a All right. By that time you had hired Mr. McConnell, 
isn ' t that right?

A. That is true..

a Now, what I am asking you is, that in '68-'69, Mr.

Thomas could have, without any criticism, without any 

adverse results to the District, taught exactly what 

Mr. McConnell taught, isn't that right, with his 
certification?

A. Did he make application?

0- Sir, is that right?

A. I am still not convinced that he could provide the type 

instruction that I wanted produced in that classroom.

G  Sir, could he not have taught exactly what Mr, McConnell 

taught without anyone suffering any adverse consequences, 

without that District suffering from the State Board of 
Education any adverse consequences?

A. The State Department probably would have permitted him 
to do this.

G All right. And exactly at that time in that school year
GLENN H PERRIN

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Chat District had non-certified white personnel teachxng, 
isn't that right?

That's true, but I think in their performance it was 

justiciable to retain them with the District.
Because they were white?

No, sir.

It just so happened they were all white, didn’t it?

They might have been white, but they were providing the 

type of instruction that our boys and girls are entitled 
to receive.

And the State Department of Education says that their 

certification required is minimum for what a child 

should receive from a teacher, isn't that right?

They are permitted to work but must return to school, 

pick up additional hours to eliminate those deficiencies, 

which these individuals are doing, Mr. Kaplan.
iI see. And Mr. Klutts didn’t do it for three years,

did he?

It took him three summers —

Took him three summers.

--to pick up the required education hours which he 

needed, which he has at the present time.

Did you ever consider Mr. Asive Thomas for the Job that 

Mr. McConnell held the next year?
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He did not make application, Mr. Kaplan.
GLENN H PERRIN

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He didn't make application?

N o t  t o  m e ,  I  did n o t  receive an application.

Did you ever consider black man, Mr. Asive Thomas, for 

that position?

Are you telling me that I needed to go out and search
for this man?

I am asking you, did you ever consider Mr. Asive Thomas —  

THE COURT: Now, gentlemen, the Court is not
going to permit this to go on. Now, Mr.

Kaplan, will you ask questions in a manner, 

as you well know from your experience and 

being an experienced lawyer, to seek the 

information that you are attempting on cross i
examination, and will you, Mr. Bradshaw, will 
you answer the question,—

THE WITNESS: Yes, sir.

THE COURT: --and will you gentlemen not

engage in arguments as has been going on here 
now for the last several minutes?

THE WITNESS: Yes, sir.

Mr. Bradshaw, did you ever consider, evaluate, think 

about Mr. Asive Thomas for that position, that teaching
I

position, that we later have learned Mr. Bruce 

McConnell occupied in the school year 1968-'69?

May I answer your question in this manner: The position
GLENN H PERRIN

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was open, and I did receive some applications. I d^d 

interview different individuals, and I recommended to 

the Board that Mr. McConnell be hired. I did not take 

in consideration Mr. Thomas, because I did not receive 

an application from hixn in that particular year.
Did you tell him--

The answer is "No", that he was not c  asldered for that 

year for reemployment, because he had been out of the 
District for one year.

No, no, no, no. He had just been let go by the 

District, isn't that right, at the school year *67-'68 
he still worked for you, didn't he?

Right, he was there in '67-'68.

Right. So when Mr. McConnell began, he had only been 
out for a very, very few months?
Mr. McConnell came in-- 

' 6 8 - '69 ,  did he not?

That's correct,-- 
All right.

-- ' 69-'70.

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Q- Okay. Now, at the time you let Mr.

you have an interview with him?
A. With Mr. Thomas?

0- Uh-huh.

A. No, I did not.
GLENN H PERRIN

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b r a asnaw - Cross 425

Q. You didn’t have an interview with him?

A. As tar as the position that was open?

a Oh, no, no, no, no. Did you have an interview with him 
telling him why he was going to be let go?

A Yes, I informed him that I felt that he was weak in the 

area of instructions and I felt that the boys and girls 

needed more instructions or a higher quality of 

instructions in the area of Social Studies, and I 

discussed this with Mr. Edwards, who was the Head 

Teacher at that time, and Mr. Edwards also agreed that 

he was weak in this area, and this is why I did not 
recommend him.

a Now, did you tell him at that time that you had that 

meeting with him that you were having a position open 

up that had four hours of P.E. and only two hours of 

Social Studies? Did you tell him?
A. No, I did not tell him that.

Q. Did you know it?

A. I beg your pardon?

Q. Did you know it?

A. I don't know if I knew it at that particular time or

not.

Q. Did you know it shortly after that?

A. Yes , I did.

Q. Now, you talked about a Mr. Cornelius Sanders, who you
GLENN H PERRIN

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IS

hired now. Now, Mr. Sanders, he*s not certified, is 

he?

As of today he would be a fully certified Physical 
Education teacher and Social Studies.
He would be?

Yes, he completed his last three hours from AM&N College, 
and at the present time he is supposed to have his 

application for his certificate filed with the State 

Department of Education, and I should be receiving his 
certificate any day now.

Now, as far as you know, as his immediate employer and 

the man who has hired him and supervises him, as of 

this moment and time as we are sitting here right now,
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he isn't certified, is he?

As far as I am concerned, he is.

How about as far as the State, Arkansas State Department |
of Education?

This is what I am telling you, that he has sent his 

application in with his transcript showing that he has 

all of the requirements granted to him from Arkansas 
AM&N College.

When did you hire him?

1 hired him in the summer of '69-'70 to be employed for 
the '70-'71 school year.

At the time you hired him, he couldn't have gotten
GLENN H PERRIN

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certified, could he?

Again, I employed him on the same basis as I have 

employed other teachers, more or less emergency
certificate.,

Okay.

MR. KAPLAN: I think that's all, Mr. Bradshaw.
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REDIRECT EXAMINATION
BY MR. STARLING:

0- Mr. Bradshaw, one thing on Mr. Thomas which we have

talked about before, I believe you testified on cross 
examination that the reason that you--one of the major 

reasons that you did not renew Mr. Thomas’, Asive 

Thomas' contract for the year ‘6 8 -'6 9 --excu se  me-- 

'67-'68 was because of his weakness in the area of 

Social Studies teaching, is that correct?

A That is correct, yes, sir.

a I believe you previously testified that a man holding

the same position that Mr. Thomas did in the Plum Bayou 

High School, a Mr. Hunter Douglas, what was the reason 

that you terminated him for?

A. Identical same reasons, he was weak in the area of 

Social Studies.

0- Now, was he a white man?

A Yes, sir, he was.
GLENN H. PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 9 0



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B r a d s h a w  - R e d i r e c t 428
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Did you consider Mr. Hunter Douglas for the job of P.E. 

instructor and Social Studies teacner in 1968-'69 as 

Mr. Kaplan has asked you to consider Hfc. Thomas?
No, sir, I did not.
Why?

Because he was weak in the area of Social Studies and 

this individual had to teach in this particular area. 

Did you discharge or not renew or recommend to the 

Board that Mr. Hunter Douglas' contract not be renewed 

at the exact same time that you did Mr. Aslve Thomas? 
Yes, sir, that is true.

I believe those letters of termination are entered in 

evidence as Plaintiffs' Exhibits 1 and 2, is that not
correct?

Yes, sir.

Now, this Mr. Sanders who you recently hired, '69-'70, 
is he a Negro?

Yes, sir, he is.

So there is really not any discrimination because you 

hired him in reference to Mr. Thomas, is there?

MR. KAPLAN: Objection, Your Honor.

No, sir, none whatsoever.

MR. KAPLAN: Objection, and move to strike.
THE COURT: Well,—

MR. KAPLAN: He has just asked this witness the
GLENN H PERRIN  

O f f i c i a l  C o u r t  R p o r t ir  
F e d e r a l  B u il d in s  

EL Do r a d o . A r k a n s a s  7 i 7 «o



429B r a dshaw - R e d i r e c t

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conclusionary questions that the Court is being 
required to answer.

MR. STARLING: Your Honor, my only feeling is--

THE COURT: Well, about the fourth time that 

question has been asked and answered in th is 
record, and I see no reason— the Court 

remembers it, I will tell you, gentlemen, 

both of you, so 1 would suggest that there 

would be no necessity to ask him that question 
again.

Mr. Bradshaw, in allegation XV of the plaintiffs* 

Complaint, they allege that "Black teachers are not 

given the opportunity to earn extra money as bus 

drivers. Only white teachers are allowed this privilege.* 

Now, how many black teachers— how many black bus drivers 
do you have?

We have two.

And are those two black bus drivers— how long have they 
been employed by the District as bus drivers?

One of them has been employed 15 years or more, and we 

employed one for the *70-’71 school year.

During your tenure as Superintendent, has any black 

teacher ever requested or make application to become 

a bus driver with the District?

Since I became Superintendent in 1966-'67, 1 have never
G U IN N  H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 * 0



430
araas n a v  - R e d i r e c t

had a black teacher to make a request for a bus driving 
position.

In the year 1970-'71, did you have a black teacher to
4

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make a request to become a bus driver?

Yes, sir, I did. He did express a desire to drive a
bus.

What is his name?

Mr. Cornelius Sanders.

And was he denied that opportunity to earn extra money 
as a bus driver?

No, sir, he was employed as a bus driver.

So then your testimony is, since you have become 

Superintendent in '66-*67, there have been no black 

teachers that have ever requested or made application—  

No, sir.

--to become a bus driver, with exception of one?

With the exception of one for the *70-'71 school year, 
Mr. Sanders.

And you hired him. Now, Mr. Bradshaw, how many non­

teaching administrative positions do you have in the
District?

We have three non-teaching administrative positions 
in our District.

What are those?

We have two, which are secretaries, primarily
GLENN H PERRIN 

O f f i c i a l  C o u r t  R epo r t er  
F e d e r a l  B u il d in g  

EL Do r a d o . A r k a n s a s  7 i7 »o



braasnaw R e d i r e c t 431

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responsible tor maintaining books, keeping books, and 

one parttime Health Coordinator.

Now, who are the two secretaries, what are their names? 

Mrs. Maynard and Mrs. Charlene Archer.
Are they white?

Yes, sir, they are.

And who is the Health Coordinator?
Mrs. Robbie Keith.

And is she white?
i

Yes, sir, she is.

How long have the two secretaries held the jobs in thete 

non-teaching administrative positions?

Mrs. Archer was employed, I believe, in 1965 prior to 

me becoming Superintendent, and Mrs. Maynard was 

employed in 1966-'67, 1 believe that's correct, and Mrs. 
Robbie Keith was employed prior to me becoming 

Superintendent of the District in 1965-'66 school year. 

Since you have been Superintendent of this District 

beginning in 1966-'67, has any Negro person, patron, 

teacher, or otherwise, ever requested or made application
i

to you for a job, a non-teaching administrative job, in 

your District?
No, sir, they have not.

Now, briefly, Mr. Bradshaw, looking back at the 

evaluation form, is it true that Mrs. Ramsey was
GLENN H PERRIN 

O f f ic ia l  Co u n t  R epo rter  
F e d e r al  B u il d in g  

EL Do r a d o . A r k a n s a s  7 i7 »o



n r a u s n a w  - K e a i r e c t 432
1| certified in elementary education?
2 A. That is true.

* a ^ d  is it true that Mr. Edwards was certified in

secondary education but not in elementary education?
||

5j A. Yes, sir, Mr. Edwards was certified in secondary
I

8 education.
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And Mr. Edwards is a Negro, right?
That is true.

And Mrs. Ramsey is white?

That is correct.

And it's true that Mrs. Janet Dye was certified in 
secondary education and not—
That is true.

--elementary education? Do you recall what Mrs. Dye's 
transcript revealed in reference to her academic
background?

Yes, sir. She probably has--in fact, I know she has 

the highest grade point average or overall grades on 

her transcript than any teacher in the Plum Bayou- 

Tucker School District. In fact, I believe it's about 

3.3 or 3.8, which would be approximately a B+. She 

has all A's and B's with exception one grade which is 
a C.

I show you a document here entitled "Permanent Record" 

from the Arkansas State Teachers' College, name Janet
G L E N N  H P ER R IN

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a n s a s  7 i 7 s o



1
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4 a
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20 | Q.
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Dye, and ask. y o u  i f  you can identify  vhat copy of her 

transcript?

Yes, this is her transcript.

Would you read the grade point average on that transcript? 

Yes, s i r .  Possible "4.0" and Mrs. Wall has a "3.75".
All right, thank you.

(Whereupon, a document is shown to counsel for the
plaintiffs.)

MR. KAPLAN: No objection.

MR. STARLING: I would like this marked for

identification, Your Honor, and introduced in 
evidence.

THE COURT: Let it be received.

MR. STARLING: Your Honor, with that, I have no

further questions.

MR. KAPLAN: Very briefly, Your Honor.

RECROSS EXAMINATION
. KAPLAN:

In looking at Mr. Thomas' weakness in Social Studies, 

did you consider his transcript, too?

Yes, I had access to all teachers' transcripts. This 
is one requirement of the State Department that we have 

on file a transcript of each teacher.

You consider that the transcript of a teacher can be
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



B r a d s h a w  - Recr o s s

i important in evaluating his performance as a teacher

434

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and whether or not you might want to retain him?

I believe I have testified that this should be taken 

into consideration, yes.

Take a look at the answers to interrogatories, the 

transcript of James Henry Klutts. He was a Math 

teacher, wasn't he?

MR. STARLING: Your Honor, I am going to object,

because I think there is a definite distinction 

between Mr. Klutts, who was a Math teacher, and 

Mr. Thomas, who was a Social Studies teacher. If 

you are going to consider Mr. Thomas' transcript, 

consider it against Mr. Hunter Douglas, who, in 

fact, the District fired at the same time, because 

both were teaching the same subject.

MR. KAPLAN: Your Honor, in addition, I am using

this to test this witness' credibility in regard 

specifically to his evaluation of transcripts.

THE COURT: Well, it's certainly been tested,

I will say that. For whatever good, if any, 

why go ahead with it.

H e ’s a Math teacher, isn't he?

Yes, he is.

Would you go over with me for a moment his Math grades 

on that?

G L E N N  H PERR IN
O f f ic ia l  C o u r t  R e p o r t e r  

F ederal  B u il d in g  
EL Do r a d o  A r k a n s a s  71730



435Bradshaw -  Recross

1 ! A.
2 a
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22 a
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24 a
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All right*

First semester, an "F* in College Aigeora. That was the 
only Math grade, is that right?

Yes, he did.

(Jh-huh. Second semester, he took two Math courses, a 
"C" and an "F", is that right?

Which were College Algebra and Plain Trigonometry.

All right. Next semester, a “D" in Plain Trigonometry, 

that he took over again, is that right?
Yes.

The very next semester that he took any Math courses 

was spring semester ’63-'64, with a notation previous 
to that of "Probation", when he got a "B" in Plain

iTrigonometry, the third time he took that course, isn't 
that rignt?

Which one was that, now?

Right at the bottom of the first column.

Plain Trigonometry, three hours, “B".

Right. The very next course, spring semester, *64-'65, 
a "B" in Analytical Geometry, is that right?

That is correct*

All right* But the next course, Calculus, a "C“?

That is correct.

A “8“ in Algebra and a "C" in Calculus?

That is correct*
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



auDuaw - RCCrOSS 436
i| Q. “C" in Theory of Equasions?

Right.

And then the next page, a ~Cm in Modern Abstract Algebra, 
a "C" in Calculus III, and a "C* in Independent Study, 
College Geometry?

That is correct.

All right. Your Math teacher, those were his Math 
grades, is that right?

Yes , they are.

All right. Now, you also testified yesterday that his 

strength lay also in the fact that he was a Chemistry 

major, is that right, with a strong minor in Chemistry? 

Yes, I think he has approximately 43 hours in Chemistry. 

Let’s take a look at those Chemistry hours, too, for 

the last thing we will look at on this. An “F “ , first 

semester, in Inorganic, is that right?

Yes, he did make an "F" in Inorganic Chemistry.
Then fall semester, *63-'64, he took it again and got a 
"C"?

That is true.

A "B“ in General Chemistry, the second half of that 
course, the next semester?
That is true.

All right. And then in the fall semester, *64-'65, he 

got three Chemistry grades, two "C's" and a "D", is that

2 A.
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GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 i7»o



! 437

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right?

A. Which courses were those?

Q. Quantitative Analysis, History of Chemistry, and Chemical 

Calculations, is that right?

A. That is correct.

Q, Then two "C's" in the fall semester, '65-'66, Organic 

and Physical Chemistry?
A. That is correct.

Q. Another two "C's“ in '65-'66, spring, Organic and 

Physical, the second half of those courses?

A  That is true.

Q. And got an "A" in second summer term in 1966 in Chemical 

Preparation?

A. That is true.

Q. But the next semester, an "F" in Advanced Inorganic 

and an "F" in Quantitative Organic Analysis, is that

right?

A. That is true.

Q- And a "C" in Physical Chemistry?

Bradshaw -  Recross

20 A.

21 Q.
a  A.
Ij

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24

25 A.

Right.

And "C" in Independent Study?

Right.

Transcripts important in your evaluation of a t e a c h e r ’s 

performance and ability?

I beg your pardon?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



urausnaw tie cross 438

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Is che academic transcript--

THE COURT: Well, if you are referring to Mr.

that is not proper, he is not a man 

that is involved in this matter, Mr. Kaplan, 

and Mr. Klutts is no competitive area between 

Mr. Asive Thomas and Mr. Klutts, they were 

entirely different fields.

MR. KAPLAN: He is involved, Your Honor, to the

extent that this man considered Lranscripts for 
one individual but not for another.

THE COURT: No, I don't believe that's proper,
1 don't think that's correct. .

However, he has testified that transcripts are 
important and he considered them.

MR. KAPLAN: That's all.

THE COURT: You may stand aside--1 want to
ask you--

19 !j BY THE COURT:
20 Q.11
21 ji A.

22 Q.

23 11 A.

24 li Cl
25 A.

How many teachers do you have now?

We have 18 teachers.

The same number that you had a year ago? 

We have ten white, eight black, yes, sir, 

Well, you have ten in elementary?

I believe that's correct.
GLENN H PERRIN  

O f f i c i a l  C o u r r  R k f o r t k k  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  t i 7 » o



Di» a u o u a w court
439

HI a
2 :j A.

3 a 

*: a.

5 j| Q.

And eight in high school,—
True.

— is that right?
Yes, sir.

The ten teachers that you evaluated in 1969 and *70, is 
that the year?

7 I A. 1968-'69.
8 a Well, you had made your evaluation in the spring of
9 1969, did you not?

10 A. That is correct.
11 Q And that was for a determination of teachers to be i
12 retained, that is, ten teachers to be retained, for the
13 year of 1969 and *70?
14 A. That is correct.1

1

15
Q. Now, you say Mr. Edwards resigned?

16 A. Yes, sir.
17 Q- And someone else resigned?
18

1 A. Yes, sir.
19 Q. Who was that?
20 A. Mrs. Ramsey.
21 ; Q. Were those the only two that voluntarily resigned from
22 your school?

j

23
1

a. Yes, sir, that is correct. On the elementary level.
24 a That is what I am talking about. Mr. Edwards was
25 certified, I believe in these interrogatories, responses

GLENN H PERRIN

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 9 0 V



440I

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to interrogatories, certified as secondary education, 

high school?

A. Yes, sir, that is true.

Q. And then when Mrs. Ramsey and Mr. Edwards resigned, that 
left a vacancy with the ten and you moved up Mrs.
Gordon?

A. That is correct.

Q. And that made the 10th teacher?
A. T r u e .

Q. And that was for the year of 1969 and ' 70?
A. Yes, sir.

a  Did you have any vacancy to develop for the year— in the 

elementary school for the year of 1970-’71?

A- Yes, sir, we did have.

Q. Who was that?

A- Mrs. Rosen, I believe it was, that left our District, 

and she was replaced with Mrs. Florida Roaxm,

Q- Is that a new teacher?
A. Mrs. Roann?

Q. Yes.

A. Yes, sir. Mrs. Rosen was a white teacher which left the 

District; Mrs. Roann was a Negro teacher who was
e m ployed.

a  Why d i d n ’t you offer it to Mrs. Thomas?

A Well, I did not know where Mrs. Thomas was at that
GLENN H PERRIN

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 * 0

Bradshaw - Court



jjraasnaw uourt 441

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p a r t i c u l a r  t i n i c , I  d i d  n o t  have art i m p l i c a t i o n  o n  t i e r  

at that particular time.

Well, that wasn't the question, Mr. Bradshaw. You were 

evaluating these teachers and they had a record which 

was a part of your records and you made the record, 

and the question was, Mrs. Thomas having been let out 

and you had a vacancy, why didn't you give her 
consideration?

Well, we had already had one year since she had been out 

of the District, and as I told you, I really did not 

know where she was at that time or whether she was 
employed, and she did not-- 

Did you make any inquiry about it?

— she did not have application on file in Mr. Turner's
office.

Did you make an inquiry about where she was?

No, sir, none other than whether or not there was an 
application on file.

Did you go to Mr. Turner's office to find out if she 
did have an application on file?

Yes, sir, I did check with his office.

And she did not have an application on file?

I could not find an application on her. Now, I did 

receive a letter from Mrs. Thomas after the Board had 

already employed Mrs. Florida Roann.
GLENN H PERRIN 

O f f i c i a l  C o u r t  R v o r t k  

F c d c r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  t i t r o



orausnaw Court 442

1 a

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15 a

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19 a

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24 a

25 A.

'
i!

And you had already signed a contract?

Yes, sir, she had already signed a contract, and I did 

receive a letter from Mrs. Thomas indicating that she 

would like to be considered for a position in the 

District.

Did you respond to that letter?

Yes, I did. I simply wrote her a letter and stated that ! 

the position had been filled, and had I received her 

letter indicating an interest, I would have presented
I

this to the Board and we would have considered her.

Did you advise her that you went to the Superintendent's 

office--I mean the Supervisor's office of the County to 

determine whether she or-- 

No, sir, I did not advise her about that.

Now, where did Mrs. Dora Thomas go?

I don't know where Mrs. Thomas is.

Do you know whether she is teaching or not?

