Carter v. School Board of Arlington County, Virginia Appendix on Behalf of Appellants

    APPENDIX ON BEHALF OF APPELLANTS

UNITED STATES COURT OF APPEALS
FO R T H E FO U RTH  CIRCUIT,

No, 6064.

CONSTANCE CARTER, an infant, by her Parent 
and Next Friend, ELEANOR TAYLOR, et al„ 

Appellants,

versus

THE SCHOOL BOARD OF ARLINGTON COUNTY, 
VIRGINIA, a body corporate, and FLETCH ER 
KEMP, Superintendent of Schools of Arlington 

County, Virginia, et al.,
Appellees.

A p p e a l  f r o m  th e  D is t r ic t  C ourt o f  th e  Un ited  
St a t e s  fo r  th e  E a stern  D ist r ic t  o f  V irg in ia , 

Alexandria  D iv isio n .

H il l , M artin  & R obinson , 
623 North Third Street, 
Richmond 19, Virginia. 
L eon  A. R ansom  
1939 13th Street, 
Washington, D. C.

Counsel for Appellants

Lawyers Publishing Co. ,  Inc.—Richmond, Va.



INDEX TO APPENDIX
Page

Amended Complaint .....................................................................  1
Petition for Intervention ............................................................. 12
Extracts for Testimony ............................................................. 17

Eleanor Taylor ..........................................................................  17
J. Ruppert Picott ...................................................................  23
Martin D. Jenkins ................................................................ 78
Edward B. Henderson.................................................................  150
Ellis O. Knox ..........................................................................  157
Julius Brevard ..........................................................................  207
Peggy Council ..........................................................................  211
Charles J. Walsh .....................................................................  223
Stephen McClelland Sydnor ...............................................  234
William A. Early ....................................................................  241
Howard A. Dawson ...............................................................  246
Elizabeth Pfohl Campbell 269
William A. Early (Recalled) .............................................  271
Allen C. Brodnax .....................................................................  275
William A. Early (Recalled) ...............................................  276
Peggy Council (Recalled) .................................................... 277
C. N. Bennett ............................................................................  283
Simon L, Alsop ..........................................................................  288
William H. Barnes ...................................................................  297
J. Ruppert Picott (Recalled) ...............................................  310
Martin D. Jenkins (Recalled) 314
Ellis O. Knox (Recalled) ......................................................  323
R. Worth Peters ........................................................................ 328

Excerpts from “A Report On a Comparison of the Wash­
ington-Lee and Hoffman-Boston High Schools, Arlington 
County, Virginia,” by Howard A. Dawson 331

Table XXX — Number & Titles of Books Under 
Each Classification in Libraries of 
Washington-Lee and Hoffman-Bos­
ton Schools, Arlington County, Vir­
ginia ........................................................  332



INDEX (Continued)
Page

Table XXXVII — Courses a Student Has An Opportun­
ity to Take In a Three-Year Cycle, 
Washington-Lee and Hoffman-Bos- 
ton Senior High Schools, Arlington 
County, Virginia .........................  333-334

Table XXXIX — Club and Activity Programs in Wash­
ington-Lee anl Hoffman-Boston Sen­
ior High Schools, Arlington County, 
Virginia, 1948-49 ..................................  335

Table XXXX — Summer Programs of Instruction, 
Washington-Lee and Hoffman-Bos­
ton Senior High Schools, Arlington 
County, Virginia, 1948-49   336

Appendix H — List of Subjects Taught By Grades 
and Number of Pupils Enrolled in 
Each Subject, Washington-Lee and 
Hoffman-Boston Senior High Schools, 
Arlington County, Virginia, 1948- 
49   337-339

Excerpt from Plaintiff’s Exhibit 94 — “Report of Principal,
June 10, 1949”   340

Excerpt from Plaintiff’s Exhibit’s 99 — “A Comprehensive 
Program of Education for Virginia’s Public Schools” .... 340

Opinion of the Court .....................................................................  343

Final Decree 364



UNITED STATES COURT OF APPEALS
FO R TH E FO U RTH  CIRCUIT.

No. 8064.

CONSTANCE CARTER, an infant, by her Parent 
and Next Friend, ELEANOR TAYLOR, et a l, 

Appellants,

versus

THE SCHOOL BOARD OF ARLINGTON COUNTY, 
VIRGINIA, a body corporate, and FLETCH ER 
KEMP, Superintendent of Schools of Arlington 

County, Virginia, et al.,
Appellees.

A p p e a l  fr o m  th e  D ist r ic t  C ourt o f  th e  U n ited  
Sta t es  fo r  t h e  E a stern  D is t r ic t  o f  V irgin ia , 

Alexan dria  D iv isio n .

APPENDIX ON BEHALF OF APPELLANT

AMENDED COMPLAINT FOR A MANDATORY 
INJUNCTION AND FOR A DECLARATORY 

JUDGMENT

(R. pp. 15-22)

1. The jurisdiction of this Court is invoked under 
Judicial Code, section 24 (1) (28 U. S. C. section 
4 1 (1 )) , this being a suit in equity which arises under



[ 2 ]

the Constitution and/or laws of the United States, 
viz., the Fourteenth Amendment to said Constitution, 
andy'or Sections 41 and 43 of Title 8 of the United 
States Code, wherein the matter in controversy ex­
ceeds, exclusive of interest and costs, the sum of 
$300.00. The jurisdiction of this Court is also invoked 
under Judicial Code, section 24 (14), (28 U. S. C., 
section 4 1 (1 4 )) this being a suit in equity authorized 
by law to be brought to redress the deprivation, under 
color of law, statute, regulation, custom and usage 
of a State, of rights, privileges and immunities secured 
by the Constitution of the United States, viz., the Four­
teenth Amendment to said Constitution, and of rights 
secured by laws of the United States providing for 
equal rights of citizens of the United States and of 
all persons within the jurisdiction of the United States, 
viz., sections 41 and 43 of Title 8 of the United States 
Code.

2. Plaintiff shows further that this is a proceeding 
for a declaratory judgment and an injunction under 
Section 274d of the Judicial Code (28 U. S. C., sec. 
400) for the purpose of determining a question in actual 
controversy between the parties, to-wit, the question 
of whether the practice of the defendants, in adopt­
ing, enforcing and maintaining the policy, custom 
and usage by which plaintiff and other Negro children 
of high school age in Arlington County, Virginia, are 
denied and deprived of the same or equal educational 
facilities, courses and curricula in the public high 
schools of Arlington County, Virginia which are fur­
nished and provided for white school children of Ar­
lington County possessing the same qualifications and 
experience, solely on account of their race and color



[ 3 ]

is unconstitutional and void, being a violation of the 
Fourteenth Amendment to the Constitution of the 
United States and of the laws of the United States and 
of the Constitution and Laws of the Commonwealth of 
Virginia, all of which will appear more fully herein­
after.

3. All parties to this action, both plaintiff and de­
fendant, are citizens of the United States and of the 
State of Virginia, and are resident in and domiciled 
in said State. Defendant School Board of Arlington 
County at all times mentioned herein was and is by­
law declared to be a body corporate and is an agency 
of the State of Virginia.

4. Plaintiff, Constance Carter, and her Mother and 
Next Friend, Eleanor Taylor, are colored, persons of 
African descent and of the Negro race and blood. They 
are taxpayers of the County of Arlington and of the 
State of Virginia. Plaintiff is an infant of school age, 
required by the laws of the State of Virginia to at­
tend the public schools of the County of Arlington. 
Having completed, in June, 1947 the requirements for 
Junior High School Education established by the de­
fendants, plaintiff is now eligible for and required 
by law to enter the Senior High School Division of 
the public school system of Arlington County, Vir­
ginia. This suit is brought on her own behalf and 
also on behalf of more than three hundred other per­
sons, namely students in the colored schools of Ar­
lington County, Virginia, similarly situated and affect­
ed, as will hereinafter more fully appear, and who 
are too numerous to be brought into this court.

5. Defendant School Board of the County of Ar­
lington exists pursuant to the laws of Virginia as an



[ 4 ]

administrative department of the State of Virginia 
discharging governmental functions ( Constitution of 
Virginia, Article IX, Section 133; Chapter 33, Sec­
tions 653, 653al, Michie’s Code of Virginia, 1942, as 
amended). Defendant Fletcher Kemp is Superinten­
dent of Schools of Arlington County, Virginia and 
holds office pursuant to the Constitution and laws of 
Virginia as an administrative officer of the public free 
school system of Virginia (Constitution of Virginia, 
Article IX, Section 133; Chapter 33, Sections 611, 611a, 
Michie’s Code of Virginia, 1942, as amended). Defend­
ant Fletcher Kemp is made a defendant herein and is 
sued in his official capacity.

6. The State of Virginia has declared public ed­
ucation a State function. The Constitution of Virgin­
ia, Article IX, Section 129, provides:

“Free schools to be maintained.---- The general
assembly shall establish and maintain an efficient 
system of public free schools throughout the State.”

Pursuant to this mandate the General Assembly of 
Virginia has established a system of free public schools 
in the State of Virginia according to a plan set out in 
Chapters 33 and 35, Michie’s Code of Virginia, 1942 
as amended, Provision has been made for the establish­
ment of separate schools for white and colored per­
sons with the positive duty of maintaining these sep­
arate and segregated schools under the same general 
regulations as to management, usefulness and efficiency 
(Section 680, Michie’s Code of Virginia, 1942, as a- 
mended). The. establishment, maintance and adminis­
tration of the public schools of Virginia and of the 
public school system of said state is vested in a



[ 5 ]

State Board of Education, a Superintendant of Public 
Instruction, division superintendents of schools and 
county and city school boards (Constitution of Virgin­
ia, Article IX, Sections 131-183; Section 611, 611a, 
Michie’s Code of Virginia, 1942, as amended).

7. By virtue of Chapter 33, Section 682, Michie’s 
Code of Virginia, 1942, as amended, all children be­
tween the ages of seven and twenty are entitled to a 
free education at the public expense; between the ages 
of seven, and the the end of the fifteenth year all such 
children, by virtue of the provisions of Chapter 33, Sec­
tion 683, Michie’s Code of Virginia, 1942, as amended, 
are compelled to attend the public free schools. The 
duty of enforcing this system is imposed upon the 
several county and city school boards, including the 
defendant School Board of Arlington County (Chapter 
33, Section 660, Michie’s Code of Virginia, 1942, as 
amended). Negro and white children alike must meet 
these requirements and are entitled to the same pri­
vileges therein (Chapter 33, Section 680, Michies Code 
of Virginia, 1942, as amended).

8. The public schools of the County of Arlington, 
Virginia, including the Hoffman-Boston Senior High 
School (for Negro pupils) and the Washington-Lee Sen­
ior High School (for white pupils) in the City of Arling­
ton, Virginia, are under the direct control and super­
vision of the defendants acting as an administrative 
department or division of the Commonwealth of Vir­
ginia (Virginia School Code, Chapter 33, Sections 653, 
653al, 672, Michie’s Code of Virginia, 1942, as amend­
ed ); the defendants are under a duty to maintain an effi­
cient and equal system of public schools in the County 
of Arlington for the white and Negro pupils of said



[ 6 ]

county (Michie’s Code of Virginia, 1942, as amended, 
Chapter 33, Sections 611, 680); and to enforce the 
school laws of the Commonwealth of Virginia ( Michie’s 
Code of Virginia, 1942, as amended, Chapter 33, Sec­
tion 660). Defendants are under a duty to provide the 
same or equal facilities, equipment, courses of instruc­
tion, curricula and efficiency of instruction in the schools 
maintained for Negoes as those maintained for white 
residents of the county (Chapter 33, Section 680, 
Michie’s Code of Virginia, 1942, as amended).

9. Defendants over a long period of years have con­
sistently pursued and maintained and are now pursuing 
and maintaining the policy, custom and usage of pro­
viding for white pupils of the Senior High Schools of 
Arlington County, Virginia, courses of instruction, cur­
ricula, facilities for educational and recreational instruc­
tion, materials and supplies for such instruction and 
other educational opportunities which are denied to 
the Negro Senior High School pupils of Arlington 
County, Virginia, solely on account of their race and 
color, all of which practice, custom and usage is dis­
criminatory and contrary to the laws and Constitution 
of the United States and of the State of Virginia.

10. Plaintiff has completed, as of June, 1947, all of 
the requirements for a Junior High School education 
prescribed by the defendants. As a result thereof, she 
is entitled to a free education in the Senior High 
Schools of Arlington County, Virginia for the courses 
prescribed and offered therein. On to-wit, the 4th day 
of September, 1947, that being an official registra­
tion date for pupils in the said public schools of Ar­
lington County, Virginia, plaintiff presented herself 
to the Hoffman-Boston Senior High School (for Negro



[ 7 ]

pupils) in Arlington County, Virginia, and requested 
enrollment therein and registration for the courses in 
Spanish, Civics III, Typewriting and Physical Educa­
tion as elective courses, in addition to the required 
courses provided by said school under the curriculum 
estabished by state law for all pupils in said public 
school system. Plaintiff was advised and informed, 
and therefor believes and avers, by the principal of 
said school, that no course in Spanish or Civics III 
was offered by said PIoffman-Boston School, and that 
no course in Typewriting could be offered plaintiff at 
the present time because, while there were machines 
available, there were no tables or desks upon which 
thy could be operated, and that there were no facilities 
of any kind available for the course in Physical Ed­
ucation.

11. Being advised and informed, and therefor be­
lieving, that said courses desired and requested by 
plaintiff were being offered at the Washington-Lee 
Senior High School (for whites) in said Arlington 
County, Plaintiff presented herself to said Washington 
Lee High School on the same date to-wit, September 
4, 1947, and requested admission therein for the same 
courses as aforesaid; plaintiff was informed and ad­
vised, and therefor avers, that said courses of instruc­
tion are now offered to the pupils of said Washington- 
Lee High School; that typewriters and typing tables 
or desks are furnished and provided at the county 
and state expense to the pupils thereof by the defend­
ants herein and that adequate facilities for instruction 
in Physical Education, including athletic fields, gym­
nasium and equipment are likewise provided for the 
pupils in said school; nevertheless plaintiff was denied



[83

and refused admission to and registration in the courses 
solely on the ground and for the reason that she is 
a person of colored blood, of African descent and of 
Negro race and blood, and that said Washington-Lee 
High School is maintained only for persons of the 
white race and blood.

12. The curricula and facilities provided at Hoffman- 
Boston and Washington-Lee Senior High Schools for 
pupils possessing the same qualifications and having 
attained the same degree of educational proficiency 
are based solely on the race or color of the pupil and 
amount to an unlawful discrimination which consti­
tutes a denial of due process of law and equal pro­
tection of the laws guaranteed by the Fourteenth 
Amendment to the Constitution of the United States, 
and is therefore unconstitutional and void.

13. In enforcing and maintaining the policy, reg­
ulation, custom and usage by which plaintiff and other 
Negro pupils in the public schools of Arlington County, 
Virginia, are offered less and inferior courses of ed- 
ueation, and denied the privilege of taking certain 
courses that are offered to white pupils of the county 
having the same qualifications and educational back­
ground and experience, solely on account of their race 
and color, defendants, as administrative officers of the 
Commonwealth of Virginia, have violated and are con­
tinuing to violate the equal protection of the law and due 
process clauses of the Fourteenth Amendment to the 
Constitution of the United States and Section 41 and 43 
of Title 8 of the United States Code. To the extent 
that defendants in enforcing said discriminatory system 
are acting under color of statute, regulation, policy, 
custom or usage, said statute, regulation, policy, cus­



19 j

tom or usage is void and unconstitutional, and to the 
extent that defendants may be acting without benefit 
of statute, regulation, policy, custom or usage, their 
acts are nevertheless acts of the State, similarly void 
and unconstitutional.

14. Plaintiff, Constance Carter, her Mother and Next 
Friend, and those on whose behalf she sues, being 
similarly situated, are citizens and residents of the 
Commonwealth of Virginia and contribute directly and 
indirectly to the creation of the common public 
school fund of the County of Arlington and the 
Commonwealth of Virginia, which said fund is de­
voted to the maintainance of the public schools 
of Virginia (Constitution of Virginia, Article IX, Sec­
tions 135, 136; Chapter 33, Sections 657, 698a, 699, 
Michie’s Code of Virginia, 1942, as amended). Under 
the Constitution of Virginia said public school fund 
is to be administered for the equal benefit of all the 
people of the state (Constitution of Virginia, Article 
IX, Section 135).

15. By virtue of the discriminatory practice, custom 
and usage of the defendants regarding the educational 
facilities and courses offered to plaintiff and those simar- 
ly situated hereinbefore set forth in Paragraphs 10,11, 
and 12, the plaintiff is denied an equal and proportion­
ate participation in the benefit derived from that portion 
of the taxes paid by her and her parent and next friend 
and devoted to the public school fund; she is denied said 
equal and proportionate benefit and participation solely 
on account of her race and color, contrary to the pro­
visions of the Fourteenth Amendment to the Constitu­
tion of the United States and thereby suffers and sus­
tains special and particular damage from the discrim-



[ io  j

iiiatlon practiced against her in the distribution of the 
fund which her taxes help to create; and she is with­
out remedy save this Honorable Court issue its writ 
of injunction restraining the defendants from expend­
ing, on an unconstitutional basis, and according to 
the discriminatory and unconstitutional practices and 
usages hereinbefore set forth, the public school funds 
to which plaintiff contributes and which is used for 
the maintenance of the public school, by which special 
courses of instruction, privileges of education and ed­
ucational facilities are furnished to the white pupils 
of Arlington County and are denied to plaintiff and 
those on whose behalf she sues.

16. Plaintiff and those similarly situated and affected 
on whose behalf she brings this action are suffering 
irreparable injury and are threatened with irreparable 
injury in the future by reason of the acts herein com­
plained of. They have no plain adequate or complete 
remedy to redress the wrongs and illegal acts herein 
complained of other than this suit for a declaration of 
rights and an injunction. Any other right or remedy 
to which plaintiff and those on whose behalf she sues, 
who are similarly situated, could be remitted would 
be attended by such uncertainties and delays as to 
deny substantial relief, would involve a multiplicity 
of suits, cause further irreparable injury, and occasion 
damage, vexation and inconvenience not only to the 
plaintiff and those similarly situated, but to defend­
ants and governmental agencies.

17. There is between the parties hereto an actual 
controversy as hereinbefore set forth.J

W HEREFORE, THE PREMISES CONSIDERED, 
Plaintiff respectfully prays:



[ 1 1 ]

1. That the process of this Court may issue to the 
Defendants herein requiring them and each of them 
to answer the exigencies of this complaint.

2. That upon the filing of this complaint, as may 
appear proper and convenient to this Court, the Court 
advance this causes upon the docket and order a speedy 
hearing of this action according to law, and that upon 
such hearing:

a. That this Court adjudge and decree and de­
clare the rights and legal relations of the parties to 
the subject matter here in controversy, in order 
that such declaration shall have the force and 
effect of a final judgment or decree.
b. That this Court enter a judgment or decree 
declaring that the policy, custom or usage of the 
defendants in adopting, enforcing or maintaining 
a system of education, offering courses of instruc­
tion and affording facilities for educational pur­
poses to Plaintiff and other Negro pupils similarly 
situated differing from and inferior to those pro­
vided for and offered to white pupils of Arlington 
County, solely on account of their race and color, 
is a denial of the equal protection of the laws 
guaranteed by the Fourteenth Amendment to the 
Constitution of the United States and is therefore 
unconstitutional and void.
c. That this Court issue a permanent mandatory 
injunction restraining the defendants, and each of 
them, from making any distinction or difference in 
the type of instruction, number of courses offered, 
methods of instruction, facilities provided for in­
struction, or in any other manner or wise afford­
ing Plaintiff and those on whose behalf she brings



[ 1 2 ]

this action educational opportunities differing from 
those offered to and afforded white senior high 
school pupils of Arlington County, solely on ac­
count of their race and color: or, in the alternative, 
this Court issue a permanent injunction restraining 
the defendents, and each of them from denying 
Plaintiff and those on whose behalf she sues ad­
mission to and enrollment in the Washington-Lee 
High School.

