Application for Order to Show Cause

    IN THE UNITED STATES DISTRICT COURT FOR THE 

SOUTHERN DISTRICT OF MISSISSIPPI 

JACKSON DIVISION 

JOAN ANDERSON, et al., 

Plaintiff 

UNITED STATES OF AMERICA, 

Plaintiff-Intervenor, 

Vv. CIVIL ACTION NO. 370003) 

CANTON MUNICIPAL SEPARATE SCHOOL 

DISTRICT, et al.,, 

APPLICATION FOR ORDER 
i RE —— 

TO ‘SHOW CAUSE 
eseccsm— 

  

  

and 

MADISON COUNTY SCHOOL DISTRICT, 

et al., 

Defendants. 

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The United States of America, plaintiff-intervenor 

herein, applies to this Court for an order requiring the 

defendant Madison County School District to show cause why 

the student desegregation plan implemented by the School 

District failed to achieve the amount of desegre 

projected by the school board in its subsequent motion to 

modify the desegregation plan prepared by the Office of 

Education of the Department of Health, Education and’ 

Welfare and further why the School District should not be 

regation plan 

prepared by HEW for the 1970-71 school year. 

 



  

@ Xo) 

1. Prior to December 31, 196%, the Madison County 

5 

School District maintained eight schools, of which four 

were all Negro (Velma Jackson, Luther Branson, East Flora, 

: iia Wy oni de ma ras ng TEI SET A Re " Tn i CA Rosa Scott) and four were predominantly white (Farmhaven, 

Flora Madison-Ridgeland, Ridgeland). Flora and East Flora, 

each serving grades 1-12, are located in the town of Flora 

in the western section of the county. Rosa Scott and Madison- 

Ridgeland, each serving grades 1-12, are located in Madison, 

in the south =~ central section of the county. Ridgeland 

Elementary is located in Ridgeland, a town adjacent to Madison. 

Velma Jackson, Luther Branson and Farmhaven are located 

in the eastern section of the county. The location of each 

[3 

these schools is shown on the attached map. During £ 2 the 

1968-69 school year, the student enrollment of each school 

was as follows: 

School Grades h | mm 2 | 

Ia, Ahiitt :. Ad EE Re EAH 

  

Velma Jackson -12 

Luther Branson 

Farmhaven 

1-1 

1-8 

1-8 
Fast Flora 1-12 

1-1 

1-1 

1-6 
1-1 

4] 

Rosa Scott 

Madison=Ridgeland 
Ridgeland Elem, 

Flora 

- 

2. On November 7, 1969, pursuant to the Supreme 

Court's decision in Alexander v. Holmes Sonny Board of 
    

    
  

Education, 396 U.S. 19 (1969), the United States Court of 
  

Appeals for the Fifth Circuit ordered the Madison County 

School District to implement, no later than December 31, 

1969, a desegregation plan submitted by the Office of 

Z 0 964 964 
2 

2 376 2 378 

Education of the Department of Health, Education and Welfare 

except that subsections 4 through 8 of the plan for 1969-70 

bogpl, 

 



  

“ - . A igh wy for ap Cy A . ee 2 ey Fe Fw po a - . TT Pre 3 TT Ras al 

1NVOo vir 1g SiLuact \Coassignment in zones 1 I ona 111 were 

“ A Sa XY Dirty wal vero RAR EC le yin Tbh Td 
eliminated and in its place sections A.2 and A.3 of the 

school district's plan covering these same zones were 

¢ 

ls i BAe a ET %] Bs BE Wr SE. Se 
3 . In zone 11 s Si 1 students were ass 1gned CO 

either the formerly white Ridgeland Elementary (grades 1-6) 

a er, SEE TA BL SE lly, SLR © Far ligts “ a mle = 
and the Madison-Ridgeland High (grades 1-12) or the formerly 

Negro Rosa Scott (grades 1-12) based upon sub-zones wi 

this main zone, Similarly, students in zone 11] were assigned 

to either the formerly white Flora (grades 1-12) or the form- 

erly Negro East Flora (grades 1-12). The projected enrollment 

for these two zones and the actual enrollment during the second 

semester are as follows: 