No, sir, I do not.

She has had no contact with you since?

None other than wanted to know if we were going to send 

her her underpayment.

And where was that contact from?

I believe it was from some address here in Pine Bluff.

Do you know where Mrs. Kidd is?

I--exactly, I don't know where she lives, but I believe
GLENN H. PERRIN

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 9 0



j

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1C

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oiciusiiciw - tourc
443

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h e r  h o m e  i s  h e r e  i n  P i n e  B l u f f .

Do you know what she is doing?

No, sir, I do not.

You don't know whether she is teaching or not?

No, sir, I do not.

Has she made any indication of any interest since she
left?

None whatsoever.

Did she ask to come before the Board when she received 

the letter--

No, sir.

--advising of her being discharged?

No, sir, she did not.

Did Mrs. Dora Thomas ask to come before the Board when 

she received her letter?

No, sir, she did not.

Did Mrs. Lois Thomas ask to come before the Board when 

she received her letter of dismissal?

No, sir, she did not.

THE C O U R T : Anything further, gentlemen?

MR. STARLING: I just have one question, Your Honor.

REDIRECT EXAMINATION
BY MR. STARLING:

G  Mr. Bradshaw, the only elementary teacher which you

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



Bradshaw - Redirect 44A

3 A.

4 ; a
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6 a

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3

h i r e d  since t h e  t e r m i n a t i o n  o f  t h e  t e a c h e r s  i n  C h e  

evaluation is Mrs. Florida Roann, is tnac correct? 

That is true.
p  - f .. -rp

And Mrs. Roarrn is a Negro, is that not correct? 
That is correct.

And you have not hired any white teachers?
No, sir.

MR. STARLING: All right.

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BY THE COURT:

Q- Well, let me make it very plain, I wasn't interested in 
the color at this moment, I was interested in the 
individual,--

A. Yes, sir.

a --as to whether or not Mrs. Lois Thomas had been

considered when you had a vacancy, whether she was white 
or black.

A (Nods head affirmatively)

THE COURT: You may stand aside.

THE WITNESS: Thank you, sir.

(Witness excused.)

THE COURT: You have other witnesses, do you
not?

MR. STARLING: Yes, sir. My witnesses, Your Honor,
GLENN H. PERRIN

O f f i c i a l . C o u r t  R n  

F e d e r a l  B u i l d i n o  

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i.uiuci - uirecc

1  should ta*e about — two at tan minutes apiece, and

2 Cfte ochers at about three minutes apiece.

3 THE COURT: I think we will have about a five-
4 minute recess.

5 3

(Whereupon, at 3:04 p.m ., a short recess is taken; 

thereupon, at 3:13 p.m., the parties present as 

heretofore, the following further proceedings are

9 ij had, to-wit:)
10
:ji|

11 **• STARLING: Your Honor, at this time I would like

to call Mr. B. E. Turner to the stand.
13 |!

I I
14 B. E, T U R N E R .
j I

15 :| called as a witness on behalf of the defendants, being first

16 duly sworn, testified as follows:

1 DIRECT EXAMINATION
j

181| BY MR. STARLING:

Would you state your name and address, please, sir?
B. E. Turner, Pine Bluff, Arkansas.

How are you employed, Mr. Turner?

By the County Board of Education.

How long have you been associated with the teaching 

profession, which includes Principalship, Superintendent, 

and the job of County Superintendent, which you now hold?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 * 0

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I20!| A.

21 i| Q.
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23 I Q.

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445



X U i. UV-i. k j  XX CC x 446

1 | A.

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Thirty-four years,.

How long have you been employee as a County School 
Superintendent in Jefferson County?

Four and a half years.

What is the function of a County School Supervisor or 
Superintendent?

Outside of maintaining and keeping all teacher 

certification, auditing, social security, retirement, 

basic other elements, it's give advice to and counsel
I

with Superintendents, Principals, others who might call 
upon us.

Do many Superintendents seek your office's advice tor 

information or recommendations?
They do.

Are you familiar with the Plum Bayou School District 
No. 1?

I am.

Are you familiar with the Superintendent of that 
District?
I am.

What is his name?

James K. Bradshaw.

Has Mr* Bradshaw ever sought your help, advice, 

information, or recommendation from your office?

He has on many occasions.
GLENN H PERRIN

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7  i t  s o 4 T 0  2  4 -



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xurner - uixect | 447

a In che school year 1968-’69, did Mr. Bradshaw contact

you in reference to a possible reduction in the
|

elementary teacher staff?

A. He did.

a Did you discuss with Mr. Bradshaw the question of how 

many elementary teachers unification would require?
A. I did.

Q. Do you recall how many elementary teachers that the 

decision was made to retain— or, let me ask you this, 

do you recall how many elementary teachers were at the 

Plum Bayou Elementary School and the Tucker-RosenwaId 
Elementary School at that time?

A. Fifteen.

Q. Do you recall, after your discussion with Mr. Bradshaw 

how many elementary teachers the School District would 
need after unification?

A. Ten.

Q. What was the basis or the reasons for your determination 1 

in your discussion with Mr. Bradshaw that after 

unification the District would need only 10 of the 15 

available teachers?

A. Pupil-teacher ratio was one factor on which it was

discussed, and the other is the formula for distribution 

of Scate Aid is based upon so many students per teaching 

position.
GLENN H. PERRIN

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 i 7 » o



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During the same period of clme, Mr. Turner, did Mr. 

Bradshaw discuss with you the problem of how he would 

determine what ceachers would be retained and what 

ceacners would n o t  b e  retained after unitization* 

rie d i d .

What did he explain tnis problem to you as or a solution 

that he may have?

Mr. Bradshaw seemed quite concerned on how he could best 

keep, select, and retain the 10 teachers that he would 

need in the unified system.

Did he indicate to you any ideas that he had in reference 

to how this would be accomplished?

Yes, we exchanged ideas.

Did you agree with Mr. Bradshaw in reference to the 

manner in which the reduction of teacher faculty would 

take affect?

Yes, from the standpoint, as we discussed, the criteria 

on which it would be made. 1 suggested that one of the 

rairest manners that I knew, and I think there are those 

here that will attest to this other than Mr. Bradshaw, 

that I favored giving a National Teacher Examination 

and let it be administered by some outside source and 

graded by ■ ome outside source, that nobody in this 

D - c r t c t  or tnis County or anyplace else could ever say 

b u t  what it was done in accordance with--l made that
GLENN H PERRIN 

O p p i c i a l . C o u r t  Reporter 
F e d e r a l  B u i l d i n g  

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iurner - Direct 449

recommendation that we give, or that he administer or 

have administered a National Teacher Examination and 
let the chips rail where they would.

Q. Now, when vou talk about this, are you talking about 

evaluating or giving this test to all 15 elementary 

teachers?

A That's right.

Q. Both black and white?

A. Right.

Q. Did, in fact, Mr. Bradshaw administer this type of test?

A. He did not, to my knowledge, no, sir.

Q. Do you know why he didn't?

A. Well, there were those that objected to it.

Q. Would you explain that?

A. Well, there are those here that I am looking at arid they 

are looking at me that will recall that after it was 

mentioned, and I told it to Mr. Bradshaw, I had a 

telephone call from the teachers at the Tucker-RosenwaId 

School to make an appointment with me in my office, and 

they all came, each and every one of them, and they 

objected to that type of test, and we discussed it 

thoroughly in my office, each and every teacher of that 

faculty present, along with their Principal, and some of

them are here to attest to what I am saying.

Q. Did you explain to them that you thought that would be
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



iuraer Direct 450
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as fair--a legal and fair way?

I did„

What did those teachers recommend that they would rather 

have in place of it?

Some kind of an evaluated criteria that would be based 

upon circumstances evolving around the present status 

of which they were teaching.

Do you know, of your own personal knowledge, if Mr, 

Bradshaw used the National Administrative Test?

He did not, because after this visit that evening, all 

of these people were my friends, and it that was going 

to cause any upset in his faculty, I contacted him 

and asked him not to consider that, and he did not. I 

asked him not to give the test, and he d i d n ’t.

After this, did Mr. Bradshaw or you discuss any other 

form of evaluation?

We did.

Would you describe what you discussed?
I

Yes, sir. We had secured several means of evaluation 

for teachers from various schools and from various 

concerns, and we presented him some of the findings that 

we had, and we went over those that were being used in 

some of the other schools in Jefferson County and some 

that we had obtained from other schools outside of the I !
c o u n t y .

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

f e d e r a l  B u il d in g  
EL Do r a d o . A r k a n r a r  71730



Turner - Direct
____________ _________

I
: | Q.
1 Axter the evaluation form ana criteria had been basically

1 agreed upon by Mr. Bradshaw and he had come up with his
3

i
rough draft, did he visit with you again concerning this

4 criteria?
5

1
|1 A. He did.

6 What did you all do then?
7 Jj A. He minimized and cut down and made it as short as he
8 ] possibly could to obtain the needed results that he was
9 looking for because he told me he had been advised that
10
] he would have to come up with something specific in

11 1
i
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evaluating each teacher that he had on his staff, so it
12 1 was condensed into a form that he could take it and

I

13 administer it.
14 Q. In your knowledge of the School District, do you know a
15!

i
Mr. Edwards? !

16
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A. Yes .

17 a Did you know what position he held in the year 1968-*69?
18 A. He was Principal, Tucker-Rosenwald.
19 a Did you know a Mrs. Blair?
20 A. Yes.
211 a What was her position?
22

H
A. She was Principal over at the Elementary School at

23 Wright, Plum Bayou.
24 a Do you think that Mrs. Blair or Mr. Edwards was in a
25 I more favorable position to evaluate all 15 of the

1|
i|

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  iiJJV**

F e d e r a l  B u i l d i n g  ^*7$ 
EL D o r a d o , a r k a n s a e  7 1 7 3 0  ejjg  $ K



1 teachers Involved?

2 A.

3 a

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13 a

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is aII

I do not.

Why?

Because Mrs. Blair c o u l d n ’t evaluate Jean's teachers, 

neither could he evaluate hers, that would have been an 

unfair situation to ask her to evaluate Tucker, for Jean 

to evaluate Plum Bayou. No, sir, that wouldn't have

been fair.

D i d--who do you think was the most— the person in the 

most favorable position to make the evaluation of all 

teachers and whose responsibility was it?

It was Mr. Bradshaw’s responsibility.

Once Mr0 Bradshaw made the evaluation of the 15 teachers, 

do you know how many Negro teachers he retained?
Five „

Do you know how many white he retained?
F i v e .

Mr. Turner, my final question is, to you, that during
19

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this entire period, that is, the period which you 

discussed the evaluation with Mr. Bradshaw, you discussed 

the objective written test with the Negro teachers, and 

all of your conversation with Mr. Bradshaw concerning 
the criteria and evaluation test, did Mr. Bradshaw 

indicate to you in any way or make any statements to
25
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you that his evaluation of these teachers would be based
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL Do r a d o . A r k a n s a s  7 i7»o

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- Liireci

upon race?

rie certainly did n o t v

What was his attitude towards this problem?

His attitude was one of professionalism approaching this 

in a manner whereby he could stand upon the decisions 
that he made from his evaluation.

MR. STARLING: I believe that's all.

10 BY!
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21 a
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CROSS EXAMINATION
MR. KAPLAN:

Mr. Turner, in your 34 years' experience, have you found 

that black teachers are as good as white teachers, white 
teachers are as good as black teachers?

I haven't seen where their color made any difference.

In the last several years in your experience as County 

Supervisor here in Jefferson County as more and more 

school districts move to unification, has it also been 

your experience that many more black teachers have been 

let go from teaching positions than white teachers?
Not necessarily so.

Not necessarily?
No, sir.

Some teachers--some school districts haven't let anybody
go, have they?

I think that's true, and we have some where they have
GLENN H. PERKIN

O f f i c i a l  C o u n t  R v o u m  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0

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i 454T u r n e r  - Cross

1 gone to a unitary system that have more black teachers

2 than they had before they u n itized .

3
1 Q‘ I  see. Which ones are those?

4 A . W ell, Linwood.

5 i a Anyone else?

6 j A . That is the one that I r e c a ll that has more.

7
Q. Now, how about those that haven't le t  anybody go at a ll?

8 A . I  wouldn't know how they have handled e ith er color on

9 le tt in g  go or reta in in g. Now, I  don 't keep those

10 records.

11 a W ell, you had a number o f black teachers come by and see

12 you about applications and whether you knew anybody

13 that--

14 A . Black and white, yes, s ir .

15 Q. Black and white?

18 A . Right.

17 a A ll  r igh t. I see. Lois Ann Thomas came by to see you,

18 did she not?

19 A . I  am sure she has. There has been three or four

20 hundred.

21 o. Do you remember?

22 A . Sir?
i

23 ; Q. Do you remember Lois Ann Thomas?

24 A . Yes, I remember Lois Ann.

2 5
a Can you point her out in the courtroom? |

OLENN H PERRIN
O f f ic ia l  C o u r t  R■FORTE* 

F e d e r al  B u il d in g  
E L  Do r a d o . A r k a n s a s  t i 7 *o *



Turner Cross 455
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No, I don’t know ir I could identify a teacher in here 
just by pointing them out because there is too many cooes 

by.

I see. Do you recall her coming by and asking you about 

putting in an application?

Yes, she's been by the office, yes, sir.

And you told her, did you not, that her transcript 

which was already on file with you and her certification 

would serve as application, didn't you?

I am not sure that I said that, because I don't know if 

I have her transcript.

Well, don't you keep certifications and transcripts of 

teachers —

No, sir.

--in the District?

We keep transcripts —  I mean certification, but not 

necessarily transcripts.

I see. Now, is that your custom— is it a custom of 

yours to take actual applications from teachers or just

to consider —

We take applications and keep them in folders, yes, sir.

I see. Did you ever take one from her?

I don't know.

I see.

But we have three or four hundred down there, and Lois'
GLENN H PERRIN

O f f ic ia l  C o u r t  R epo rter  
F e d e r al  B u il d in g  

EL Do r a d o . A r k a n s a s  7t7so



iuiuci. - or oss i 456

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could very ea s ily  be there and Dora's could be th ere ,

I  am sure several o f tnem are, but id en tify in g  one out
j

o f that 300, s ir ,  I cou ldn 't.

I see. Now, these c r it e r ia  that you are talk ing about, 

where did you get them from, what are these forms that 

you talked to Mr. S tarling about?

Since I have been up to the County School O ffic e , I 

have w ritten  to other schools asking for copies o f the 

c r it e r ia  on which they evaluate their personnel and have 

taken those and accumulated them. I used them in my own

school.

Which school was that?

County School D is tr ic t .

You were a Superintendent of the County School D is tr ic t?

I s t i l l  am, yes, s ir .

I see. What did you do before you were made County 

Supervisor?

I was Superintendent or Linwood School.

How long were you Superintendent there?

Five years.

And teacher in that d is t r ic t  before then? 

Principal-Teacher, yes, s ir .

I see. Did you ever make w ritten  evaluations while you 

were there?

Written evaluations?

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7 so



Turner Cross

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0- Yes, s ir*

A. Not as such, no, s ir .

a Who did you w rite to , what school d is tr ic ts  did you w rite  

to to get these forms, to get these c r ite r ia ?

A. I think we could substantiate i t  from the schools here 

in Jefferson County.

Q. Which ones did you w rite to?

A. Dollarway, W hitehall, Pine B lu ff, Watson Chapel.

0- A l l  r igh t. Did you w rite  to AM&N College and ask them 

for their help, too?

A. I don’ t —no, s ir .

Q. You didn’ t?

A. No, s ir .

Q. A l l  r igh t. Are you fam ilia r with some o f the forms

that they— that these various in stitu tion s  use, then, 

since you wrote for them?

A. The schools, yes, s ir .

Q. Have you ever seen one that used f iv e  c r it e r ia  lik e  

this?

A. Not only as sub-heads, they would have qu ite a few more 

things under those.

Q. They would a l l  have a great many more l i t t l e  items or 

sub-topics under general c la ss ifica tion s?

A. Most of them, yes, s ir .

Q. A l l  r igh t. Now, would you say, in your experience as a

G L E N N  H P ER R IN
O f f ic ia l  C o u r t  R epo rter  

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iurner cross 458

teacher and as administrator, that chose sub-topi.cs, 
sub-neadings, are extremely helpful in defining the 
strengths and weaknesses within a given area?

A. Yes, you can have many other criteria under these main 
headings here that are valuable, yes, sir.

a All right. Now, when you served as Principal in the
Linwood School District, did you feel that you were in 
a very unique position to really know best the teachers 
that were working under you?

A. I felt with the contact with my Superintendent, Mr.
Dowell, that together we could evaluate them, yes, sir.

!Q. Well, now, was Mr. Dowell in the same building as you?
A. Yes, sir.
Q. Did you have a black school there, too,--
a. Yes, sir.
Q. --in the district at that time?
A. Yes, sir.
a All right. Now, did they have a Superintendent— I mean 

a Principal?
A. Yes, sir.
Q. All right. Now, who, in your school, had the most

contact, day-to-day contact, with the teachers, was it 
you as Principal?

A. From day to day?
Q. Uh-huh.

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7«79o



i u i u e r i,ross 459
I wouldn't know that the Superintendent d idn 't have 

anything in the world to do but to go about and super­

v ise  and I had some other a c t iv it ie s  other than being 

Principa l o f the School. In that particu lar s ituation , 

s ir ,  I wouldn’ t know.

AH r igh t. I t  is common, in a two-school s ituation , one 

black, one white, that the Superintendent is  in da ily

8 i

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a

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contact with a l l  aspects at the white school, is n 't  that 

what was common in this county?

No, in this county the Superintendent is the administra­

t iv e  o f f ic e r .

But he has, genera lly , in this county, his o f f ic e  in the 

white school, is n 't  that r igh t, or what used to be the 

white school?

His resp on s ib ility  as a Superintendent has been the 

en tire  d is t r ic t .

I know, but hasn't his o f f ic e  and almost a l l  o f his 

day-to-day a c t iv ity  been in the white school?

His o f f ic e ,  yes.

20 : Q.
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23 l| Q-

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A ll r igh t. And most o f his time is spent there, too,

is n 't  it?

When he is in his o f f ic e ,  he is there, yes.

A ll r igh t. Now, the situation  has been, espec ia lly  in 

larger d is t r ic ts ,  and then in black schools, a lso , that 

the Principal there has the most day-to-day contact with

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7 »o



xurner -  cross 46 0
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his teachers, isn ’ t that righ t?

Any Principa l that is  involved with his teachers should 

have, yes.

A l l  r igh t. Now, i f  you were evaluating a group of 

teachers, would you think anything wrong about advancing 

the causes, the good poin ts, the bad po in ts , the 

d e fic ien c ies , the good teacher q u a lit ie s , about the 

men and women who worked under you as a Principal?

No, I have no ob jection , because here's what I  did, I 

gave them the sheet and le t  them evaluate themselves, 

then 1 gave the Principa l a sheet and le t  him evaluate 

them, and then I evaluated them, and I ag ree ,-- 

A ll  r igh t.

- - s o ,  no, I don 't ob ject, I am glad for i t  to  be. 

Self-appra isa l is  an important part o f any teacher 

evaluation, is n 't  that right?

I lik e  for i t  to be a factor in my own personal judg­

ment .

A ll  r igh t. Then the immediate supervisor, his appraisal 

is a c r i t ic a l  function, too, is n 't  it?

I think d e fin ite ly  we take that under consideration.

A ll  r igh t. Now, then, the supervisor's appraisal, the 

Superintendent's appraisal, his is another fa c to r , is 

that righ t?

W ell, the immediate supervisor reports to the

GLENN H PERRIN
Of f ic ia l  Co u nt  R nfontcn

F e d e r al  B u il d in g  
EL Do n a d o . A r k a n s a n  717*o



CrossTurner - 461

1 Superintendent,- -

2
a Right.

3 A. --and i f  they are a team, they are working c o lle c t iv e ly

4 s ir ,  they are not working separately; i f they a re , they
II

5 II
I

are not having a school system.

6 a Did you hear Mr. Bradshaw te s t i fy  that he did not

7 i| consider at a l l  Mr. Edwards' evaluations o f his

8 teachers?

9 | A. No, I don 't know that I heard that.

10 a Oh, you d idn 't hear that?

11 A. I  don 't know as I did.

12 ! a A ll  r igh t. T e ll  me, s ir , i f  Mr. Edwards' evaluations

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23 A.

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25 a

o f his facu lty  members were not considered at a l l  by 

the Superintendent, Mr. Bradshaw, when he evaluated his 

15 teachers, what would you think?

W ell, I  don 'fc--I don't — I think i f  Mr. Bradshaw said 

that, i t  was taken out o f context, because I  think he 

evaluated what Mr. Edwards said to him about his 

teachers , but 1 think what he was saying or what 1 

believe  he would have said was that he had the 

resp on s ib ility  and he made the decision w ithout-- 

No, no, no, no.

—depending on what Jean said, but I am sure he talked

with him.

I f  he said that he d idn 't consider them at a l l ,  what

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n s a s  71730



462

1 would you chink? Wouldn't you think he would have to

2 I consider them to get a true picture?

Turner - Cross

3 I A.

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5 ; Q-

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A.

a
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A.

a

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a
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I don 't know why he would say that, you would have to 

ask him.

No, wouldn't you think that he would have to  consider 

his P r in c ip a l's  evaluations in order to get a good 

p icture, a true p icture, a fa ir  picture?

I think he did.

Wouldn't you say that he would have to do that in order 

to get that, in order to get a true and a fa ir  picture 

of the teachers?

No, I wouldn't know i f  he would have to .

Do you think i t  would be easy to do without it?

I  think i t  would be p ra c tica l, in my judgment.

To do i t  that way, to use the P rin c ipa l's?

In my judgment, yes.

MR. KAPLAN: Uh-huh. That's a l l .

MR. STARLING: No more, Your Honor.

THE COURT: You may stand aside. Have you

concluded with th is witness?

MR. STARLING: Yes, s ir .

THE WITNESS: May I go, s ir?

THE COURT: Do you have any further need of

I

i

24

25

Mr. Turner?