3. Plaintiff further prays that this Court will allow 
her costs herein and for such other and further relief 
as may to the Court seem just and proper in the pre­
mises.

ft ft ft ft ft

PETITION FOR INTERVENTION

(R. pp. 1272 1275)

1. Petitioners, Julius Brevard and Peggy Council, 
both infants, suing herein through their respective par­
ents and next friends, Julius Brevard and William 
Council, say they reside respectfully at 2900 20th 
Street South Arlington, Virginia and 3458 22nd Street 
South Arlington, Virginia; that they are Negroes, de­
scendants of the African race; that they are citizens 
and residents of the State of Virginia and of the 
United States; that they are registered and enrolled 
students of the Hoffman-Boston High School of Ar­
lington, Viringia; that they are members of the class on 
whose behalf the original claimant filed this suit; that 
they are entitled to the benefit of any decree or order 
passed herein; and that they are within the original 
jurisdiction of this court in this cause.



[ 1 3 ]

2. That they adopt the original complaint in this 
cause, as amended, and all of the prior pleadings here­
in, as fully and completely as if herein copied again; 
that they waive all notices, summons and other formal 
requirements as to their participation in this cause; 
that they adopt and are bound by all prior proceed­
ings herein, including the taking of testimony, as fully 
and completely as if they had been original complaints; 
and that they join in the prayers of the original com­
plaint except as they may be modified by the additional 
prayers in this, their petition for intervention.

8. That they have a common interest with the orig­
inal complaint herein since the filing of the orginal 
complaint herein facts have occured which materially 
affect the rights of the intervenors and which should 
be brought to the attention of this court, as wall more 
fully hereinafter appear.

4. That on September 6, 1949 the Intervenor, Julius 
Brevard was accepted and enrolled as a duly accredited 
student in the Hoffman-Boston High School at Arling­
ton, Virginia, said school being one operated and main­
tained by the defendants for the education of Negro 
youth in Arlington County, Virginia; that the said In­
tervenor applied to and asked from the proper officials 
in charge of said school, being the agents of the de­
fendants herein, for instruction in a course known as 
“Auto-mechanics”; that said course is regularly given 
and announced as a course for credit in the Washington- 
Lee High School, a school maintained and operated 
by the defendants herein for the instruction of white 
youth in Arlington County, Virginia; that the Inter­
venor was informed, and believes, and therefore avers 
that no such course was available or given in the Hoff­
man-Boston School for Negroes; that he could not be



[ 1 4 ]

granted admission to such course in Washington-Lee 
High School inasmuch as that school could accept 
only white pupils, that no such course of instruction 
was available to him in Arlington County, Virginia, 
because he was a Negro; and that, by reason of such 
denial and refusal he has been and is being deprived 
of a right to an education of his own choice solely 
on account of his race and color, all in violation of 
the laws and Constitutions of the State of Virginia and 
of the United States.

5. That on September 6, 1949, the Intervenor, 
Peggy Council was accepted and enrolled as a duly 
accredited student in the Hoffman-Boston High School 
at Arlington, Virginia, said school being one operated 
and maintained by the defendants for the education 
of Negro youth in Arlington County, Virginia; that 
the Intervenor, on said day, applied to and asked 
from the proper officials in charge of said school, they 
being the agents of the defendants herein, for instruc­
tion in a course in “Latin”, for a course in Chemistry 
and for a course in “Shorthand Reporting”; that the 
courses in Latin and Chemistry were required courses 
for her further education in a School of Nursing, which 
she desires to attend in order to accomplish her aim and 
purpose in life, that of being a nurse; that she was advis­
ed by the agents of the defendants that there was no 
course in “Latin” offered in the Hoffman-Boston High 
School; although such course is now, and always has 
been offered regularly at the Washington-Lee High 
School, a school maintained and operated by the defend­
ants for the instruction and education of the white youth 
of Arlington County, Virginia; that she was advised 
that there was and would not be offered any course 
of instruction in Latin to her in Arlington County, Vir­



[ 1 5 ]

ginia, during the current semester of the school year; 
that she could not attend the Latin classes in Wash­
ington-Lee High School, because of the fact that she 
is a Negro and said school is maintained solely for the 
instruction of white pupils; that she was informed 
that there was no class in Chemistry at Hoffman-Bos- 
ton High School for the current semester of the school 
year; that there is a class in Chemistry at Washington- 
Lee High School for the present and current semester 
of the school year; that she was informed, and be­
lieves, and therefore avers, that she could not attend 
said class in Chemistry at Washington-Lee High School 
because of the fact that she was a Negro and that 
she was a Negro and that said Washington-Lee High 
School was maintained and operated by the defendants 
for white youth only; and that she was further informed 
that she could not and would not receive instruction in 
Shorthand Reporting for the current school semester 
for the reason that there was no such course of instruc­
tion provided for in the curriculum of the Hoffman- 
Boston High School, although there was similar in­
struction then and now being given at Washington- 
Lee High School; that she, being a Negro, was not 
eligible for admission to such instruction at Washing­
ton-Lee High School, then and now being maintained 
and operated by the defendants herein solely for the 
education of white pupils of Arlington County, Vir­
ginia; and that she has been and is now being de­
prived of and denied the right to an equal education 
by the defendants herein solely because of her race 
and color, all in violation of the laws and Constitu­
tions of the State of Virginia and of the United States.

W HEREFORE, THE PREMISES CONSIDERED, 
the Intervenors, and each of them, pray:



[ 1 6 ]

1. That all of the prayers of the original complaint 
herein be granted.

2. That this, their petition in intervention, be con­
sidered as a part of the original complaint herein and 
be treated and considered as though filed at the same 
time and against the original parties defendant.

3. That the relief prayed for by the orignal com­
plainant, in entirety, be extended to the advantage 
and relief of these intervenors and all others similarly 
situated.

4. That the Court issue its declaratory judgment in 
this case, in favor of the Intervenors, Julius Brevard 
and Peggy Council, and all others similarly situated, 
to the same extent and within the same limitations, 
as it may issue in the case of the original complainant 
herein.

5. That the Court may order and decree that the 
defendants be required to furnish the said Intervenors, 
and each of them, the same and identical type of 
instruction prayed for, and offered to the white stu­
dents of Arlington County, Virginia, in Arlington County 
Virginia at Hoffman-Boston High School; and that, 
in the alternative, the Intervenors be enrolled and reg­
istered in the Washington-Lee High School in Arling­
ton County, Virginia for the courses desired and re­
quested by them and each of them for the current 
school year and semester thereof.

6. And for such other and further relief as may to 
the Court seem just and proper in the premises, includ­
ing all relief originally prayed for by the original 
complaint herein.

# # # #



[ 1 7 ]

EXTRACTS FROM TESTIMONY 

ELEANOR TAYLOR 

D ir e c t  E xam ination  

(R. p. 252) By Mr. R a n so m :

Q. State your name and address.
(R. p. 253) A. My name is Eleanor Taylor, ad­

dress 3425 South 22nd Street, Arlington.
Q. That is Arlington, Virginia.
A. Arlington, Virginia.
Q. Are you the mother of Constance Carter?
A. I am.
Q. Who is the plaintiff in this case?
A. Yes, I am.

# # * * #

Q. At the time that this suit was brought were 
you then a resident of Arlington County, Virginia?

A. Yes, I was.
Q. And still are?
A. Yes.
Q. Is your daughter in school at the present time? 
A. Not today.
Q. I mean she is still attending school?
A. Yes.
.Q Where has she attended school, Mrs. Taylor? 
A. Before she was in Dunbar High School and then 

finished up the term in Hoffman-Boston.
Q. Where is Dunbar High School?
A. First and O Streets, Northwest, Washington.
Q. Did she attend any other school in Washing­

ton?
(R. p. 254) A. Francis Junior High School.



[ 1 8 ]

# #

Q. Why did she go to Francis Junior High School 
in Washington and Dunbar High School in Washing­
ton rather than attend the high schools in Arlington?

A. They have better facilities for you there. They 
don’t have a junior high school in Arlington that I 
know of.

Q. Do you know whether or not she tried to get 
some courses at Hoffman-Boston which were not avail­
able to her?

A. Yes, she did. She tried and didn’t get them.
Q. And they were not avaiable in that school?
A. Not available at that time.

# # # # *

Q. Pay no attention to that. Mrs. Taylor, during 
the time that your daughter was attending the schools 
in Washington were you billed for tuition for her?

(R. p. 255) A. Yes, I was.
Q. Have you paid any tuition for her?
A. I paid tuition in ‘46 and ‘47 and one in ‘49.

& # # & $

Q. This is a letter addresed to you by the Director 
of Finance of the Public Schools of the District of Co­
lumbia. Do you remember receiving such letter?

A. Yes, I do.
Q. In which it points out that on December 3, 

1946, you paid $26.40 for your child’s tuition?
A. That is right.
Q. And on January 29, 1947, you paid $16.72?
A. I did.
Q. And that there was $38.59 paid by Arlington



[ 1 9 ]

County for her and subsequently $28.29? Is that cor­
rect?

(R. p. 256) A. Yes.
# # # # #

Q. As of June of this year were you billed by the 
District for a balance of $106.00?

A. That is right.
Q. For tuition paid by you for the education of 

your child in Washington? Is that correct?
A. Yes.

# # # # *

Q. Did your daughter attend Hoffman-Boston last 
year?

A. Yes. t
(R. p. 257) Q. And expects to attend this year?
A. Yes.

C ross E xam ination  

B y M r . D ouglas:

Q. Mrs. Taylor, how old is your daughter now?
A. Seventeen.

# # # # #

(R. p. 258) Q. Your daughter complained in her 
amended bill of complaint that she made application 
at the Hoffman-Boston High School in the fall of 
1947, that is when school opened in the early autumn 
of 1947, for instruction in Spanish but that she was 
advised that that course was not offered. Where did 
you get the information on which you based that al­
legation?



[ 2 0 ]

A. That they didn’t have it?
Q. Yes.
A. They told me they didn’t have it.
Q. Who told you?
A, The principal of the school.
Q. Mr. Sydnor?
A. That is right.
O. Who asked him about that course?
A. I asked him.
Q. And you are quite certain that he told you that 

that course was not being offered that year and would 
not be offered that year?

A. He said that wasn’t offered.
Q. Do you know, as a matter of fact, whether that 

course was given at the high school?
A. At what high school?
Q. At the Hoffman-Boston High School?
A. I don’t think it was.
(R. p. 259) Q. The complaint alleges that she was 

denied the opportunity to take a course known as 
Civics 3. Who requested that she be given a course 
known as Civics 3?

A. Who gave her the request to ask for that sub­
ject? Is that what you said?

Q. Who requested information as to that subject? 
A. I did.
Q. Of whom did you request?
A. I requested it all from the Principal of the 

school.
Q. When you went there to make that request did

anyone else go with you?
A. Constance.
Q. Who else? Didn’t your attorney, Mr. Ransom,

go with you?



A. Yes, I think Mr. Ransom did. It has been so 
long, I have to think.

Q. You have plenty of time to think and we don t 
mean to crowd you. Isn’t it a fact that the conversa­
tion that was had with Mr. Sydnor was had by Mr. 
Ransom with Mr. Sydnor?

A. Partly.
Q. Are you sure that he did not make these re­

quests rather than you?
A. No.
Q. You made them yourself?
A. Yes.
(R. p. 260) Q. Do you know whether or not the 

Civics 3 was given that year in the high school?
A. They said they didn’t have it, I don’t know 

whether it was given. She didn’t get it.
Q. Did anyone tell you that that was an 11th 

grade subject and that your daughter wouldn’t be 
eligible to take it until the next to the last year of her 
high school course?

A. I don’t remember anybody telling me that.
# # # # #

Q. What conversation took place on the occasion 
that we are talking about concerning a course in type­
writing?

A. They didn’t have it. They had a few typewriters 
but no tables and — let me see what else. She just
couldn’t get it then.

(R. p. 261) Q. How do you know she couldn’t get
it then?

A. That is what he said.
Q. Who said that?
A. The principal.



[ 2 2 ]

Q. Who asked the Principal about the course in 
typewriting?

A. She did.
Q. You mean your daughter?
A. Yes.
Q. Who asked the Principal about the course in 

Civics?
A. Well, Constance and I asked these questions 

together. We went to the school to get the information 
and we simply talked about it.

* * * * *

A. How did you happen to ask about her taking 
Civic 3?

A. Because those were her desired subjects.
» * * * *

(R. p. 262) Q. What did you do after you left the 
Hoffman-Boston School on that occasion?

A. What did I do? I went to Washington and Lee 
to see if we couldn’t get the courses there.

Q. And what were you told there?
A. I was told that he didn’t have any authortiy to 

admit colored students.
Q. Where did your daughter then go to school 

in the next following school year?
A. She went on to Dunbar.
Q. Did she get the courses that she wanted at 

Dunbar?
A. Yes, she did.
Q. Did she take them?
A. Yes, she did.

* * * * *



[ 2 3 ]

(R. p. 263) A. No, I don’t think so.
<* # X* # # ■

(R. p. 265) Q. And, as you think about this matter, 
you are certain in your recollection that Mr. Sydnor, 
the Principal of the Hoffman-Boston School, told you 
that these courses about which we have been talking 
were not being offered at the Hoffman-Boston School? 
Is that correct?

(R. p, 266) A. He said she couldn’t get them right 
then.

Q. Right then?
A. Yes.
Q. When did he say she could get them?
A. He didn’t know.

# # # #

Q. Where did she attend the first half of last year? 
A. Dunbar High School.

# # # # #

(R. p. 268)

J. RUPPERT PICOTT 

D ir e c t  E xam ination

B y  M r . R o bin so n :

Q. Will you state your name?
A. J. Ruppert Picott.
O. Where do you live, Mr. Picott?
A. In Richmond, Virginia.
Q. What is your age?
A. Thirty-eight.



[ 2 4 ]

Q. What is your position?
A. I am Executive Secretary of the Virginia Tea­

chers’ Association.
Q. How long have you held that position, Mr. 

Picott?
A. I have been there since 1943.
Q. What is the nature of that organization?
A. A professional organization of the 5,145 teachers 

in Virginia.
Q. In what do your duties as Executive Secretary 

of that organization consist?
A. We are primarily concerned with the teachers, 

white and colored, who work in the schools for colored 
children in the State and, of course, we are interested 
in better education for children and improved work­
ing conditions and, generally speaking, our program 
(R. p. 269) is based on the welfare of the child with 
particular emphasis on the improvement of the ed­
ucational opportunities for all children, white and negro.

Q. What previous experience, if any, did you have 
in the field of education prior to the time that you be­
came Executive Secretary of that organization?

A. I was a teacher in a rual high school in South 
Boston, I think, for a year. I was a principal of a school 
in the City of Newport News of 29 teachers, an ele­
mentary school, for about seven years. I taught in 
two colleges, one of which was Hampton Institute 
and 1 taught in a city high school.

Q. And over what period of time and term of 
years did this experience to which you have just testi­
fied extend?

A. A period of about fifteen years, I would say.
Q. And what are your academic qualifications, Mr. 

Picott?



[ 2 5 ]

A. I have a college degree from Virginia Union 
University in Richmond. I have had courses in educa­
tion at Hampton Institute. I have a Master s Degree in 
eductional administration and supervision from Temple 
University in Philadelphia and I have done, I believe, 
a large part of the work at New York University to­
ward a Doctor s Degree in education.

Q. Mr. Picott, did you have occasion to examine 
(R. p. 270) the Washington and Lee High School and 
the Hoffman-Boston High School in Arlington County, 
Virginia?

A. Yes, I have had the opportunity of being at 
the Hoffman-Boston School on numerous occasions in 
the past four or five years. I was, however, at both of 
those schools, I believe, August 20th and 21st at 
any rate, the Saturday and Sunday of that weekend.

Q. Of what year?
A. Of this year, the past month.
Q. Please state whether or not upon the latter oc­

casion you made a detail inspection of both the Hoff­
man-Boston and the Washington and Lee High Schools?

A. Yes, I think we spent all day Saturday and 
a major portion of the day on Sunday morning or Sun­
day.

Q. Mr. Picott, did you have occasion to make an 
examination of the facilities for instruction in art at
the Washington and Lee High School?

A. Yes, I did.
Q. Will you state for the information of the Court 

what facilities you found at that high school for in­
struction in art?

A. There seemed to be the proper tables for draw­
ing.

* * * * *



[2 6 ]

(R. p. 271) A. I was very much impressed with the 
drawing boards which project from the side of the 
room.

B y  th e  C o u r t :

Q. Which school are you speaking of?
A. The Washington and Lee School. There was no 

drawing facility at Hoffman-Boston School that I saw, 
certainly comparable to this. These drawing boards — 
I haven’t seen them at any other school. I thought 
they would add greatly to ability to draw because they 
swing out from the wall. It seemed to me, in addition, 
that the room was conducive — very frankly, there 
was one picture in the room to which I object stren­
uously because of its racial attitude which was shown 
but, other than that, it seems to me that the facilities 
were fairly adequate.

B y  M r . R o bin so n :

Q. Please state whether or not the drawing boards 
(R. p. 272) or easels to which you have just referred 
in your testimony are those which are shown in Plain­
tiff’s Exhibit No. 40?

A. Yes, that seems to be it.
Q. Please state whether or not at the Washington 

and Lee High School instruction in art is offered in 
a separate classroom or in separate classrooms? By 
that I mean in specially equipped classrooms?

A. It seems at least in this room there was special 
equipment for the offering of it so I should say yes.

Q. Please state what, if any, facilities you saw at 
the Hoffman-Boston School for instruction in art?

A. I saw none. I don’t recall any that could be said 
to be specially designed for that purpose.



[ 2 7 ]

Q. Please, Mr. Picott, state your opinion as to wheth­
er or not the facilities for instruction in art at the 
Washington and Lee High School are superior, in­
ferior or comparable to those of the Hoffman-Boston 
School?

A. Unquestionably superior. I would say there was 
no other way to look at it. They were unquestionably 
superior.

Q. Did you have an occasion to make an examina­
tion of athletic fields and playing areas, and that sort 
of thing, at the Hoffman-Boston and at the Washing­
ton and Lee High Schools?

A. Yes.
(R. p. 273) Q. Please state what athletic facilities 

and facilities for recreation you found at the Washing­
ton and Lee High School?

A. They seemed to be very good. In front of the 
building you had this huge and, I would say, very fine 
athletic field with concrete stand, with a track around 
it and with other facilities, in addition, of course, to 
your indoor arrangements which you might have. All 
of these details are apportioned so they can be well 
used for the purpose, whereas at Hoffman-Boston I 
saw a field, not all level, certainly on August 20th it 
appeared as if it couldn’t be used at all because a 
large portion of the field is downhill to the ravine 
or the highway which is in the rear of the school, 
and I certainly saw no track around the school or any­
thing that would approach a comparison of the two.

Q. Did you see any grandstand facilities over at 
Hoffman-Boston School?

A, They weren’t there on August 20th.
Q. Any artifical lighting facilities?
A. Oh, no, of course not.



[2 8 ]

Q. Any football gridiron or baseball diamond?
A. No.
Q. Did you see any facilities at all at Hoffman- 

Boston School which, in your opinion, could be used 
for sports, for play and for recreation?

(R. p. 274) A. I saw very little.
Q. Did you have an occasion to make an examina­

tion of the auditorium at the Washington and Lee 
High School?

A. Yes, I did.
Q. Will you state for the information of the Court 

the situation at that school with reference to an aud­
itorium or with reference to one or more auditoriums?

A. I think there was an adequate auditorium, the
main auditorium, which has, as I understand i t ----
have been informed has a seating capacity of about 
1157, say roughly about 1200 persons, with a stage 
facing it. These seats are fixed theatre auditorium 
type seats and I sat in one. They are comfortable. 
Immediately behind the movable partition, which is 
or can be used as a part of the auditorium, is the 
gymnasium floor. I would assmne that if you put 
chairs in the gymnasium and faced from the side you 
might easily seat 2,000 persons. There might be some 
difficulty but you might do it.

Q. Please state whether or not there were any 
other seating facilities in the auditorium or gymna­
sium portion of the auditorium than the seats in the 
auditorium proper to which you have just testified?

A. Well, there was a balcony which I think I have 
overlooksd.

(R. p. 275) Q. Please state whether or not there 
were any seating facilities on the stage portion of the 
auditorium which you recall?



[2 9 ]

A. On the day I was there I don t believe I saw too 
many chairs. That was the portion I was speaking 
of — from the gym portion.

Q. Did you observe any facilities in the auditor­
ium at the Washington and Lee High School for the 
showing or projection of moving pictures?

A. Oh, yes. Washington and Lee auditorium seem­
ed to have been built some years ago at a time, I 
suspect, when all of these auditoriums were equipped 
with a moving picture booth and there seems to be 
one. I didn’t go up and examine it but it appears 
to be there.

