Correspondence from Reynolds to DeJean
Correspondence
September 23, 1988

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Case Files, Sheff v. O'Neill Hardbacks. Defendants' Proposed Findings of Fact, 1995. 84842f15-a246-f011-877a-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/ed415a95-ea3c-41ea-9a6b-81e8cf9e55e0/defendants-proposed-findings-of-fact. Accessed August 19, 2025.
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May 31 'S35 18:06 KONICA FAX 7208 » RP. 2 §.C. 15288 MILO SHEFF, ET AL. : SUPREME COURT Vv. WILLIAM A. O'NEILL, ET AL. : MAY 25, 1995 The following are proposed findings of fact submitted in addition to the facts contained in the parties’ joint stipulation of facts and submitted pursuant to the order of the Supreme Court dated May 11, 1995:1/ A The Plaintiffs Have Not Proven That The State Has Taken Any Actions Which Violate The Equal Protection Clause, the Due Process Clause Or The Education Article Of The Connecticut Constitution ' 1/ Each proposed finding of fact is based on the evidence presented, and therefore the circumstances prevailing, at the time of trial - December 1992 through February 1993. lay 31 "SO 18:97 KUNICA FAX 728 Pe J x. Connecticut has always been a leader in the field of public education. (Collier, Vol. 16, PP. 23, 71-72) 2. The quality of publijc education in Connecticut has improved continuously over the past 200 years. (Collier, vol. 16, pp. 9-10, 23, 56-57) 3, The African-American population patterns in the 22 town region during this century have been dynamic and unpredictable. (Steahr, Vol. 23, pp. 20-21, 80-81; DX 1.14) 4, The percentage of African-American residents in Hartford has declined from 88% in 1970 to 65% in 1980 to 68% in 1990 to 63.7% in 1992. (Steahr, vol. 23, PP. 35-37; DX 2.13) 5. Between 1970 and 1980, the African-American population in the 21 suburban towns increased by 141.1% and by 74.4% between 1980 and 1990. (DX 1.4) 6. From 1980 to 1990, the Latino population in the 21 Suburban towns increased by 128.8% and the Latino student {Population grew by 122.2%. (DX 1.5) H May 31 95 10:07 KONICA FAX 728 7s There have been Significant increases in Latino Population in East Hartford, Manchester, West Hartford, Vernon and Windsor. (Steahr, vol. 23, p. 40) 8. There is no professionally agreed upon standard for racial, ethnic and socio-economic balance in schools which can be applied to schools in Hartford and the 21 suburban towns. (Carter, vol. 1, PP. 33-34; Senteio, Vol. 3, PP. 51; Martinez~Pitre, Vol. 6, PP. 45-46; Trent, vol. 7, PP. 81, 114; Natriello, vol. 11, p. 144; Allison, vol. 12, pp. 72-75, Gordon, Vol. 13, p. 149; vol. 14, pp. 76-79; LaFontaine, vol. 14, pp. 114-120; Haig, Vol. 18, pp. 113) 9. The Harvard Study correctly Projected the decline in Hartford’s African-American student population, the only significant minority group in Hartford in 1965, but failed to Pradist the massive influx of Latino students, primarily of Puerto Rican ancestry. (DX 13.2, p. 2} Gordon, Vol. 13, PP. Changes in the demographic composition of Hartford and ithe 21 surrounding suburban towns have occurred because of individuals’ choices about their residences, (Steahr, vol. 23, | 'pP. 67; Armor, Vol. 32, p. 129; DX 11.21-11.25) May 31 95 10:08 KONICA FAX 720 11. The state has not taken any action which would encourage any individuals to choose any racially imbalanced residential settings. (Armor, Vel. 32, p. 129) 12. The primary purpose of the Strategic Schools Profiles (”S8P”) is (1) to make school districts accountable for compliance with their legal requirements and (2) to be a vehicle for school-based improvement. (Rindone, Vol. 29, pp. 80-81) 13. Because the newness of the SSP program, the J Sonnissioner of Education has instructed school superintendents ! how to use SSP data to make comparisons between their district and other districts or between schools in their district and schools in other districts. (Rindone, Vol. 29, PP. 81, 146-147) 14. Connecticut’s SSP program is one of the most extenszive ‘8uch programs in the country. (Rindone, vol. 15. The CMT was not developed to compare or to contrast student performance in one school district with student performances in other districts. (Nearine, Vol. 20; PX 290~308) | | Hi | : 16. The CMT measures mathematics, reading and writing : skills in the 4th, 6th, and 8th grades. (px 290-309) I) ; i i i bir May 31 ’95 18:89 KONICA FAX 720 eso l oh 17. The CMT measures a relatively narrow part of students’ achievement. (px 493; Ferrandino Deposition, p. 37; Natriello, Vol. 11, p. 189) 18. The rate of Hartford public school students who participate in the CMT is higher than the participation rate of other large cities in the state. (Nearine, vol. 24, Pp. 73) 19. Hartford public schools attempt to administer the CMT to every eligible student in the school system. (Nearine, vol 24, p. 73) 20. Individual socioeconomic status (7SgEs”), primarily ‘poverty, has the largest impact on lack of student achievement when measured for large groups of