MR. KAPLAN: No, Your Honor.

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  717*0

1
.

SVSx



C i a u  - uirecc 463

THE COURT: You may oe excused, then„

THE WITNESS: Tnank you, s ir .

(Witness excused.)

MR. STARLING: My next witness is Mrs. Blair.

10

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MILDRED BLAIR.

ca lled  as a witness on behalf o f the defendants, being f i r s t  

duly sworn, t e s t i f ie d  as follows:

DIRECT EXAMINATION
BY MR. STARLING:

a

A

a

A.
a

A
a

A.
Q.

A
a

25 '__

Would you state your name and address, please, ma'am?

I am Mildred Blair and I live at Sherrill.

What is your job, Mrs. Blair?

Well, I am Head Teacher at Plum Bayou School.

How long have you been in the teaching profession? 
Forty-one years.

How long have you been a teacher in the Plum Bayou
D is tr ic t  No. 1?

Oh, about 30 years.

How long have you been the Head Teacher at the Plum 
Bayou Elementary School?
Ten years.

In the school year '68-'69 when the unitization o f the 

elementary schools became a possibility, did Mr.
GLENN H PERRIN

O f f ic ia l  C o u r t  R epo rter  
F e d e r al  B u il d in g  

EL Do r a d o . A r k a n e a r  71730 S79 A



IJ JLO jLi. U Jl-L C L  L

1
2

*;| A.

6

71 a. 

8

9

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12

A.

G

13 l! A.

Bradshaw ta lk  with you and your teachers about a 

necessary reduction in teacner faculty?

Yes.

What was his discussion along these lines?

Was that there would be a necessity probably that some 

would have to not be retained .

In talk ing with you and your teachers at the Plum Bayou 

Elementary School, did he indicate that he was attempting 

to come up with some method o f determining who would be

retained and who would not?

Yes, s ir ,  he did.

What did he say he was attempting to do?

To determine those that he would reta in .

14 j G In other words, what was his ideas in reference to who
15 he would determine— how he would determine who would be

18 retained and who would not?

17 A. You mean whether they would g ive  th is te s t— th is te s t ,

“ or what?

19 a W ell, le t me ask you—rephrase my question in that

20 respect. Did Mr, Bradshaw mention to you and your

21 teachers that he was thinking about g iv in g  a N ational--

22 A. Yes.

23 G --type of •  SB

24 A. Yes.

25 G --administered test?

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7 »o



Biatr -  Direct

li A.

2 a

3

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|| A .
6 Q.

i
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8 | a

9

Yes, he did.

And did he state to you that, in ta c t, those ten teachers 

who scored the highest would be retained and those that 

scored the lowest would not be retained?

(Nods head a ffirm a tiv e ly )

You have to answer "Yes".

Yes.

What was the reaction  of you and the teachers at the 

Plum Bayou Elementary School with reference to this

10:i type o f test?

11 A. W ell, most everyone kinds dreads a test but we didn’ t
12 make any objection to having to take the te s t .
13 a Did Mr. Bradshaw give you this te s t- -

14 1 A No.

IS a --or g ive the teachers this test?

16 A- No, he did not.

17 Q-
i

When he was talk ing about administering th is type o f
18 te s t , was he talk ing about administering i t  only to the
19 white teachers?

20 A . N o .
21 | a Who was he ta lk ing about?

22 A To a l l  the teachers.

2 3 a Both black and white?

24 A Yes, in both schools.

2 5 Q. Do you know whether or not th is te s t was given?

GLENN H PERRIN
O f f ic ia l  C o u r t  R epo rter  

F ederal  B u il d in g  
E L Do r a d o . A r k a n s a s  7 i7 »o



A. As far as I know, it was not given.
Q. Did Mr. Bradshaw talk to you and your teachers at a

later date concerning another method of evaluation of 
teachers?

A He did.
Q And what, basically, did he tell you about this method

of evaluation?
A .  Well, he was trying to come up with something that he 

felt would be fair and impartial way of deciding whom 
he should keep.

Q. Did he indicate to you or your teachers or state before 
you and your teachers that it was his idea to come up 
with a method of evaluation which would best evaluate 
both the black and white teachers to determine which 
was the best overall teaching ability?

A. That's right, all of them were to be judged alike.
Q. Mrs. Blair, during this period of time, did Mr. Bradshaw

ever tell you or any of your teachers, white teachers 
at the Plum Bayou Elementary School, or make any 
statements to you concerning the fact that he was not 
going to let go any of the white teachers, so don't 
worry, and, therefore, he would only let the black 
teachers go in reference to this evaluation test?

A. That was never said.
Q. What did he say along these lines?

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  t i t  so

B la ir  - Direct



2

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8 ii

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A. That he would make Che evaluation and would retain the 
ones that he felt was qualified, as he saw them.

Q. Did you ever v is i t  the Tucker-Rosenwald Elementary
I

School to observe the teachers and their performance 

in their classroom duties?

A. No, s ir ,  I  did not.

Q. Do you know whether Mr. Edwards ever v is ited  the Plum 

Bayou Elementary School to observe the teaching 

performance of your teachers?

A. He did not.
!

Q. Could you have evaluated Tucker-Rosenwald teachers?
I

A. I  wouldn't have dared try .
i

a Do you know i f  Mr. Bradshaw v is ited  in the classrooms 

in your— in the Plum Bayou Elementary School?

A. He did.

Q. How often would he v is i t  those classrooms?

A. W ell, he came regu la rly , 1 would say possibly once a

month, to v i s i t  the classroom. He often  walked through 

the building and observed what was going on in the 

build ing.

Q Mrs. B la ir , at anytime at the fa ll--b eg in n in g  in the
I

f a l l  of 1968-'69 and u n til present, has Mr. Bradshaw 

made any statements to you or to the teachers in your 

presence that he based his evaluation of these teachers

on race?
----------------------------------------------------------------------------- ----— — -----i-

GLENN H PERRIN 
O f f ic ia l . C o u r t  R epo rter  

F ed e r al  B u il d in g  
EL Do r a d o . A r k a im a *  7 i7 »o

o ia ir  -  uirecc

5 2 . 3

467



BJ-air - Direct 46 8
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8 ! Q.

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Oh, no, never„

MR. STARLING: That's a l l .  Just a minute.

THE COURT: Any questions, Mr. Kaplan?

MR. STARLING: I am through.

CROSS EXAMINATION

3Y MR. KAPLAN:

Did you prepare, in any way, for Mr. Bradshaw, your 

evaluation o f your facu lty members?

Yes, we discussed the teachers in my-«

Did you ever put i t  in writing?

I  think I jo tted  down some notes, but I  d idn 't g ive  them 

to him.

How long did you spend with him when you did ta lk  about 

your facu lty members?

I t 's  been a good w hile, I couldn 't t e l l  you exactly .

Could you t e l l  me approximately, to the best o f  your 

a b ility ?

I doubt i f  I could t e l l  you exactly , but possibly 45 

minutes or an hour.

Do you think that in a meeting between you and Mr.

Edwards and Mr. Bradshaw that you could have talked about 

the weaknesses and strengths o f your teachers and 

considered those strengths and weaknesses as opposed to 

what Mr. Edwards might say about his facu lty  members'

GLENN H PERRIN 
O f f ic ia l  C o u n t  R v o u t d i  

F ederal  B u il d in g  
EL Do r a d o . A r k a n s a s  71730

s ' z y . ,



A.O 11 V*I. & 469
---1

1

2 A.

3

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6

7 A.

8 a

9 I A-

10 a

11

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14 A.

15 Q.

16

17 !| A.

181 ! a
19 A.

20 a

21 ;!

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23 ; A.

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■

II

strengths and weaknesses?

You know, I don't know whether you could or not. You 

could certa in ly  discuss i t ,  but whether or not there 

would be an understanding o f what one of you meant.

I see. But you could have, in a meeting, discussed 

with a l l - -

You can discuss i t , —

R igh t.

--whether or not you come to a decision.

Uh-huh. And would you have been prepared to do that, 

to discuss the strengths, the weaknesses, the 

c e r t if ic a t io n s , the academic records, the d isc ip lin e  of 

each o f your teachers? I

Not the c e r t i f ic a t io n , but I would have th e ir - -  

Did you know which ones were c e r t i f ie d  and which ones 

were not c e r t if ie d ?

W ell, I suppose they a l l  were.

Do you know whether they a l l  were?

Yes, they were.

Do you know whether M rs.--at that time Miss Janet Dye, 

la te r  Mrs. Janet Dye Wall, was c e r t i f ie d  to teach as an 

elementary school teacher?

Was that what you were asking, whether they were 

qu a lified  to teach there or c e r t i f ie d  to teach there?

No, I did not know. Yes, I knew she was not.

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7so 5 2 ? * .



Did 1 1 or oss

11 Q.| You knew she was not c e r t if ie d ?

2 1| a. I knew she was c e r t i f ie d  to teach, but not elementary,

3 yes.

4 a I see. At anytime during the school year 1968-'69,

5! did you learn that Mrs. Ramsey was thinking about
1!6 leaving the system?

7 | !  A . No.

8 0- You did not?

9 I A. I  d idn 't know.

10
I

n i 

12,i

13

14

15

16 

n : 

18

MR. KAPLAN: That's a l l .

THE COURT: You may stand aside, Mrs. B la ir .

(Witness excused.) |

|
MR. STARLING: Your Honor, I  have four very short

witnesses. F irs t of a l l ,  I  would lik e  to c a ll  Mr. 

Clyde Archer.

i

CLYDE ARCHER.

19 ca lled  as a witness on behalf of the defendants, being f i r s t

20 duly sworn, t e s t i f ie d  as fo llow s:

DIRECT EXAMINATION

22

23

24

25

BY MR. STARLING:

Q. Would you state your name and address, please, 

A. Clyde Archer, Wright, Arkansas.

Q. How are you employed, Mr. Archer?

GLENN H PERRIN
O f f ic ia l  C o u r t  R eporter  

F e d eral  B u il d in g  
EL Do r a d o . A r k a n s a s  717»o

sir?



47
i

1 * I am self-employed.

2 i a F armer ?

3 A. Cotton farmer.

4 a Are you on the Board--are you one o f the D irectors on
|| 

5 j the Plum Bayou School Board?
1

6 A. I am.

7 i! a Do you hold any sp ec ific  capacity as a D irector?
8 A. Secretary.

9 Q. You are the Secretary. Mr. Archer , have you attended,
10 or did you attend, the meetings o f the School Board in

11 !| the year 1968-’ 69?

12 !| A. Yes, s ir .

13 a Do you ever r e c a ll in one o f those meetings whether the
14 ! Negro teachers were there from the Tucker-RosenwaId
15

16

17

18

19

20

21 i Q.
22

23

24

25

School and a Mr. Enoch Tony, I  b e lieve , made reference 

to some question concerning the retention  o f the Negro 

teachers during the evaluation? Were you there at that 

meeting?

Yes, s ir ,  I  think I was, but I  wouldn’ t know whether i t  

was Enoch Tony or who i t  was, because I  d idn ’ t know him. 

W ell, le t  me ask you th is : While you have been in the

school—on the School Board at the meetings during the 

year 1968-’ 69, did you ever hear Mr. Bradshaw say to 

the Negro teachers present at that meeting that he would 

not f i r e  a white teacher to h ire a "N igger"?

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7»o Ssrs



472I ar c u e r  - Direct

1i|
1 ^

2! Q.

3
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4

5
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l! a.

6 I *
7

8 I

9 j

10 |

11 A.

12 Q.

13

14 A.

15 1

16!

17 i

181
19

20
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21 Q-

22;
i
A.

23 | q.
j|

24 A.
25

No, s ir .

Did you ever hear Mr. Bradshaw say to the Board or to 

any o f the Negro teachers present that he would not 

dismiss a white teacher to h ire a black teacher?
.

No, s ir .

Mr. Archer, did you ever make a statement to any o f the 

School Board or to any o f the patrons or the teachers 

of that D is tr ic t  at any School Board meeting that you 

would n o t  allow Mr. Bradshaw to f i r e  or to dismiss any 

white teacher to hire a "N igger"?

No, s ir .

What is your--what was the School Board and your
i

attitude towards u n iiica tion  o f your schools?

W ell, I think at f i r s t  we were a l i t t l e  hesitant by 

being in the south, but when i t  become the law and we 

rea lized  i t  was the law o f the land, we had desire to 

comply with the regu lations, federa l regu lations, and 

I think at that time we employed an attorney to advise 

us as to how to go about i t ,  and we have followed his 

advice a l l  o f the way through.

Have you ever been directed by a court--
'

No, s ir .

- - to  un itize?

No, s ir .

MR. STARLING: I b e lieve  th a t's  a l l ,  Your Honor.

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d eral  B u il d in g  
EL Do r a d o . A r k a n s a s  7 t7so



473

MR. KAPLAN: No questions.

THE COURT: You may scand aside.
I

(Witness excused.)

MR. STARLING: Like to c a l l  Mr. Maynard as a

witness, Your Honor.

J. B. MAYNARD.

j ca lled  as a witness on behalf of the defendants, being f i r s t

10 ii duly sworn, t e s t i f ie d  as fo llow s:

11 l| DIRECT EXAMINATION

12 BY MR. STARLING:

Would you state your name and address, please, s ir?

J. B. Maynard, Wright, Arkansas.

How are you employed, Mr. Maynard?

Self-employed, farmer.

Farmer. Are you a member o f the Plum Bayou D is tr ic t  

No. 1 School Board?

Yes , I am.

Do you hold any specia l capacity?

V ice-Presiden t.

V ice-President. Were you at attendance in the meetings 

of the School Board during the school year 1968-'69?

I am sure I was, I don’ t remember any that I  have

missed.

G L E N N  H P ER R IN  
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
E L  Do r a d o  A r k a n s a s  717»o

Maynard -  Direct

13
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25



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25

Or Do you ever recall at any school meeting which was held
during that year or any previous years to cnat where
you were present and Mr. Bradshaw made the statement 
to the Board or to the Negro patrons there, teachers, 
faculty, or whoever they may be, that he was not going 
to dismiss any white teachers to hire any "Niggers"?

A. I have not.
Q. Have you ever heard Mr. Clyde Archer, the Secretary of 

the Board, state that he would not allow Mr. Bradshaw 
to dismiss any white teachers to hire "Niggers"?

A. I have not.
Q. What was your attitude towards unification?
A Well, I am kinda like Mr. Archer said, that there was a 

law that was passed and we felt that we had to abide by 
it, and as a whole, we had the two school systems out 
there, and I had them, the colored students and also the 
white students, at heart, one as much as the other, and 
if it took that to make a better school, why then we 
was for it„

Q. Has the School Board, in any of its meetings--let me
rephrase that question. When Mr. Bradshaw recommended 
to the School Board the list of teachers who he had 
decided to retain after the evaluation, did the School 
Board discuss the races of those teachers?

A. No, sir, we did not.

M a y n a r d  - Direct 474

i

G L E N N  H PERR IN
O f f ic ia l  C o u n t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 1 7 3 0



M a y n a r a  - cross 475

MR. STARLING: I b e lieve  th a t's  a i l ,

THE COURT: Just a minute.

CROSS EXAMINATION

BY MR. KAPLAN:

6 a

7 ! A.

8 I

10

24 A.

25

Mr. Maynard, how long have you been on the Board?

W ell, I can 't remember exactly . I  think I  was appointed 

at f i r s t  to take another member's place that was moving 

out of the D is tr ic t ,  and I think I  have been ree lected  

tw ice.

11! a How about Mr. Archer? Do you know how long--was he

12 the Board before you?

U ' A. No, Mr. Archer came on the Board after I.

14 i| a Who are the other members of the Board?

15 A. Now?

16 a Yes.

» A. Mr. Surratt.

18 a How long has he been on?

19 A. Mr. Surratt, I think, has been on maybe a couple of
20 y e a r s.
21 ' a Mr. B r o w n, how long has he been on?

22 A. Mr. Brown has been on three or four years, I would

23 Q. And the fifth member?

Mr. Conley has served on the School Board, I  suppose, 

for 20 yea rs ,—

GLENN H PERRIN 
O f f ic ia l  C o u r t  R e po r t  cm 

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n g a c  717CO



C o n l e y  - Direct 476

1

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o. Thank you.

A. --maybe more.

MR. KAPLAN: That's a l l .

(Witness excused.)

MR. STARLING: Call Mr. Conley,

FRANK J. CONLEY.
ca lled  as a witness on behalf of the defendants, being f i r s t  

duly sworn, t e s t i f ie d  as fo llow s:

DIRECT EXAMINATION

BY MR. STARLING:

Q. Would you state your name and address, p lease, s ir?

A .  Frank J. Conley, Wright; Arkansas.

Q. How are you employed?

A. I am a farmer.

Q. How long have you been on the School Board?

A. Approximately 25 years, maybe a l i t t l e  longer or just

a l i t t l e  less .

Q. Were you present at the meetings of the School Board 

ca lled  during the school year 1968-‘ 69?

A. Would you repeat that?

Q. Were you present during the School Board m eetings--for 

the School Board meetings during the school year

1968-‘ 69?

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o  A r k a n s a s  7 i7 »o

"T



co n i e y  - Di r e c t 477

A. I think I was in attendance at every one of them.
Q. Do you recall at anytime that you were present at any

of the School Board meetings that Mr. Bradshaw made any
statement to you or to the Board members or to the

ij Negro teachers or to the Negro patrons to the effect 
that "I will not dismiss any white teachers so as to
hire any ’Niggers'"?

! A. No, I did not hear him make that statement.
ji Q. Did you ever hear Mr. Clyde Archer, the Secretary of the

School Board, make such a statement?
A. I did not.
Q. What was the School Board’s policy in reference to this 

reduction in teacher force and evaluation?
A. What was that, now?
Q. What was the School Board's attitude and policy in 

reference to the evaluation of the teachers?
A. What was the Board's? Well, let Mr. Bradshaw do that.

We depend on Mr. Bradshaw as Superintendent, we are not 
school men, and we let him do that, and he brought 
every one of them to us, he brought the list to us and 
presented them to us, and we backed his judgment, we 
thought he did the right thing.

Q. Did you agree with Mr. Bradshaw that both the Negroes 
and the whites should be evaluated together?

A. Well, yes.
GLENN H PERRIN

O f f ic ia l  C o u r t  R epo rter  
F e d eral  B u il d in g  

E L  Do r a d o . A r k a n s a s  717*0



C o n l e y  - Cross i 47 8

MR. STARLING: I b e lieve  th a t's  a l l .

CROSS EXAMINATION

BY MR. KAPLAN:

6

|| 0- Mr. Conley, when was the f i r s t  time that you learned

that there would have to be a reduction in the teacher

force?

W ell, when we f i r s t  un itized , began to ta lk  about i t .  

Did you ever consider any a ltern a tive  to a reduction in

f or c e ?

No. The Board d id n 't , no, that was l e f t  up to Mr. 

Bradshaw.

Did you partic ipa te  in the decision not to reh ire 

Asive Thomas?

Yes, I  sure did.

Did you fo llow  the recommendation of Mr. Bradshaw at 

that time?

That's r igh t.

That year had you had any com petitive sports at Plum

Bayou High School?

I don't think so, no.

You did re in s titu te  them the next year for '68-'69, 

is that right?

I think so.

Were you involved in the decision not to have

8 i A.
9 a

10 i

11 A.
12

13 a

14

15 A.
16 a

17

CO*H A.
19 a

20

21 A.

22
1

Q.
23
i24 A.

25 a

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  t «7 »o &



479Con l e y  - Cross

1

*'j A.
3 ;| a

4 A.

10 Q.

competitive sports?
Yes, I was.
What was the reason for that?
Well, at that time we was the only school in this part 
of the country that was fully integrated, and we 
couldn’t— we didn’t want some outsiders coming in--I 
never did believe we would have any trouble in our 
School District, but, you know, there is outsiders comes 
in and sometimes cause trouble, and we didn't want it. 
What kind of outsiders?

u

12

13

14

15

16

17

18

19

20

A.
a

A.

a

A.
a

21 II A.
22

Sir?
|

What kind of outsiders in sporting events?
You know, people come from everywhere to a basketball 
game, that was all we had was basketball and a little
baseball.
Did you participate in the decision to hire Mr.
McConnell?
I sure did.
At the time that the Board decided to hire Mr. McConnell, 
did you consider Mr. Thomas for that position?
No, we left that up to Mr. Bradshaw, Superintendent, to 
pick the teachers. I don't think it's the Board's place

23

24; aI
25

to pick teachers, we are not qualified to pick them.
I see. Did you know, of your knowledge, whether or not 
Mr. Thomas was a qualified Coach-Physical Education

GLENN H PERRIN 
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in o  
EL Do r a d o . A r k a n r a r  7 «7 »o

S S f A



i coniey - cross
- | --------------------------------------------------------------------------------------------
11 teacher?
2j A. W ell, no, I didn't know it.
3 Q. Is the black School Board member here today?
ji

4 j a. Sir?
5 Q. Is the black School Board member here today?
6 A. No, sir, I don't see him.

I7 j Q. What's his name?
8 A. Alec Brown.
9 ij Q. Alec Brown?
10 ! A. Yes , sir.
11 ! Q. Did he go to all of the meetings, also?

j
12 A He's at most of them, he misses a meeting every once in
13 awhile.

480

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15

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J
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21 [ 

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25

Q. Did Mr. Bradshaw ever discuss with the School Board the 

equalization of salaries for black and white teachers? 

A. Well, 1 don't believe Mr. Bradshaw has that, but Mr.

Elkins, back several years ago, brought it up with the 

School Board to equalize them, and so I think Mr. 

Bradshaw has kept them equalized as well as he could.

Q. You saying several years ago they were equalized?

A It was brought up before the Board, now, when Mr.

Elkins was teaching school.

Q. I see. And did you actually equalize them way back

then?

A. We come up with them as near as we could.
G L E N N  H P E R R IN  

Of f ic ia l  Court R eporter 
Federal Bu ild in g  

E L  Do rad o . A r k an sa s  t it s o



481i C o n l e y  - Cross

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A-

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19 A.
20 a

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22 A.