Q. Will you describe for the information of the 
Court the size and the set-up, as far as you can, of 
the stage or the gymuasium portion of the auditorium?

A. Will I describe that?
Q. Yes.
A. Well, I don’t recall the feet involved but it 

seemed to be adequate as a playing floor for basket­
ball games.

Q. Please state whether or not any basketball 
court was marked out on this particular portion of the 
floor?

A. Yes, there was.
(R. p. 276) Q. Now, Mr. Picott, did you have oc­

casion to make an examination of the auditorium at 
the Hoffman-Boston School?

A. Yes.
Q. Please state for the information of the Court 

what you saw and found there?
A, The auditorium at the Hoffman-Boston School 

is one with some handicaps. There is a stage, small. 
There are seats, I think, something like 300 is the 
capacity, or thereabouts. They have folding chairs, not



[3 0 ]

the stationary type of seats. The objection I would 
have to it is that in the center, as I recal it, there are 
two piers that support the roof so that you have 
this support which would effectively, in my opinion, 
block it from being used for anything else but an 
auditorium and even there you would have some 
difficulty in looking around some of these supporting 
girders.

Q. How does the size of the stage of the auditorium 
at Hoffman-Boston compare with the size of the stage 
or gymnasium portion of the main auditorium at Wash­
ington and Lee?

A. Hardly any comparison. The Washington and 
Lee arrangement is obviously many times larger.

# # # # #

(R. p. 277) A. The Hoffman-Boston stage is much 
smaller, certainly not one-tenth as large.

Q. Is it large enough to permit the playing of 
basketball games?

A. No. Is the Hoffman-Boston School stage large 
enough, you mean?

Q. Yes.
A. The answer is no.
Q. Is it large enough to permit the playing of any 

games, that is group games, of course?
A. No. You might put a table up and have a game of 

pin-pong, or something of that sort, but not a group 
Same.

Q. How did the facilities and appointments and 
equipment within the Hoffnam-Boston School com­
pare generally with those in the main auditorium at 
Washington and Lee School?

(R. p. 278) A. Oh, from the standpoint of com-



[ 3 1 ]

pleteness, of cheerfulness, of attractiveness, of general 
all-round wholesome attitude that might serve as a 
motivation, there is no comparision. Obviously, the 
Washington and Lee auditorium was designed for the 
purpose, whereas when you look at it from that view­
point it appeared as if the Hoffman-Boston is a mix­
ture — when you look at it from that viewpoint.

Q. Please state your opinion as to whether or not 
the auditorium facilities accorded the white pupils at 
the Washington and Lee School are superior, inferior 
or comparable to those which are accorded negro 
pupils at the Hoffman-Boston School?

A. Superior.
Q. How many auditoriums did you find at Hoff- 

man-Boston?
A. I recall seeing in the main auditorium----
Q. Hoffman-Boston?
A. I beg your pardon — just one.
Q. How many auditoriums do you recall examin­

ing at Washington and Lee High School?
A. At least two, maybe more. One auditorium is 

used for band practice — appeared to be.
Q. Please state whether or not the auditorium which 

you have just mentioned is the same auditorium which 
previously has been referred to as the main auditorium 
concerning which you previously testified?

(R. p. 279) A. It is not. The two are different.
Q. Will you describe, for the information of the - 

Court, the set-up and the facilities and the equipment 
in the band or music auditorium?

A. There is a stage on which, on August 20th, I 
believe, there were music stands at least and then 
there were chairs — I would surmise a hundred, I 
think — in the room so that you have a small audi­



[ 3 2 ]

torium which might be used as a multi-purpose room 
for band practice and things of that nature.

Q. Please state whether or not the auditorium con­
cerning which you have just testified is that portray­
ed in Plaintiff’s Exhibit No. 72?

A. Yes. This is it, No. 72.
Q. Mr. Picott, how does the size of the auditorium 

shown in Plaintiff’s Exhibit No. 72 compare with the 
single auditorium at the Hoffman-Boston Pligh School?

A. I would say the Hoffman-Boston High School 
is slightly larger, not too much. The one advantage of 
this even small second auditorium or second audi­
torium is that you have your view which is not ob­
structed by any supports in the center of the room.

Q. Did you discern any auditorium for the band 
or for instruction in music, if any, at the Hoffman- 
Boston High School?

(R. p. 280) A. No. I saw a room which at one 
time was the Principal’s office. It appears as if they 
have pushed him out and now that is being used for 
a music room. Whether for a band, I don’t know.

Q. Did the room which you have previously men­
tioned have a stage?

A. No.

M r . D ouglas: W h ich  room?

M r . R o bin so n : At the Hoffman-Boston that was pre­
viously used as a Principal’s room.

A. No, it does not. It is a very small room.

B y  M r . R o bin so n :

Q. Did you make an examination of the typewrit­
ing room at Washington and Lee High School?



[ 3 3 ]

A. I did.
Q. Will you state for the information of the Court, 

what facilities and conveniences you found there?
A. I found adding machines, a mimeoscope, I think, 

was there adequate tables for typing
Q. Directing your attention, Mr. Picott, to Plain­

tiff’s Exhibit No. 31, will you state for the information 
of the Court what that is?

A. That is the business office or Principal’s outer 
office.

Q. At what school?
(R. p. 281) A. Washington and Lee.
Q. Will you describe the facilities in that room,

please?
A. It seems to be quite adequately equipped for 

the Principal’s office. I was intrigued with the device 
for immediately finding names, the register, which is 
quite handy when you want to find the names. It 
appears on examination that most of the students have 
their names recorded in the Kardex arrangement.

Q. Does that appear in Plaintiff’s Exhibit No. 31?
A. Yes, it does.
Q. In which portion?
A. To the right of the picture viewed from the 

reader’s standpoint.
Q. Did you make an examination of the business 

office at PIoffman-Boston High School?
A. Yes, I did. The Principal appears to have a por­

tion of the librarian’s office or workroom.
(). Did you see at the Hoffman-Boston School any 

facilities which were the same or substantially equal 
to the facilities in the business office at Washington 
and Lee Pligh School as shown in Plaintiff’s Exhibit 
No. 31?



[ 3 4 ]

A. No, of course not, because, in the first place, 
there isn’t enough room. The Principal at Hoffman- 
Boston only has room enough for his chair and per­
haps a very small table and if the librarian is to get 
(R. p. 282) in this space, which I am sure isn’t three feet 
wide by ten, perhaps about, there is not space for this 
type of equipment. In addition, it didn’t seem to be 
there, certainly not all, as was evidenced by a visit to the 
Washington and Lee School.

Q. Mr. Picott, did you obsrve the Principal’s 
office at Washington and Lee High School having 
any device or arrangement for communication between 
that office and the remaining rooms in that building?

A. Yes. It appeared at the Washoington and Lee 
School the Principal has one of the more advanced 
types of intercommunication systems. He has a com­
plete dashboard in front of him with a chair in front 
and he can sit and just by pressing a button, can 
listen in, I would assume, and can speak with any 
one room or with all of the rooms in the entire in­
stitution at will.

Q. Did you see any such device or system in­
stalled or in operation at the Hoffman-Boston High 
School?

A. No.
Q. Did you make an examination of the classroom 

or classrooms employed at Washington and Lee High 
School for instruction in bookkeeping?

A. Yes, I looked at the bookkeeping room.
Q. Will you describe the facilities which you found 

in that room?
( R. p. 283) A. There appeared to be s o m e a t  

least, a type of the newer chairs for typing or for 
desk work, with adding machines or several adding



[ 3 5 ]

machines, and other equipment such as typewriters 
which are needed in such rooms.

Q. Did you examine to see whether or not at the 
Hoffman-Boston High School there is a room which is 
especially designed for instruction in bookkeeping?

A. I saw no such room nor did I see any adding 
machines.

Q. Did you see any other equipment at the Hoff­
man-Boston High School of the same type or sub­
stantially similar to the bookkeeping equipment em­
ployed at the Washington and Lee High School?

A. I think the answer to that is no.
Q. Did you examine the cafeteria facilities at the 

Washington and Lee High School?
A. Yes. I was impressed on several counts. One 

I — certainly not unique but certainly helpful — the 
arrangement of entering the cafeteria from the hall 
which is on the right side of the building — the right 
end of the building, facing the building. I looked also 
for exits from the cafeteria. There were several and 
they seemed to provide easy space to get out. I took 
a look into the kitchen and it seemed to be amply 
arranged. The place is quite attractive. Apparently 
large enough to seat a number of the pupils at any one 
session or any one time. I would count the cafeteria at 
Washington and Lee School as being adequate as 
(R. p. 284) cafeterias go for the purpose.

Q. Did you make an examination for cafeteria fa­
cilities at the Hoffman-Boston High School?

A. Yes, I looked for that.
Q. Did you find any facilities for cafeteria service 

or any caferteria whatsoever at the Hoffman-Boston 
High School?

A. I found no cafeteria.



[ 3 6 ]

* # # * *

Q. As to Hoffman-Boston School, I understood you 
to say there was not as ample equipment there as in 
Washington and Lee. Was there any equipment?

A. No, I saw no room which had been set up 
aside apparently for the teaching of bookkeeping.

(R. p. 285) Q. How about the machines?
A. I saw no machines. I was there on August 20th 

which was summer and conceivably one or two might 
have been put away but I saw no machines while I 
was there, whereas there were machines available and 
on the desks and several adding machines when I was 
at the other school.

Q. Will you state for the information of the Court 
what you observed as to classrooms in the Hoffman- 
Boston School and in the Washington and Lee High 
School, used for the education and instruction of sen­
ior high school pupils?

A. I think a general statement might be made which 
could be supported certainly, I think, from the visit, 
that generally speaking, the facilities and equipment 
in the classrooms at the Washington and Lee School- 
all such things are, for the most part, superior to that 
found at the Hoffman-Boston School. It would ap­
pear — well, to begin with, the Washington and Lee 
School is a much more attractive place. There is no 
comparison when you look at the two schools from 
attractiveness. I almost think you could make that state­
ment without fear of contradiction, that there is no 
comparison between the two schools. It is true one 
is large and the other is small, but certainly they just 
aren’t two similar schools. In addition, it would ap­
pear that in special rooms such as Art and in book­



[ 3 7 ]

keeping, and certainly in the rooms devoted to voca- 
(R. p. 286) tional studies, the equipment at the 
Washington and Lee School is superior to most of the 
schools in the entire State of Virginia, white or colored, 
and at the Hoffman-Boston School it either does not 
exist at all or else is only fair.

Q. I should like to direct your attention to Plain­
tiff’s Exhibit No. 42 which is a photograph of a class­
room at the Washington and Lee High School.

A. I have it.
Q. Will you state whether or not you saw at tire 

Hoffman-Boston High School any classrooms com­
parable with the classroom which is shown in Plain­
tiff’s Exhibit No. 42 at at the Washington and Lee 
High School?

A. No, I did not. This seems to be one of the larg­
er rooms which again might be used as a resource 
room, a multiple purpose room, and which in the ag­
gregate could easily seat many more persons than 
you would normally expect in a classroom. I would 
say seventy-five or one hundred persons might be seat­
ed here. This room could be used for teaching where 
you needed to have a larger group together than you 
would normally expect in regular classroom instruc­
tion.

Q. Mr. Picott, will you express your opinion as 
to whether or not the classroom facilities for the in­
struction of senior high school pupils at the Wash­
ington and Lee High School are superior to the class­
room facilities offered at the Hoffman-Boston High 
(R. p. 287) School for the instruction of senior high 
school pupils there?

A. Yes. When you count in the special facilities 
that seem to be available, the special multi-purpose



[ 3 8 ]

rooms, the special equipment, it seems to me the pen­
dulum swings heavier in favor — quite heavier in favor 
of the Washington and Lee School.

Q. Did you make an examination of the corridors 
at the Washington and Lee High School and the Hoff­
man-Boston High School.

A. Yes, I did.
Q. Will you state for the information of the Court

how these compared?
A. One was not too clean. The Hoffman-Boston 

School seemed to be not too well kept in order and I 
think I should add that was prior to school, in fair­
ness, and also at the time the Washington and Lee 
corridors were being painted.

Q. Was there any renovation at that time taking 
place in the Hoffman-Boston High School?

A. No. I talked with the janitor, I belive it was, 
and I think they washed some of the walls but I saw 
no painting going on.

Q. Mr. Picott, I should like to direct your attention 
to Plaintiff’s Exhibit No. 43 which is a photograph of 
the distributive education room or office at Washington 
and Lee High School.

(R. p. 288) A. I recall that, yes.
Q. Did you make an examination of this room?
A, Yes, I did.
Q. Will you state for the information of the Court

the purpose of this room?
A. The State of Virginia, along with a number of 

other states, participates in a program which I think 
is rather widespread in America whereby a student 
may spend a portion of his time in the classroom and 
then he would have some actual work experience 
in the field. Your better high schools will have to



[ 39 ]

do that. They do in Virginia, both white and negro. 
For example, on the walls of this room at the Wash­
ington and Lee School there was a huge banner which 
said “Distributive Education,” and on the sidewall, 
that is the side facing the door, there were very good 
pictures of department store participation on the part 
of some of these pupils. One could very easily gather 
from the literature which was available that here 
was a room where teacher or teachers will work with 
children from the viewpoint of making a corelation 
between the school work and the actual work in the 
field so that when the pupil finished at Washington 
and Lee School he might, without difficulty, or cer­
tainly with greater facility, be able to make the transi­
tion from the school to work.

(R. p. 289) Q. Did you make an examination of the 
HofFman-Roston High School to determine whether or 
not there were facilities there the same or substantially 
similar to those at Washington and Lee concerning 
which you have just testified?

A. Yes, I looked particularly but I didn’t see it.
Q. Did you find any facilities whatsoever at Hoff- 

man-Boston High School?
A. I saw nothing that would indicate on that day 

that Hoffman-Boston had such a course.
Q. Mr. Picott, did you have an occasion to examine 

the room which is shown in Plaintiffs Exhibit No. 36, 
a guidance room or office at Washington and Lee 
High School?

A. Yes, I did. I would like to get that. May I 
look at the one you have to refresh my memory?

Q. Did you have occasion to examine that, Mr. 
Picott?

A. Yes, I did.



[4 0 ]

Q. Will you state for the information of the Court 
what facilities and equipment you found there?

A. It appeared that there are two desks in the room. 
At the time there were a number of boxes on the desks 
and possibly one typewriter table with a telephone. 
It would appear that here a special person trained in 
guidance might use this facility to aid pupils from 
this office. In addition, there was a washstand. The 
part that impressed me about it was not the view of 
the office or the equipment of the office because I 
(It. p. 290) think that is not unusal; I was impressed 
that there was in this school a room set aside for the 
guidance instructor and that there was no such room 
at the Hoffman-Boston School.

Q. At the Hoffman-Boston School were there any 
facilities whatsoever for the guidance of pupils?

A. Well, of course, in education, I think, at least 
some people do, that every teacher is a teacher of 
guidance but over and above that, in the better schools 
we have special persons. By special persons I mean 
persons who have a Master's Degree in guidance who 
have pursued further work toward a doctorate in guid­
ance. Guidance is a special field and those persons 
might easily know more about the subject and be 
more helpful specifically to pupils than could the av­
erage teacher. They would obviously have more time 
because they would devote their full time to the sub­
ject and the Washington and Lee School seems to 
have at least a room for such a person.

Q. Did you find any special facilities for guidance 
at Hoffman-Boston?

A. I saw none.
Q. Mr. Picott, did you have occasion to examine



[ 41]

the gymnasium at the Hoffman-Boston and at the 
Washington and Lee High Schools?

A. I am not advised that the Hoffman-Boston has 
(R. p. 291) a gymnasium per se. There are at least 
two gymnasiums, a boys’ and a girls’ at the Washing­
ton and Lee High School. Both seemed, on the day 
we visited them, to be quite well equipped. I think 
you ought to say that the boys’ gymnasium — at least 
the rooms adjoining the gymnasium showed there 
were boys at Washington and Lee without a doubt, 
but other than that the wall marking, the facilities in­
cluding lockers seemed to be quite good for the pur­
pose.

Q. At this point, let me ask you this question: How 
many gymnasiums did you see at Washington and 
Lee?

A. I recall vividly two at least, two full gymnasiums.
Q. Please state whether or not you have or will 

refer to one of these two as the boys’ gymnasium and 
the other as the girls' gymnasium?

A. Yes, one used by boys and one by girls.
Q. Will you state for the information of the Court 

the location of the girls’ gymnasium with reference 
to the auditorium at the Washington and Lee High 
School, the main auditorium?

A. The girls’ gymnasium is approached facing the 
stage. To a person facing the stage of the auditorium, 
the girls’ gymnasium, I believe, is to the left, whereas 
the one for boys is the one immediately behind or 
on part of the stage. I believe I am correct in that,

Q. With reference to the gymnasium which on the 
(R. p. 292) stage of the auditorium at Washington 
and Lee, will you state for the information of the 
C o u rt----



[4 2 ]

A. Just a moment. I believe, upon thinking about 
it, I have them just in the opposite order from what 
they are.

Q. Will you state now?
A. Yes, I would like to say that after I think about 

it, because I saw certain portion of the curtain which
was used, for example, as a dressing room, a part of 
it, the girls’ gymnasium appeared to be the gymnasium 
right behind a part of the platform or stage of the 
main auditorium, whereas the boys’ is to the left. I 
think I am correct on that now because I think I 
remember we had to walk through several passage­
ways and find keys to get through the boys’ portion.

Q. What facilities or set-up did you find with 
respect to the gymnasium which you have identified 
as a girls’ gymnasium?

A. There were shower rooms, toilet facilities, cer­
tainly a large enough play space marked off, adequately 
marked so that a girls’ basketball team might easily 
be held in that gymnasium.

Q. What about a boys’ basketball gymnasium?
A. I think it is probably standard for boys, and 

girls could use it with some revisions.
Q. I should like to direct your attention to Plain­

tiff’s Exhibit No. 18. Please state whether or not that 
(R. p. 293) is the auditorium which you have re­
ferred to as the girls’ auditorium?

A. Yes.
Q. I mean the gymnasium which is referred to as 

the girls’ gymnasium?
A. Yes. There is a standing basketball goal, yes.
Q. Please state what the structure is on the right- 

hand side■ of that photograph?
A. There is a piano.



[ 4 3 ]

Q. On the rigbthand side?
A. That is a tier of seats possibly for a basketball 

game, for persons who might look on.
Q. Please state whether or not you had occasion to 

examine to see whether or not there were any shower 
facilities adjoining the girls’ gymnasium?

A. Yes, there were.
Q. Will you examine Plaintiff’s Exhibit No. 20 and 

state whether or not a portion of those facilities are 
shown in that photograph?

A. Yes, this is the one.
Q. Will you state for the information of the Court 

what other facilities you found adjoining the girls’ gym­
nasium?

A. Well, you had your lavatory facilities, toilet 
(R. p. 294) facilities, in addition to the shower facili­
ties. I believe there was a room for dressing — lockers.

Q. Please state whether or not the facilities which 
you last mentioned are those shown in Plaintiff’s Ex­
hibit No. 22?

A. Yes, that is correct. There was a big locker 
room right off from the gymnasium.

Q. Mr. Picott, did you see a team room adjacent 
to the girls’ gymnasium?

A. Yes.
Q. Is the room a portion of which is shown in 

Plaintiff’s Exhibit No. 21?
A. Yes. This is a room apparently where they had 

what they call still pracitice for football. The room 
had pictures of the football players in action and 
there was a blackboard on which, as I recall it, there 
were some designs for plays. So that there appeared 
to be a special room in the Washington and Lee School 
where the boys who play football might be versed



[4 4 ]

in that practice in the classroom in addition to what­
ever practice they get outside of the building itself.

Q. Directing your attention to Plaintiff’s Exhibit 
No. 28, please state whether or not that is the gym­
nasium at Washnigton and Lee High School which 
you have referred to as the boys’ gymnasium?

A. Well, I don't seem to have 28 here. Yes, this 
(R. p. 295) seems to be the boys’ gymnasium.

Q. Did you notice any facilities which were a part 
of or connected with that particular gymnasium?

A. Yes, there seemed to be a shower room, ad­
equate lockers which extended down a portion of a 
room or a walkway, toilet facilities, and with a gym 
floor adequately marked, with basketball goals or the 
backstop for basketball.

