Briggs v. Elliot Motion of Louis L. Brown and Robert W. Wesley for Leave to File Brief Amicus Curiae in the Supreme Court of the United States, Pro Interesse Suo

    Supreme Court 
Of the United States

October Term, 1954 

NUMBER 2

HARRY BRIGGS, Jr., et al„ Appellants, 

v.

R. W. E L L IO T T  et al.

Motion of Louis L. Brown and Robert W. Wesley for 
leave to file brief Amicus Curiae in the Supreme Court of 

the United States, pro interesse suo.

Louis L. Brown
Fort Valley, Georgia 

and
Robert W. W esley 

Macon, Georgia 
Attorneys at Law



SUPREME COURT OF TH E UNITED STATES

FILE NUMBER

HARRY BRIGGS, Jr., et al.,
Appellants

v.

P v . W. EL LIO T T , c\ al. (No. 2.)
. , - * * * >  4  -  ** ♦  " i

We, the undersigned attorneys at law, move for leave 
to file a brief amicus curiae.

The nature of our interest, concisely stated, is as follows: 
pro inter esse suo, to wit: a portion of the livelihood of the 
last one of us whose names are signed below, is derived 
from compensation received by his spouse as Principal of 
Pearl Stephens Elementary School, Macon, Georgia, operat­
ed by the Bibb County Board of Education, which functions 
under a charter granted by the Legislature of the State of 
Georgia on August 23, 1872. See Public Laws of Georgia 
for 1872. (This charter antedates the charter of the State 
Board of Education of Georgia.)

The fact given above is also set forth as evidence of intent 
with which the Fourteenth Amendment to the Constitution 
of the United States was adopted in the year 1868; and 
because of that fact, the way in which the Charter of the 
above-mentioned Board of Education of Bibb County, Geor­
gia, was granted, and the circumstances under which it was 
granted, become relevant to the argument on Questions 
4 and 5 previously propounded by your Flonorable Court 
and requested to be reargued.

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MOTION
FOR

LEAVE TO  
FILE BRIEF 

AMICUS 
CURIAE



The argument we desire to present in the brief amicus 
curiae is for an affirmative answer to Question 4 (b ), with 
the related argument for a grant of discretion to duly con­
stituted local authorities, in order to carry out the terms of 
such affirmative answer; and an argument for a similar 
answer to Question 5 (c) above. The brief amicus curiae 
also sets forth further argument on the importance of the 
moral issue involved, which we are of opinion becomes rele­
vant to the fact of which your Most Honorable Court has 
taken cognizance, that local conditions are different.

SIGNED Louis L. B rown  *  
Attorney at Law 

A D D a l l ^ ^  a

SIGNITO R o b e r t  W ^ W e s l e y ^  
Attorney at Law 

ADDRESS Macon, Georgia

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