23 a

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25 A.

As near as you could?

Yes.

Was chere something that prevented you from equalizing 

them a l l  the way?

W ell> i t ' s —with the Board, i t  would be. Now, Mr.

Elkins is the one that—the Superintendent, he is the 

one that fixes  out the teachers’ sa la r ies .

1 see. Do you r e c a ll having a discussion at which Mr. 

Edwards—Mr. Jean Edwards, do you know him?

Yes, I  know Mr. Edwards.

--a t which Mr. Jean Edwards was present when he asked 

the School Board about equalization o f sa laries?

No, I  can 't r e c a l l .

Are you saying that such a meeting never took place?

I  can 't r e c a ll of one.

At the time that Mr. Bradshaw brought the l i s t  of 

teachers to you, did you know that Mrs. Ramsey was going 

to be resign ing anyway?

No, I  d id n 't.

Did he have Mrs. Ramsey's name on the l i s t ,  or do you 

remember?

1 don 't remember.

How about Mr. Edwards, did you know whether or not he 

was going to resign?

No, I d idn 't know he was going to res ign .

G L E N N  H P E R R IN  
O f f ic ia l  C o u n t  R eporter  

F e d e r al  B u il d in g  
EL  Do r a d o . A r k a n s a s  7i7SO



482uonj.ey - tross

1
a Haw did you fe e l about un ifica tion  in the D is tr ic t , Mr.

2 Conley?

3 A. Unification?

4 a (Nods head a ffirm a tiv e ly )

5 i A W ell, i t  was the only thing we could do, i t was the

6 law, and as c itizen s  of America, why i t  was the law o f

7 the land, and we try  to abide by i t .

8 ! ^ Did you know that a l l  of the teachers that were being

9 le t  go were black?

10 A Sir?

11 a Did you know that a l l  of the teachers that were being

12 i
1

le t  go were black?

13 i A.i They w eren 't. No, I d idn 't know.

14 a You d idn 't know that? Who wasn't?

15 A. Mrs. Ramsey.

16 i o. You knew she was leaving o f her a*m, d idn 't you?

17 A No, s ir .

18 a You d idn 't know that?

19 A No.

20 j a Did you la te r  learn it?

21 A. What, her leaving on her own accord?
i

22 Q. Uh-huh. Yes.

23 1 A. No.

24 a You never learned that?

25 A. (Shakes head n egative ly )

GLENN H PERRIN
O f f ic ia l  Co u n t  R eporter  

F e d e r al  B u il d in g  
E L  Do r a d o . A r k a n s a s  7 i7 so



burr a t t Direct 483

MR. KAPLAN: Thank you.

MR. STARLING: That's a l l ,  Your Honor,

THE COURT: Stand aside,

(Witness excused.) 

MR. STARLING: We c a l l  Mr, Surratt as the la s t one,

J, W, SURRATT.

ca lled  as a witness on behalf o f the defendants, being f i r s t  

duly sworn, t e s t i f ie d  as fo llow s:

DIRECT EXAMINATION

BY MR. STARLING:

Q. Would you state your name and address, please, s ir?

A. J. W. Surratt, Star Route, Tucker.

Q. And how are you employed?

A. W ell, I am a parttime farmer and a construction worker, 

an e le c tr ic ia n .

a Mr. Surratt, are you on the Plum Bayou School D is tr ic t  

No. 1 School Board?

A. Yes, s ir ,  I am.

Q. Do you hold any position  on that Board?

A. No, s ir .

Q. Just a member?

A. Right.

Q. Were you present during the Plum Bayou School Board

GLENN H PERRIN 
O f f ic ia l  C o u r t  R eporter  

F e d e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7so



1
1

2 A.

3 a
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9 a

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16

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meetings during the school year 1968-'69?

I am sure I was.

W ell, tor those meetings which you were present, did you 

ever hear Mr. Bradshaw make a statement to you or to the 

Board or to any o f the Negro facu lty or patrons of the 

D is tr ic t that he would not dismiss any white teachers 

to h ire a "Nigger"?

No, s ir ,  1 did not.

Did you ever hear Mr. Clyde Archer, Secretary o f the 

Board, at any meeting o f the School Board, make such 

a statement to the Board or to the Negro facu lty  or 

patrons of the D istric t?

No, s ir ,  I did not.

What was your attitude toward un itization?

W ell, I knew that this thing wasn’ t going to be easy, 

and that i t  was going to be a hard decision , because 

I knew there would be c o n flic t  there, that there would 

be some people hurt, and, the fac t is ,  we were warned 

when we had meetings with Mr. Turner and them that there 

would be some people hurt. I t ’ s just lik e  saying you 

had a basketball team out there, w e ll, everybody is 

wanting to play, but you can only put f iv e  on the

f lo o r .  We had 15 people and we could only use 10, and

somebody h a d  to be terminated, and that we d idn 't have 

room for a l l  o f them.

Surratt - Dir e c t 484

A.

Q.

G L E N N  H P ER R IN  
O f f ic ia l  C o u r t  R epo rter  

F e d e r al  B u il d in g  
E L  Do r a d o . A r k a n s a s  7I7SO £ 7 0 * .



burratt Direct 485

; 0. What was your attitude towards the evaluation form and 

the tact that Mr. Bradshaw was going to evaluate both 

Negro and white?

A. I thought i t  was the only fa ir  way that he could.

I Q. Had the School Board contacted their attorney?
j

A .  I am sure they had, yes, s ir .

-2. Has this School Board or D is tr ic t  ever been ordered by 

a court to do anything in regards to integration?

A. No, s ir ,  we have not.

Q. What is your a ttitude towards lawsuits with the
|

Federal Government or w ith—with the Federal Government?

A. W ell, now, I understand that th is lawsuit is for

discrim ination, and looks to me lik e  us grown people 

are discrim inating from our ch ildren , because we are a 

poor School D is tr ic t  and we need every penny to buy what 

needs our teachers need, and i t  is  costing us time and 

money to do th is , and i f  there is any discrim ination,

I think i t ’ s against our school children, 

a W ell, I  d idn 't r e a lly  ask for that answer, what I r e a lly  I 

asked was, your D is tr ic t , has i t  ever had the attitude 

o f wanting to become embroiled in suits by the Federal 

Government?

A. No, s ir .
I

Q. What has been your attitude in th is respect?

A. I beg your pardon?

GLENN H PERRIN 
O f f ic ia l  Co u r t  R epo rter  

F ed e r al  B u il d in g  
EL Do r a d o . A r k a n s a s  7 i7 *o



I 486Surratt - Cross
i

1 i| a

2 A.

3 a

4 A.

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7

8 A.

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BY

13 Q.
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15 A.

16 !;

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20
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21 j| A.
22 1 Q.

What has been your attitude in this respect?

In obeying the law?
(Nods head affirmatively)
I don't think you have any choice, you have to obey the 

law.
Were you one of the first School Districts in this area 

to unitize your schools?

So far as I know, we were.

MR. STARLING: That's all.

CROSS EXAMINATION

MR. KAPLAN:
Mr. Surratt, when did you first learn that there would 

be a reduction from 15 to 10 members on the faculty? 

Well, I didn't know exactly how many that we would 

retain or how many we would have to dismiss, but I knew 

that we had too many teachers and somebody would have 

to go.
Did you ever ask your administration, Mr. Bradshaw, to

consider --

No, sir, I didn't.
--any alternatives which would not require teachers to

i

be displaced?

24 i A.

25 a

No, sir, I did not.
Did you, yourself, ever consider any?

GLENN H PERRIN  
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 i 7 s o



487I Edwards - Direct 
i  j j  A. No, sir.
2’I Q. To your knowledge, any of the Boar a saembers? 

3 A. No, sir.

MR. KAPLAN: That's all.
MR. STARLING: I have no further witnesses, Your

Honor.

THE COURT: Stand aside.

13

14

(Witness excused.)

THE COURT: Anything further, Mr. Kaplan?

MR. KAPLAN: One rebuttal witness, if Your Honor

please. Mr. Edwards:

JEAN C. EDWARDS.
15

16 

17

21 jj

22 

23

25

called as a witness on behalf of the plaintiffs, in rebuttal, jI
having been previously duly sworn, testified as follows:

DIRECT EXAMINATION

BY MR. KAPLAN:
Q. Mr. Edwards, you are the same Jean Edwards who testified 

here previously, I believe, on yesterday?

A. Yes, sir, I am.
a Mr. Edwards, do you have anything at all now to do with 

this School District?

A. No.
a Mr. Edwards, did you ever have a conversation with the

GLENN H PERRIN
O f f i c i a l  C o u r t  R epo rter  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n g a e  7 t 7 a o



Board of the Plum Bayou-Tucker School District and with 

Mr. James K. Bradshaw regarding Mrs. Evans’ serving as 

Health Coordinator?

A. Yes, I did. In April of 1967, that year I was associated 

with the National Teacher Corps., but due to the 

circumstances under which I left, I felt that I was 

still responsible for the welfare of my teachers, and 

it was understood and agreed that I would return as 

Principal, '67-'68 school year.

Q. '68- '69 school year, is that right?
A. No, '67-'68 school year. This was April of '67.

Q. I see.
I

A. And at this time, with Mr. Frank Conley, Mr. Clyde
|

Archer, Mr. Alec Brown, Mr. J. P. Maynard, Mr.

Surratt, Mr. B. E. Turner coming in about 15 minutes 

late, and myself, I discussed teacher equalization, 

because it had been promised under the administration of 

Mr. Elkins, it had been promised under the administration
!

of Mr. Anderson, who had died, and Mr. Bradshaw had 

taken over this position. At this meeting we were 

discussing this, and they say that the salaries was 

equal. I knew that they were not. And they say that 

the onliest difference in the salary were based on 

special duty, teachers who performed special duties.

At this time I mentioned that Mr. Robert Hall had been
GLENN H PERRIN

O f f i c i a l .  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n q  

E L  D o r a d o . A r k a n s a s  7 i 7 * o

Edwards - Direct



acting as Coach and Mrs. Evans had been acting as Hea._ 
Coordinator and that none or our black teachers had been 
paid for these duties, and at that point Mr. Clyde 

Archer say "Y e s , some of the black teachers are being 

paid for special duties because you are as Principal". 

And this was the statement. Mr. Turner, after this 

conversation was over and we discussed the equalization 

of teacher salary, he got up and Addressed the Board 

and told them that this was the trend. At this 

particular meeting, the School Board members who 

argued in favor of equalization or felt that the salaries 

should be equalized was Mr. Surratt and Mr. Alec Brown, 

the other members was opposed. This was in April of 

1967.

When you returned as Principal the next year, were the 

teachers ' salaries equalized between blacks and whites? 

Not that I know of.

Was Mr. Bradshaw present at that meeting?

Yes, he was. In tact, at that meeting, Mr. Bradshaw 

and I had a discussion, because Mr. Bradshaw had stated 

to the ^acuity of the Rosenwald School that there would 

not be a position for me in the School District the 

next year and he had not talked with me concerning 

this. <u*d I asked Mr. Bradshaw if in the future he had 

anything concerning my affairs to discuss with anyone,
G L E N N  H P ER R IN  

O f f ic ia l  C o u r t  R epo rter  
F e d e r al  B u il d in g  

E L  Do r a d o  A r k a n s a s  t i t *o



490Edwards - Direct
1

3 a

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22 A.
i

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if he would discuss them with me instead of my faculty, 

because I felt that this was unethical.

Did you actually return that next year?

Yes, 1 did.

MR. KAPLAN: That's all--oh, just one other matter,

Mr. Edwards.

When did you tell Mr. Bradshaw that you would not be 

returning for the academic year '69-'70?

I don't know the exact date, but I turned in my 

resignation to Mr. Bradshaw, I am sure, prior to the 

Board meeting where the decision on unification was to 

be made, and the reason that I am fairly sure of this 

is because I had planned to leave the District prior to 

the end of that year, and I approached Mr. Bradshaw on 

the day of the Board meeting and told him that since I 

had contracted myself for that year's service and that 

I had talked with Dr. Price and Dr. Price said he would 

hold the job open for me for 60 days, that I would 

remain with the School District for the remainder of 

the year.

Were you a certified Math teacher?

I was certified in Vocational Agriculture, Mathematics, 

and General Science.

MR. KAPLAN: Just one second, Your Honor. (Confer­

ring with co-counsel) T h a t ’s all. Your witness.
G L E N N  H PERR IN  

O f f ic ia l  C o u r t  R e p o r t e r  

F e d eral  B u il d in g  
E L  Do r a d o  A r k a n s a s  717S0 5 % , 6



THE COURT: Any questions, Mr. Starling?

MR. STARLING: I don't believe 1 have any questions
Your Honor.

THE COURT: You may stand aside.

(Witness excused.)

MR. KAPLAN: Just one brief question from Mrs.
Thomas.

L. Thomas - Direct

! '
LOIS THOMAS.

called as a witness on behalf of the plaintiffs, in rebuttal, 

having been previously duly sworn, testified as follows:

DIRECT EXAMINATION
| BY MR. KAPLAN:

0- Mrs. Thomas, you are the same Mrs. Lois Ann Thomas who 
testified here before?i

A. Yes, I am.

Q. Mrs. Thomas, you testified earlier about all of the

school districts around here that you went to and put 

in an application in in the school year '69-'70. Did 

you also go to Mr. Turner's office?
j

A Yes, I did.
I

Q. When did you?
jiA. Well, it was probably a little while after I was

dismissed from Plum Bayou.
GLENN H PERRIN

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 i 7 a o

491



l . i nomas - Direct
i 492

1 a

2 i A.

3 a

5! A.
6’ aiii
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Q.

A.
14

15

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a

A.

Did you talk to Mr. Turner?

Yes, I did.

And did you tell him that you wanted to make application 

for a teaching position?

Yes, I did.

What did he tell you?

He told me that he would try all that he could to help 

me get another position and he would use the records 

that he had in his office on me as an application and 

that I would not have to send in an application. He 

also--

I am sorry, go ahead.

He also asked me to call him once every week because 

he d i d n ’t know when they would have some vacancies,-- 

Did you call--

— so I called him once every week for two or three 

m o n t h s .

MR. KAPLAN: Thank you.

THE COLRT: Just one minute. Keep your seat.

21

22

23

24

25

CROSS EXAMINATION
BY MR. STARLING:

Q. Had you ever put in an application at the County

Suoeri n tendent’s Office before?

A- No, I did not. He told me that I d i d n ’t have to.
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n e a i  71730 5



L .

1 a

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3 Q.

4 A.

5 Q.

6 A.

7
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9 Q.

10 : a .

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a

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16 a

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20

21:

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24

25 I

II

When you first graduated from college?
Oh, no, I didn't.
You didn ' t?
No, I didn't.
You never have put in an application?
No, I haven't.
How did Mr. Bradshaw hire you?
Mr. Bradshaw was not Superintendent when I was hired.
How did Mr. Anderson hire you?
Through Mr. Edwards, I was recommended through Mr.
Edwards.
If you had a so-called application from Mr. Turner, or 
rather, you really didn't put in a formal application,
did you?
No, I didn't.
How do you expect that Mr. Bradshaw, if he called Mr.
Turner's office, wouLd know whether or not you had an 
application in if you didn’t have one on file?
Well, as many times as I called down to the Superintend- i
ent's Office, he knew that I was looking for a job, 
because I did this for a long, long time, and he knew 
that.
Are you saying Mr. Turner, now, is the one that is at

iblame for this rather than Mr. Bradshaw?
IMR. KAPLAN: Objection, Your Honor, she hasn’t said

GLENN H PERRIN 
O f f i c i a l  C o u r t  R epo rter  

F e d e r a l  B u il d in g  
EL Do r a d o . A r k a n e a *  7 17S 0

Thomas - Cross 493



L. inomas Cross 494
that anybody was at blame for anything

MR. STARLING: Well,-

Q. Why did you write Mr. Bradshaw a letter on September 1,

1970, which states: “Dear Mr. Bradshaw: Please consider

I an* a 1964 graduate of AM&N College, Pine Bluff, 

Arkansas, with a major in elementary education. I have 

five years' teaching experience at the Rosenwald 

Elementary School, Tucker, Arkansas. I will be available 

for an interview at your convenience." Did you write
;l

that letter?

A. Yes, I did write it. Yes, I did.
ji

Q. Well, if you had an application on file down at the 

County Supervisor's Office, or at least you say that 

Mr. Turner said he did,—

! A  He did.

! Q. --why did you write this letter to tell Mr. Bradshaw 

you were now applying for a job? 

j A. Why did I write it? Because I was applying for the job.

me an applicant for a teaching position in your school

I had heard there was a position open, and I decided

to write it.

Q. Mr. Bradshaw answer you back?

A. Yas , he d i d .

Q. I shew you a letter dated September the 3rd, two days

after your letter, and ask you--it says: “Dear Mrs.
GLENN H PERRIN

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0



L. Thomas - Cross 

1 Thomas: Thank you for your letter of application. At

i the present time no teaching positions are open at the

3 Plum Bayou-Tucker School District. Sincerely, James K.

4 Bradshaw." Is that the letter Mr. Bradshaw wrote to
5 jj you?
!3 A. Yes, it is.

495

8 1 

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MR. STARLING: 1 would like to mark that for

identification and enter it as defendants' exhibit, 
Your Honor.

THE COURT: Let it be received.

MR. STARLING: I have nothing further, Your Honor.

REDIRECT EXAMINATION

BY MR. KAPLAN:

Cl Mrs. Thomas, had you had contact with some of the 

teachers who were still at the Plum Bayou School?

A. Yes, I did.

Q And did they advise you that there was a position

available?
A. Yes, they did.

Q. And did you talk to counsel about what to do about that? 

A. Yes, I did.
Q. And did counsel advise you you might as well just write

i
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i
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'I
24 agair
25 A. Yes, they sure did.

GLENN H PERRIN 
Of f i c i a l  C o u r t  R e p o r t o  

F e d e r a l  B u il d in g  
EL Dor ado  A r k a n i a i  7 1 7 3 0

1

1



L. Thomas Recross 496

MR. KAPLAN: All right.

RECROSS EXAMINATION

BY MR. STARLING:
Q. Mrs. Thomas, what position was available?

A. I heard there was an elementary position open.

Q. Did you write— did the letter you write on September 1, 

was that prior to Mr. Bradshaw hiring Mrs. Florida
i

Roann?
A. I don't know when he hired Mrs. Roann. i

MR. STARLING: 1 believe that's all.
i

MR. KAPLAN: Nothing further, Your Honor.
(Witness excused.) j

THE COURT: Do you have anything further to

present to the Court?

MR. KAPLAN: We have no further evidence, Your

Honor.
MR. STARLING: We have no further evidence, Your

Honor.
THE COURT: You gentlemen care to proceed

further, or do you want to make any argument 

to the Court, or you want to present anything 
further to the Court in connection with this 

matter?
GLENN H PERRIN 

O f f i c i a l  C o u r t  R k p o r t s r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a n s a s  7 i 7 » o

i



MR. STARLING: Your Honor, I would like to a

tew closing remarks, but on the other hand I would 
also like to renew my motion which I made at the 

close of the plaintiffs’ case.

THE COURT: Yes. All right. But--you have

anything you want to present, Mr, Kaplan?

MR. KAPLAN: If Your Honor is disposed to make a
ruling from the bench, I would like to make a few 
remarks; but if not, then I would reserve those to j 

submit in the form of a very brief memorandum 
within a period of a few weeks.

THE COURT: Well, whichever you desire. If

you wish to submit a memorandum, narrow these 

issues, the Court would have to delineate what 

has been presented here as evidence of the
j

various questions;you have already eliminated
!

certain of the issues which y>u contend, I 

think, such as with reference to the Rosenwald 

facility, and visitation, I think, maybe some
|

other th i n g s .

M R . KAPLAN: Your Honor is correct.

THE COURT: And instead of having to take up

the points one by one and say "This is no
I

longer an issue" or "This is an issue", 

probably could be narrowed by taking up the
GLENN H PERRIN  

O f f i c i a l  C o u n t  R e p o r t e r  

F e d e r a l  R u i l d i n o  

EL D o r a d o . A r k a n s a s  7 i7*o



498
points that you would contend chat is at 

issue, and that way we might eliminate a lot 

of unnecessary consideration of matters that 
are no longer involved.

MR. KAPLAN: Your Honor, I would be happy to submit

a memorandum to the Court within 20 days with the 

aim of both narrowing all of the issues and 

providing the Court with what we consider to be the 

applicable law and theory in the case.

THE COURT: Well, now, do you— among this--it’s

perfectly all right, if that’s agreeable to Mr. 

Starling, too, but this question of the 

salary schedule or equalization of salaries,

I am not sure that that was an issue involved 

in this case until the development of the 

testimony here, perhaps it could be included. 

Your Complaint is, I think, intended to be in 
general terms in some of its paragraphs, 

covers a great many things in connection with 

it, but I think one of the things the Court's 

going to require you to do, Mr. Starling, is 

to present a salary schedule recognized 

generally in this state. Other districts have 

done it. Based completely on the record, that 

is, the record of the teachers with reference
GLENN H PERRIN  

O f f i c i a l  C o u r t  R s p o r t k r  

F e d e r a l  B u i l d i n g  

E L  D o r a d o . A r k a n s a s  7 1 7 3 0



to their accomplishments, the degrees they 
nold, and the years' experience, which I 
understand from other districts submitting 

salary schedules that they are entitled to 

salary advancement on the basis of their 

experience and years' service and in accordance 
with the accomplishments of their academic 

program. Now, 1 am not sure if there is a 

regular adopted salary schedule of the state 

or not, I have a feeling there is. If this i
iDistrict has one, it hasn't come up with it, 

and if there is any question of equalization 

of salaries, if it hasn't been done, then the 

District should do it, 1 will say th a t  touch 

at this point. I would suspect you had better 

consult Mr. Bradshaw and see that that has been j
done and this record should state the status 

of it somewhere along the line, and I should 

think that an acceptable salary schedule in 

accordance with the accomplishments of the 
teachers and the recognized--the recognized 

points which they are entitled to receive 
certain salaries and increases on whatever 

record is made that would justify as has been 

done in other cases that this Court is familiar
GLENN H. PERRIN  

Of f ic ia l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 i 7 s o



with. As an example, if a person has &

Master's Degree, they are entitled to a minimum 

salary; if they have a Bachelor of Science 

Degree, there is a minimum schedule, with 

increases on the years of experience, and so 

forth. You are familiar with that, Mr.