Q. Mr. Picott, please state whether or not the facil­
ities which are known as the boys’ gymnasium are in 
addition to those facilities which are a part of the 
gymnasium which you have previously referred to as 
the girls’ gymnasium?

A. Yes, there are two of them. In other words, a
girls’ and a boys’.

Q. Please state whether or not the facilities of the 
girls’ gymnasium might be used for such atheltic con­
tests as basketball, boxing, wrestling, and that sort of 
th in g ---- boys’ teams as well as girl teams.

A. It would appear so, yes.
Q. Did von find any gymnasium at all at Hoffman- 

Boston School?
A. I found no gymnasium per se. There is an au­

ditorium from which I suppose you might remove the 
folding chairs but even there, in my opinion, it is 
entirely impossible to play a game of basketball because 
of these uprights which support the roof and which



[ 4 5 ]

come down to the floor actually in the auditorium. 
(R. p. 296) For example, we had in this room cer­
tain supports to the ceiling or to the roof. You can 
see that they would effectively, if your space was 
limited, block any game of basketball or any such 
other activity of that sort.

Q. Please state whether or not, in order to use 
the auditorium at Hoffman-Boston High School to any 
degree for such puposes, it would be necessary to make 
any physical improvement of any equipment therein 
before it could be used for such purposes?

A. I should certainly think you would be at a 
terrific disadvantage for playing basketball or volley­
ball or any of these other games because of the sup­
ports, these upright supports.

Q. What about the seats?
A. The seats would have to be moved and I may 

remark on that, if I may, that this combination gym­
nasium-auditorium which is in some of our schools — 
in the minds of many persons who have had to do 
with education, they are certainly not a good solution 
to the problem. If it is used frequently for gymnasium 
purposes, then it is always dirty and sometimes filthy 
so that it cannot be effectively used for an auditorium. 
In other words, what I am saying is that in the minds 
of at least some persons who have to do with educa­
tion in our State, the combination of a gymnasium- 
auditorium is a serious mistake. I taught in one high 
(R. p. 297) school which had that in a city and we came 
to the conclusion that it was a great mistake. There is the 
added disadvantage of unattractiveness for an audi­
torium. You never can have the attractiveness or keep 
it so if it is used frequently as an auditorium, so that 
either you have a very poor combination auditorium-



[ 4 6 ]

gymnasium or you just use it for one or the other. In my 
judgment, it is never satisfactory and I have come to 
this conclusion after having taught in a high school 
where there was one for a period of five years.

May I also say this? It is a solution that is some­
times used to save money but I think quite unsatis­
factory.

Q. Please state whether or not, in you opinion, the 
gymnasium facilities at the Hoffman-Boston School are 
equal or unequal to those at the Washington and Lee 
High School?

A. There is no comparison, the fact is, definitely 
not. In my judgment, there is no gymnasium at the 
Hoffman-Boston School. There is an auditorium which 
I suppose might be used for light calisthenics but, 
even so, they are handicapped, so in reality I find it 
difficult to see any comparison between the two.

Q. Did you make an examination of the library at 
Washington and Lee High School?

A. Yes, I did. I was impressed with that library at 
(R. p. 298) Washington and Lee. I have had an op­
portunity to visit some of our better colleges. The li­
brary there at Washington and Lee, from the stand­
point of the cost, from the standpoint of attractive­
ness, particuarly the portion which is the second por­
tion, the card file or section, is quite attractive. For 
example, the type of lights make it extremely nice 
from the standpoint of motivation. In my experience, 
the Washington and Lee — least part of the library, 
the second room would do credit to any of our small 
colleges.

Q. Did you find any workroom or any office or 
some of the rooms adjacent to the library at the Wash­
ington and Lee High School?



[4 7 ]

A. Yes, there seemed to be adequate workrooms. 

B y  M r . D ouglas:

Q. The witness has used the word “motivation”. 
He used it once before and I don’t know what it 
means.

A. In education, we think in terms of a child be­
ing helped because of his surroundings to actually 
study and to participate in the program. By motiva­
tion we mean sometimes an intangible thing, that is, 
in the attractiveness of the library. For example, when 
I was in the Washington and Lee library I sat down 
in one of the chairs because to me here was a place 
beautiful of itself.

# # # # $

B y  M r . R o bin so n :

(R. p. 299) Q. Mr. Picott, did you make an ex­
amination of the library at the Hoffman-Boston School?

A. Yes.
(.). Will you describe, for the information of the 

Court, the equipment and the facilities and apoint- 
ments of that library.

A. There were not so many books on the shelves 
but the major portion of the library is books and mag­
azines. I had no opportunity to look at the books and 
magazines except casually. The Hoffman-Boston li­
brary, compared to the Washington and Lee library — 
the Hoffman-Boston is a practical place, whereas the 
Washington and Lee library is a beatiful place, as 
well as practical.

Q. Mr. Picott, please state your opinion as to wheth­
er or not the physical set-up and equipment of the



[ 4 8 ]

library of Hoffman-Boston High School makes that 
library equal to or leaves it unequal to the library 
at the Washington and Lee High School?

A. I would say the Washington and Lee library is 
way head and shoulders over tire Hoffman-Boston 
library. If I were a student at the Hoffman-Boston 
School I would be willing any day to trade for the 
Washington and Lee library.

B y  th e  C o u r t :

(R. p, 300) Q. When you speak of the library, are 
you referring to the room or are you referring to the 
contents?

A. I am referring to the room, to the chairs, to 
everything else except the books. I saw the books 
but I had no time to actually look at every book and 
put them down and see just which one was better. 
I am referring to everything in the library except the 
books.

Q. You mean the facilities for the use of the books 
or the books themselves were of a practical character?

A. No. I make no comment as to the books but 
the room itself was simply another room. There was 
nothing unusual about it.

B y  M r . R o bin so n :

Q. At which school is that?
A. At the Hoffman-Boston School.
Q. Mr. Picott, did you have occasion to examine 

the facilities for instruction of music at the Washing­
ton and Lee and Hoffman-Boston High Schools, re- 
(R. p. 301) spectively.

A. Yes. I would like to refresh my memory from



[4 9 ]

one of the pictures outside of the special music room. 
I recall this room. This is a classroom, I suppose the 
average size, although it might be slightly larger. There 
is a baby grand piano in the front which is needed, 
of course. There is a teacher’s desk; there are several 
paintings on the wall. There was one painting which 
I insist I will object to, but it is there. There were 
several paintings showing several nationalities. There 
appeared to be some sort of filing cabinet in the left- 
hand corner, looked at from the reader’s viewpoint. 
There was at least a podium or stand from which a 
director might place the sheet music and, of course, 
direct the band or orchestra. There were movable 
chairs. There was a little shelf for books.

Q. Did you notice any facilities at Washington 
and Lee High School for storage of musical instru­
ments?

A, Yes, I did. I recall seeing some, I think, in the 
passageway through this room. There is a little pass­
ageway through this room which is lined on either 
side by storage cabinets. I think I am correct on that. 
From the hallway you first enter into this passageway 
and then to the music room. That is my memory on it.

Q. You have previously testified with reference to 
the music or band auditorium at the Washington and 
Lee High School. Please state whether or not you 
(R. p. 802) recall seeing any lockers or other facilities 
in that auditorium for the storage of musical instru­
ments?

A. At Washington and Lee?
Q. Washington and Lee band auditorium.
A. There seemed to be adequate storage space.
Q. Mr. Picott, did you examine the Hoffman-Bos- 

ton High School for the purposes of determining what, if



[5 0 ]

any, facilities for instruction in music were afforded
there?

A. I saw none. My understanding is, upon ask­
ing questions at the time, that the Principal's former 
office is now used as a music room. If so, you have 
a space which is not much larger than this jury box 
here, certainly not very much larger than this space 
here which of course, would be totally inadequate 
for the purpose. I don't recall seeing any storage space.

Q. Please state whether or not the music room at 
the Hoffman-Boston, concerning which you have just 
testified, is the room which is shown in Plaintiff’s 
Exhibit No. 11?

A. Yes, this seems to be the music room or what 
I was told is the music room.

Q. Will you state whether or not the facilities 
afforded at the Hoffman-Boston High School for the 
instruction of pupils there in music are equal or are 
unequal to those facilities which are afforded white 
pupils at the Washington and Lee High School for 
(R. p. 303) instruction in music?

A. There is obviously no comparison. It isn’t al­
ways necessary, for example, to have a piano but it 
is nice to have a baby grand piano, whether it is in 
good or poor state of repair. It is very fine to have 
a space to store the instruments. All of that, I would 
say, undeniably would put Washington and Lee music 
room in the category of being superior to the Hoff­
man-Boston music room or so-called music room where 
none of these facilities were in evidence as of the 
day when I visited the room.

# # # # #

Q. Mr. Picott, did you have occasion to examine



[ 5 1 ]

the science laboratories at the Washington and Lee 
High School?

A. Yes, I did. I would like to have a picture though 
to refresh my memory on it.

Q. How many different science rooms did you 
see or examine at the Washington and Lee High 
School?

A. My memory is that I looked at at least four. 
There may have been others.

(R. p. 304) Q. Please state whether or not the 
science room that is shown in Plaintiff’s Exhibit Nos. 
29 and 70 are two of the science rooms at the Wash­
ington and Lee High School which you examined.

A. Yes.
Q. Will you describe the facilities in these and 

any other science rooms which you examined at that 
school?

A. No. 29 seems to be a room where allergy is taught. 
I would look at it from that standpoint because of the 
type of desk or table which is there; also because of 
the wall space and how it is used, the table at the 
front, so that it appears, for biology at least, this 
is fairly well equipped. Of course, it is difficult in 
August to say how it would look in September, but, 
at least, there appears to be the equipment necessary, 
as to Plaintiff’s Exhibit No. 29 for this science room.

As to No. 70, there again, there also appears to 
be a room which might be used for the teaching of 
science and which has equipment adequate, I would 
say.

Q. Are you able to testify what particular science 
is taught in the laboratory which is Plaintiff’s Exhibit 
No. 70?



[ 5 2 ]

A. I would say chemistry might be taught and
physics.

O. Did you see any science room or rooms equip­
ped for instruction in physics at the Washington and 
Lee High School?

(R. p. 305) A. Yes, it would appear to be.
Q. For instruction in general science at the Wash­

ington and Lee High School?
A. Yes, I would say in Plaintiff’s Exhibit 7, that 

room might be used. You have got a demonstration 
table in the front portion of the room; you have got
the movable ch a irs----
B y  M r . D ou glas:

(). Did you say No. 70?
A. I was speaking in terms of No. 7. Let me look 

at 70 again. I suppose general science might be taught 
in No. 70. I think room No. 7 measures up more to 
it. Science rooms are interchangeable, at least to some 
extent.

B y  M r . R o bin so n :

Q. My question was not whether or not general 
science might be taught in the science room which is 
shown in Plaintiff’s Exhibit No. 70 but whether or 
not in the Washington and Lee High School you saw 
any room or lavatory which might be devoted to in­
struction in general science?

A. Yes, I did see such room.
Q. Did you make an examination of the science 

facilities at Hoffman-Boston High School?
A. Yes, I did.
Q. Will you state whether or not they are the 

(R. p. 306) facilities which are shown in Plaintiff’s 
Exhibit Nos. 6 and 7?



[5 3 ]

A. Yes. This appears to be the room in the Hoff- 
man-Boston School.

Q. No. 7?
A. No. 7 appears to be a room in the Hoffman- 

Boston School.
Q. How many science rooms did you find in the 

Hoffman-Boston School?
A. I am not too certain whether No. 6 and No. 7 

is the same room, a different view, but I recall see­
ing one at least. There may have been others.

Q. Did you see any equipment for instruction in 
science at Washington and Lee High School other 
than that shown in Plaintiff’s Exhibit Nos. 29 and 70?

A. Yes, I recall seeing several rooms where ap­
parently science was taught.

Q. Did you see any apparatus other than shown 
in these photographs at the Washington and Lee High 
School?

A. Yes, I think so.
Q. Will you describe, for the information of the 

Court, in a general way, what additional equipment 
or apparatus you observed at the Washington and Lee 
High School?

A. I believe I recall seeing microscopes at least in 
one room, additional tables for experimentation, tea­
cher’s desk, etc.

(R. p. 307) Q. Did you see any equipment of sub­
stantial character or apparatus of substantial character 
for instruction in science at the Hoffman-Boston High 
School other than that which is shown in Plaintiff’s Ex­
hibit Nos. 8 and 7?

A. I think this covers it very well.
Q. Did you see any microscopes at Hoffman-Bos­

ton High School?



[5 4 ]

A. I didn’t see any. I saw none, so I had no way 
of knowing whether they had any.

Q. Please state whether or not, in your opinion, 
the facilities for instruction in science at the Hoffman- 
Boston High School are equal or unequal to the facili­
ties for instruction of science in the Washington and 
Lee High School?

A. At the Washington and Lee High School 
there are facilities that are superior because of the 
number of rooms. That per se would not be a rea­
son for thinking they are superior, but there are 
enough rooms where you might have special at­
tention given to a particular subject in a particular 
room. I think the conclusion might easily be reached

Q. In your professional opinion, Mr. Picott, is it 
better for the students in science to have a separate 
room devoted to the instruction of a particular type 
of science as, for example, a separate and specially 
equipped room for physics and another for chemistry 
and another for biology and another for general science, 
(R. p. 308) than it would be to have a single room 
or laboratory equipped in which different courses in 
science might attempted to be taught?

A. The answer is obvious to that. You can cer­
tainly have a broader space and by broader space I 
mean more facilities and more equipment which would 
mean that you would have better opportunity to use 
more of this equipment and become acquainted with 
its use and your instruction might be helped if you 
had separate rooms. Obviously, you could do a better 
job if you had a room especially devoted to physics 
than if you had all of the sciences, chemistry, physics, 
biology and general science in one room. Of course,



[55]

that assumes also that you would have teachers who 
might be likewise defined in their majors.

Q. Mr. Pieott did you make an examination of 
the teacher’s lounges at the Washington and Lee High 
School?

A. Yes. I was impressed with their abundance and 
with their decorations. I think there might be some 
question as to whether they are large enough but, 
if I know teaching correctly, they are large enough 
for the time that teachers would have to use a lounge 
room, which isn’t too often.

Q. About how many lounges for teachers did you 
see at the Washington and Lee High School?

A. I don’t know if I can accurately count up but 
I recall seeing a lounge for men and for women, I 
would say, on each floor there are three floors. 1 am 
(R. p. 309) not too sure about that.

Q. Will you describe for the information of the 
Court the equipment and the conveniences and the 
appointments which you saw in the teachers’ lounges 
at Washington and Lee High School?

A. I recall in one lounge for the men there was 
the usual lavatory facility. There were chairs bound 
with new plastic material or they might have been 
real leather. I would suppose they were the ordinary 
plastic bound sofas and lounge chairs. There was a 
table. I recall vividly on the second floor, facing the 
building to the right rear, there was quite an impres­
sive woman’s lounge. I say impressive because I thought 
it was equipped fairly well for the purpose, that is with 
the usual table, possibly as many lounge chairs and one 
large lounge and many other smaller chairs, with a 
wash basin.

Q. Any lavatory facilities?



A. And lavatory facilities.
Q. What, if anything, did you find at the Hoff- 

man-Boston High Schoool in the way of a teachers’ 
lounge or lounges?

A. There is a section off from the platform of the 
auditorium which I understand had marked on it, if I 
remember correctly, a lounge.

(R. p. 310) Q. Please state whether or not this 
is the portion of the Hoffman-Boston High School 
which is shown in Plaintiff’s Exhibit No. 9?

A. Yes, it is called a teachers’ lounge. At the time 
we visited it, there was a washstand, there were two 
tables, one turned on top of the other one; there were 
no lounge chairs, no appointments certainly that were 
recommended as a lounge. I don t know whether it was 
a lounge for women or men. I recall seeing stored in 
the corner some mats for tumbling and, generally 
speaking, it was certainly not impressive of being con­
ducive to rest that a lounge, I suppose, is designed to 
afford.

Q. How did it compare in size with the lounges 
found at the Washington and Lee High School for 
teachers?

A. Generally speaking, the Washington and Lee 
lounges are rectangular, if I recall, whereas this space, 
taking out the space taken up by the steps, is al­
most a square. The Washington and Lee lounges are 
larger.

Q. Did you find any equipment in the so-called 
teachers’ lounge at the Hoffman-Boston High School 
of the same or similar character as the equipment 
found in the teachers’ lounges at the Washington and 
Lee High School?

A. I am glad you said "so-called because if it



[5 7 ]

hadn’t been labeled “Teachers’ Lounge”, I should 
not have known that it was a teachers’ lounge, where­
as obviously one, upon entering the teachers’ lounge 
(R. p. 311) in the Washington and Lee School, would 
know that this is a teachers’ lounge and I think that 
is as it should be. Washington and Lee has the proper 
type of lounge, maybe not enough of them, and this 
word “so-called” is the word that applies to it.

Q. Did you see any equipment in the lounge of 
the Hoffman-Boston which was the same or substan- 
iallv similar in character to any of the equipment which 
you found at Washington and Lee?

A. No.
Q. Did you make an examination of facilities for 

instruction in typewriting at the Washington and Lee 
High School?

A. Yes. I went in the room for typing.
Q. Will you describe the facilities which you ob­

served at the Washington and Lee High School?
A. May I have the pictures on that? Well, the basic 

difference that I saw in the two rooms, aside from their 
size, and the preponderance of typewriters in the 
Washington and Lee room, was the mimeograph ma­
chine which was very much in sight in Washington and 
Lee and which, to my way of thinking, is a good ad­
dition to the teaching of commercial subjects or to 
a commercial course. I do not recall seeing a mimeo­
graph machine in the Hoffman.-Boston School. I 
wouldn’t want to say there wasn’t one in the room 
designed for that purpose but I don’t recall seeing 
it.

(R. p. 312) Q. How many rooms at Washington 
and Lee are devoted to instruction in typewriting?

A. I remember seeing two, I think.



[ 5 8 ]

Q. How was the equipment in these two rooms so 
devoted to instruction in typewriting?

A. Both rooms were quite filled with typewriters.
In almost all available space in both rooms you found 
typewriters.

Q. Did you have an occasion to examine the facili­
ties for instruction in typewriting at the Hoffman- Bos­
ton High School?

A. Yes, I did. If I counted them correctly, there 
were nine. I think the figures are immaterial. I count­
ed the typewriters but, at least, they were all stored 
on the desks on one side of the room.

Q. Nine typewriters, did you say?
A. I would say that. I wouldn’t want to be too 

certain of the number. I remember counting them for 
my own purposes.

Q. How many rooms are devoted to instruction in 
typewriting at Hoffman-Boston?

A. It really appears that a portion of one room is.
Q. Did you notice any charts and other instruc­

tional aids present in the typewriting classroom at 
Washington and Lee?

A. Yes. There was the Royal typewriter chart, 
Underwood typewriter chart and the Underwood type­
writer firm seems to have designed a chart which was 
(R. p. 313) hanging from the wall. I didn’t see any 
charts at the Hoffman-Boston School. It might be that 
those charts are available but they weren’t there on the 
day I made the visit.

Q. Please state your opinion as to whether or not 
the facilities for instruction in typewriting at the Hofi- 
man-Boston School are equal or unequal to the facili­
ties afforded for the instruction of typewriting in the 
Washington and Lee High School.



[5 9 ]

A. Here is the type of thing that I think one ought 
to pay attention to: Certainly good posture is essential 
in the teaching of typing. In most of the chairs and 
most of the seating arrangements at the Washing­
ton and Lee School I found what is considered by 
many to be the proper type of chair, whereas, on the 
contrary, at Hoffman-Boston some of the chairs were 
the simple type of folding chair, which it seems had 
been borrowed from the auditorium and I presume, 
when the auditorium is in use, must immediately be 
carried back to the auditorium. Items of that sort, it 
seemed to me, need attention.

Q. Did you make an examination of the Washing­
ton and Lee High School with reference to site, grounds, 
and architectural construction of the buildings which 
compose that school unit?

A. Yes.
(R. p. 314) Q. Will you describe for the informa­

tion of the Court what you observed in that connec­
tion?

A. I should say that certainly as compared — and 
I emphasize “as compared” — to Hoffman-Boston, the 
Washington and Lee School is a beautiful place. I 
have seen many schools that are much more beauti­
ful, if you want to make the comparison, in other 
states, but in my opinion the Washington and Lee 
School outside of one other high school in Virginia, 
the one located in Winchester is about as beautiful 
as any other school in the State of Virginia. That is 
a matter of opinion, and I am referring, of course, 
to the white high schools. Obviously, there is no com­
parison of the two when you look at the Hoffman- 
Boston High School.