students. (Natriello, vol. 8 [4 PP. 64-65; Armor, Vol. 32, Pp. 21; Crain, Vol. 35, p. 76) 21. To understand the quality or effectiveness of a particular educational program, the effects of the disadvantages (| that students bring to school with them to that program must be i t | separated from the effects of the particular educational program. | (Natriello, Vol. 11, pp. 8, 9, 22-23, 89, 91; Crain, Vol. 33, ‘pp. 79-80) LI | ‘ May 31 'S5 10:89 KONICA FAX 720 22. None of the plaintiffs’ witnesses conducted a study in which they reviewed the quality of the educational programs offered in Hartford by separating the effects of the disadvantages that Hartford’s students bring with them to school from the affects of the particular educational programs in Hartford. (Natriello, vol. 11, pp. 8, 9, 22-23, 89, 91; Crain, Vol. 35, pp. 79-80; Trent, vol. 7, p. 100, 118-22; Kennedy, vol. 14, p. 74) ¢3. Standarized test scores alone do not reflect the quality of an education program. (Natriello, Vol. 11, p. 11, 189; Flynn, Vol. 31, p. 151; Lafontaine, Vol. 15, p. 140; Nearine, Vol. 2, p. 16; Negron, Vol. 2, pp. 15-16; Shea, Vol. 1. Pp. 140) 24. Among other things, Hartford students score lower on the CMT than the state average (1) because many Hartford students - move among Hartford schools and/or move in and out of the Hartford school district, and (2) because many Hartford students N] di i . | are still learning the English language. (Shea, Vol. 3, P-140; Ii ‘|Nearine, Vol. 24, pp. 68-69; Negron, Vol. 2, PP. 15-16) ¥ H May 31 95 10:10 KONICA FAX 720 pe RP. 0 25. Differences in SES are the primary factor in explaining the differences in student performance on the CMT across the state. (DX 12.14, pp. v, vi; PX 59, p. 5; Haig, Vol. 18, p. 95) 26. If two groups of students which are equal in all respects except that one group has a larger Percentage of students with “at risk” factors such as low birth weight babies and mothers on drugs at birth, the group with a larger percentage with #at risk” characteristics will perform more poorly in an educational sense than the group with a smaller Percentage of those students with ”at rigk~ characteristics. (Natriello, Vol. 11, pp. 4-5) 27. Virtually all of the differences in performance between students in Hartford and students in the 21 suburban school districts on the CMT are attributable to differences in SES and to the background factors that SES represents. (Armor, Vol. 32, PP. 30, 93-94) 28. Virtually all of the differences in the rate of Jeni at four year colleges between Hartford students and 4 the students of the 21 suburban school districts are attributable to SES and to the background factors that SES represents. . (Armor, Vol. 33, pp. 30, 93-94) May 31 "95 16:10 KONICA FAX 720 » P. 0 29. When SES factors are taken into account, CMT and other standarized test scores for Hartford students and for suburban students, as groups, do not establish any inequality of programs between Hartford and the suburban schools. {drior, Vol. 22, p. 94-95) 30. Studies of Project Concern which controlled for SES-related background factors have not shown that Project Concern students, African-American Hartford students who attended school in suburban school districts, have had any greater academic achievement than they would have had, had they remained in Hartford public schools. (DX 13.19, pp. 26-27, DX 13.20, Go. 87) 31. When measured with appropriate controls for SES-related background factors, Project Concern had no statistically significant effect on Project Concern students dropping out of high school, on the number of years they completed in college, on | their later life incomes, or on their contact with whites. J: | (Crain, Vol. 10, pp. 75-77, 105-108, 128-133) {} 3 ji 32. Forty-six percent of Hartford students who started 1 “Project Concern left Project Concern and returned to the Hartford : -8chool system. (DX 11.26 (Table 1)) I i | -f - May 31 '95 18:11 ® KONICA FAX 728 33. The amount of time a student spent in Project Concern had no significant bearing on the student’s academic achievement. (Armor, Vol. 32, pp. 117-119; DX 11.26 (Tables 4 and 5)) 34. The only group of Project Concern students who demonstrated better academic performance than students in Hartford schools are those students who volunteered for Project Concern, and who finished their educations in the suburban school district regardless of the amount of time spent in the suburban sohool district, reflecting a phenomenon known as "self-selection bias.” (DX 11.26, Tables 3 and 5) 35. No study has shown that students who finished their ‘educations in Project Concern would not have done as well | academically if those students had remained in the Hartford public schools. (Crain, Vol. 35, p. 103) 36. When Hartford children who are afflicted by poverty enter kindergarten, many of them are already delayed one and one-half to two years in educational development. (LaFontaine, Vol. 5, p. 132; Cloud, Vol. 17, p. 86; Montanez-Pitre, Vol. 6, pp. 11, 41; Negron, Vol. 1, p. 81)