B r a d s h a w ,--

MR. JAMES K. BRADSHAW: Yes, sir.

THE COURT: --and I think it should be done,

if it is not already.

MR. STARLING: Your Honor, if I may say so for the

District, I was not familiar with the problem 

because I d i d n ’t realize it was an issue, but all 

I can say is that the District w i l l — I think we 

already have one right here, but if the District 

does not, I can assure the Court it is not our 

intention and probably unknowing to the fact--I 

think Mr. Bradshaw's statement was that he was 

giving just base increments which the legislature 

gave to both black and white.

THE COURT: Apparently the School Board has

considered it along with the administration.

The first time Mr. El k i n s — was that his name-- 

was brought into this picture was the last 

witness. I d o n ’t know when Mr. Elkin* t

F e d e r a l  B u i l d i n g  

EL D o r a d o  A r k a n s a s  7 1 7 * 0

O f f i c i a l  C o u r t  R e p o r t e r

GLENN H PERRIN



suppose, was Superintendent, but apparently 

rroui the School Boara members' testimony and 

Mr. Edwards, there is consideration given to 

doing so way back even probably prior to 1965 

MR. STARLING: I have a teacher salary schedule,
Your Honor, for 1966-'67, which is what they used, 

shows "Training", "Bachelor's Degree", "Master's 

Degree", "Form of Advanced Study", "Beginning 

Salary", "Annual Increments up to 10 years",

"Extra Duty", and the "Maximum".

THE COURT: Well, I think whatever— what, if

anything, has been done in this regard would 

be advisable if you were to present it to Mr. 

Kaplan and give him the explanation and in 
this regard to determine whether or not there 

is an equalization of salaries; if not, it 
should be done.

MR. STARLING: Yes, sir, we will do that, no

problem. We will do that.
THE COURT: Now, on the other questions, you

can decide which you contend are still at 

issue and file whatever brief you would like, 

in that regard, if you would like to do so.

>*P „ KAPLAN: We would , Your Honor .

THE COURT: Is that agreeable?
OLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 i 7 » o



502
1 MR. STARLING: I would like for Your honor, if

2 poss Lble — the only reason I say make a ruling,
3 Your Honor, is the fact that it's been two and a
4 hair years since the School Board has been under
5 this .

6 THE COURT: Well, I was hoping that somebody
7 would bring that up, because I think this

record is cieficient on it, and whatever course
9 this matter takes and review considered, this

10 case was filed July 22nd, 1969. On Thursday,
11 October 23rd, 1969, there was a pre-trial
12 scheduled in the regular pre-trial docket by
13 this Court on October 23rd, 1969. The Court
14 scheduled this matter for trial on December
15 the 11th, 1969, and by request of both

i
16 parties, it was continued. There was some
17 conversation with the Court in which each of
18| you indicated a desire that the matter be

• tried early in 1970. The Court scheduled the j
20 matter for trial following that for the next
2! session of the Court. Mr. Kaplan, along with
22 the understanding of Mr. Starling, contended

23̂ that it could not be possible— it would not
24 b e  possible that the matter could be tried in
25 one day and suggested a later date.

GLENN H PERRIN
O f f ic ia l  C o u r t  R v o r t u  ^  

F e d eral  B u il d in g  qT 
EL Do r a d o . A r k a n s a s  71730



February 17th, 1970, the Court advised both 

of you that the matter would be included on 

the pre-trial calendar in April, 1970, and 

suggested that it would be a good time to 

schedule the matter for a hearing to the Court 
at that time. So I think it should be noted 

that the Court has attempted to schedule this 

matter for consideration during each of the 

sessions in connection with the work here 

during that time, and due to various factors,

I assume, everybody is busy, particularly most 

ail lawyers, and this Court certainly is, and 

I have endeavored to hold myself available 

for it at each time, the session beginning in 

1969 and until this time, which is in 

connection with the special setting of the 

docket which the Court did in view of the 

schedule last November. And so 1 do not 

believe that the gentleman is in a position 

to contend at this time that merely because 

it has been here since July, 1969, that there 
should not be consideration given to such 
other presentation to the Court in view of 

the hearing today as would be reasonable. And 

I do think that the matter should be disposed
GLENN H PERRIN 

O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 i 7 s o



oi„ If I remember correctly, Mr. Kaplan 

advised tne by telephone sometime ago that 

many of the issues as he originally alleged 

are no longer at issue in this case, and 

there was really no great hurry.

Now, at the present time, you gentlemen may 

present something else in connection with your 

own contentions in it, but appears to me other 

than such matters as the salary schedule that 
I mentioned a moment ago, that this matter is 

limited only to the contention of Mrs. Evans 

here, whatever that may be at this time, and 

Mr. Thomas, who seems to be quite happy in 

his present situation from his testimony, and 

Mrs. Thomas, who appears to be very unhappy 
about her situation. It seems to me those 

are the only major things or major issues or 

questions left at this time.

I know there are circumstances, just like— just 

as one of the School Board members endeavored 

to explain a moment ago, when you reach this 

kind of a situation, somebody is going to get 

left out, and in considering what should be 

done with reference to the teachers, the Court, 

of course, will have to take into consideration
GLENN H PERRIN 

Of f i c i a l  C o u r t  R v o r t i k  
F e d e r al  B u il d in g  

EL Do r a d o . A r k a n s a s  7 i7 »o

504



505

che face  t h e r e  were ab out  215,  2 2 0 ,  225 

students in the elementary grades, one to 

eight, during the years of this transition of 

1967, 1968, and 1969, each one of them, so 

the time they went to the ten-teacher 

elementary grades, there is only about a ratio 

of one teacher to 22. All of those things 

should be taken into consideration as to 

whether or not Mru Bradshaw was justified in 

this determination.

So I believe the record is very clear on what 

the status of things are now. This Court 
would like very much to see a lot better 

understanding among some people than what 
apparently exists, because anyone that is 

employed, whatever position that it may be, 

that is not compatible with those that he 

is associated with, particularly their 

supervisors, the School Board, or otherwise, 

you are not going to have the kind of 

cooperation that is desired in a situation 

like this. I think it's got to be understood 

that a school superintendent, as well as every 

teacher and everyone connected with the school 

has got his own responsibilities and those

IiiI
i

i

!

I

GLENN H PERRIN
O f f i c i a l  C o u r t  R b f o m t i r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 t7 »o



506
responsibilities must be recognized, and that 

is true with the Board. I know the Board 

itself has got to depend a great deal on the 

Superintendent or whatever administrative 

officer you may have in that regard. So this, 

nor any other school, can operate as it 

should unless there is that degree of 

cooperation, understanding, and willingness 

to get along. And I would say that anyone, 

regardless of who it is, that is not willing 

to cooperate and get along, sooner or later is 

going to come to the position that they are 

just not compatible and cannot keep on in 

any organization. That's what makes our 

public institutions more difficult, and since 

the general public is involved.

I don't know, you have a School District here 

with obviously a great many more black people 

than white people, but evidently there must be 

that confidence and understanding among the 

patrons as to wh o m  they want to serve in the 

School Board. They have an election that 

comes up every year, I believe, isn't it?

MR. JAMES K. BRADSHAW: Yes, sir.

THE COURT: I know when I used to have to run

I

i

i

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 I 7 S O



507
for office, and I did for 15 straight political 

years, which is a total o£--little more than 
that, 34 years, 17, used to tell me "Well, 

just wait until the next time, we will get you 

when you come up for vote again". That’s the 

usual procedure in this country in positions 

of this kind where the public make their 

choices as to who represents them, and I am 

constrained to think there is a whole lot 

more understanding and cooperation generally 

among the people there than this record 

indicates, but even those who are involved, 

seems to me that some at least could have a I
better understanding and be a lot better for 

the children of that School District.

How much time, Mr. Kaplan, do you want?
MR. KAPLAN: Twenty days, Your Honor.

THE COURT: How much time do you want to I
respond?

MR. STARLING: Ten days, Your Honor.

THE COURT: And the Court will proceed to

decide this matter very shortly thereafter.

Or do you want to reply?

MR „ KAPLAN: No, Your Honor.
THE COURT: The Court, then, will proceed to

GLENN H PERRIN
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 i 7 » o *



decide this natter very soon after you 
gentlemen file your respective briefs.
If there is nothing else, the Court will now 
be in recess.

* * *

!
I

II

I

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e p o r t e r  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0 s W



I, Glenn H. Perrin, Certified Shorthand Reporter, hereby 
I; certify that T am Official Court Reporter for the United 
States District Court, Eastern and Western Districts of 
Arkansas; that on the 8th and 9th day of February, 1971, I 

was present in court ai d reported the proceedings had in the 
within-named and numbered cause before the Honorable Oren 

j Harris, Judge of said Court, and that the foregoing, consist- 
j ing of 508 typewritten pages, contains a true and correct 
transcription of testimony given, as reported by me at the 
time, and transcribed and reduced to typewriting by me.

WITNESS my hand this 10th day of July, 1971.

Glenn H. Perrin, C.S.R. 
Official Court Reporter 
201 Federal Building 
El Dorado, Arkansas 71730

GLENN H PERRIN 
O f f i c i a l  C o u r t  R e f o r t  e h  

F e d e r a l  B u i l d i n g  

EL D o r a d o . A r k a n s a s  7 1 7 3 0





PI UM BAYOU-TUCKLP SCHOOL DISTRICT NO 1
.'.RIGHT ApK a>MNA^ 79 1 Q2

JAM ES V A N 0 € »S O K , SUTT 
J E M A Y N A R O

T «U M A N  L O E TlS

May 9, 1967

T a c i t  r  R o s c n v a M  n . T . A .
T u r lu r ,  A r ^ a n s n s

RE: L i t t e r  i a t e d  M a r c h  2 7 ,  1 9 6 7 ,  d i r e c t e d  t o
t h e  E o a r d  o f  E d u c a t i o n

I n  a n s w e r i n g  y o u r  q u t s t i o n  c o n c e r n i n g  w h o  w i l l  d e t e r m i n e  v h i c h  
s t u d e n t  w i l l  b e  s e n t  hom e a s  a d i s c i p l i n a r y  m e a s u r e ,  i s  a  r e ­
s p o n s i b i l i t y  o f  t h e  P r i n c i p a l  o r  S u p e r i n t e n d e n t ,  g r a n t e d  b y  
th< h o a r d  o f  E d u c a t i o n ,  T h e  S c h o o l  L a v ,  p a g e  1 L 7 ,  S e c t i o n  8 0 - 1 5 1 6 :

S u s p e n s i o n  o f  P u p i l s ;  C a u s e  -  T h e  d i r e c t o r s  o f  a n y  s c h o o l  
d i s t r i c t  m ay s u s p e n d  a n y  p e r s o n  f r o m  s c h o o l  f o r  i m m o r a l i t y ,  
r e f a c t o r y  c o n d u c t ,  i n s u b o r d i n a t i o n ,  i n f e c t i o u s  d i s e a s e ,  
h a b i t u a l  u n c l e a n l i n e s s  o r  o t h e r  c o n d u c t  t h a t  w o u l d  t e n d  t o  
i m n a i r  t h e  d i s c  i n l i n e  o f  t h e  s c h o o l ,  o r  h a rm  t h e  o t h e r  p u p i l s ,  
b u t  s u c h  s u s o e n s i . c n  s h a l l  n o t  e x t e n d  b e y o n d  t h e  c u r r e n t  t e r m .  
T h e  b o a r d  o f  i i r e c t o r s  m ay a u t h o r i z e  t h e  t e a c h e r  t o  s u s p e n d  
a n y  p u o i l s ,  s u b j e c t  t o  a n n e a l  t o  t h e  b o a r d .  I d .  S e c t i o n  1 7 0 .

Th  r n  w e r e  s e v e r a l  r e a s o n s  t h a t  i n t e r - s c h o o l  s p o r t s  w e r e  d i s ­
c o n t i n u e d  a t  P lu m  E a y o u .

( 1 )  T h i s  s c h o o l  h a d  d i s c o n t i n u e d  i n t e r - s c h o o l  s p o r t s  f o r  o u r  
s e n i o r  b o v s  b e f o r e  t h e  s c h o o l s  w e r e  i n t e g r a t e d ,  d u e  t o  
t h e  f a c t  t h a t  we w e r e  u n a b l e  t o  s c h e d u l e  gam es  w i t h  o t h e r
s c h o o l s .

( 2 )  T h e  H e a r d  f e l t  t h a t  i n t e r - s c h o o l  s p o r t s  s h o u l d  b e  d i s ­
c o n t i n u e d  u n t i l  a l a t e r  l a t e .  T h i s  d e c i s i o n  w as  b a s e d  
on  th< o r e v o n t i o n  o f  i n c i d e n t s  b e t w e e n  t h e  n e s r r o  a n d
• h i t c  i n  o u r  c o m m u n i t i e s .

I  w i l l  a g r e e  i n  m o s t  c a s e s  c o m p e t i t i v e  s n o r t s  b u i l d  s c h o o l  s p i r i t  
a n d  c o m m u n i t y  p r i d e ,  b u t  i f  we. a r t  t o  p e r m i t  t r o u b l e  w i t h i n  o u r  
c o m m u n i t y  I  d o  n o t  f e d  we w i l l  h a v e  a n y t h i n g  t o  b e  p r o u d  o f .

J a m e s  K . B r a d s h a w ,  A c t i n g  S u p e r i n t e n d e n t  
By A u t h o r i t y  o f  B o a r d  o f  D i r e c t o r s  
.H um  B a y o u - T u c k e r  S c h o o l  D i s t r i c t



D i v i s i o n  o f  
T e a c h e r  E d u ca t io n

S tu d e n t  T e a c h in g  
C e n te r

Name o f  Stud 

S c h o o l________

Grade _____

d i r e c t i o n s :

COMPETENCIES

P e r s o n a l

I n s t r u c t i o n a l

AuRaCw L i U R / i M C ■ aSmL a Nu

P in e  b l u f f ,  A rkansas

■ ' i 7 T . 1 ?o l n i ,  A J u

C o n f i d e n t i a l  R e p o r t  o f  S tu d e n t  T ea ch e r

snt a d d ress Date

L o c a t i o n
C i t y S t r e e t  and Nunioer

_ C o o p e ra t in g  T ea ch e r

ir c m  yo u r  o b s e r v a t i o n s  and work w i th  t h i s  s tu d e n t  t e a c h e r ,  p l e a s e  l i s t  
y o u r  assessm en t o f  h i s  co m p e te n c ie s  i n  each c f  the c a t e g o r i e s  b e lo w .  
C i r c l e  the  number wh ich  most a p p r o p r i a t e l y  r e f l e c t s  t h e ° o e g r e e  r f  com­
p e te n c e  you f e e l  t h i s  s tu d en t  h as .  The h ig h e r  th e  numoer, th e  g r e a t e r  
d e g r e e  o f  com petence i s  f e l t .  Cne i s  the l o w e s t  d e g r e e  o f  com petence- 
t h r e e  r e p r e s e n t s  an a v e r a g e  d e g r e e  o f  com pe tence ; and f i v e  r e p r e s e n t s *  
o u t s ta n d in g  com pe tence .  »

1 . A ppearance  (g r o o m in g ,  d r e s s ,  e t c . )
2 .  E m o t io n a l  s t a o i l i t y
3 .  E n e rg y  and stam ina
4 . V o ic e  and speech
5. C o n s id e r a t e n e s s  ( t a c t ,  c o u r t e s y ,  e t c . )
6 .  C r e a t i v e  and r e s o u r c e fu l
7 .  P o i s e  and r e f in e m e n t
8. Sense o f  humor
9 . P u n c t u a l i t y  

10. R e l i a b i l i t y

12 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5

1. Knowledge o f  s u b j e c t  m a t t e r
2 .  S k i l l  i n  p r e s e n t in g  s u o j e c t  m a t t e r
3 .  P u p i l  s tu dy
U. S y s t e m a t ic  and c a r e f u l l y  p lanned l e s s o n s  
>. E f f e c t i v e  use o f  p lan s
6. U n d e rs ta n d irg  o f  p u p i l ' s  n eeds , i n t e r e s t s  and b e h a v io r
7 . S k i l l  in  s t im u la t in g  p u . i l  growth
8. S k i l l  i n  p r o v id in g  f o r  i n d i v i d u a l  d i f f e r e n c e s
9 . Use o f  v a r i e t y  o f  m a t e r i a l s  and r e s o u r c e s  

10. W ise use o f  th e  t e a c h in g  t im e

1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5

. 9L



>

1.1
' ■  •

3.
4.

Classroom  5. 
Management 6 .

7 .

*.
9.

10.

D i r e c t s  p u p i l s  t o  s e t  h igh  s ta n a a re ?  o
R e s p e c t s  th e  i n i ; v i s u a l
R e s p e c te d  uy p u p i ls
Care and h a n d l in g  o f  m a t e r i a l
R e f l e c t s  w ho lescr .e  c la s s ro o m  a t i t u d e
Care  o f  room and en v iron m en t
Uses T e a c ' r .e r - ru p i l  p la n n in g
R ro v id e s  f o r  p h y s i c a l  c o m fo r t
^ • t i l l  i n  movement from  one a c t i v i t y  to
a b i l i t y  t o  d i s c i p l i n e  when needed

f  s e l f  d

a n o th e r

i s c i p l i n e 1 2 3 1 5  
1 2  3 4 5 
1 2 3 2* 5 
12 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
12 3 4 5

1.
2 .
3.
4.

P r o f e s s i o n a l  5. 
Growth 6 .

7.
a.
9.
10.

Understands h i s  r o l e  in  t , .e  t o t a l  p ro  cram 
F a i r  ana im p a r t i a l  
Prompt i n  the a i s c h a r g e  o f  d u t i e s  
e v id e n c e s  d e s i r e  to  grow p r o f e s s i o n a l l y  
C o n s id e r a t e  o f  o th e r s
A ccep ts  c o n s t r u c t i v e  c r i t i c i s m  g r a c i o u s l y
P u b l i c  r e l a t i o n s
C o o p e ra t io n
P r o f e s s i o n a l  e t h i c s
L o y a l t y

1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5 
1 2 3 4 5

P le a s e  sum up i n  a few  s e n te n c e s  
s t r e n g th s  and w eaknesses  t h a t  g i v e  an 
t e a c h in g  p r o f e s s i o n .

y ou r  b e l i e f s  as to  the  s tu a e n t  t e a c h e r ' s  
i n d i c a t i o n  o f  f u t u r e  s u cce ss  as a member o f  the

*
»

C o o p e ra t in g  T e a c h e r

I



AGRICULTURAL, MECHANIC vL AND NORfiAL COLLEGE 
Fine; b l u f f ,  A rkansas

D i v i s i o n  o f  T ea ch er  E d u ca t io n

STUDENT TE.'CHER SELF-APFRAISAL FORK

S tu d e n t 's  Name ______

Course No. _

-o p e ra t in g  T ea ch er

______________________ ____  S em es te r

C r e d i t  H o u r s ___________ Grade o f  S u b je c t

_______ ________  S u p e r v i s o r ________ _ _ _ _

X. R e l a t i o n s  w i t h  C h i ld r e n E v a lu a t i o n s  Comments

Low Medium H igh

A .  F r i e n d l i n e s s  _______________________________

C. C o n s t r u c t i v e  approach  t o
J

D. S y m p a th e t ic  u n d e rs ta n d in g

I n s t r u c t i o n a l  Q u a l i t i e s

B. r i a n s  l o r  ln d i v iG u a i  u i u c i c h c w d  i

B r o v i c e s  l o r  l n a i v i a u a i  u iu c i c u t ' - o j  

D. Uses v o c a b u la r y  on c h i l d r e n ' s

E .  P o s s e s s e s  s u f f i c i e n t  academ ic

F .  Adapts s u b j e c t  m a t t e r  t o

G. Uses v a r i e t y  o f  t e a c h in g

H. Uses v a r i e t y  o f  t e a c h in g !

-1-----------

I ,  C r e a k s  d e s i r e  t o  l e a r n  _ ... i___ 1
-  —  — —



II. Continued:

III.

E v a lu a t i o n  Comments

Lew Medium H igh

G u ides  s tu d e n ts  i n t o  e f f e c t i v e
s tu d y  h a b i t s  ----

K P r o v id e s  f o r  c r e a t i v e  w ork

L .  S ecu res  b a la n c e  be tw een  p u p i l

M. M a in ta in s  s a t i s f a c t o r y  
nVivQi p p I pn\ri rnrjnents

N. C o l l e c t s  in f o r m a t io n  about

0 .  Uses in f o r m a t i o n  c o l l e c t e d

P e r s o n a l  Q u a l i t i e s

B .  I n t e r e s t i n g  and p le a s a n t

D„ B e h a v io r  w o r th y  o f  s tu d en t
p.miil - t. i on

M. Sonoo -.t >.un<.r _____ - ..



III. Continued:
E v a lu a t i o n  Comment^

Low Medium High

N. Ccrrr.u*:L«:ntlor r k i ’ r .

0 „  M utual r e s p e c t  and t o l e r a n c e

P r o f e s s i o n a l  R e la t i o n s h ip s  

A .  W i l l i n g n e s s  t o  c o - o p e r a t e

B . A t t i t u d e  tow ard  c r i t i c i s m

C. P r o f e s s i o n a l  e t h i c s

D. A c t i v i t y  tow a rd  s e l f - im p r o v e m e n t

E .  U nderstands e d u c a t i o n a l  
o b j e c t i v e s

Community R e l a t i o n s h ip s  

A .  U t i l i z e s  community r e s o u r c e s

B . U nders tands  community r e s o u r c e s

C . C o - o p e ra t e s  w i t h  p a re n ts

D. P a r t i c i p a t e s  i n  community 
a c t i v i t i e s

E .  C o - o p e ra t e s  i n  s c h o o l -w id e  
a c t i v i t i e s

V i c t o r  P a g e n k o p f ,  Chairman 
R o b e r t  L e w i s , r e c o r d e r
June Dawson 
F lo r e n c e  Dunn 
Mary Jo H e w i t t  
Ben B . L ew is

N o r th  C e n t r a l  A s s o c i a t i o n  W orkshop, U n i v e r s i t y  o f
M in n e s o ta ,  Simmer 1954



Name o f  S tu d e n t  T ea ch er  ________________________________________________  L a t e

S c h o o l _______________________ _ P r i n c i p a l  _____________

M a jo r S u b je c t  ar.a/or Grade

i'o t h e  C o o p e ra t in g  T e a c h e r :  P l e a s e  c r e e k  each  q u e s t i o n  a t  some p o in t  on th e  s ca u e ,
a c c o r d in g  t o  th e  stuueno t e a c h e r ' s  b e h a v io r  as p r o s p e c t i v e  t e a c h e r .  A s tu d en t  
t e a c h e r ' s  a b i l i t y  o r  d i s a b i l i t y  in  one fo rm  o f  b e h a v io r  shou ld  n o t  c o l o r  o n e 's  
judgment o f  him i n  a n o th e r .