Again, I think that the Hoffman-Boston School wasO ?



[6 0 ]

designed on the old pragmatic theory that what you 
put up you insist be useful and that ornaments are 
entirely out of the question.

Q. Do ornaments in any wise affect the instruc­
tional value of the school?

A. I would say they add to the the morale of the 
school as far as beauty goes. I would say yes; it might 
be a question as to how much. I always notice, how­
ever, that the better high schools all over our State 
of Virginia are, particularly those for at least one group 
of people, always ornamental. I have come therefore 
to the inescapable conclusion that if you wish the 
(R. p. 315) community to have pride in the school, then 
the school, in order to be the community type of school, 
to afford the type of spirit, esprit de corps that we 
want, should have some decoration. I think it adds 
to the school.

Again, there may be persons who feel that all you 
need is a teacher on one end of a log and a pupil on 
the other end, but most people in education have 
long ago decried that pernicious consent and now look 
upon the school as being first of all, useful, but also 
beautiful.

Q. Would you express an opinion as to the com­
parison of these two schools in those respects, that 
is, whether Hoffman-Boston is equal to or unequal to 
the Washington and Lee High School in those respects?

A. It is difficult for me and I should think it would 
be difficult for any person in education or out of ed­
ucation to honestly look at the two buildings and not 
choose the Washington and Lee building.

#  #  #  & #

(R. p. 316) Q. Mr. Pieott, did you have occasion



[ 6 1 ]

to examine the industrial arts facilities at Hoffman- 
(R. p. 317) Boston High School?

A. Yes, I did. We were there on Sunday morning 
because we couldn’t get in on Saturday.

Q. How many industrial shops or vocational shops 
did you see at the Hoffman-Boston High School?

A. There was one room. I would suppose you 
could call that the shop.

Q. Please state whether or not the facilities which 
you have just made reference to are those which are 
shown in Plaintiff’s Exhibits Nos. 67 and 68?

A. That is correct.
Q. How many vocational shops did you see at the 

Washington and Lee High School?
A. In this regard or category, Washington and Lee 

obviously has one of the finest set-ups of any high 
school — I would say it compares favorably with any 
high school in America, that is, those east of the Miss­
issippi that I have had contact with. It has an adequate 
building, easily divided into a half dozen or more 
rather complete shops.

B y  th e  C o u r t :

Q. Is it a building separate from the high school?
A. Yes, a separate building which apparently has 

been erected at some cost and the equipment seems 
to be the best type available.

B y  M r . R o bin so n :

(R. p. 318) Q. I should like to direct your atten­
tion to Plaintiff’s Exhibits Nos. 53 and 54, being photo­
graphs of the industrial arts shop in the Washington 
and Lee High School.

A. Yes.



[ 62]

Q. Did you examine that shop?
A. Yes, I did. I spent some time there.
Q. Would you express an opinion as to whether 

or not the single shop which is found at the Hoff- 
man-Boston High School is equal to or is unequal 
to the industrial arts shop alone at the Washington 
and Lee High School?

A. I should think this one room, one shop alone, 
at the Washington and Lee School is superior defi­
nitely to the entire shop at Hoffman-Boston. Here 
are my reasons. This one shop seems to have more 
equipment. The arrangement of the equipment in the 
Hoffman-Boston School — you have got some brick­
laying over here in the corner which apparently was 
left in June, not in the best of condition or order, 
and you have got another something over here. There 
didn’t seem to be any semblance of a type of orderly 
arrangement that you have in the shop at Washington 
and Lee. It would appear to me definitely that this 
one shop might have merit and would be rated above 
the shop at Hoffman-Boston. I am not saying any­
thing at all about the numerous other shops at Wash­
ington and Lee.

Q. In addition to the industrial arts shop, please 
(ft. p. 319) state whether or not you examined the 
automobile mechinics shop at the Washington and Lee 
School which is shown in Plaintiff’s Exhibits Nos. 51
and 52?

A. Yes, I did. I was impressed with several things. 
Here you have got a 1949 Pontiac in cream color 
facing the door.

Q. For what purpose?
A. This is one of these dual cars. In the State of 

Virginia we have rightly gone on record to do some­



[ 6 3 ]

thing about the terrific toll of accidents that we have 
and so many schools now are teaching youngsters 
how to drive cars, and, in my humble opinion, it is 
a fine move. It is under our Department of Physical 
Education — safety. I immediately wondered did the 
Hoffman-Boston have any 1949 Pontiac car of similar 
type. I did not find that. In addition, it appears that 
this shop is quite well equipped for the purpose. For 
example, there are several engines which would seem 
to be in sight on which I assume the students worked 
at times to get practice. Of course, space would not 
permit that in the shop at Hoffman-Boston, to say 
nothing of other considerations.

Q. Did you see anything in the vicinity of the 
automobile mechanics’ shop at Washington and Lee 
which was an aeroplane?

A. Yes, I saw the body parts of a former plane 
(R. p. 320) minus the wings. I believe that is what it 
was, which was at one time an aeroplane, yes.

Q. Did you see anything at all at Hoffman-Boston 
High School which would afford facilities for instruc­
tion there of a course or courses in automobile me­
chanics?

A. No, not in automobile mechanics.
Q. Mr. Picott, I should like to direct your atten­

tion to Plaintiff’s Exhibit No. 55 which is a photograph 
of the mechanical drawing room. Did you make an 
examination of the mechanical drawing room at Wash­
ington and Lee High School?

A. Yes. The room is filled with tables suitable for 
drawing, with drawers on one side—the type desk which 
has leg space on one half of the desk or a similar 
portion of that desk and on the righthand side, that 
is the righthand side of the person facing the desk.



[ 6 4 ]

who is sitting at the desk, there are several drawers. 
The top is flat. The type of chair or seat is the school 
type which is generally found in the mechanical arts 
rooms. There was a library, certainly a small book­
case. The lighting seemed to be excellent, at least, it 
seemed to be adequate for the purpose. We turned on 
the lights and it looked to me, and all in all I would 
say, with a good teacher, this mechanical drawing 
division would stand up with the other parts of the 
shop.

Q. Did you see any facilities whatsoever for in­
struction in mechanical drawing at the Hoffman- Bos­
ton High School?

(R. p. 321) A. I recall none.
Q. Mr. Picott, I should like to direct your atten­

tion to Plaintiff’s Exhibits Nos. 56 and 57, the photo­
graphs of the machine shop.

A. Just a moment please.
Q. At the Washington and Lee High School. Did 

you make an examination of this shop?
A. Yes. This shop seems to have quite an abund­

ance of machinery. It would appear that here is a 
place where a sizeable — in quotation marks — chunk 
of money has been spent to equip the shop and I 
again think rightly so. There appear to be numerous 
types of machines, heavy and light in addition to 
the Link trainer which was in the rear part of the 
room which is used for, I suppose, if it is used at 
all, training in aviation or pre-aviation courses. I was 
very much impressed also with the fact that you have 
got some desks right in the shop. This is one of the 
larger rooms.

Q. Did you see any facilities whatsoever at the 
Hoffman-Boston School which in any way were sim­



[ 6 5 ]

ilar or comparable to the facilities in the machine shop 
in the Washington and Lee High School?

A. Oh, no. There was no comparison.
Q. Was there any machine shop or anything re­

motely resembling a machine shop at all at the Hoff- 
(R. p, 823) man-Boston High School?

A. It is possible that several of these lathes in this 
one room alone cost almost as much as the entire 
equipment in the Hoffman-Boston shop.

Q. Is your answer to my question “no”?
A. No.
Q. Mr. Picott, directing your attention to Plain­

tiff’s Exhibit No. 58, which is a photograph of the 
sheet metal shop of the Washington and Lee High 
School, did you make an examination of this room?

A. Yes, I did.
Q. Will you say for the information of the Court 

the equipment and appointments which you found
present in that room?

A. There was evidence, for example, of tables suit­
able for sheet metal work, and in the roof part of 
the room there was some actual sheet metal work 
that I presume had been done by the pupils or cer­
tainly there were examples of the proper type of sheet 
metal work which should be done. There was an 
office, I would say, for the instructor and the part 
that impressed me was that I saw no sheet metal 
work at all, if my memory is correct, in the Hoffman- 
Boston School.

Q. Did you see any facilities at all in Hoffman- 
Boston for the instruction there of courses or a course 
in sheet metal work?

(R. p. 323) A. There wasn’t any evidence on the 
day I was there.



[ 66 ]

Q. Mr. Picott, directing your attention to Plain­
tiff’s Exhibits Nos. 59 and 60, being photographs of the 
woodworking shop at Washington and Lee High 
School did you make an examination of that shop?

A. Yes. Here is obviously a very well equipped 
shop. For example, the equipment extends to the por­
tion on the rear of the building which carries away all 
of the waste or sawdust outside of the building so 
that in most of the machines you don’t need to sweep 
it up, but in most of them the sawdust is automatic­
ally carried out of the room.

Q. Are they the ducts which are shown in the 
photographs?

A. Yes. A good bit of money has been spent on ducts 
runn in g  to many machines or most of the machines, 
so there was no need to sweep up even the sawdust 
that would accrue from cutting a piece of board. We 
saw some samples of some of the work.

Q. Can you refer to the photographs and point 
out such examples which you have just mentioned?

A. Yes, there was a cabinet which was in evidence 
which is on Plaintiff’s Exhibit No. 59.

Q. On which side?
A. On the righthand side from the reader’s view.
(R. p. 324) (). In what position is it shown to be?
A. It is flat with the doors or glass portion facing 

upward. It could very well be used for book storage 
and I thought it was certainly a fair example of good 
teaching, if that is a sample of the work. If I recall 
also we saw doors, complete doors.

Q. Can you refer to either of the two photographs 
and to such an example?

A. Yes. In Plaintiff’s Exhibit No. 60 there is to 
the right center an example of a door which I took



[ 67 ]

up and looked at from all sides and this door was 
made in the shop. It is more or less a very good pro­
fessional job so that it appears that not only the 
facilities are adequate but here you have got a shop 
that does fairly good work.

Q. Did you see any facilities of the Hoffman-Bos- 
ton High School the same or substantially similar to 
the facilities contained in the woodworking shop at 
Washington and Lee High School?

A. Definitely, no. The woodworking shop — the 
answer is no.

Q. Please state v/ether or not, in your opinion, the 
industrial arts shop at Hoffman-Boston High School 
is equal to or unequal to the woodworking shop at 
Washington and Lee High School?

A. I would say unequal.
(R. p. 325) Q. Calling your attention, Mr. Picott, 

to Plaintiff’s Exhibit Nos. 61 and 62, being photo­
graphs of the printing shop at the Washington and 
Lee High School, did you make an examination of 
this printing shop?

A. Yes. There was in evidence a sample of the 
work that was done there. This print shop seems to 
have a galley for type, they have one or two short 
run machines for practice, tables, a display of the 
different type of type, that is actual lead type that is 
used, Gothic or Roman, etc. I would say that this shop 
certainly could give a person the beginning of work­
ing in a print shop so he could secure a job and fit 
in rather well as an apprentice in a regular business.

Q. Did you have an occasion to examine the Hoff­
man-Boston High School to determine whether or not 
it had any printing shop or any facilities whatsoever 
for instruction in printing there?



[ 68]

A. I saw none whatsoever.
Q. Mr. Picott, would you express your opinion as 

to whether or not the equipment for instruction in vo­
cational subjects at Hoffman-Boston High School is 
equal to or unequal to the equipment and the facilities 
afforded for the instruction of vocational subjects at 
the Washington and Lee High School?

A. There is no basis, as I see it, or certainly very 
(R. p. 326) little for comparison — Washington and 
Lee School is so superior.

Q. Both with respect to physical plant and set­
up, facilities and equipment?

A. I would say yes.
Q. Would you express your opinion, Mr. Picott, 

as to whether or not the facilities and equipment and 
the appointments and conveniences for academic in­
struction at the Hoffman-Boston High School are equal 
to or unequal to those afforded for the academic in­
struction of pupils at the Washington and Lee High 
School?

A. There is, of course, a difference in the size of 
buildings which must he taken into consideration, so 
that you have more rooms at the Washington and 
Lee than you have obviously at Hoffman-Boston, but, 
outside of that, the equipment and the facilities for 
academic training at the Washington and Lee School 
seem to me to be definitely superior.

Q. In your previous testimony, Mr. Picott, you 
made reference to a certain painting or picture in the 
art classroom at Washingto nand Lee High School. 
Will you give the Court the benefit of your explana­
tion in regard to that?

A. Yes. I suppose I had no reason to be riled but 
I wish the picture hadn’t been there.



[ 6 9 ]

Q. Which room was it in?
A. It was in the art room, I belive. You have pic- 

(R. p. 327) tures of four or five nationalities and here 
I suspect the teacher has taken for her pupils samples of 
the best that these nationalities have as a part of their 
racial culture and background. For example, in the 
Spanish, you have the Spanish dancer which is in­
herently a part of the great Spanish tradition. Like­
wise, in the Chinese there was something which praised 
the Chinese and which I would assume would tell the 
generation of white boys and girls who might, attend 
Washington and Lee that the Chinese are a great 
people and here is something to tell you they are 
great, but right in the center was this picture of the 
race of which I happen to belong, and a picture which 
I hope is not indicative of the thinking, of that teacher 
nor the school. I was ashamed of it. Here was a
picture of a number of persons of my r a c e ---- and
I suppose the teacher wanted it to be typical, although 
I despise such an assertion — here was a picture of 
two persons who were shooting, as we call it, craps, 
in quotation marks. If that is indicative of the desire 
on the part, either of that teacher or of the school 
itself, to promote racial good feeling and to teach 
white boys that the negro race has something in it 
besides those certain conditions, then I think you 
have a very poor way of demonstrating it. Certainly 
I would have felt much better about the whole thing 
if I hadn’t seen that picture. If they want to keep 
the Chinese, fine, or Japanese or even any other group, 
(K. p. 328) fine. I would like to see that picture come 
down because it would do something to every white 
boy and girl who attends that school.

# * # * #



[ 70 ]

(R , p. 329) B y the C o urt :

Q. In the Hoffman-Boston School is the shop in 
a separate building?

A. Yes, sir, the shop is in a separate building in 
the rear of the main building. In one part of the room, 
right on the ground there is a hallway between the 
building. One part is the home economics department 
and the other part is the shop.

Q. One room?
A. Well, it is two rooms actually. .
Q. I mean for the shop.
A. One room in the shop.
Q. Is it a one-story building?
A. One-story building which was built afterwards 

so that you have got about two good classrooms, one 
used for the shop, maybe slightly larger, and the other 
used for a home economics unit.

Q. The shop is devoted to what type of industrial 
arts — that one-room shop?

A. They try to do several things there. I would 
say certainly bricklaying was in evidence and I v/ould 
say they likewise teach some general shop.

Q. What do you call general shop?
(R. p. 330) A. It would be an indication — for 

example, they had some woodwork, more of the toy 
nature than anything substantial. There was some little 
device for holding a vase on a wall which would be 
wood-working but quite of an amateurish nature. There 
was also bricklaying and possibly some — I doubt if 
there was much else.

Q. And automobile mechanics?
A. No automobile mechanics.
Q. What type of tools were in that room?



[ 71]

A. There were some tools which were locked up 
which could be seen, tools like wrenches, hammers, 
etc.

Q. Any carpenter tools?
A. Yes, some carpenter tools.
Q. Any bricklaying tools?
A. I don’t remember seeing some but they must 

have had because they had bricklaying and some bricks 
were in evidence on the concrete floor where the in­
structor had been teaching the boys how to lay bricks 
and make a comer, so apparently they do have brick­
laying.

# # # * #

(R. p. 337)

C ross E xam ination  

B y  M r . D ouglas:

Q. Perhaps that was it. Let us leave that for a 
monment. Is there any demonstrable relation that 
necessarily follows between bigness and excellence of 
educational opportunity or instruction?

A. You can find authority on both sides. At the 
moment I can't think of such authority. I could cer­
tainly produce it if requested in time.

In Virginia, our State Board of Education has for 
a long time decided that the best school that you can 
have is what we call a comprehensive high school. 
That comprehensive high school would have about 
five or six hundred pupils. We feel in Virginia that 
(R. p. 338) a high school of about five or six hun-



[7 2]

dree! pupils will enable you without too high a cur­
rent operation cost and per capita cost to offer a 
broad curriculum. You would be able to have tea­
chers who might teach chemistry alone or physics 
alone. You would be able to employ a coach who 
has a major in physical education rather than some 
person who teaches business but has an interest in 
physical education. We feel definitely that a high 
school of fifty or one hundred is not the comprehen­
sive or the best type of school. So in the State of 
Virginia we are talking in terms now of the compre­
hensive school of about five hundred children. When 
you go over that number, obviously you may or may 
not have a continued good school. There is very de­
finitely a tendency on the part of some of our big 
schools — I have had a chance, for example, to talk 
some years ago to the Principal of one school in Brook­
lyn, New York, which had ten thousand high school 
students, on the question of whether that school is 
better because it is a large school or would you prefer 
to have a school of one thousand. That particular 
Principal in the field felt that he could offer more by 
having this big school but he insisted in talking in 
terms of trying to keep the personal contact that you 
might have and dividing the school into smaller units. 
I saw very definitely there are points on both sides 
for a good school. Smallness of itself may definitely 
(R. p. 839) be a handicap and yet bigness of itself 
may be a handicap. It depends on your school orga­
nization. It depends on the offering. Any number of 
factors must be considered before you could say yes 
or no. It is not the type of question to which I would 
want to say categoroically yes or no.

# # # # #



[ 7 3 ]

(R. p. 340)

(The question was read as follows: “In draw­
ing the comparison have you taken into consid­
eration the number of students who had to make 
use of the facilities that you have compared? 
Do you understand the question?”)

A. Yes, I have, because I feel that one child should 
be given the opportunity, if he has the qualifications 
and desire, under the democratic theory, to have that 
course if he is eligible for it.

* # # # w

(R. p. 341) Q. If you accept as a fact that at the 
Hoffman-Boston High School all students of all grades 
are given regular required physical instruction as a 
part of their curriculum or courses and if you accept as 
a fact that at Washington and Lee High School there 
are so many students that only the 10th grade can 
have physical instruction, would that make any dif­
ference in your comparison of the facilities of the two 
schools?

A. I would like to comment hurriedly on that, 
if I may.

Q. How about answering the question yes or no 
and then comment?

A. (R. p. 342) A. The answer would be no, for 
this reason: I saw no facilities at Hoffman-Boston for 
8th, 9th, 10th, 11th, or 12th grade children except out­
door facilities or slight calisthenics which could be offer­
ed in the auditorium, so that the children, especially on. 
rainy days — I would like to know what they do when it 
rains — whereas, regardless of the number of pupils 
which could use the facilities at Washington and Lee—



[ 7 4 ]

and I am certain they need more facilities — schools 
always do — there are at least some facilities like gym­
nasiums which can be used by some of the children 
whereas no gymnasium at all for any grade exists at 
Hoifman-Boston. That is the crux of my thinking. 

* * * * *

( R. p. 871) Q. I am asking you whether you know 
that Washington and Lee has equipment superior to 
that of Hoffman-Roston? I am not talking about the 
building or the architecture or the lawn; I am merely 
talking about the equipment that is contained in the 
science room.

A. I would say it is superior because you have an 
extensive operation of four rooms with a class in 
each subject one year which you cannot have in a 
smaller school and therefore, because you have an op­
portunity, it is a superior operation all around, it 
seems to me. That is a matter of opinion, of course.

Q. And because it has those four rooms and has 
a class going each year, instead of giving the science 
in rotation, you draw the conclusion that the facilities 
are superior?

A. Yes, I think that is a sensible conclusion. 
* * * * *

(R. p. 372) Q. So you wouldn’t think of main­
taining four separate rooms with four separate sets 
of equipment when there were only twenty-five stu­
dents in the group?

A. I must come back to the one child. If there is 
only one in the democracy who is entitled to get the 
courses that he needs — and it is a question, it seems 
to me here, not of how many pupils you have but



[ 7 5 ]

a question of taking care of your pupils and if it is 
one negro boy, it seems to me it ought to be done.

Q. Isn’t it a fact that one teacher teaching two 
related sciences, such as chemistry and biology, hav­
ing one room and one place to work, one demonsrta- 
tion table, can give better instruction than teachers 
who switch back and forth from one room to the other?

