Answer and Cross-Motion in Opposition to Motion for Implementation of Desegregation Plan, with Modifications

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UNITED STATES DISTRICT COURT 
FOR THE EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION

RONALD BRADLEY, et al.,

Plaintiffs,
i V S  .

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WILLIAM G. MILLIKEN, et al,

Defendants.

CIVIL ACTION

No. 35257

n.1 i J1(li
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DETROIT BOARD’S ANSWER AND CROSS-MOTION 
IN OPPOSITION TO MOTION FOR IMMEDIATE 
IMPLEMENTATION OF PLAINTIFFS' 
DESEGREGATION PLAN, WITH APPROPRIATE 
UPDATING MODIFICATIONS

NOW COMES THE BOARD OF EDUCATION of THE SCHOOL DISTRICT
OF THE CITY OF DETROIT and other Detroit Board defendants, by

’and through their attorneys, RILEY AND ROUMELL and George T.t j
Roumell, Jr. andrespectfully oppose the implementation of

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plaintiffs’ motion in support thereof, and by way of answer

thereto, respectfully petitions this Honorable Court for a hear-
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i s .ing to determine what plan, including any heretofore unformulatedEt!ior unpresented plans for the effective desegregation of the
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Detroit school system, should be approved and adopted by the Court, 

In support of this answer defendant shows unto the
Court as follows:

1. Plaintiffs correctly stated that in the July 25, 1974
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opinion and judgment, the Supreme Court of the United States
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remanded the case "for further proceedings consistent with thisi |
opinion leading to prompt formulation of a decree directed to 
eliminating the segregation found to exist in Detroit City
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schools..." Milliken v. Bradley, 41 L. Ed. 2d 1069 at 1096 (1974)

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2. The Supreme Court of the United States did not, in 

; Milliken v. Bradley, set aside the Finding of Facts as to the 
Detroit-only plans of desegregation entered by the late Honorable 

Stephen J. Roth, United States District Judge for the Eastern 

District of Michigan on March 28, 1972.



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3. The late Honorable Stephen J. Roth found and determined 
that the school desegregation plans of the Detroit Board and the 

'presently re-proposed plan of the plaintiffs were ineffective in
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remedying the segregated conditions by stating; "in summary, we 
; find that none of the three plans would result in the desegrega-! i .

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tion of the public schools of the Detroit School District."
[Findings of fact on Detroit-only plans of Desegregation,

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''March 23, 1972 at p . 4. ]

4. That in the time since the aforementioned finding ofnj>1| facts, the racial composition of the School District for the City
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Hof Detroit has changed, bringing forth new facts that bear upon
ii .■the issue of desegregation.i|

5. For these reasons this. Honorable Court should have theH ■ . . .
iibenefit of an update on all relevant facts for a plan of:; 
i ! desegregation for the School District for the City of Detroit,
i and should allow the Board of Education for the School District
Iiof the City of Detroit the opportunity to provide its expertise
|i■ Iin the presentation of an advisable plan for the desegregationii
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j!of said district under the current state of the facts.
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WHEREFORE, for the foregoing reasons, defendant
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■Detroit Board prays that the motion of the plaintiffs be denied,
ii< j and in the alternative, a hearing be noticed for the purposeHi;of developing the record as to the current relevant facts, and
uan opportunity be granted to the Detroit Board to present a plan
jjjj or plans consistent with the remand instructions of the SupremeIj!Court of the United States and the previous finding of facts by\ \ . •j! - . ■this Honorable Court.jj

Respectfully submitted,if ' _ .
RILEY & ROUMELL

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George T.^Roumell, JX*. s  f  
Attorneys for Board of Educati9*r 
of the School District of the 
City of Detroit 
7th Floor Ford Building 
Detroit, Michigan 48226 
Telephone: 962-8255

Dated: September 27, 1974