How Does H is P e r s o n a l  
.A ppearance  Im press  
You?

I -L I
Makes poor  
im p re s s io n

Manes a v e r a g e  
im p re s s io n

A lw ays  w e l l  groom ed, 
shows e x c e l l e n t  t a s t e

How Does H is  P e r -  
s o n a i i t y  A f f e c t  O the r  
P e o p le ?  ■■

I
A n ta g o n iz  e  and 
i r r i t a t e s  c t h - r s

G ets  a lo n g E s p e c i a l l y  harmonious
r e a s o n a b ly  w e l l  r e l a t i o n s  w i th  o th e r s

How Do P u p i l s  R e a c t  
Toward Him?

I
P u p i l s  d i s l i k e  him P u p i l  re sp on se  
& show l i t t l e  i n -  shows r e a s o n -  
t e r e s t  i n  v o rk  a b l e  i n t e r e s t

P u p i l3  a re  e a g e r ,  
a l e r t ,  i n t e r e s t e d

I s  He E m o t io n a l l y  W e l l  
P o is e d ?

I
Too E a s i l y  moved 
t o  a n ge r  o r  
d e p r e s s io n

U n re s p o n s iv e , 
a p a t h e t i c

U s u a l l y  w e l l
c o n t r o l l e d ,
r e s p o n s i v e

A ppears  a t  ea se  i n  
d i f f i c u l t  s i t u a t i o n s

Does He E x p re ss  H im s e l f  
C l e a r l y ?

What i s  H is  A t t i t u d e  
Toward P u p i l s  i n  
S c h o o l  A c t i v i t i e s ?

What i s  The A tmosphere 
o f  H is  C lassroom ?

Makes f r e q u e n t  
e r r o r s  in  sp eech ;  
e x p r e s s io n  poor

1 i

Makes h im s e l f  
u n d ers to od  
q u i t e  w e l l  
E n g l i s h  u s u a l l y  
good

1

E x c e l l e n t  E n g l i s h ,  
c on veys  id e a s  c l e a r l y  
and e f f e c t i v e l y

i_______________ i_______________
D om inates ,  d e c id e s Encourages Encourages  P u p i l
a l l  a c t i v i t i e s P u p i l  p a r t i c i - i n i a t i v e ,  c a r e f u l

p o t i o n  t o  some gu id an ce  e v id e n t

1 !

e x t e n t

1__________ t ________ !_______________
Atmosphere d e p r e s s -  Atmosphere com- A tmosphere l i v e l y ,  
i n g ,  d u l l ,  p r o s in c  f o r t a b l e ,  good humor p r e s e n t

p u p i l s  f e e l  a t

1*



uxi/uaoxuiD i

A re  The L esson s

c o n t r o l

i 1

Auxi jlj
w e l l

1 A

 ̂ O V V41W w»
prob lem s

___

W e l l  P lan ned  And - ' C on fu sed  abou t L esson s  f a i r l y C a r e fu l  p la n n in g

E xecu ted ? w here t o  b e g in  a: 
what t o  do

:d w e l l  p lan n ed  
and e x e c u te d

r e s u l t s  in  p u rp o s e fu l 
p u p i l  a c t i v i t y

What Use Does He 1 1 ! i - /__________________ -
Make O f M a t e r ia ls Use t e x tb o o k Supplem ents Uses w id e  v a r i e t y  o f

O f In s t r u c t io n s ? o n ly t e x tb o o k  t o  
some e x te n t

s o u rc e  m a t e r ia ls

Does He Show In — 1 1 i f ____________ 1________________ —
i t i a t i v e  and Am- R e q u ire s  p r o a - W orks c h e e r - F in d s  th in g s  t o  d o

b i t i o n ? d in g ;  s h irk s  
r e s p o n s ib i l i t y

f u l l y  bu t r e ­
q u ir e s  o c c a ­
s io n a l  h e lp

w ith o u t  s u p e r v is io n

How Does He R ea c t 1 1 _ J_______L - J ___________________
To S u g g e s t io n s ? I s  o f fe n d e d  by  

s u g g e s t io n s
A c c e p ts  sug­
g e s t io n s  and 
p e r fo rm s  a s ­
s ig n e d  d u t ie s

C o n s ta n t ly  seeks  h e lp  
and c o o p e ra te s  c h e e r ­
f u l l y

How Does He 1 / 1 1 ■ J ____________________
P r o v id e  F o r N e g le c t s  e q u ip - K eeps n e c e s s a ry E x c e l le n t  c a re

Equipir i t ? m ent; room 
d i s o r d e r l y

equ ipm ent in  
o rd e r

o f  equ ipm ent

W i l l  He Be L ik e l y  
To Grow in  E f f e c -

1 1 1 1 1____________________
Seldom  seeks M o d i f ie s  p r a c - C o n s ta n t ly  s eek in g

t i v e n e s s ? . ___ new m ethods or 
m a t e r ia ls

t i c e s  t o  some 
e x te n t

b e t t e r  m a t e r ia l  and 
m ethods

SUPPLEMENTARY OR SUMMARY STATEMENT:

SIGNATURE

t



AGRICULTURAL, MECHa Ni LmL  ND NORMAL COLLEGE 
D iv is io n  f T e a c h e r  Education

P in e  B l u f f ,  A rk an sas

PROGRESS RECORD Or

SCHOOL

ADDRESS

I .  How huz th e  s tu d e n t  t e a c h e r  p r o g r e s s e d  in  th e  a r e a s  b e lo w ?  Check 
th e  s ta te m e n ts  th a t  r e f e r  t o  h is  p r o g r e s s .
A .  U s in g  th e  f a c t s  a b ou t each  p u p i l  in  te a c h in g

1 . Uses S e v e r a l  te c h n iq u e s  f o r  g a th e r in g  in fo r m a t io n  on pupils,
______a ,  W r i t e s  a n e c d o ta l r e c o r d s .
_____ b . S tu d ie s  a v a i l a b l e  r e c o r d s .
_____ c .  W orks on ca se  s tu d y .
______d .  V i s i t s  p u p i l ’ s hom es.
______e .  O b se rves  s tu d e n ts  in  s e v e r a l  s i t u a t i o n s .
______ f .  H o lds  c o n fe r e n c e s  w ith  p u p i l s .  ,
_____ g .  O b se ryes  s tu d e n ts  in  s e v e r a l  s i t u a t i o n s .
______h . A d m in is te r s  t e s t s  t o  f in d  and d ia g n o s is  needs.',.
______i .  R e c e iv e s  my h e lp  in  th e s e  a r e a s .
______j .  Needs m ore h e lp  in  th e s e  a r e a s .
_____ k . S eeks h e lp  in  th e s e  a r e a s .

1 .  COMMENTS (may use back  s i c e )
2 .  Uses g a th e r e d  in fo r m a t io n  i n  p la n n in g  and c o n d u c t in g  le a r n in g  

e x p e r ie n c e s .

a •
b .

c .

d .
0 _
f .

O b je c t iv e s  g i v e  a t t e n t io n  t o  g rou p  n eeds and in d i v id u a l  p u p i l  n e ed s . 
A c t i v i t i e s  a r e  s u i t a b le  to  m eet th e  m e n ta l,  p h y s ic a l ,  s o c i a l  and 
e m o t io n a l needs o f  th e  p u p i l s .
Has s p e c i a l  a s s ig n m e n ts , p r o j e c t s ,  a c t i v i t i e s ,  e t c . 5 f o r  m e e t in g  
s p e c ia l  s tu d en t n e e d s .
Show s.a  gen u in e  e m o t io n a l f e e l i n g  f o r  an  in t e r e s t  in  a l l  s tu d e n ts .  
Seeks Y ie lp  in  t h i s  a r e a .
R e c e iv e s  my h e lp  in  th e s e  a r e a s .  *•
Needs h e lp  in  th e s ^  a r e a s .

B . C on d u ctin g  l e a r n in g  e x p e r ie n c e s  
1 . liana gang th e  c la s s ro o m ,

______a .  M eets the c la s s  on t im e .
_____ b . K eeps th e  a tm osp h ere  in  th e  c la s s ro o m  i n v i t i n g .
_____ c .  K eeps th e  c la s s ro o m  and equ ipm ent c le a n  and o r d e r l y .
______d . I s  a o s e n t  o n ly  when i t  i s  a o s o lu t e l y  n e c e s s a r y .
_____e .  P r o v id e s  fu r  in d i v id u a l  g rou p  n eed s in  a r r a n g in g  and r e a r r a n g in g  seat*?
_____ f .  D ir e c t s  m ovem ents o f  p u p i ls  w ith  l i t t l e  o r  no in t e r r u p t io n  o f  th e

program .
_____ g .  I s  s y s t e m a t ic  in  p r o c e d u re s : a s s ig n in g  t a s k s ,  c h e c k in g  r e s u l t s ,

b e g in n in g  and en d in g  on t im ? ,  k e e p in g  e v e r y b o d y  e f f e c t i v e l y  en ga ge d .



______(7) I l l u s t r a t i o n s : (c h a r t s ,  g ra p h s , n ap s , p ic tu r e s
_______(8 )  R ep o r ts  on t e s t  papers
_______( 9 )  C o c io l i z e d  r e c i t a t i o n
______ r ( l 0 )  Lr.,ii,’s r ' la t .-d  work
_____ O l )  d is c u s s io n s :  p a n e l,  r o u n ta b le ,  d e b a te ,  symposium, fo ru m .
_____ (1 2 ) Q u es tson -a n sw er
_____ (1 3 )  W r i t t e n  r e p o r t s  (P u p i l s ,  t e a c h e r )
_____ ( 1 l )  Games r e la t e d  to  work
_____ (1 5 )  Com m ittee w ork and r e p o r t s
_____ (1 6 )  La jo ro . t o r y
_____ ( 1 7 )  d i r e c t e d  s tu d y
_____ (1 8 )  C o r r e la t io n  o f  o th e r  a r e a s :  a r t ,  p h y s ic a l  e d u c a t io n ,  e t c .
_____ (1 9 )  S ta n d a rd iz e d  t e s t i n g
_____ (2 0 )  O th ers

_____ 1 . Makes a ss ign m en ts  c l e a r .
_____ a .  shows m a s te ry  o f  s u o je c t
_____ n . T ea ch in g  m eets  p u p ils  n eed s : h e a lth ,  k n ow led ges , s k i l l s ,  a p p r e c ia t io n

and a t t i t u d e s .
_____ o . Uses t e x to o o k  e f f e c t i v e l y .
______p . E n cou rages  and p r o v id e s  f o r  p roo lera  s o lv in g .
_____ q .  I n s t r u c t io n  i s  s u it e d  t o  p u p i l 's  l e v e l .
_____ r .  I s  v e r y  c o r d ia l  t o  p u p i l s :  does n o t  use sa rcasm .
______s .  I s  n e t  s e l f - c e n t e r e d  m  h is  t e a c h in g .
_____ t .  Uses a v a i l a b l e  community r e s o u r c e s .
_____ u. Knows and uses d e s i r a b le  and e f f e c t i v e  means o f  im p ro v in g  le a r n in g

in  h is  a rea  o f  t e a c h in g .
_____ v .  i u p i ls  a re  le a r n in g  in  a d e s i r a b le  m anner.
_____ w„ Uses many d i f f e r e n t  fo rm s c f  e v a lu a t io n .

___________ ( 1 )  P u p i l  e v a lu a t io n  o f  p r o g r e s s
___________ (2 )  T ea ch er e v a lu a t io n  o f  p r o g r e s s

_____ x .  B r in g s  each  le a r n in g  ex r^ er ien ce  to  a d e s i r a b le  c l o s e ,  t e a c h e r  and
p u p i l  r e a l i z i n g  when i t  has been  a c c o m p lis h e d ,

_____ y .  L e a rn in g  e x p e r ie n c e  moves fo rw a rd  to  d e s i r a b le  g o a l .
_______ z .  C a p i t a l i z e s  on f e l t  need  f o r  new le a r n in g  e x p e r ie n c e s  when th e y  a r i s e .

3 . COMMENTS: (may use back a id e )

\
-3-

1 . G row ing P r o f e s s i o n a l l y
1 . T r i e s  t o  keep  in fo rm e d  on new id e a s  in  h is  t e a c h in g  f i e l d .
2 .  Takes p a r t  in  e d u c a t io n a l m e e t in g s  and c o n fe r e n c e s .
3 .  E x p e r iem en ts  w ith  d i f f e r e n t  met ods t o  im p rove  in s t r u c t i o n .
4 .  Reads e d u c a t io n a l  p e r i o d i c a l s  r e g u l a r l y , ( L i s t )

a .
b .
c .

5 . Reads p r o f e s s io n a l  oooks r e g u l a r l y . ( L i s t )
a .
b.

6.

7 .
8,
9 .

10,

c .
Takes p a r t  in  th e  P a r e n t -T e a c h e r  A s s o c ia t io n  and o th e r  activities related
t o  com m u n ity -sch oo l p rogram .
R ead s , w r i t e s ,  s p e l l s  c o r r e c t l y  and e f f e c t i v e l y .
S tu d ie s  comm unity and u ses  know ledge to  im p rove  instruction.
U nd erstan ds t e a c h e r s ' d u t i e s ,  r e l a t i o n  to total program and the administra­
t i o n  and o r g a n iz a t io n  o f  th e  s c h o o l .
U nd erstan ds t e a c h in g  p ro ce d u res  he o b s e r v e s .

4 . COMMENTS: (may use oack s i d e )



D » Im p ro v in g  p e r s o n a l i t y  and p e rs o n a l r e la t io n s
_______1 . I s  a t t r a c t i v e l y  d r e s s e d .

2 . I s  f r i e n d l y  and c o r d ia l  in  r e la t i o n e  w ith  o th e r s .
_______3 . Has genu ine f e e l i n g  f o r  h e lp in g  s tu d en ts  l e a n t  and g row .

4 , Does no g o s s ip  auout s tu d en ts  and f e l l o w  t e a c h e r s .
_ 5 .  Has a sen se  o f  humor.

__6 . Ha3 b e h a v io r  w o r th y  o f  p u p i l s '  e m u la t io n .
___ 7 , Has no d i s t r a c t i n g  h a b its  in  c la s s ro o m : w ord c r u tc h e s ,

t w i t c h in g ,  o v e r  use o f  hands, p a c in g  the f l o o r ,  e t c .
______ 8 .  I s  ca lm , w e l l  p o is e d .

____ 9 . R e s p e c ts  th e  o p in io n s  o f  p u p i ls  and c o -w o rk e r s .
^ ____10 . Has a p le a s in g  v o i c e ,  f r e e  from  i r r i t a t i o n ,  fu s s in g ,  r a s p in g .
_____ 11 . S tu d en ts  r e s p e c t  him .

12. I s  op en -m in ded j w elcom es c o n s t r u c t iv e  c r i t i c i s m .
_____ 13. G e ts  a lo n g  w e l l  w ith  p u p i ls ,  c o -w o rk e r s ,  a d m in is t r a t o r s ,  p a r e n ts .

_____ 14. Seems s e c u r e .
______15 . D e s ir e s  t o  do a good  jo h  o f  t e a c h in g .
_____ 16. H and les d i s c i p l i n e  p rob lem s w e l l .
_____ 17. R e c e iv e s  my h e lp  in  th e s e  a r e a s .
____ 18. Needs h e lp  in  th e s e  a r e a s .

5 . COMMENTS: (may use back s id e )

SUMMARY PROGRESS CHa RT. Check p r o g r e s s  f o r  each  a re a  r a t in g  from  one to f i v e  in  
any p r o g r e s s  a re a  th a t  th e  r a t in g  f a l l s .  Rank p ro g r e s s e s  from  "1", the lo w e s t ,  

t o  " 5 %  th e  h ig h e s t  in  each  a r e a .

A R E A S P R O G R E S S R A U N G

P o o r F ' i r Good V e r y  Good

1 2 3 4 5 □ Z T T T f ' t t t ’ l L - J  2 3 A J _____

1 . U s in g  f a c t s  a oo u t each  
p u p il  in  te a c h in g

2 .  C on d u ctin g  le a r n in g
e x o e r ie n c e s - A . P la n n in g

B . In s t r u c t io n

C . C lassroom  Management

3 * Grcw->ng F r o f c s s i  .n a l l y

4 . Im p ro v in g  p e r s o n a l i t y  and 
p e r s o n a l r e la t i o n s

6 . COMMENTS: (may use oack s id e )

I I .  How may th e  s tu d en t t e a c h e r  im p rove h is  r a t e  o f  p r o g r e s s ?  L i s t  s p e c i f i c  
recom m endations f o r  the rem a in d er o f  h is  t e a c h in g  p e r io d ,
A .

B.

Signed_:



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Giydi Arclwr 
, Saultaur
Carlo* We*®-!.*
L im it  c>ai> g 
4c u l» X. i t  fa
' * * * »  * .  £r«vi*»ui%', Chairman

T».« f- j  .• j»«i funot: -r>* at th»- Cuannitta* w i l l  *e •

.■*•5 ’-n4 j- loti C3ac*r t . l «4 v i «w t  ®f pareatui aoJ
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*  • e » 4 ) ia i « t »  about tkw pi!T^r*a ate aait« rtcaM im tatioa*
£ » t  it* Laorov *»«mt .

7. J?*rt iei|o*t« t» pprai**l« ur tit* pregroa.

i x M c m r * L y  ,

O

Jabca K. £r*d*hav, Super im a.w t$t 
l»lim k i j ^ T i c ^ r  School*

<



TITLE I  POSITIONS

1968-69

Name
Lucreaeia Evans 
James H. Klutts 
Robbie Keith
J. 0. Porter 
Elisabeth A. Ramsey 
Alma vihite

• Gdespa Davis
Geraldine Bradshaw 
Gharlene Archer

Race

N
W
w
w
w
w
N
w
w

Position
Remedial Reading Instructor
Instructor
Health Coordinator
Instructor
R a c i a l  Reading InstructorTeacher Aide
Te* cher Aide
Socia l Worker
Secretary

1969-70

Name

Artie Davis 
Lucreasia Evans 
Maxine Clark 
Robbie Keith 
Danny Young 
Charlene Archer

Race Poe it ion
N
N
N
W
w
w

Instructor
Remedial Reading Instructor
Instructor
Health Coordinator
Instructor
Secretary

1970-71

Name
Artie Davis 
Luc re as ia Evans 
Robbie Keith 
Charlene Archer

Race
N
N
W
W

Poe It i on
Instructor

Reeling Instrv co: 
Health Comrdinator 
Secretary



TEAC8BR IALM T SQffiOOIX 

1H9-70
Training Rationing Salary

' . . .. . . - - - -
Annual lncr«-« up 
to 10 year* a err let

Eatra Duty Ma - i au*
i
Bachelor* a degree 
but not folly certified 14500.00 ISO 00 $900 00 $5900.00

Ba hf1 or'• degree
ful . y r  «■ rt If tad 5000.00 50.00 *00.00 6400. '0

M #t-r’a iegrrf 5500 00 50 00 *0C . 00 6^ > . <'-0

W p ’^na of Advanced
' • t ud / 6000.00 50 00 7U >0.0*

>i.~' - ' nt indent and 'fine ipai - Salary t o  h*> ivt‘-mined ‘■'y Boar ' of l:ir»r t i>ra

Annua ,'*xih«ri eal*ri%a payable if funda art available.\nnud



W A Q g lt 9ALAXT tc w u m jt

m ® . w

Beginning S*Lary Annua] l » c r # u «  It K x t r *  Out/ Max'^****
___________________________ fund* a r m  a v i  labia _____

P a e h x l e r ’ a l « g r « «
’>ut not fully certified 5*100.00 ISO.00 t<H>0 00 5 56 >5. OC

r«rh#lr»r'a iv*Jr« 
lth'iut i^fir .*nc i;’a <♦500.00 so.oc *00 00 >  { >  ."V ) /O

taat • r ’ • * 5000 00 50 00 >00 00 6*0 Oo

Mploaa of
5 t  u * y 5500.00 50.00 3 *0 . 00 £. « v >0

iup#r lnt<n... t.;. ,d*? farin' l, * * - 1 ~jry to »* 4« tarsia* 1 Uy BoarJ of jir<*ct ~Jt a



TE A C H E R  S A L A R Y SCHEDULE

1 9 6 7 - 6 8

T  i 3 i  m  nj? B e g i n n i n g  S a l a r y A n n u a l I n r r r a f p E x t r a  du* v V 3 v rm i it

v  ) Seir< s * e r  H r s .

P a r  h e 1 o r  ’ s D e f f r r p  - - ... $ U ? 0 0  OO $ 5 0 . 0 0 $ 9 0 0 .0 0 $ 5 6 0 * ,;0

v 1 i c f r f  c ■ li'j-rr- t> 9 6 0 0  o o 5 0 .  o n 9 , . 0 0 o y (' >

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a l a r y  t o  b e  It-t. <'zhi i n e d  b y  Boa r d  • it D i r e c t o r s .