A. In fact, just the opposite. We have become in 
America a nation of specialists and, definitely speak- 
(R. p. 373) ing the case is just the opposite. If you 
have got people who have specilialized in biology and 
who go to Woods Hole, Massachusetts, every year to 
study biology, naturally, they would be better per­
sons. I would much prefer to be taught by specialists. 
That isn’t always true.

# # # # *

(R. p. 374) Q. While you are on that subject of 
the spirit of the school, doesn’t a student in a small 
school benefit infinitely more in absorbing the spirit 
of the school than a student in a large school?

A. That isn’t true. I don’t think you can get facts 
to show that, simply because you have a small school, 
you have a good school. You come back to that. It 
depends on the school. A small school can be a de­
finite handicap because it doesn’t have certain sports, 
for example, and the morale would be low. It de­
pends on the school. I certainly would feel that there is 
great virtue in being average, perhaps five hundred. 
There may or may not be virtue in being large but 
the answer is certainly is not a definite one, either yes 
or no.

# # a # #



[7 6 ]

R e d ir ec t  E xam ination

(JR. p. 380) B y  M r . R o bin so n :

Q. It is necessary, Mr. Picott, to assemble, as a 
general rule, all of the pupils of a given high school, 
either in the auditorium of that school or in the gym­
nasium of that school, at one single time or at any 
single time?

A. I can think of a few instances where you want 
all of your pupils together. There may be some. As 
a general rule, you probably divide your pupils per­
haps according to age levels or perhaps for various 
other reasons.

Q. Considering the enrollment of Washington and 
Lee High School at somewhere between eighteen hun­
dred and nineteen hundred pupils, would you state 
your opinion as to whether or not the auditorium fa­
cilities and the gymnasium facilities at that school 
(R. p. 381) are adequate for the needs of the pupils 
and for the purposes for which those facilities are there 
maintained?

A. It seems to me they are quite adequate. The 
auditorium will seat 1157 or 1127, approximately, which 
means that more than half of your pupils or there­
abouts, could be seated at one time and, when you 
put in the additional space, you might get most of 
them. Certainly, your gymnasium facilities, it would 
appear to me, if you had a stagger system, you could 
arrange to give physical education to all of your child­
ren provided the administration worked out the system 
properly at sometime during the week, because you 
could arrange such a stagger system for it.

Q. Mr. Picott, please state whether or not it is



[ 7 7 ]

possible in the main auditorium at Washington and 
Lee High School to have one activity conducted in 
the auditorium and another activity conducted in the 
girls’ gymnasium which is, in fact, the stage of that
auditorium, all at one time?

A. Yes, sir. It appears so because you have folding 
doors which serve as a partition between the platform 
of the auditorium and the gymnasium portion and 
simply by means of closing those folding doors prop­
erly, it would be possible to have two activities go­
ing on at the same time, one in the auditorium and 
the other in your gymnasium section.

(R. p. 382) Q. Please state whether or not at the 
same time it would also be possible to have, going on 
simultaneously, another activity in the music auditor­
ium of Washington and Lee High School?

A. Yes.
Q. Is it possible that there could be conducted at 

Hoffman-Boston High School more than a single ac­
tivity which would require the use or a need for au­
ditorium facilities?

A. No, because there are no partitions or folding 
doors to separate any space in the Hoffman-Boston 
auditorium.

Q. Referring again to Washington and Lee High 
School, would it also be possible to have conducted in 
the boys’ gymnasium an activity in addition to activities 
which might be simultaneously conducted also in the 
main auditorium in the girls’ gymnasium and in the 
music auditorium?

A. I should think yes.
# * # ** «

(R. p. 383) Q. If it should be necessary to use the



[7 8 ]

auditorium or, as Mr. Douglas called it, the assembly 
room at Hoffman-Boston High School for study pur­
poses, would it be possible at any plase at Hoffman- 
Boston High School to conduct an activity at the same 
time which would require a need for auditorium facili­
ties?

A. Very difficult. The only other space I could 
think of that you might use would be the library and 
then you wouldn’t have the library in use as a library, 
so the answer would probably be no.

# # # #

MARTIN D. JENKINS 

D ir e c t  E xam ination

(R . p. 384) B y  M r . R a n so m :

Q. Will you state your full name and title?
A. Martin D. Jenkins.
Q. And your address?
A. Baltimore, Maryland.
Q. Will you state to the Court your academic ac­

hievements and degrees and the schools from which 
you obtained degrees?

A. I have a Bachelor of Science Degree from Ho­
ward University, Bachelor of Arts Degree from In­
diana State Teachers’ College, Master of Science De­
gree in Education from Northwestern University and 
a Ph. D. Degr ee.

Q. That is Doctor of Philosophy?
A. That is right, from Northwestern University.
Q. Assuming that the Doctor of Philosophy was 

the last one, when did you receive that?



[7 9 ]

A. 1935.
Q. In what field did you specialize for your ed­

ucation in these various schools?
A. In the field of education after the first under­

graduate degree.
(R. p. 385) Q. Have you had any teaching or ed­

ucational experience in actual practice?
A. I have taught in a number of different colleges, 

first the Virginia State College.
Q. What year?
A. 1930 to 1932, then at North Carolina A. and T. 

College, 1935 to ’37, then Dean of Instruction at Cha­
ney 1937 and ’38, and I have taught at Howard Uni­
versity for ten years.

Q. In all of those experiences were you engaged
in the field of teaching education as a subject?

A. Yes.
Q. Have you had any experience, Dr. Jenkins, in 

investigating schools and making surveys of educa­
tional systems throughout the country?

A. Well, a good part of my time during the last 
ten years has been in this type of activity. I am a mem­
ber of the Bureau of Educational Research at Howard 
University.

In 1940 and ’41 I was senior specialist in higher ed­
ucation at the United States Office of Education, at 
which time I had an opportunity to make studies of 
negro schools in each of the seventeen southern states 
and the District of Columbia.

I have also been a staff member of the study of public 
schools in Delaware which was done under the aus­
pices of the American Council on Education at the 
(R. p. 388) direction of the Legislature of the State 
of Delaware.



[8 0 ]

I was also a staff member of the survey staff for 
the study of public schools and colleges in the State 
of Maryland which was also done under the auspices 
of the American Council on Education.

Q. Was that also under the direction of the General 
Assembly of Maryland?

A. Paid for by the General Assembly of the State 
of Maryland. I have done a number of individual 
studies — studies of individual school systems in Char­
lotte, North Carolina, Little Rock, Arkansas, Baltimore, 
Maryland, and at various times in Washington, D. C., 
and the study here in Arlington.

Q. The study in Arlington was done at the request 
and under the direction of counsel for the plaintiff in 
this case? Is that correct?

A. That is right.
Q. Have you any publications to your credit in 

the field of education?
A. Well, I have written several monographs in 

the field of education and perhaps fifty different art­
icles appearing in the leading professional and ed­
ucational journals.

Q. Are you listed in ‘'Who’s Who in America” as 
a leader in educational field, to your knowledge?

(R. p. 387) A. Yes, I am.
Q. Are you listed in any of the other so-called 

compendia of the leading educators, to your know­
ledge?

A. Well, “Who's Who in America” of course covers 
the entire field of American life. I am listed also in 
Leaders in Education which is sort of who’s who of 
people in education and I am to be listed in the new 
volume being issued by Marcus & Company, the pub­
lishers of “Who’s Who in America”, in a volume en­



[ 8 1 ]

titled “Who Knows and What’ in which they attempt 
to present biographical sketches of the experts in each 
field in the United States, such as metallurgy or ar­
cheology or education. I have the honor of being -in­
vited to be listed in that volume which is a forthcom­
ing publication.

Q. One further question before I tender you to 
the Court. You stated that from the period of 1940 
to 1941 you did study the negro schools in seventeen 
of the southern states under the auspices of the United 
States Office of Education?

A. That is right.
Q. You were a senior specialist in that?
A. That is right.
Q. That was your title?
A. Yes.
Q- Were you on loan from Howard University

for that period?
(R. p. 388) A. At that time.

M r . R a n so m : I wish to tender Dr. Jenkins
to my opposing counsel and to the Court as 
an expert, with the understanding that I will, 
of course, ask him to offer opinions based upon 
his own observation and upon his general field 
of knowledge.

T he C o u r t : Any cross exam ination?

M r . D ouglas: N o.

T h e  C o u r t : Let him  be admitted.

B y M r . R a n so m :

Q Dr. Jenkins, at the request of counsel for the



[ 8 2 ]

plaintiff in this case, did you in 1947 make a study 
and an examination and a comparison of the Hoff- 
man-Boston High School and the Washington and Lee 
High School in Arlington County, Virginia?

A. Yes, in late ’47 and early 1948.
Q. And is that the report which you submitted to 

me on January 21st of 1948?
A. Yes.

# * # # #

(R. p. 389) Q, Dr. Jenkins, since you completed 
your exmination and comparison of those two schools 
in late ’47 and made your report in ’48, have you had an 
opporunity to examine statistics and studies of the two 
schools in Arlington County which have been pre­
pared by Dr. Dawson, Howard A. Dawson, Director 
of Rural Service for the National Education Associa­
tion, which purports to bring that information up to 
date? Have you had an opportunity to examine that?

A. I have seen the report by Dr. Dawson dated 
August 1949, and a supplementary appendix.

Q. And did you see a copy of the statistics that 
were prepared for him or under his direction upon 
which his report is based?

A. Yes, and largely incorporated in the memoran­
dum.

# # # # #

(R. p. 391) Q. Dr. Jenkins, in preparing your own 
report which you made on January 21, 1948, to what 
information did you have access?

A. Well, I followed the usual procedure in studies 
of this kind, I had access to certain statistical data 
which was provided by the School officials such as en­



[ 8 3 ]

rollment and curriculum and the like. I visited both 
of the schools concerned, Hoffman-Boston and Wash­
ington and Lee, and talked with the Principals, sup­
ervisors, teachers, — some teachers — superintendents, 
observed the equipment, observed some of the classes 
in both schools.

Q. Did you observe the actual facilities at both 
schools, physical plant, the equipment that was used 
in the classrooms?

A. I paid very careful attention to those items.
Q. Did you also talk to the various teachers as 

(R. p. 392) to the method of instruction used in the 
two schools so as to make a comparison?

A. To some extent. There was no attempt to in­
terview each teacher nor was any attempt made to 
explore with any individual teacher fully the question.

Q. Did you discuss with the Principals or the pre­
siding officers at each of the schoools the types of 
courses and the names and numbers of courses offered 
and then discuss with them the method in which those 
courses were taught?

A. Again, in a partial way.
Q. What do you mean by “partial”? Will you ex­

plain that?
A. There was no attempt, for example, in either 

school to go down course by course and ask what 
methods are used in teaching this course and what 
mehods are used in teaching this course. On the other 
hand, where at the Hoffman-Boston five or six grades 
are in one class, then an attempt was made to find 
out from both the Principal and the teacher how the 
work was accomplished.

Q. For our benefit, will you tell us, first, so far 
as class structure is concerned of the two schools,



[8 4 ]

whether they are divided into different age groups or 
different educational levels or not?

A. At the Hoffman-Boston School there is an ele­
mentary junior-senior high school organization and 
Washington and Lee is a junior-senior high schol, pre- 
(R. p. 393) dominantly a senior high school. At the 
time I studied the Hoffman-Boston School it was pre­
dominantly an elementary school in terms of the num­
ber of pupils enrolled.

Q. As to the administration of that school, that 
is the immediate administration, is the Principal, I 
suppose you call him, the supervisor of the school, 
the officer in charge — does he have charge of both 
elementary, junior and senior high work?

A. Yes. At the time I made this study he was res­
ponsible for three units.

* * * * *

(Ft. p. 394) Q. Just in order to make the record 
clear, how are these schools designated racially? What 
is Hoffman-Boston School?

A. The Hoffman-Boston School is what is com­
monly known as a negro school.

Q. Washington and Lee is what?
A. Meaning that the Hoffman-Boston School only- 

takes children who are negroes. I won’t atempt to 
go into a definition of that. At Washington and Lee 
only those children who are known as white persons 
attend.

* * * * *

(R. p. 395) Q. During the period that you made 
this report, did you make an inquiry as to the number 
of students who are of either compellable or permiss-



[ 85]

able age in Arlington County who were attending 
schools outside of the County, either at their own 
expense or under some compensation system provid­
ed by the County?

A. There was a plan at this time whereby many 
of the pupils who normally would have attended 
Hoffman-Boston were going to the Washington schools,

Q. You mean the District of Columbia schools?
A. The District of Columbia schools.

*s # *> * *

(R. p. 398) A. During ’46-’47 the Arlington School 
Board paid the tuition of twenty-one negro schoool 
pupils who were attending the senior high schools in 
Washington, D. C.

Q. Dr. Jenkins, after having examined the stat­
istics that have been prepared by Dr. Dawson which 
puport to bring the facts up to date, that is since you 
made your report, have you found any appreciable- 
change in ratios as to attendance at either of these 
schools?

A. Yes.
Q. How did that change occur, assuming the stat­

istics are correct?
(R. p. 397) A. Well, there are two interesting

things. One is that enrollment of senior high school 
pupils at Hoffman-Boston School has greatly increas­
ed. The second is that there seems to be a general 
decrease in the school population among the negro 
population of Arlington. I don’t know whether negroes 
are leaving Arlington, or not. There is a slight or 
some increase in the white school population as a whole, 
including the elementary.



[ 8 6 ]

Q. Do you have any explanation for that, any con­
clusion as to why that has occurred?

A. Not the latter. It is my understanding — I 
don’t think it is either of these reports, however, that 
the School Board no longer is paying the tuition of 
negro pupils who attend the Washington, D. C., schools 
and therefore, many of those pupils are now attend­
ing the Arlington School. That is a matter of hearsay, 
however.

# # # # #

(R. p. 398) Q. In the studies you have made in 
comparison with the figures that are brought up to 
date, that is by Dr. Dawson, assuming that a con­
clusion is reached by Dr. Dawson to the effect that 
there is more money spent per negro child for ed­
ucation in Arlington County than there is for the 
white child — and that includes the overall picture, 
capital outlay, actual tuition costs, library and every 
other facility that is provided — does that have any 
significance, the fact that more is spent on the negro 
child than on the white child?

A. It has some significance but it is not crucial, 
I should say. It was not a crucial way of testing the hy­
pothesis, I say, that schools for whites and negroes 
are equal.

Q. That is the question I want. Would that be 
proof that the negroes are getting superior education, 
because more money is spent for them?

A. No. I would like to explain what I mean by 
that. It is common practice in American education 
in comparing school systems, to compute the per cap­
ita eductional cost and draw certain conclusions about 
the relative merits of school systems, which is an ac-



[ 87]

(R. p. 399) ceptable procedure where school popu­
lations are of comparable size. It is well known, how­
ever, that where there is a disparity, where there is 
disparity in the size of the populations being com­
pared, the per capita costs are almost or might al­
most be worthless and I am surprised to find that 
Dr. Dawson places so much confidence in that partic­
ular figure.

If I might explain by an example how it might 
operate, the data here show — I don’t recall now but 
I could refer to this — that the per capita costs at 
Hoffman-Boston are considerably greater than those at 
Washington and Lee. I think the greatest differential is 
in custodial costs where it is computed that it costs $78.00 
a pupil, or something of the sort, for the custodian at 
Hoffman-Boston and only a dollar or so at Washington 
and Lee, which might make an unsophisticated person 
think that the Hoffman-Boston pupil is getting seventy- 
eight times as much janitorial service. But back to the 
point, we might have a situation of this kind: Let us take 
a course that is not being offered, no claim that any 
part of it is being offered at Hoffman-Boston — print­
ing — but it is being offered at Washington and Lee. 
It is my understanding that if printing is available 
to a white child in this community it must also be 
available to a negro child and therefore the School 
Board must set up a complete unit of printing at Hoff­
man-Boston. Let us say that that is true. That may 
(R. p. 4.00) cost, to set up a printing shop, $20,000 
in capital outlay — just a rough guess. You certainly 
would have to employ a printing teacher at about 
$3,000.00 a year. We would have to buy supplies, 
and so on. Let us hypothesize that we have one pupil 
taking that and then somebody comes along and com­



[8 8 ]

putes the per capita cost that will run up in current 
expense to perhaps $4,000.00 per snnum, or we may 
compute the per capita cost in capital outlay for a 
particular year and it may run up to $20,000 per 
pupil where at the Washington and Lee School the 
comparable cost may be, let us say, $200.00 for cur­
rent operating expenses and $50.00 per pupil for 
captial outlay. Now, as I say, the naive person may 
look at those two figures — and I hope it is clear to the 
Court that this is just a hypothetical example — may 
look at these two figures and say, “With this great 
differential, $4,000.00 per pupil for current operating 
expenses in one school and only $50.00' in another, 
certainly these persons are being well treated”, but 
it does not take an educator nor a lawyer to see that 
that does not reveal at all the matter of equality. As 
a matter of fact, it may be that even under that cir­
cumstance the facilities offered the single pupil at 
Hoffman-Boston are not equal, and I might go on 
with examples of that kind.

The conclusion is, in my opinion, that where there 
(Pi. p. 401) is — and I think this is a generalization 
which you might apply to any situation — that where 
there is a great disparity in the school population 
being compared, comparisons on a per capita basis, 
whether for expenditures or for use, are worthless.

Q. Would that same conclusion be true for the 
expenditures that are made for teaching personnel? 
In other words, the fact that the amount per student 
that is used just for teachers, to pay the salaries of 
teachers — could that authoritatively be compared 
as a basis of determining whether there is equality 
or not with the amount that is spent over in another 
school which is operated for a seperate racial group?



[ 8 9 ]

A. I think that is false under the same general­
ization that was illustrated by the example that I 
gave. The answer would be no.

(R. p. 403) A. I don’t quite understand the ques­
tion.

I guess I had better clarify that in this fashion: 
As I understand your original question, we did not 
have the word “ratio” in it as to whether the number 
of teachers employed in each of these schools is of 
some significance. Of course, it is. I am illustrating. 
We might get to the point at Hoffman-Boston or Wash­
ington and Lee, as far as that is concerned, or school 
X, to get away from the emotional connotations of these 
situations, and you might say we have only one pupil, 
we have one negro pupil, and we have got to pro­
vide for him and we will give him one teacher and 
that teacher will teach everything. The one teacher 
would not be sufficient. I will put it that way. When 
we get into the matter of ratios, we might use the 
same example. I would say if there were only one 
negro pupil in this County, he certainly couldn’t go 
to Washington and Lee School and the School Board 
certainly would set up a school for him and they 
would have to provide a minimum of, let us say, 
ten teachers, giving a ratio of ten teachers to one 
pupil. Let us suppose — I think Dr. Dawson states 
somewhere that you have got to have at least ten 
teachers. I am not certain about that. But let us sup­
pose the School Board provided only five teachers, 
(R. p. 404) then you would have a ratio of one pupil 
to five teachers. You go to Washington and Lee School 
and you will find a ratio of twenty-two pupils to one 
teacher. There is a great difference there, talking 
about ratios, and said no.



[ 90]

In this example, even though we have the ratio of 
one pupil to five teachers, I think it could still be 
demonstrated that there was inequality there, even 
though the ratio was greatly----

B y  M r . R a n so m :

Q. I think you have cleared it up and your an­
swer has made my question clear. That is the point 
I wanted to determine, because it is a small school 
and the fact that there are few teachers over there, 
you can justify the small number of teachers because 
of the small number of pupils if you are going to 
maintain separate schools? Is that correct?

A. That is right. You have to go back further than 
those ratios.

Q. So far as the two schools are concerned, basing 
your conclusion upon not only your own examination 
but the report that Dr. Dawson made, are you of 
the opinion that Hoffman-Boston at the present time 
has an equal or substantially equal — and I am using 
that word “substantially” very advisedly because I 
am going to withdraw it from any consideration — 
(R. p. 405) at least, I hope to withdraw it from any 
consideration in this case, but I am using it now for 
the purpose of getting an opinion from you — do they 
have an equal teaching facility at Hoffman-Boston 
in comparison with that of Washington and Lee? By 
teaching facility I mean do they have a sufficient 
number of teachers to give the courses that are offered 
or should be offered at the school?

A. No.
Q. And that is a conclusion you arrived at even 

after examining this last report of Dr. Dawson and 
that is based on the latest figures available to you?