School Projected Enrollment 
BE =a aa aaa a 

W N ¥ oF 
oan wr p— 

Zone II 

Ridgeland Elementary (1-6) 253 109 
Madison~-Ridgeland (1-12) 301 180 * 401 
Rosa Scott 1-12) 256 6638 

Zone 111 

Flora {18 2) 235 181 416 
East Flora (1-12) 141 619 760 

Actual Enrollment, Second Semester 

: (1969-70) 5 
{ School Elementary Secondary 

Grades Grades Total 
Se E——— a EE TAT a ae A i LS 

Zone II W N W N W N T 

  

Ridgeland (1-6) 295... 37 - - 205 37 5333 
Madison-Ridgeland 

(1-12) 8. W13 227 120 263 ..235 i508 
g5082 Scott. (1-12) 4. 382 25 30% 3% 703 735 

Zone ITT 

5..:7327 50 477 
3 0 740 740 

Flora (1-12) 157. 1153:=170 35 
East Flora (1-12) 0. 4 8 

 



  

& AS Tne above enrollment Licures Lhglicace, ne 

J 

plan of student assignment presently in operation in the J 

1 

Madison County School District has proved ineffective in 

(] eliminating the racial identity of the schools within 

system, After implementation of this plan during the 

second semester 1969-70, East Flora in zone III remained 

all Negro and Rosa Scott in zone II was attended primarily 

by Negro students. Ridgeland Elementary in zone II and 

the high school grades at Flora in zone III remained 

predominantly white. 

5. The original plan for zones II and ILI of Madison 

* 

County was prepared by the Office of Education of the U.S. 

Department of Health Education and Welfare. The projected 

the schools in zones I student enrollments for Land III [1 

under this plan are as follows: 

Prva 
zone 11 W N T 

Ridgeland Elem, (1-6) 253 109 362 
Rosa Scott Elem, (1-6) 179 L475 654 
Rosa Scott Jr. High (7-8) lol 15 289 
Madison-Ridgeland (9-12) 209 257 L6G 

on 

Zone ITI 

East Flora (1-7) 251 592 842 
Flora H.35. (8-12) 125 210 335 

This plan paired the East Flora and Flora schools 

in zone III. In zone 1I the H.EZ.W. plan paired the Rosa 

Scott and Madison~Ridgeland schools. The zone for Ridgeland Oo SS 

‘Elementary was identical with the school board's plan. 

ry he 

 



  

1A 3 3 TT CY I~, - fu om EY 
Rearli 12 gare an d ro 2 Liciiil. 

necessary and proper relief, 

  

ates ALtorney 

& 

¥ dui-fova Tl J ws 5% Feryy yr fd go Respectfully submitted 

Assistant Attorney General 

im i | g 

Lor. A aad Ain EE 

BRIAN K, 
Attorney 

Department of Justice 

   ANNDCRITD G 
NLIO DIA 

  

py i "sb ) 

’ Fi 
1 ® 3 - a tar ait 

/ 
  

a i ret BS EA A A A AAT CA mm 

C.J. CALNAN 
BEN L. KRAGE 
Attorneys 

Department of Justice 

Washington, D. C, 

     



  

  

/lapisoN Counry 

    

  

\ EAST Flora 
Hou Schoot       KEARNEY, 

\ PARK £orl),   

  

   

   

1)
! CANTON MUN. SER SCHobL DisTerer 

Tewwors Cepear CL) 
/ 

> 

/   
  

/ 
i 

ZONE i 

MAD Ison / 

Kesa Scorr 
Hien Street 

Civee Lamp 

  

  

CAMDEN 

IT 

    
    

@ YWELHA TACkson 
Hien SeHooL 

ZONE 1 

Luther BRANSON ELEM. SCHOO fpr" 

FARM HAVEN El 

  

EMER, a 

(CLOSED) 

   
   

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1h Ok SER Vv] i Ck 

  

3 :s 1 - hn «Ly ~ : mn 
I hereby certify that I have this day served 

J 

a on ££ ~ yr 1 v ~y Pu $~ 

copies Or the roregoing App Licalion Loi nn Order tO 

parties, by mailing same, postage 

prepaid, to the following counsel of record: 

L.. Goza 

Montgomery 

  

  

FEO a 
Department of Justice