TEACHER SALARY SCHEDULE 
1966-67

r a i n i n g Beginning Salary Annual Increase up 
t o  1 0  years service

Extra Duty M a x i m u m

a c h e l o r ' s  d e c r e e $ 9 , 0 0 0 $ 5 0 $ 9 0 0 $ 9 9 5 0

a s t e r ' s  degree 9 , 3 5 0 5 C 9 0 0 5 3 0 0

iploma o f  Advanced 
tuly 9 , 7 0 0 5 0 9 0 0 5 6 5 0

j p e r i n t e n d e n t  a n d P r i n c i p a l  -  S a l a r y  t o  be d e t e r m i n e d  b y  F o a r d  of d i r e c t o r s

mual Teachers sa lar ies  payable i f  funds are ava i lab le .



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3

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10 1 t4j

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1 3*50.00
3700.00

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W5C.00

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3900.00
W O.M
mOOQ.90

001.01



n  i L  h  D

JUN7 1971
_______ W. H. Mo . lc.llaN, LLtfiK
IN  THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF ARKANSAS®*----------
PINE BLUFF DIVISION

Utp. Clu.it

LOIS THOMAS; ASIVE THOMAS;
LUCREASIA A. EVANS; ELOIS WOODS 
and TROY E. WOODS, by t h e i r  parent 
and next f r i e n d ,  MRS. CORINE WOODS; 
ERIC DINWIDDIE, DONALD R. DINWIDDIE, 
RODNEY DINWIDDIE, and DARRYLE HARRIS, 
by t h e i r  guardian and next f r i e n d ,  
MRS. CORINE WOODS,

P l a i n t i f f s ,

NO. PB 69-C-46

THE BOARD OF EDUCATION OF THE 
PLUM BAYOU-TUCKER SCHOOL DISTRICT 
NO. 1, W righ t , Arkansas; FRANK CONLEY, 
P r e s id e n t ;  and JAMES K. BRADSHAW, 
Superin tendent o f  Schools  o f  the plum 
Bayou-Tucker School D i s t r i c t  No. 1,

D e fendan ts .

MEMORANDUM OPINION

The p l a i n t i f f s  b r in g  th is  a c t io n  a ga in s t  the defendants 

seek ing r e l i e f  pursuant t o  the p ro v is io n s  o f  28 U .S .C .A . §1342(3) 

( 4 ) ,  42 U .S .C .A . §§1981 and 1983; and the r i g h t s ,  p r i v i l e g e s  and 

immunities guaranteed by the due p rocess  and equal p r o t e c t io n  

c lau ses  o f  the Fourteen th  Amendment t o  the C o n s t i tu t io n  o f  the 

United  S ta te s .

The p l a i n t i f f s  a ls o  seek d e c la r a to r y  judgment under the

p r o v is io n  o f  28 U .S .C .A . §2201 to  determine the l e g a l  r i g h t s  

and r e la t i o n s  o f  and between the r e s p e c t i v e  p a r t i e s .  Mandatory 

in ju n c t iv e  r e l i e f  a ga in s t  the defendants i s  sought f o r  r e in s t a t e -  ■ 

ment o f  c e r t a in  p l a i n t i f f s  as teach ers  in the p u b l ic  schoo l system j

o f  plum Bayou-Tucker School D i s t r i c t  No. 1, and o th er  r e l i e f  f o r  1
i

a l l e g e d  w rong fu l a c t io n  by the de fendan ts .  Further mandatory

T



!
to  cease a l l e g e d  d is c r im in a t io n  a ga in s t  b la ck  patrons o f  the |
d i s t r i c t .

j

Th is  cause was f i l e d  Ju ly  22, 1969, and ass igned  to  D i s t r i c t  

Judge Gordon E. Young, now deceased. Subsequently, i t  was ass igned  

t o  th is  Court f o r  a p p rop r ia te  a c t io n .  The m atter was duly 

scheduled f o r  p r e - t r i a l  October 23, 1969, and scheduled f o r  t r i a l  ! 

December 11, 1969. Due t o  the scheduled t ime f o r  the t r i a l ,  i t I
was continued by agreement o f  the p a r t i e s  and by re qu es t ,  subse-

I
q u en t ly  continued f o r  a l a t e r  s ch edu lin g . The case was heard by

j
the Court as t im e ly  scheduled on Monday, February 8, 1971, and 

Tuesday, February 9, 1971.

The com pla in t o f  the p l a i n t i f f s  a l l e g e d  numerous and sundry

a l l e g a t i o n s  a ga in s t  the defendants in  connect ion  w ith  the  operation !
1

o f  the sch oo ls ,  employment o f  tea ch ers  and o th e r  p ersonn e l,  

c la im in g  d is c r im in a t io n  a ga in s t  the b lacks  and p r e f e r e n t i a l  

trea tm ent accorded the w h ite s .  A t  the commencement o f  the hear ing  1 

a t to rn e y  f o r  the p l a i n t i f f s  w ithdrew  a number o f  the a l l e g a t i o n s  j

in  the com pla in t and during the course  o f  the hea r ing  produced 

no test im ony in v o lv in g  c e r t a in  o th e r  o f  the  a l l e g a t i o n s .  Fo llow ing! 

the h ea r in g ,  which inc luded  o re  tenus test im ony o f  numerous 

w i tn e s s e s ,  response to  in t e r r o g a t o r i e s  and e x h ib i t s ,  the  case was 

submitted w ith  t im e p rov id ed  f o r  the a t to rn ey s  t o  f i l e  r e s p e c t i v e  

b r i e f s .

For a b e t t e r  understanding o f  the  problems p resen ted  in  th is I
case , a b r i e f  d e s c r ip t io n  o f  the  h i s t o r y  and o p e ra t io n  o f  the 

d i s t r i c t ' s  schoo ls  would be h e lp fu l .  Plum Bayou-Tucker School 

D i s t r i c t  No. 1 i s  a sm all r u r a l  schoo l d i s t r i c t  o f  some f i f t y - t h r e e  

square m i le s .  The sch oo l d i s t r i c t  p r e v io u s ly  opera ted  a dual.

i n j u n c t i v e  r e l i e f  i s  s o u g h t  b y  t h e  p l a i n t i f f  r e q u i r i n g  d e f e n d a n t s



seg rega ted  schoo l system. plum Bayou School lo ca te d  at W righ t , 

Arkansas, was f o r  w h ites  and p rov id ed  f o r  grades one through 

tw e lv e .  Tucker-Rosenwald School lo ca te d  a t  Tucker, Arkansas, 

opera ted  f o r  b la ck  c h i ld r e n  w ith  grades one through tw e lv e .  The 

two communities are  some e ig h t  m ile s  apart  and th e .tw o  schoo ls  

t r a d i t i o n a l l y  were opera ted  on a seg rega ted  b a s is  as t o  both 

p u p i ls  and f a c u l t y .

In  the schoo l y ea r  1965-66 the h igh  schools  o f  the d i s t r i c t  

opera ted  under " freedom  o f  c h o ic e " .  Commencing w ith  the  schoo l 

year  1966-67 the schoo l d i s t r i c t  v o lu n t a r i l y  u n i t i z e d  the high 

schoo l w ith  Plum Bayou as the c e n te r  h igh  schoo l s i t e ,  thus 

com p le te ly  in t e g r a t in g  i t s  h igh  sch oo l as to  p u p i ls  and f a c u l t y .  

The Tucker-Rosenwald High School ( fo rm e r ly  b la ck )  was c lo s e d .

I t  appears th e re  was no problem o f  any magnitude in  the  op e ra t io n  

o f  the in te g ra t e d  h igh  schoo l as t o  e i t h e r  s tudents o r  f a c u l t y .

The plum Bayou and Tucker-Rosenwald e lem entary  schoo ls  

continued to  op e ra te  on a s eg rega ted  b a s is  as to  s tudents and 

fa c u l t y  u n t i l  the  commencement o f  th e  sch oo l year  1969-70. For 

t h i s  schoo l year  the schoo l board by unanimous a c t io n  v o lu n t a r i l y  

u n i t i z e d  the  two e lem entary  schoo ls  based p r im a r i l y  on economic 

and ed u ca t ion a l  requ irem ents .  As a r e s u l t  o f  t h is  a c t io n  the 

Tucker-Rosenwald e lem entary  schoo l was c lo s e d  and s in ce  the 

Plum Bayou e lem entary  schoo l f a c i l i t i e s  were s u f f i c i e n t  and more 

modern to  meet the  needs, plum Bayou became the c e n t r a l  schoo l 

s i t e  o f  the sch oo l d i s t r i c t ' s  u n i t i z e d  and in te g ra t e d  system. 

Consequently , th e re  no longer  e x i s t s  dual opera ted  schoo ls  by 

the  d i s t r i c t  and i t  is  undisputed th a t  the schoo l system is  

t o t a l l y  and com p le te ly  in te g ra te d  both  as t o  p u p i ls  and f a c u l t y .

-3-



From the hearing  to  the Court, and as s ta ted  in  the p l a i n t i f f s ^I
b r i e f ,  the o n ly  qu es t ion s  remaining f o r  de te rm in a t ion  by the 

Court a r e :  (1) the  f a i l u r e  t o  r e h i r e  b la ck  tea ch ers ,  (2) the

f a i l u r e  t o  pay b la ck  teach ers  a t  the  same r a t e  as the w h ite  

t e a ch e rs ,  and (3) the f a i l u r e  t o  o f f e r  equal employment and 

earn ing o p p o r tu n i t ie s  t o  b la ck  te a c h e rs .  A l l  o th er  q u es t ion s  

have been withdrawn or  d isposed  o f  o th e rw is e .
j

1. FAILURE TO REHIRE BLACK TEACHERS.
|

A t the o u ts e t  o f  the  hear ing  the a t to rn ey s  f o r  the p a r t i e s  

o u t l in e d  to  the co u r t  the qu es t ion s  t o  be p resen ted  by the
i

tes t im on y .  On th i s  con ten t ion  o f  the p l a i n t i f f s  the  tes t im ony 

r e f e r r e d  on ly  t o  th re e  b la ck  tea ch ers  o f  the defendant sch oo l ,  

Lu creas ia  A. Evans, A s iv e  Thomas and L o is  Thomas. However, the 

p l a i n t i f f s ’ b r i e f  has r e fe r e n c e  t o  t h i s  con ten t ion  o f  f a i l u r e  

t o  r e h i r e  b la ck  tea ch ers  f o r  whom monetary r e l i e f  (back-pay ) i s
i

sought concerns o n ly  A s iv e  Thomas and L o is  Thomas. From the 

re c o rd ,  i t  appears the  r e l i e f  sought by p l a i n t i f f ,  L u cre s ia  A. 

Evans, i s  a d i f f e r e n t  assignment as a member o f  the f a c u l t y .

From hearing  tes t im ony she in s i s t s  th a t  she should be employed 

in  the schoo l system as a h ea lth  c o - o r d in a to r .  The Court w i l l

c on s id e r  the con ten t ion  o f  each o f  these  th re e  p a r t i e s  as d is c lo s e d
!

by the  re co rd .

A. MRS. LUCREASIA A. EVANS.

Mrs. Lu creas ia  A. Evans has beer, employed by the schoo l 

d i s t r i c t  as a t ea ch er  f o r  tw en ty - th re e  y e a r s .  Mrs. Evans became | 

a T i t l e  I  rem ed ia l read ing  tea ch er  f o r  the schoo l d i s t r i c t
I

ass igned  to  the Tucker-Rosenwald Elementary School in 1965-66.

i
She was c e r t i f i e d  BSE as e lem entary  in s t ru c t o r  fo r  s i x  y e a rs .

She continued as a tea ch er  under the  T i t l e  I  rem ed ia l read ing



I
I

program when the  d i s t r i c t  v o lu n t a r i l y  adopted i t s  u n i f i c a t i o n  o f  

the  e lem entary  schoo l in 1969-70. She had been recommended by 

her p r in c ip a l  a t  the fo rm er ly  a l l - b l a c k  Tucker-RosenwaId Schoo l, j 

Jean C. Edwards. She continues  in  th i s  p o s i t i o n  o f  teach ing  in 

the d e fen d a n t 's  schoo ls  under T i t l e  I  as "rem ed ia l  read ing  teacher"|.

Mrs. Evans' s a la r y  has in creased  each yea r  s in ce  the schoo l 

year  1966-67 from a annual s a la r y  o f  $4500 to  her p resen t  s a la r y  '
i

in  the  schoo l system o f  $6,200.

During the years  the schoo l d i s t r i c t  has r e c e iv e d  T i t l e  I  

funds and s in ce  1965-66 the  schoo l d i s t r i c t  has employed both  

b la ck  and w h ite  tea ch ers  as a p a r t  o f  i t s  s c h o la s t i c  and educationajl 

t r a in in g  programs. During the p e r io d  o f  t im e, 1965 through 1970, 

the  sch oo l has employed f i v e  w h ite  tea ch ers  and th re e  b la ck  

tea ch ers  under T i t l e  I ,  a f e d e r a l  program f o r  needy s tu den ts .

I t  appears the f e d e r a l  government r e q u ir e s  th a t  the t e a c h e r 's  

c o n t ra c ts  under the program inc lude  " c o n t ra c t  payab le  as funds 

a re  a v a i l a b l e " .  Her com pla in t th a t  t h is  in  some way r e s u l t s  in 

d is c r im in a t io n ,  b r in g in g  the issue w i th in  the j u r i s d i c t i o n  o f  

t h i s  a c t io n  i s  f a r f e t c h e d  and beyond comprehension. The re co rd  

c l e a r l y  e s ta b l i s h e s  the f a c t  th a t  in the  even t  T i t l e  I  funds 

become u n a v a i la b le ,  th a t  Mrs. Evans would be re ta in e d  under the

r e g u la r  p a y r o l l  as was done in the case o f  another b la ck  tea ch e r ,

Mrs. Maxine C la rk .  I t  i s  e s ta b l is h e d  th a t  the p o s i t i o n  o f

Mrs. Evans has in  no way been je o p a rd iz e d  and n e i th e r  has she

been damaged by her continued employment as a teacher in  the

d e fe n d a n t 's  p u b l ic  s ch o o ls .  The tes t im ony f a i l s  to  e s t a b l i s h  any
1/

b a s is  f o r  her c la im  o f  d is c r im in a t io n .______________ _________________________
_1/ Mrs. Evans c la im s th a t  the schoo l d i s t r i c t  should pay her 
expenses f o r  go ing  t o  summer schoo l f o r  a d d i t io n a l  courses  and the 
f a i l u r e  t o  do so i s  d is c r im in a to r y .  Th is  c on ten t ion  i s  unsupported 
by the  tes t im ony and w ithou t  m e r i t .  The schoo l d i s t r i c t  does not 
pay the  expenses and n ever  has p a id  the  expenses o f  i t s  tea ch ers  | 
f o r  a t ten d in g  summer t r a in in g  programs._________

i***’-*’’*



B. ASIVE THOMAS.

A s iv e  Thomas was f i r s t  employed by the defendant schoo l 

' d i s t r i c t  f o r  the school year  1966-67 as a teacher f o r  s o c i a l

s tu d ies  a t  the Tucker-Rosenwald Schoo l. s in ce  he had not ob ta in ed  j 
j recIul-red c r e d i t s ,  he d id  not en joy  a c e r t i f i c a t e  f o r  p u b l ic  

schoo l teach ing  but was employed under an Emergency C e r t i f i c a t e  

issued by the Department o f  Education. He continued to  teach 

s o c i a l  s tu d ies  f o r  the schoo l year  1967-68 under BSE Emergency 

C e r t i f i c a t e .  During the summer o f  1968 he r e c e iv e d  a deg ree  in 

j r e c r e a t io n .  His pr im ary in t e r e s t  was in  p h y s ic a l  education  and

j more s p e c i f i c a l l y  in  coach ing . The re co rd  f a i l s  to  d i s c l o s e  th a t  ii
j! he had any s p e c ia l  t r a in in g  o r  exp e r ien ce  in t h i s  f i e l d .  During [

•j the two years he was employed by the schoo l d i s t r i c t  he had no 

| d u t ie s  in the f i e l d  o f  p h ys ic a l  educa t ion  o r  in coaching a c t i v i t i e s ;

|| w ith  the schoo l d i s t r i c t  a t  Tucker-Rosenwald Schoo l.

Mr. Thomas was not reemployed as a s o c i a l  s tu d ies  teach er  

j f o r  the schoo l y ea r  1968-69. He was in formed o f  t h is  a c t io n  by -
j

t im e ly  l e t t e r  from the super in tenden t o f  schoo ls  as re q u ir e d  by

Ark . S ta t s .  80-1304 (1960 R e p l . ) .

The reason g iv e n  by the schoo l d i s t r i c t  f o r  f a i l i n g  t o  renew 

j, h is  teach ing  c o n tra c t  as a s o c i a l  s tu d ies  teach er  in  the  Tucker-

j Roselw a ld  Elementary School was h is  f a i l u r e  t o  adequ a te ly  per fo rm  j
I

jj as such t e a c h e r . Th is a c t io n  was p r i o r  to  the adoption  o f  the 

sch° o1 d i s t r i c t ' s  u n i ta ry  system in the e lem entary schoo ls  and

th e re  is  no tes t im ony t o  support the con ten t ion  th a t  such a c t io n  j
jj
jl was ln  any way d is c r im in a to r y  as t o  race  o r  o th e rw is e .  Even I
|J though Mr. Thomas was employed in t h i s  c a p a c i t y  f o r  two yea rs ,  

he f a i l e d  t o  become c e r t i f i e d  in the f i e l d  o f  s o c i a l  s tu d ies  and 

th e re  was no in d ic a t io n  th a t  he would become so c e r t i f i e d  in  the 

fu tu re .  He had not been c e r t i f i e d  a t  the t ime o f  h is  test im ony



in this proceeding.

F o llow in g  t o t a l  in t e g r a t io n  o f  the schoo ls  and u n i f i c a t i o n  

j colraT,encin9 w ith  the schoo l y ea r  1969-70, Mr. Thomas contends tha t  j 

!| he WaS e n t i t l e d  t o  be employed as a p h y s ic a l  education  in s t ru c t o r  j 

jj ° r  C° aCh in  the  schODl d i s t r i c t ' s  h igh  sch oo l .  Mr. Hunter Doug la s .  I 

ji 3 Whlte t e a c h e r ' employed as a tea ch er  in  s o c i a l  s tu d ie s  and !

Jf Phy s l c a l  education  in s t ru c to r  f o r  the schoo l y e a r  1966-67 and
i !
|| reemPloyed a t  the  d i s t r i c t ' s  Plum Bayou High School f o r  the  schoo l j 

I Year 1967-68‘ The schoo l d i s t r i c t  f a i l e d  t o  reemploy him f o r  the j 
jj sch° o1 y ea r  1968-69 f o r  the same reason th a t  i t  f a i l e d  t o  reemploy !

|i Mr' A s lv e  Thomas as a s o c i a l  s tu d ies  tea ch er  in the e lem entary  

j j  schoo l o f  Tucker-Rosenwald; th a t  i s .  f a i l u r e  t o  adequ a te ly  

j per fo rm  the  d u t ie s  as such in s t r u c t o r .

For the schoo l y ea r  1968-69 the schoo l d i s t r i c t  employed 

I Mr. Bruce McConnell, a w h ite  t ea ch er ,  f o r  s o c i a l  s tu d ie s  and 

j p h y s ic a l  educa t ion  in i t s  h igh  s ch o o l .  He was c e r t i f i e d  in  both  

f i e l d s .  He re s ign e d  a t  the end o f  the schoo l y ea r  1969-70. To

i r e p la c e  him, the d i s t r i c t  employed Mr. C o rn e l iu s  Sanders, a b lack
ji

: t e a ch e r ,  f o r  i t s  h igh  schoo l teach ing  s o c i a l  s tu d ies  and p h y s ic a l

j edu ca t ion . Mr. Sanders a ls o  perform s ex tra  d u t ie s  as a coach in  i
|j the  h igh sch° o 1 - The tes t im ony f a i l s  t o  e s t a b l i s h  the con ten t ion

j o f  Mr. Thomas th a t  h is  te rm in a t ion  as an e lem entary  tea ch er  a t  the
{ j

|J all-b lack  school. Tucker-Rosenwald. prior to the school's
Ij:  u n i f i c a t i o n  o f  the e lem entary  g rades ,  was a r e s u l t  o f  d isc r im ina tor jy
|i . f
■ Practlces by the school d istr ic t  and his contention is  without 
j! merit.

However, i t  is  e s ta b l is h e d  th a t  Mr. Thomas ob ta in ed  employ- 

j ment as a tea ch er  a t  B r in k le y .  Arkansas, f o r  the sch oo l year  

| 1968-69 where he r e c e iv e d  an annual s a la r y  o f  more than $5,000.

-7-



A f t e r  one yea r  he l e f t  the B r in k le y  School system and was 

employed as a teach er  f o r  the sch oo l year  1969-70 a t  Wabbaseka, 

Arkansas, a t  a s a la r y  o f  some $5,600. He t e s t i f i e d  a t  the hear ing  j 

th a t  he was s t i l l  employed a t  Wabbaseka f o r  the sch oo l year  

1970-71 a t  a s a la r y  o f  more than $6,000 and a ch ieved  h is  d e s i r e  

o f  per fo rm ing  coaching d u t ie s .  He made i t  c l e a r  th a t  he was 

s a t i s f i e d  w ith  h is  p o s i t i o n  a t  Wabbaseka and had no fu r th e r  

d e s i r e  f o r  a p o s i t i o n  w ith  the plum Bayou School D i s t r i c t .  He 

s u f f e r e d  no damages as c la imed and such con ten t ion  i s  not 

susta ined  by the tes t im ony . N e v e r th e le s s ,  in  v iew  o f  the C o u r t 's  

r u l in g  on the  qu es t ion  o f  d is c r im in a t io n ,  he cou ld  c la im  no 

damages even i f  i t  cou ld  have been shown by the tes t im ony  .to  

be due.