[ 91]

A. Yes.
Q. Where is the deficiency, if you can point out

any?
A. I am not able to say in great detail but I can 

give some examples. It would be over in the area of 
shop work for example, where at Washington and 
Lee there are several shop teachers, each in his spe­
cialty, and I think no one would argue that at the 
vocational level the teacher must not be a specialist 
in his field. At Hoffman-Boston we have one general 
shop teacher, who, as I gather from Dr. Dawson s 
report, since he said units of other courses are taught, 
I take it at the Hoffman-Boston School there is a 
single teacher that teaches industrial arts, bricklay­
ing as a vocation, and I take it also — this comes 
(R. p. 406) from Dr. Dawson — I take it also he 
teaches a vocational unit in auto mechanics, a voca­
tional unit in sheet metal and maybe vocational unit 
in something else but, to get to your question----

Q. May I interrupt. Do you understand from 
Dr. Dawson’s report that this man teaches the voca­
tional units in those specialties that you have just 
enumerated?

A. I say that that is my understanding of the re­
port.

Q. The report will speak for itself.
A. But to get back to your original question, I 

will say that I don’t know of anybody — I shouldn t 
say that because I have been in a lot of cases of 
this kind and some surprising statements are made, 
but you would require several teachers in the shop. 
I was about to say that we can in this academic work 
argue that a person who is a specialist in history 
ought to be able to teach physical education. Some­



[ 9 2 ]

body might make that argument, but certainly no­
body can argue that a man who has training in auto 
mechanics can teach printing, so you must have ad­
ditional teachers there.

1 would say further in the languages that you would 
need to have additional teachers at the Hoffman-Bos- 
ton School and probably in the sciences, but I am not 
prepared to go into a detailed analysis of the needs 
there.

Q. I don’t want you to go into a comparison of 
(R. p. 407) the individual teachers or to go into their 
capacities. I wanted to get your general opinion.

While we are on that point, would the compara­
tive experience of teaching both in Arlington County 
and elsewhere have any significance in determining 
the problem of equality in the schools? For instance, 
let us assume from Dr. Dawson’s report and your own 
study, that there are a number of teachers in Wash­
ington and Lee who have taught in Arlington County 
for a long number of years. I think in the Hoffman- 
Boston School probably six or seven years is the max­
imum of experience. There are some reasons assigned 
for that. Would the factor of teaching experience af­
fect the quality offered the children of the County?

A. Yes. May I extend that remark?
Q. Certainly.
A. I would say yes, with qualifications. The State 

of Virginia says yes — period — because the salary scale 
is based on experience. I don’t suppose the State or 
Arlington just gives teachers money because of need 
but rather the salary scale in this State is based — 
or in Arlington is based in part on experience so that 
up to a certain number of years of experience — I 
don’t know whether it stops at ten years or twenty,



[ 9 3 ]

but, up to a certain point, the more years of experience 
a person lias had, the more money the school system 
pays him, and that is clearly based on the assumption 
(R. p, 408) that he is worth more, that he is better 
able to direct the development of children. That is 
the answer clearly. There can be no dispute on that 
point. That is the answer of the Arlington School 
Board and of the State and I would agree with them 
in part. My reservation is that I think sometimes a 
teacher can have too much experience in individual 
cases.

Q. Assuming that Dr. Dawson concludes that, 
after maybe four or five years, experience is relative­
ly unimportant; would you agree or disagree with that?

A. I would disagree and I think that the State 
school salary schedule and the salary schedule in the 
Arlington schools would, of course, controvert that 
statement. What I meant when we have too much ex­
perience, we sometimes find a teacher with, let us 
say, forty years of experience who is just too old for 
the system and yet almost all salary scales have in­
crement up through not more than twenty years tea­
ching experience and then they stop.

Q. If you will refer to Dr. Dawson’s report — do 
you have that before you?

A. Yes, I do.
Q. Will you look at his Table 11 on page 27?
A. Yes.
Q. Looking at those totals, what would be your 

opinion — those tables, incidently, give the age or 
years experience in both schools of the number of 
(R. p. 409) teacher What would be your opinion as 
to the comparative efficiency of the teachers in the



[9 4 ]

two schools, without regard to the numbers involved, 
just based upon the experience ratings?

A. Well, it shows here — I will have to look at 
this table. Counsel will understand that I have not 
had an opportunity to examine in detail each of these 
many tables. It may take a minute or two.

There are 78 teachers in the Washington and Lee 
School and the median teacher has had about nine 
years of experience. There are ten teachers in the 
Hoffman-Boston School and the median teacher has 
had about five years of experience. So your question 
as posed, just on the fact of experience, discounting 
all other factors, the teaching staff at the Hoffman- 
Boston School is superior — of the Washington and 
Lee School is superior to that of the Hoffman-Boston 
School.

Q. While we are on this subject of teachers, you 
had occasion to make your own study as to the tea­
ching load at Hoffman-Boston and at Washington and 
Lee, that is the number of classes taught that are 
taught today and the number of subjects. I think per­
haps there are two divisions. It is the number of 
hours actually taught and also the number of sub­
jects that are taught and you also have seen what 
Dr, Dawson says is true as of today. What is your opinion 
(R. p. 410) as to the comparison between the teaching 
load, using the testimony that I have used as to the 
two schools? Is it an undue burden at Hoffman-Bos­
ton or is it an undue burden at Washington and 
Lee upon the teacher in that they have to teach more 
classes or more hours or have to teach more subjects 
than the teachers at the other schools? Compare them 
either way; I don’t care.

A. Let me take up both of those because they are



[9 5 ]

two different things. First, I have here the number 
of different subjects taught and one of the striking 
things which I observe in the 1947-48 year is that the 
teachers at the Hoffman-Boston School have to teach a 
number of different subjects, while those at the Wash­
ington and Lee School were almost altogether in the 
fields of specialization. I have here, for example, 
showing in this tabulation, subjects such as history 
and civics, science and biology, and so on, are regard­
ed as a single subject. I think attention needs to 
be called to a difference but a defensible definition 
made by Dr. Dawson in his covering of this same 
topic where, as I understand, he would define a sub­
ject in terms of number of different preparations.

Q. Will you explain that for us?
A. I hope this doesn’t become too confused on the 

terminology of education. I am in the statistics going 
to quote subjects as major fields of knowledge because 
(R. p. 411) what I wanted to get at here was whether 
the teacher was competent in terms of his training 
to teach the subject concerned. As 1 understand, Dr. 
Dawson’s summary on this same point was not con­
cerned with that. He was oncerned with how much 
work the teacher had to do after school. I wasn’t too 
much concerned with that. He was concerned with 
the number of different preparations. It is my under­
standing if a teacher had one subject in English 
literature and another subject in American literature, 
that would count as two subjects, while in the stat­
istics I am going to cite here, I would count it only 
as one.

You see, Mr. Ransom, the State of Virginia, and 
every other state in the United States, as far as that 
is concerned, has set up certain certification require­



[ 96 ]

ments in which a person who teaches a subject must 
have a certain amount of work in that field, the as­
sumption being that a person needs to know the sub­
ject he teachers. This report shows that in ’47-’48 there 
was a total of 81 teachers at Washington and Lee 
School and 78 of them taught one subject in their 
own field of specialization. Dr. Dawson’s report will 
show something else because of the difference in de­
fining the terms. The other three taught two subjects. 
At Hoffman-Boston School one teacher taught one sub­
ject, three taught two subjects — two; I am sorry. I 
will go back over that. At Hoffman-Boston School, one 
(R. p. 412) teacher taught one subject, three teachers 
taught two subjects, two teachers taught three sub­
jects, one teacher taught four subjects, and there is 
an example here somewhere of a teacher in ’46-’47, 
Miss Griffin, who taught five different subjects — 
history, english, typing, physical education and math­
ematics. I do not have in this report any study of 
Miss Griffin’s qualifications but she did not at that 
time have certification in history, english, typing, physi­
cal education and mathematics, and that is the gen­
eral thing in this report, although that is an unusual 
case. That is what I was trying to show here.

The second part of your question was concerned with 
the teaching load, the number of pupils, and I think 
Dr. Dawson’s report shows — I don’t know on which 
p a g e-------

M r . R o bin so n : Page 30.

A. (continuing) Total number of pupils taught, 
both junior and senior high schools — this would show” 
that the teaching load of the Washington and Lee



[ 9 7 ]

teachers is somewhat higher than that of the Hoffman- 
Boston teachers and therefore they are better off.

B y  M r . R a n so m : *

Q. I am not talking about the number of teachers, 
I am talking about the number of hours per day that 
the teachers teach in classes.

A. I am answering the question in number of pu- 
( R. p. 413) pupils taught. I am through with this number 
( R. p. 414) of subjects.

A. I can say this, that at the time the study was 
made, there was no teacher of physical education at 
Hoffman-Boston. I think that five teachers taught physi­
cal education or were supposed to have taught physi­
cal education. They did not hold certification in this 
field and, as a matter of fact, in some of the observa­
tions I made — I can’t say that this went on during 
the entire year and I want to make that clear, but 
in some instances, at least, the teacher did not direct 
the physical education. It was more or less a free 
period for pupils in which physical education was 
listed but the pupils were doing whatever they wanted 
to do in going about the building and talking or what­
not and the teacher was doing the same thing, but 
there was no certification there and that is the question 
you have asked.

Q. In your opinion, is that good educational prac­
tice?

A. No. I want to make it clear that I did not ob­
serve throughout the year and I would not claim that 
was typical.

Q. Still talking about teachers, in your original re­
port you found that, of course, on paper there was



[ 98 J

no difference so far as the salaries of teachers was con­
cerned, that is, theoretically negro and white teachers 
(R. p. 415) paid alike on the basis of their experience 
and their educational attainments.

A. I wouldn’t say theoretically. They are paid ac­
cording to the same salary scale.

Q. But you did find that the median salary for 
negro teachers was much below that of the whites? 
Is that true?

A. Yes, that is true, and I know that Dr. Dawson’s 
report shows that is true now. In fact, the differential 
for this year is greater than it was last year.

Q. The differential this year is actually greater than 
it was at the time you made your study?

A. Well, I would have to refer to the figures for 
that. I just noted that for the second year covered 
by Dr. Dawson.

Q. Look at Table 8 on page 22 of Dr. Dawson’s 
report and your own figures on page 4 of your report. 
Your tables is on page 5, your conclusions on page 4.

A. Dr. Dawson’s report shows that in ’46-’47 — 
this covers the same period, so we could use Dr. 
Dawson’s report — the median salary of Washington 
and Lee teachers in ’46-’47 was $2,861 plus, Hoffman- 
Boston $2,274, a difference of about $600.00. For the 
next year, ’47-’48, the difference is approximately $425.00. 
For the current year or rather for ’48-’49, the difference 
is $542,00.

(R. p. 416) Q. $542.50, to be exact?
A. That is right, so that although the difference is 

not as great as it was in ’48-’47, it is greater than it 
was in ’47-’48 and I want to make clear that that dif­
ference is not a difference in scale. They both pay ac­



[9 9 ]

cording to the same scale but it reveals a difference in 
qualifications, that is the qualification set up by the 
School Board of Arlington County — not my qualifica­
tions.

Q. That is what I wanted. The difference, because 
of the qualifications of the teachers that are employed 
under the sytem that is in existence over there at the 
present time?

A. That is right
Q. Doctor, let us get down to these plants. As­

suming that the plants have not been increased in size, 
that is so far as building structures are concerned, ex­
cept in one respect, that there has been a two-room 
elementary building erected on Hoffman-Boston ground 
since you were there, and assuming that the build­
ings are otherwise in substantially the same condition 
as to external structure and the number of rooms in­
volved, will you tell us whether or not the two schools 
can afford equal instructional opportunities to the 
members of the two races if they are segregated for 
education? I am talking about the building itself and 
the rooms; I am not talking about equipment or any­
thing else.

A. The answer to that question would have to be 
(R. p.417) no, with this qualification or explanation, 
that the Hoffman-Boston School has no facilities — I 
would say meagre facilities for physical education for 
the standard high school sports, such as basketball, 
and would require more space for that. It did not have 
an adequate amount of space for shop subjects and 
possibly not for commercial education.

Q. Possibly what?
A. Possibly not enough space for physical education. 

There is no provision for a lunch room which would need



[ 100]

to be made or cafeteria. There is no provision for art. 
Did I mention art?

Q. No, you haven’t. Is there any provision for 
music?

A. I thought I mentioned music. I should mention 
that also. So that, in the absence of any possible pro­
vision for the subjects and field of knowledge I have 
mentioned, it would be impossible to provide equality 
under those conditions.

# # # # &

(R. p. 418) Q. In the light of your own observa­
tion and the photographs you have seen on the con­
ditions of the two auditoriums today, would you say 
that there is equality in the auditorium provisions at 
the two schools?

A. No, there is not.
Q. And in whose favor or disfavor?
A. In favor of Washington and Lee pupils.
Q. When you were at Washington and Lee you 

saw the two gymnasiums that are used there?
A. I did and the adjacent dressing room.
Q. Showers and locker facilities?
A. All of which are an integral part of gymnasium 

facilities.
(R. p. 419) Q. Each one of those capable of being 

used independently of the other?
A. Yes.
Q. Did you find any similar facilities at Washing­

ton and Lee — I mean at Hoffman-Boston?
A. No.
Q. Is there a gymnasium at all there, to your know­

ledge?
A. Only by courtesy of title.



[ 1 0 1 ]

Q. What do you mean by that?
A. Well, the room which is called a combination au­

ditorium and gymnasium, I think, referred to that in 
my report, because that is what it is called — actually 
it is not a convertible auditorium-gymnasium. The 
ceiling is not high enough for gymnasium purposes. 
The lights hang down and are not protected; the win­
dows are not protected; so that it is only by courtesy 
or discourtesy that it may be called a gymnasium. Act­
ually, it is not a gymnasium in a functional sense and it 
cannot be.

O. Doctor, in your opinion, after all the chairs are 
removed from there and assuming that those lights 
were protected and the windows were protected, is 
that room large enough for any competitive indoor 
sport, such as basketball, which I understand is one 
of the things that you refer to as a common school 
(Ft. p. 420) sport?

A. I don’t remember that.
Q. You do remember there are supporting posts?
A. That is right. I don’t remember the dimensions 

of the room and I don’t know now the dimensions of 
a minimum size basketball court, so I hesitate to an­
swer that. I think I should add this too: An integral 
part of the gymnasium is the provision made for sani­
tary facilities. You see, these things are put in schools to 
educate the pupils. I mean in a gymnasium facility there 
should be showers, lockers and the like which are 
provided at Washington and Lee School but, as I re­
call, are not provided at ail at the Hoffman-Boston 
School as a part of the gymnasium facilities.

Q. Will you still be of the opinion that the facili­
ties for recreation at Hoffman-Boston in the so-called 
auditorium-gymnasium are still inferior to those at



[ 1 0 2 ]

Washington and Lee, if I should tell you that since 
you saw the auditorium over there they have put some 
lockers in the hall. There are no showers, no addition 
to the plumbing facilities at all, but there are lockers 
which are — well, they are lockers. I won’t say what 
they are for. Would that make any difference in your 
conclusion as to the inferiortiy?

A. No, it would not affect the conclusion.
Q. You would still say that the provisions at Wash­

ington and Lee are far superior to those at Hoffman- 
(K. p. 421) Boston?

A. That is right.
Q, Do you recall, when you were at the negro 

school, Hoffman-Boston, where the principal’s office is 
located?

A. Yes.
Q. On what floor was that?
A. Well, that was on the second floor, I think it 

was on the second floor facing the front of the build­
ing.

Q. If I should inform .you, and it the facts will 
disclose, as they have been testified in this testimony 
prior to your appearance on the stand, that that room 
which was formerly occupied by Mr. Sydnor, the Prin­
cipal, as his office, has been converted into what is 
called a music room with no structural change in it 
and with no instruments placed therein, would you 
say that compares equally or unequally with the music 
instruction that is afforded at Washington and Lee?

A. I would say it was unequal.
# # # * #

(R. p. 422) Q. Assuming that the choral room 
and music room at Washington and Lee are sound­



[ 1 0 3 ]

proofed — that the choral room is well sound-proofed 
with Celotex and the instrument room has poor sound­
proofing — the instrument room has no sound-proof­
ing — would you then say in comparing that one room, 
which was the Principal’s office — would you say that it 
is better — I am sorry I am getting tangled up — the 
opportunities for music instruction in Washington and 
Lee are superior or inferior to those of Hoffman-Bos- 
ton?

A. The facilities at Washington and Lee are far 
superior, regardless of the sound-proofing. There are 
differences in sound-proofing, of course, the matter 
of size, the matter of the facilities, the piano, the 
sound reproducing machine. I don’t see how the choral 
group gets in this small Principal’s office.

Q. Let us move on. When you were at Hoffman- 
Boston, and assuming that there has been no change, 
did you find any facilities for instruction in art?

A. No.
(R. p. 423) Q. Would you say therefore, that the 

opportunities for instruction in art are equal or unequal 
in the two schools?

A. Obviously unequal.
Q. Is art instruction considered essential or at least 

helpful toward a general well-rounded education for 
a high school student?

A. I think there would be absolutely no disagree­
ment among American educators or, indeed, the en­
tire aesthetic side of experience that it is an essential 
part of the curriculum of children in American schools.

Q. You said the entire aesthetic side; you include 
music along with that?

A. That is right.
Q. This is not aesthetic but it is a question of es­



[ 1 0 4]

sentials. Physical education is also considered an es­
sential part of the general education at the high school
level? Is that correct?

A. That is light, and, of course, in Virginia, it is 
required. I think I pointed out in my report that the 
provision made at Hoffman-Boston High School at the 
time I made this study did not meet the legal require­
ments of the State of Virginia and I don’t know how 
the Board got away with breaking that law.

e # * # *

(B. p. 424) Have you seen the pictures of the library 
at the Hoffman-Boston School that have been introduc­
ed in evidence?

A. Yes.
Q. That library has been changed since you made 

your personal inspection? Isn’t that true?
A. Yes.
Q. Have you examined in Dr. Dawson’s report, the 

appendix which is supplementary to his main report 
(R. p. 425) on page 10, appendix B — have you ex­
amined the list of the periodicals that are provided 
in the two high schools?

A. Which page is that?
Q. Page 10 of the appendix, appendix B?
A. Yes, I have seen that listing. Are you referring 

to the listing on page 38 of the appendix?
■Q. Page 10 of the appendix and it is probably in 

another place in the report.
A. Yes, I have examined this.
■Q. Assuming that there are ninety periodicals furn­

ished for Washington and Lee High School as against, 
I believe, fifteen or twenty-one — I am not sure since 
you have my copy — at Hoffman-Boston, would you



[ 1 0 5 ]

say that without regard to the book content, just per­
iodical content of the library, that the facilities are 
equal?

A. No, they are unequal.
* & * # #

(R. p. 426) Q. Make any comment you want,
A. I think it is rather important. There is shown 

here a listing — I don’t know the number but certainly 
there are three or four times as many magazines and 
periodicals available to the child attending Washing­
ton and Lee Scohol as to the child attending Hoffman- 
Boston School. You might wind this up with this per 
capita too because it is a good illustration. A slanted 
opinion might be given that when we divide the num­
ber of periodicals by the number of pupils that the 
pupil at Hoffman-Boston is better off than the pupil 
at Washington and Lee but here we get a clear ex­
ample of the fallacy involved in any such reasoning. 
Actually, the white child in this community lias avail­
able to him many, many periodicals which the negro 
child never sees. The negro child doesn’t have them 
in the home and neither does the white child. The 
only place he can see these are in the school and the 
only place he has direction in using them.

I could look at any of a dozen of these things but 
let us take the United Siaes News, a very important 
summary of national news, what goes on in the Con­
gress. Here is a pupil who is assigned a term paper 
or essay in civics in learning to be an American cit- 
(R. p. 427) izen. If he is at the Washington and Lee 
School he may go and look at this United States News. 
If he is at the Hoffman-Boston School he may not, and 
we could take that right on down the line, and it



[ 108]

is quite clear, and I don’t see how the National Ed­
ucation Association or Dr. Dawson could come to 
any other conclusion but that it is quite clear that 
the child who has access only to this limited number 
of periodicals is disadvantaged in his educational de­
velopment compared to having available this long list, 
nor do I think it is a relevant argument to say that 
this listing here is a longer listing than is furnished 
to white children in some other county in Virginia. It 
is clear here that in this community the white child 
has many more opportunities for experience and de­
velopment in the area of magazine and periodicals 
than the negro child does in this community. That 
is just crystal clear and you can’t by any hocus-pocus 
of per captia usage break down the validity of that 
argument which is apparent to any logical mind, I 
would think. It doesn’t require any extended train­
ing to say that that is true.