C. MRS. LOIS THOMAS.

The con ten t ion  o f  Mrs. L o is  Thomas p resen ts  the  v e r y  

d i f f i c u l t  problem o f  a red u c t ion  o f  f a c u l t y  in a sch oo l system 

as a r e s u l t  o f  u n i f i c a t i o n  o f  i t s  sch oo ls  re q u ir e d  by law . Th is  

problem has caused concern in a g r e a t  many in s tances  where in  

in t e g r a t i o n  was r e q u ir e d  and by the e l im in a t io n  o f  a s t a t e
i

mandated dual system o f  s e g r e g a t io n .  I t  has been a su b je c t  m atter  : 

f o r  the C o u r t 's  in  many in s tan ces .

Mrs. L o is  Thomas s ta r t e d  tea ch ing  in  the d e fe n d a n t 's  schoo l 

a t  the a l l - b l a c k  Tucker-Rosenwald Elementary Schoo l.  She was 

f i r s t  employed as a th i r d  grade teach er  and subsequently  a 

tea ch er  f o r  the f i r s t  g rade . She was c e r t i f i e d  in e lem entary  

education  BSE w ith  s i x  years  e x p e r ie n c e .  Her c o n t ra c t  was 

term ina ted  a t  the  end o f  the 1968-69 schoo l y e a r .  The schoo l 

d i s t r i c t  had a lre a d y  determ ined to  u n i f y  the plum Bayou-Tucker- 

Rosenwald Elementary schoo ls  e f f e c t i v e  the f o l l o w in g  yea r  1969-70. '



The e n t i r e  schoo l system had a t o t a l  o f  302 s tu den ts ,  228 

o f  the s tudents were b la ck  and 74 w h ite  f o r  the schoo l year
:

1969-70. For the  schoo l year  1970-71 th e re  were 151 students 

in  the e lem entary  g rades , 27 w h ite  and 124 b la c k .  In  h igh  schoo l 

th e re  was some 17 w h ite  students and 104 b la c k .  i t  i s  q u i te  

obvious th a t  the schoo l d i s t r i c t  attempted to  op e ra te  i t s  a l l -  

w h ite  e lem entary  schoo l w ith  27 s tudents w ithou t j u s t i f i c a t i o n ,  

e d u c a t io n a l ly  o r  on any sound b a s is  w hatsoever . i t  is  q u i te  

apparent the schoo l board come to  r e a l i z e  the in e v i t a b l e  as e a r l y  j 

as 1965 and attempted to  p repare  the d i s t r i c t  f o r  i t .  When the 

day a r r i v e d  f o r  the schoo l d i s t r i c t  to  p ro v id e  a f u l l y  in te g ra te d  

and t o t a l l y  d eseg rega ted  schoo l system, i t  n e c e s s i ta t e d  a 

red u c t ion  in  e lem entary  t ea ch ers .  B e fo re  t o t a l  u n i f i c a t i o n  th e re I
were f i f t e e n  e lem entary  teach ers  a t  the b la ck  Tucker-Rosenwald !
School and s i x  e lem entary  teachers  a t  the w h ite  Plum Bayou Schoo l.  , 

A reasonab le  d e te rm in a t ion  was made th a t  a f t e r  u n i f i c a t i o n  tha t  

o n ly  ten e lem entary  teach ers  would be needed.
I

I t  i s  e s ta b l is h e d  by test im ony th a t  the  super in tenden t o f  

schoo ls  and the  schoo l board, a f t e r  c o n s u lta t io n  w ith  tea ch ers  

bo th  b lack  and w h ite ,  the County School S up erv iso r ,  and l e g a l  

counse l,  adopted a method o f  e v a lu a t io n  o f  a l l  e lem en tary  teachers  

in  an e f f o r t  to  a r r i v e  a t  a f a i r  and o b j e c t i v e  b a s is  f o r  the
!

e l im in a t io n  o f  f i v e  o f  i t s  e lem en tary  tea ch ers .

Whether the  method f i n a l l y  adopted was the b e s t  method f o r  

such e v a lu a t io n  was the r e s p o n s ib i l i t y  o f  the schoo l board , unless 

i t  r e s u l t e d  in obvious d is c r im in a t io n .  The Court has c a r e f u l l y

rev iew ed  the in v e s t i g a t i o n  made by the schoo l d i s t r i c t  and the 

e x t e n t  to  which the super in tenden t o f  schoo ls  went in  cons idera t ion ) 

o f  the v iew s o f  a l l  teach ers  and the ad v ise  from the county School !

I



Superv isor  as to  the proper c r i t e r i a  t o  be u t i l i z e d  as w e l l  as 

l e g a l  counse l,  and concludes th a t  the  method o f  e v a lu a t io n  

adopted was reason ab le ,  f a i r  and o b j e c t i v e .

From t h i s  method o f  e v a lu a t io n  o f  the  ten teach ers  o f  the

I

e lem entary  tea ch ers  r e ta in e d  f i v e  were b la ck  teach ers  and f i v e  

were w h ite  te a c h e rs .  Of the f i v e  tea ch ers  who were not r e ta in e d  

fo u r  were b la ck  and one was w h ite .  Subsequently , one o f  the b la ck  i 

tea ch ers  r e ta in e d  re s ign ed  and the w h ite  teach er  not r e ta in e d
I

r e s ig n e d .  A b la ck  tea ch er  ranked next on the  e v a lu a t io n  form 

was not  r e ta in e d  but moved to  the number ten  p o s i t i o n  and thereby  

reemployed. O f the th re e  b la ck  tea ch ers  not r e ta in e d  on ly

Mrs. L o is  Thomas complains o f  d is c r im in a t io n  and seeks r e l i e f  in  i
2/

t h i s  a c t io n .

From the test im ony and the re co rd  in  th is  p roceed in g ,  the 

Court i s  unable t o  conclude th a t  any d is c r im in a t io n  has r e s u l te d  

as t o  the method o f  e v a lu a t io n  o f  the e lem entary  teach ers  and 

in  the red u c t ion  o f  the teachers  f o r  t h is  schoo l n e c e s s i ta t e d  by- | 

u n i f i c a t i o n  o f  the  d e fe n d a n t 's  schoo l system.

i
The Court i s  c on s tra in ed  to  h o ld  th a t  the con ten t ion  o f  

Mrs. L o is  Thomas o f  d is c r im in a t io n  and damages i s  not substan tia ted ; 

by the tes t im ony and w ithou t b a s is .

P a r e n t h e t i c a l l y ,  a vacancy occu rred  during the  f o l l o w in g  year  ! 
o f  the e v a lu a t io n  o f  1969 by a w h ite  e lem entary  t ea ch er  r e s ig n in g  j 
a t  the end o f  the  schoo l year  1969-70. To r e p la c e  t h i s  w h ite  
tea ch er  the School D i s t r i c t  employed a b la ck  tea ch er ,  r e s u l t in g  
f o r  t h i s  schoo l y ea r  s i x  b la ck  tea ch ers  in  the e lem en tary  schoo l 
and fou r  w h ite  tea ch e rs .

Fu r th er ,  by way o f  a l e t t e r  rega rd in g  Mrs. Thomas, the sch oo l 
Board has in v i t e d  Mrs. Thomas t o  app ly  f o r  a vacancy as an 
e lem en tary  t ea ch er  o f  t r a in in g  in  e lem en tary  educa t ion  f o r  the 
sch oo l y ea r  commencing 1971,________________________ _____________________



2. FAILURE TO PAY BLACK TEACHERS AT THE SAME 
RATE AS THE WHITE TEACHERS.

I t  is  c l e a r l y  e s ta b l is h e d  by the test im ony and the e n t i r e  

re co rd  in th is  case ,  su b s ta n t ia ted  by e x h ib i t s ,  th a t  the  defendant
i

schoo l d i s t r i c t  adopted a uniform  s a la r y  schedule f o r  teach ing  

personnel p r i o r  to  the schoo l y ea r  1966-67. The schoo l d i s t r i c t ' s  j 

t each er  s a la r y  schedule in  e f f e c t  f o r  the schoo l y ea r  1969-70 is  

a t  a minimum s a la r y  based on the t e a c h e r 's  c o l l e g e  d eg ree ,  

c e r t i f i c a t i o n  and diploma o f  advanced study w ith  anannual in c rease  • 

up to  ten  years  o f  s e r v i c e  and a maximum s a la ry  on the same b a s is  

with an additional $900 a year for extra duty. The salary schedule 

i s  a p p l ic a b le  t o  a l l  teach ers  on the same b a s is  and t h i s  contention ! 

o f  the p l a i n t i f f s  i s  w ithou t m e r i t .

3. FAILURE TO OFFER EQUAL EMPLOYMENT AND EARNING 
OPPORTUNITIES TO BLACK TEACHERS.

From the tes t im on y , th is  con ten t ion  i s  o b v io u s ly  l im i t e d  t o  

| sch oo l bus d r i v e r s .  In s o fa r  as ncn-teaching p ersonn e l,  th e re  i s  

| no con ten t ion  th a t  any b la ck  person was d ep r iv ed  o f  any such 

j! p o s i t i o n  or  op p o r tu n ity  f o r  such p o s i t i o n .
I

The re co rd  d is c lo s e s  from the tes t im ony tha t  the schoo l board

has g iv en  employment as e x t ra  duty s e r v i c e  to  both  w h ite  and
il
j b la ck  tea ch e rs .  For the year  1969-70 th e re  were f i v e  bus d r i v e r s ,
!j

j| fou r  w h ite  and one b la c k .  I t  i s  fu r th e r  e s ta b l is h e d  th a t  these 

were exper ienced  bus d r i v e r s  and had been employed by the schoo l 

d i s t r i c t  f o r  some t im e. When a vacancy occurred  the  schoo l 

d i s t r i c t  employed another b la ck  person as a schoo l-bus d r i v e r  

j| commencing w ith  the schoo l year  1970-71. The cou rt  concludes 

th a t  th is  con ten t ion  o f  the p l a i n t i f f s  i s  not su b s ta n t ia ted  by 

the test im ony and w ithou t  m e r i t .

-11-



CONCLUSIONS OF LAW

J u r i s d i c t i o n  o f  th is  p roceed ing  i s  adm itted  and e s ta b l is h e d  

28 U .S .C .A . § 1 3 4 2 (3 ) (4 ) ;  42 U .S .C .A . §§1981 and 1983; 28 U .S .C .A . \

| §2201, and the due process  and p r o t e c t io n  c lauses  o f  the Fourteenth

Amendment to  the c o n s t i tu t io n  o f  the United  S ta te s . I
I t  i s  w e l l  e s ta b l is h e d  tha t  a schoo l d i s t r i c t  may not

j
| c o n s t i t u t i o n a l l y  d is c r im in a te  a ga in s t  Negro schoo l personnel and

j i
[ teachers  on the  b a s is  o f  t h e i r  ra c e .  I t  i s  fu r th e r  e s ta b l is h e d
i
l| th a t  no tea ch er  has an i n d e f i n i t e  tenure r i g h t  under Arkansas law

II 1
j |  and a schoo l d i s t r i c t  is  not r e q u ir e d  t o  r e t a in ,  promote or

I compensate s o l e l y  on the b a s is  o f  s e n i o r i t y  -
I . i
j As s ta te d  in  McBeth v .  Board o f  Education, by th is  c o u r t ,

i !j Henley, C .J . ,  300 F.Supp. 270 (1970):

" I t  i s  s e t t l e d  in th is  C i r c u i t ,  as e lsew h ere ,  tha t  
those in charge o f  p u b l ic  schoo l systems may not 
c o n s t i t u t i o n a l l y  d is c r im in a te  a ga in s t  Negro schoo l 
a d m in is t ra to rs  and teach ers  on the b a s is  o f  t h e i r  ra ce .
When student body in t e g r a t io n  perm its  a schoo l d i s t r i c t

I t o  reduce i t s  f o r c e  o f  ad m in is t ra to rs  and tea ch ers ,  the
re d u c t ion  i s  not t o  be e n t i r e l y  a t  the expense o f  Negro 
employees. The problem must be s o lv ed  in a r a c i a l l y  
n on -d is c r im in a to ry  manner. Walton v .  N a s h v i l l e ,  Arkansas 
S p e c ia l  School D i s t r i c t  No. 1, 401 F.2d 137; Smith v .  Board 
o f  Education o f  M o r r i l t o n  School D i s t r i c t  No. 32, 365 F .2d i 
770; Brooks v .  School D i s t r i c t  o f  C i t y  o f  M obeley ,
267 F .2d 733 ."

ij
F u r th e r :

"Arkansas p r in c ip a ls  and c lassroom  teach ers  have 
but l im i t e d  tenure r i g h t  under Arkansas law, and l o c a l  
schoo l d i s t r i c t s  are  not r e qu ir ed  to  h i r e ,  r e t a in ,  
promote o r  compensate on the b a s is  o f  s e n i o r i t y .  And 
w h i le  a Negro employee o f  the schoo l d i s t r i c t  has a 
f e d e r a l l y  c o n s t i t u t i o n a l  immunity from d is c r im in a t io n  on 
the count o f  ra ce ,  he does not have a v e s te d  r i g h t  to  
remain in  the employ o f  the schoo l d i s t r i c t . "

I . I
In  another case emanating in  th is  Court, Jackson v .  W h ea t ley , ]

|i 430 F . 2d 1359 (1970) the E ighth C i r c u i t  cou rt  o f  Appea ls  s ta t e d :II
" In  Arkansas, a schoo l d i s t r i c t  has the r i g h t  to  

in v e s t i g a t e  competency and f i t n e s s  o f  those employed 
to  teach in i t s  s ch o o ls .  There i s  no o b l i g a t i o n  on the

-12-



p a r t  o f  the board to  r e h i r e  a teacher should a 
de te rm in a t ion  be made tha t  i t  would not be in  the 
b es t  i n t e r e s t  o f  the schoo l system i f  such d e c is io n  
i s  not based on the grounds o f  r a c i a l  c o n s id e r a t io n s . "  
c f - Haney v .  S e v ie r  County Board o f  Education .
284 F.Supp. 916; Smith v .  Board o f  Education o f  
the M o r r i l t o n  School D i s t r i c t . 365 F.2d 770 (8th 
C i r .  1966) .

j
The cou r t  determ ines from the test im ony, response to  

jj in t e r r o g a t o r i e s ,  e x h ib i t s  and the e n t i r e  re co rd  and in accordance 

w ith  the f in d in g s  o f  f a c t  and conc lus ion s  o f  law tha t  the qu es t ion s

I! •
in v o lv e d  h e re in ,  the con ten t ion s  o f  the p l a i n t i f f s  and the r e l i e f  

sought, i s  w ithou t m er i t  and the com pla in t o f  the p l a i n t i f f s  

jj should be d ism issed .

The requ es t  o f  counse l o f  the p l a i n t i f f s  in th is  case f o r  

a t t o r n e y 's  f e e  ch a rgeab le  to  the defendant schoo l d i s t r i c t  i s  

j u n ju s t i f i e d  and den ied .

An o rd er  w i l l  be en te red  in accordance w ith  th is  op in ion .

13'



BY:
I N  T H E  U N I T E D  S T A T E S  D I S T R I C T  C O U R T  

E A S T E R N  D I S T R I C T  O F  A R K A N S A S  

E A S T E R N  D I V I S I O N

h i L E D
JuN7 1971

W. H. McoLfeulArt, LLutiK

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L O I S  T H O M A S :  A S I V E  T H O M A S :

L U C R E A S I A  A .  E V A N S :  E L O I S  WOODS 

a n d  T R O Y  E .  W O O D S ,  b y  t h e i r  p a r e n t  

a n d  n e x t  f r i e n d ,  M R S .  C O R I N E  W O O D S :  

E R I C E  D I N W I D D I E ,  D O N A L D  R .  D I N W I D D I E ,  

R O D N E Y  D I N W I D D I E ,  a n d  D A R R Y L E  H A R R I S ,  

b y  t h e i r  g u a r d i a n  a n d  n e x t  f r i e n d ,  

M R S .  C O R I N E  W O O D S ,

P l a i n t i f f s ,

T H E  B O A R D  O F  E D U C A T I O N  O F  T H E  
P L U M  B A Y O U - T U C K E R  S C H O O L  D I S T R I C T  

N O .  1 ,  W r i g h t ,  A r k a n s a s ;  F R A N K  C O N L E Y ,  

P r e s i d e n t :  a n d  J A M E S  K .  B R A D S H A W ,  
S u p e r i n t e n d e n t  o f  S c h o o l s  o f  t h e  P l u m  

B a y o u - T u c k e r  s c h o o l  D i s t r i c t  N o .  1 ,

N O .  P B  6 9 - C - 4 6

D e f e n d a n t s .

ORDER

P u r s u a n t  t o  M e m o r a n d u m  O p i n i o n  f i l e d  t h i s  d a t e  i n  t h i s  

p r o c e e d i n g  a n d  f r o m  t h e  e n t i r e  r e c o r d ,  t h e  C o u r t ,  b e i n g  w e l l  

a n d  s u f f i c i e n t l y  a d v i s e d ,  t h e  c o m p l a i n t  o f  t h e  p l a i n t i f f s  a g a i n s t  

t h e  d e f e n d a n t  i s  h e r e b y  c o n s i d e r e d ,  o r d e r e d  a n d  a d j u d g e d  t o  b e

w i t h o u t  m e r i t  a n d  i s  h e r e b y  d i s m i s s e d .

I T  I S  F U R T H E R  O R D E R E D  t h a t  t h e  r e q u e s t  o f  t h e  p l a i n t i f f s '

D A T E D :  J u n e  7 ,  1 9 7 1 .

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s w o
JUL 6 1971

P I N E  B L U F F  D I V I S I O N  ' ----- :--------- ’

L O I S  T H O M A S ,  e t  a l .

P L A I N T I F F S ,  )

V s .

T H E  B O A R D  O F  E D U C A T I O N  O F  T H E  1

P L U M  B A Y O U - T U C K E R  S C H O O L  D I S T R I C T  
N O .  1 ,  W r i g h t ,  A r k a n s a s ,  e t  a l . ,  )

C I V I L  A C T I O N  

N O .  PB 6 9 - C - 4 6

)
D E F E N D A N T S .  )

N O T I C E  O F  A P P E A T ,

p l e a s e  T A K E  N O T I C E  t h a t  p l a i n t i f f s  h e r e b y  a p p e a l  t o  

t h e  u n i t e d  S t a t e s  C o u r t  o f  A p p e a l s  f o r  t h e  E i g h t h  C i r c u i t

f r “  t h e  0 r d 6 r  e n t e r e d  i n  ^ i S _ T h o I m s J_ e t  a l .  v ,  T h p  ^  

E d u c a t i o n  o f  t h e  P l u m  B a y o u - T u c k e r  c c h o o i  D i s f r i r . ^  ^  ,  '

^ ^ ^ a n s M z _ e ^ a l . ;  u n i t e d  s t a t e s  D i s t r i c t  C o u r t  ’

N o .  P B  6 9 - C - 4 6 ,  b y  t h e  U n i t e d  S t a t e s  D i s t r i c t  C o u r t ,  E a s t e r n  

D i s t r i c t  o f  A r k a n s a s ,  P i n e  B l u f f  D i v i s i o n ,  d a t e d  J u n e  7 .  1 9 7 1 ,  

t h e  H o n o r a b l e  O r e n  H a r r i s ,  D i s t r i c t  J u d g e .

DATED

* R e s p e c t f u l l y  s u b m i t t e d ,

K A f L A N ,  L A V E Y  &  M A Y S  
1 8 2 0  W e s t  1 3 t h  S t r e e t  

L i t t l e  R o c k ,  A r k a n s a s  7 2 2 0 2

,5 1 '| * I1.-, ft N >T • V 2i
P H I L I P  E .  -i K A P L A N --------

A t t o r n e y s  f o r  P l a i n t i f f s

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Dep. Clerk'



IH  THE TOUTED STATES DISTRICT COURT 
EASTSRU DISTRICT 0?  ARKANSAS 

PIHE BLUFF D IV IS IO N

LOIS THOMAS, e t  a l . ,

C IV IL  ACTION 

HO. PB 69-C—46

PLA IN T IFFS , )
)

V * .  )
)

THE BOARD OF EDOCATION OF THE )
PLUM BA YOU-TUCKER SCHOOL D ISTRICT )
HO. 1, W r ig h t ,  A rk a n sa s , « t  * 1. ,  )

)
DEFENDANTS, )

9QSS.. ZfflL fflSTS a m z a t

Tha p l a i n t i f f a  h ava  f i l e d  in  t h i s  C ou rt a  M o t io n  o f  

A p p e a l.  P u rsu an t t o  R u la  7 o f  th a  F s d a ra l R u le s  o f  A p p e l la t a  

P ro c e d u re , th e  p l a i n t i f f s  end C a r l  B ro o k s , s u r e t y ,  a r e  h e ld  

and f i r m ly  bound f o r  th a  paym ent b y  th e  p l a i n t i f f s  o f  a l l  c o s ta  

and d isb u rsem en ts  up t o  th e  sum o f  Two Hundred F i f t y  D o l la r s  

($250. 00) ah ou ld  i t  h e  d e te rm in ed  th a t  th a  a p p a a l i s  w ith o u t  m e r i t .

I f  th e  p l a i n t i f f e  p ay  a l l  c o a t s  and d isb u rsem sn ta  

in c u r r e d  b y  ren eo n  o f  t h i s  a p p e a l sh ou ld  i t  b e  d e te rm in ed  th a t  

th e  a p p e a l i s  w ith o u t  m a r i t ,  t h i s  o b l i g a t i o n  s h a l l  b e  v o id ,  

o th e r w is e  i t  s h a l l  rem a in  in  f u l l  f o r c e  and e f f a e t .

E x ecu ted  t h i s __________day  o f  1971.

LOIS THOMAS, a t  e l .

»y_
P h i l i p  E . K ap lan

WALKER, KAPLAN, LAVEY «. NAYS 
1820 M ea t 13th  s t r e e t  
L i t t l e  Book , A rk an sas  72202

A t t o r n e y s  f o r  P l a i n t i f f s

®y_
CARL BROOKS, SURETY