If you wish me to, I could point out many of these 
other periodicals which are available in one school 
and not in the other.

(R. p. 428) A. Here is an example, and I will try 
not to be so verbose, but to take care of the matter 
of the Saturday Review of Literature, which I suppose 
is read by most of the well educated people along the
eastern seaboard, at least, the child gets access to the 
Saturday Review of Literature during his high school 
days. It is available in one school and not in another. 
I think that is an example of how the child is handi- 
(K, p. 429) capped in a minor way in this instance 
in. his educational development.



[ 107  J

B y  M r . R a n so m :

Q. I am going to leave the library in a moment. 
I will probably have a question about that later but 
I want to go into the question of the science teaching 
at the two schools, that is the science facilities. Do 
you recall how much space or how many rooms were 
devoted to science teaching at Washington and Lee 
when you visited it?

A. I think that is shown in the report. I think there 
were four science rooms. I may be in error.

Q. Did you observe the equipment available there?
A. Yes, I did.
Q. Did you observe the number of 'rooms which 

are devoted to the teaching of science at Hoffman- 
Boston? If so, how many do you recall?

A. Yes, there was one room.
Q. Did you observe the equipment there?
A. Yes.
Q. Assuming that there are no changes in the num­

ber of rooms or in the type of equipment, are the pro­
visions for teaching science at Hoffman-Boston equal 
to those of teaching science at Washington and Lee?

A. No.
Q. Explain where the difference lies?
(R. p. 430) A. I think if we use Dr. Dawson’s re­

port, we could bring that right up to date. It is not 
necessary to make that assumption. If we were to look 
in the appendix at the equipment----

Q. Appendix B, page 14?
A. Yes. Following the instruction of the Court I 

will not go into detail at this point.
Q. You don’t need to enumerate.
A. The general tiring is that there is much more



[ 1 0 8]

equipment available in the sciences in each instance, 
whether in biology, chemistry, or physics, for the in­
struction of pupils at Washington and Lee School.

Let us start with the first item and I am not going 
to say any more about it. The Washington and Lee 
pupil has — there are thirty-four microscopes. At the 
Hoffman-Boston there are no microscopes.

Q. There is one.
A. There is one miscrope. There are opaque pro­

jectors — in general, there is a great deal more equip­
ment and greater variety of equipment.

In the teaching of science, although in high schools
generally the demonstration method is used rather 
than the laboratory method, it is not simply a matter 
of the teacher standing up and giving demonstrations- 
The pupils themselves participate, set up small dem­
onstrations of their own, and it is simply not possible 
(R. p. 431) with the difference in the amount of equip­
ment to have the same level of instruction.

Q. Doctor, as far as the teaching of the commer­
cial subjects are concerned, assuming that at Wash­
ington and Lee there are typewriting machines, just 
as there are at Hoffman- Boston School, but that they 
also have business machines such as the adding ma­
chine, the mimeograph and perhaps other duplicating 
machines but do not have anything but the typing 
machines at Hoffman-Boston, would you say that the 
teaching of the commercial courses can be or is equal?

A. I would say they are unequal.
Q. Against whom would the inequality exist?
A. It would be in favor of the Washington and 

Lee pupils.
Q. Now, finally we come to the shops. Let us as­

sume that there has been no change in the shops since



[ 109]

you made your inspection. If you will refer to the 
Dawson appendix E, starting at page 18, and continu­
ing through, what would you say as to the compara­
tive abillity to teach shop subjects, vocational subjects, 
at the two schools, just looking at the list of equip­
ment that is available without reference to the courses?

A. Well, the provisions at Washington and Lee are 
(K. p. 432) far superior to those at Hoffman-Boston.

Q. You will notice that both of those schools have 
what is listed as a general shop. Aside from that, 
there are no provisions, according to the report that 
you are now examining, for teaching the subject of 
automobile mechanics, mechanical drawing, machine 
shop, sheet metal work, printing shop or the wood 
shop. In your opinion, can those subjects be taught in 
the general shop that you saw at Hoffman-Boston with 
the equipment that is there and listed here and in the 
space that they have at the present time?

A. Not as vocational subjects.
Q. Would it be possible to even, give any dem­

onstration work with the equipment that they have on 
these various subjects?

A. Well, there is no equipment listed here in these 
subjects other than for mechanical drawing. I seem 
to recall in Dr. Dawson’s report it was stated that cer­
tain vocational units were offered in this school. It is 
not clear to me how this is possible or what the de­
finition of a vocation unit is. I note at the Hoffman- 
Boston School there is a grinder, for example. It may 
be in the machine shop the student may learn to grind 
a chisel and that may be a unit — I don’t know — but 
I did not see how it would be possible at all to offer 
units from the equipment listed here, to offer voca­
tional units of any of these other subjects.



[ 1 1 0 ]

(R. p. 433) Q. I think at the moment we can aban­
don this question of the physical equipment. When you 
were there did you discover, when you made your ex­
amination, any infirmary at either school for the care 
of children who might become temporarily ill?

A. There was, as I recall, an infirmary at the Wash­
ington and Lee School. I don’t recall a provision at 
Hoffman-Boston; I am sorry.

Q. Dr. Jenkins, I want you to look at Table 30 in 
the appendix or in the report on page 55 of the Daw­
son report which refers to the number and titles of 
the books that are in the schools. Do you have that 
before you?

A. Yes, I am looking at that.
Q. Will you tell me the total number of volumes 

in the two schools, that is, in each school, as it ap­
pears from that report.

(R. p. 434) A. This shows a total of 8,682 for 
Washington and Lee, 1,007 for grade 7 to 12 and 211 
for elementary. I don’t know on what basis that dis­
tinction is made.

Q. Without going into the classification of those 
works which appears from the table, will you express 
an opinion as to the relative efficiency for teaching 
purposes of the two libraries?

A. The library at Washington and Lee, both from 
this and from my observation of the types of books 
they have, is far superior to that of Hoffman-Boston.

Q. Would the fact that Hoffman-Boston has fewer 
pupils have any relation to the necessity for fewer 
volumes of works over there?

A. Only a very minor relationship as it may relate 
to duplicate copies. The larger school may need more 
duplicate copies of certain general references and



[ I l l ]

other books but that is a minor item and, substan­
tially, the Hoffman-Boston School would have sub­
stantially the same number of volumes as Washington 
and Lee and I won’t take the time to go into the same 
general explanation of that. It is the same thing I men­
tioned under the periodicals.

Q. Why should they have the same number? I 
do you want to answer that?

A. I say I can repeat that. It is the same thing I 
mentioned under periodicals. We could take the same 
(R. p. 435) type of example.

Q. When you were over there in 1947, and from 
the examination of the pictures that you have seen 
here and which have been introduced in evidence, 
you have a general knowledge of the atheltic fields 
at both schools, that is the outdoor recreation space?

A. Yes, the outdoor space.
Q. Is there, in your opinion, an adequate outdoor 

recreation space at Hoffman-Boston?
A. No.
Q. Is there such an adequate space at Washington 

and Lee?
A. Yes.
Q. Does the atheltic space, that is for outdoor rec- 

reaction, have any educational value? Does it affect 
the quality of education that can be offered at the sep­
arate school?

A. I think it quite obviously does.
Q. In what respect, sir?
A. At Washington and Lee School there are pro­

visions for playing football, a football field, soccer if 
they wish to play soccer; there is a running track in 
which they may have events in running, jumping, and 
the like, and those physical education activities are



[ 112]

an integral part of the development of youngsters in 
(R. p. 436) their general education. That is one.

Second, the provision of these facilities for these 
sports in these days, fortunately or unfortunately, pro­
vides a great motivating factor. Many boys stay in 
high school because they can play football. That is 
their major interest and as an educational program, we 
build on that interest and try to get the pupil to 
learn something in addition. Certainly among the ne­
gro boys whom I know very well, the success of negroes 
in athletics recently, in professional football teams and 
professional baseball teams and in track events, Olym­
pics and inter-collegiate events, have aroused great 
interest in that area. At Hoffman-Boston there is no 
opportunity for yougsters to engage in those activties. 
Therefore, they lose the general educational value and 
they lose the motivating value of the experience, i 
might mention also there is a certain vocational value. 
Fortunately, or unfortunately, a good football player 
at Washington and Lee, if he is good, and he makes 
the All-State team, doesn’t have to worry about his 
college expenses. If he is very good he may get fifty 
or one hundred offers from colleges all over the country 
to go to college at no cost and that is possible because 
there is a football field where he can build up a rep­
utation of that kind.

(R. p. 437) Further, it may be that vocationally 
he may get on a pro team and earn a living. Those 
are the three things that I have mentioned that pupils 
in Washington and Lee have an opportunity, simply 
because the physical facilities are available and which 
pupils from Hoffman-Boston are absolutely excluded 
altogether

Q. I am going back to a point that I asked you a



[ 113]

little while ago. I don’t think that I developed it as 
thoroughly as it should be. In the commerical courses 
that are offered at the two schools did you find at 
Hoffman-Boston any provision such as a bookkeeping 
room where bookkeeping may be taught?

A. No.
Q. Did you find any equipment such as calculat­

ing machines over there which could be used for in­
structional purposes at Hoffman-Boston?

A. Other than typewriters, there was no equip­
ment. '

Q. 1 am talking about calculatng machines.
A. No calculating machines.

M r . D ouglas: D o you m ean adding machines?

M r . R a n so m : There are several types.

B y M r . R a n so m :

Q. Where a student is not taught the use of various 
calculating machines, is it thoroughly taught?

A. A student is greatly handicapped.
(R. p. 438) Q. If he does not have that type of 

instruction?
A. That is right.
Q, At Washington and Lee, of course, you did see  

those calculating machines? Is that true?
A. One or more.
Q. Come to the cafeteria. Was there a cafeeteria 

at Hoffman-Boston?
A. No.
Q. Any type of provision for the feeding of child­

ren that you saw?
A. As I recall, there was no provision whatever for 

them.



[ 1 1 4 ]

Q. Is there a cafeteria at Washington and Lee?
A. Yes.
Q. Does the existence of a cafeteria in the school 

itself have any value, either educational or otherwise, 
and, if so, will you tell us what it is?

A. There again, it is a question on which all ed­
ucators in this country are agreed, that the educational 
value of the school lunch program and the cafeteria 
program is part of the integral part of the students 
educational experience and it is revealed in part by 
the fact that the Federal Government now spends 
millions of dollars in helping schools to develop lunch 
programs.

The educatiaonal value is this, that many, many 
(R. p. 439) children in our schools come from under­
privileged homes and in the past, when I was in school, 
a youngster would get a cold jelly sandwich and a 
cold bean sandwich and an apple and that was his 
lunch, and it has been found that there is a relation­
ship between the student’s health status and his gen­
eral vitality during the day and the kind of meals 
that he eats. So that if it is possible for a child to get 
a hot, well-balanced lunch in the middle of the day, 
that contributes to his immediate physical efficiency 
and vitality.

Secondly, there is the matter of developing health 
habits. In developing American youth we want to get 
them so they can choose the right kind of diet and 
one of the objectives of a well-organized cafeteria, 
one of the objections of the cafeteria at Washington 
and Lee High School, is to train children in the 
selection of good foods. That is conceivably as im­
portant as learning the ablative in Latin. The child­



[115]

ren at Hoffman-Boston have no such opportunity for
development in this area.

Q. Yesterday there was some discussion of the 
courses offered in Washington and Lee High School 
which were not offered at Hoffman-Boston, a course 
in so-called distributive education. Assuming that there 
is a special room provided for that at Washington and 
Lee and no such room and no such work done at Hoff­
man-Boston, would you say that there is therefore in- 
(R. p. 440) equality in the services that are offered the 
children, in the respective schools?

A. Yes.
Q. Does distributive education, as it was explain­

ed to us from the stand yesterday, have any particular 
value in an educational system, that is, does it have 
value such that it ought to be offered, in your opinion, 
to all children, if it is offered to any?

A. Well, I don’t recall how it was described yes­
terday. I will answer the question in the light of what 
is offered in these two schools. No distributive edu­
cation is offered at Hoffman-Boston. Washington and 
Lee does have some phases of distributive education.

Distributive education is concerned in general with 
the matter of the distribution of goods. They get 
people, such as sales persons and the like. It is my 
understanding now at the Washington and Lee School 
—I may be in error but it is my understanding that 
there is a part-time program in which children will 
do some of their work in school and get their practical 
experience in the community. Whether or not there 
is a part-time school, there is certainly instruction in 
such things as salesmanship.

We are a great selling nation and a large proportion 
of our employed labor forces are in the area of dis­



[ 1 1 6 ]

tribution and the children who have an opportunity 
for training in that field certainly have an advantage 
( R. p. 441) as a group over children who do not have it 
Further, the children make contacts through distribu­
tive education with prospective employers. I don t know 
how many negro salesgirls may be found in Arlington 
but there may be some relationship between the num­
ber to be found in department stores and the like and 
the opportunities they have for training. There may be 
some such relationship.

Q. Is it an accepted belief among educators that 
there should be guidance work done in the high schools 
and that there should be someone who devotes the 
major portion of his or her time to guidance of stu­
dents?

A. I am trying to think whether I should answer 
“yes” or “no”, to that question.

Q. Let me break it down for you. First of all, is
guidance work necessary in a school?

A. Yes.
Q. Would it, in your opinion, be advisable to have 

a room where the guidance of students, individual 
guidance, could be conducted privately? In other 
words, would it be advisable to have a guidance office?

A. Yes, that would be a desirable thing.
Q. Do you know whether or not there is such an 

office room devoted to that purpose alone at Wash­
ington and Lee School?

(R. p. 442) A. I think there was such a room at 
Washington and Lee. I am not too certain about that 
but I think so.

Q. Do you know whether there was such a room
at Hoffman-Boston?

A. No, there was no such room at Hoffman-Boston.



[ H 7 ]

Q. Do you know whether there was any teacher 
over there who devoted her time to guidance work?

A. No, there was not.
Q. While we are on that subject, what is the value 

of guidance work in an educational system?
A. Again, I don’t want to give the appearance of

lecturing.
Q. If you can answer in one or two sentences?
A, It isn’t a question that could be answered in 

one or two sentences because it goes back to the whole 
philosophy of education in this country where we put 
emphasis on the value of the individual, and the pur­
pose of guidance is to help the individual child to ex­
press his own abilities and interests, how intelligent 
he is, how proficient he is in academic subjects, what 
his interests are. Its purpose further is to acquaint the 
youngster with the opportunities he has for develop­
ment vocationally, to know what the opportunities are 
in government service or in mining or any of the other 
(R. p. 443) occupations.

Guidance extends into the personality area. It is an 
attempt to help the individual to become adjusted and 
get along with other individuals socially and in select­
ing avocations of music or art which contribute to the
fuller life.

Q. It resolves itself into this, that it is a matter of 
individual counselling between whoever is doing the 
guidance and the particular student.

A. That is an essential technical ----
Q. And therefore, it could be more properly done 

if it were done in a private room?
A. That is right.
Q. Let us move on, please. In regard to a library —
A. I had better qualify that and say there are



[ 118]

some phases of it that need to be done face to face 
with the individual. There are many phases of guid­
ance that are carried on. in groups or in classrooms. 
I wouln’t want to say it is exclusively a personal matter 
between counselor and student.

Q. In dealing with the library, I neglected to ask 
you about some of the requirements. Is it either a re­
quirement or is it necessary that there be a room which 
might be designated as the library office or workroom 
for the use of the person who is in charge of the li­
brary?

A. I take it it would be desirable certainly to have 
a room for a workroom for the accumulation and cata- 
(R. p. 444) ioging of books, for the repairing of books 
and periodicals and the like.

Q. Assuming — and you can make the assumption 
from the photographs that are in evidence here, that 
at Hoffman-Boston High School there is, immediately 
adjacent to the library, a room, somewhere that may 
be six by ten or seven by ten — approximately that 
size — which has now been controverted into the 
Principal’s office and is being used by the Principal 
as the administrative office, and that is the only ad­
ministrative office in Hoffman-Boston, would you. say 
that is good educational practice, depriving the library 
of any office and using that as the administrative office?

A. Does it have an outside window?
Q. No outside window.
A. Does it have a waiting room for students who 

are waiting to see the Principal?
Q. No waiting room?
A. No.
Q- You say “no”; it is bad practice?
A. Yes.



[ 119]

Q, Do you recall on your visit to Hoffman-Boston 
seeing a room which was designated as the teachers 
lounge?

A. At Hoffman-Boston?
Q. At Hoffman-Boston.
(Pi. p. 445) A. Yes.
Q. Do you recall where that room was?
A. I think it is adjacent to the auditorium.
Q, A room oft the stage?
A. I think so.
Q. Did you see teachers’ lounges at Washington 

and Lee?
A. I think I saw the men’s lounge over there but, 

again, I am a little hazy on that. I am not too certain 
that I did.

Q. Are teachers’ lounges desirable in any well- 
rounded educational system?

A. Yes, they are highly desirable.
Q. What value do they have?
A. They give the teacher an opportuity for relax­

ation and getting away for a few minutes, at least, from 
the hubbub of the school day and primarily for the 
purpose of relaxation and revitalization of the teacher, 
therefore making the teacher a little more effective 
and efficient when she goes back to the classroom 
rountine.

Q. One last question before we get into an entirely 
different field, Doctor, and that is this: I think in your 
report and certainly Dr. Dawson’s report there is some 
reference to the architectural construction of the two 
plants, the exterior views, and their relative appear­
ance. While I know that you are not an architect and 
(R. p. 446) I haven’t tried to qualify you as such, can 
you, as an educator, looking at the buildings from



[ 120]

the standpoint of the impression that they will make 
upon the relatively young mind of the student who is 
coming to the schools, say that there is equality or in­
equality between Washington and Lee and Hoffman- 
Boston?

A. Well, I would say that the Washington and 
Lee building is much more pleasing in its general ar­
chitectural appearance, much more pleasing than the 
Hoffman-Boston School.

Q. I am going to leave you on the comparison of 
the two schools and we are going to talk about study 
now — course. At both schools technically there are 
three courses of study offered, one known as academic, 
one as commerical and one as general high school 
courses. I say technically they are offered or, at least 
designated as being offered at both schools.

Will you detail the differences between those three 
(R. p. 447) types of courses of study for us?

A. In a large high school it is possible to have a 
comprehensive program offering what we call a differ­
entiated curricula, that is, curricula which are des­
igned to meet the needs of different groups of students.

In the present instance, there are three curricula 
available at Washington and Lee — either three or four.

There is the so-called academic curriculum which 
is primarily for college preparatory course for perhaps 
thirty-five percent of youngsters who are going on to 
college.

There is the commerical curriculum, centered around 
typing, shorthand, bookkeeping, office practice which 
is designed to prepare youngsters for secretarial and 
office positions.



[ 121]

There is a general curriculum which is usually orga­
nized for pupils who do not intend to go to college, 
chiefly because it is thought they don t have the ability 
to do so, find who are not taking a specialized voca­
tional curriculum.

I think that the general view of the curriculum is 
that it is an offer to hold the children in school. Now, 
there must also be at Washington and Lee a spec­
ialized vocational curriculum for individuals who are 
taking printing, auto mechanics, sheet metal, aviation 
(K. p. 448) training, and the other specialized shop 
courses. At the Hoffman-Boston School there is only 
the one curriculum offered, the general curriculum.

It is my understanding — the people who are in­
timately concerned with this may correct this but it 
is my understanding that there is not yet a specialized 
commercial curriculum in which it offers all of the sub­
jects necessary for a diploma in commercial work but 
I may be in error. Certainly at the time I made my 
study there was no such curriculum.

Q. If you refer to Table 36 on page 65 of the 
Dawson report you will find the three types of diplo­
mas and the courses that are offered under them, 
according to the records of the School Board. Have 
you that before you now?

A. Yes.
Q. Do you find anything in there which show's that 

they give any of the subjects at Washington and Lee 
which will qualify the student for either the commer­
cial or what is called the general academic diploma?
I see they have them reversed. Washington and Lee 
has academic first and general last — and under Hoff­
man- Boston, what?

A. No, there is no provision here for commercial



[ 122]

or academic. I think I might add this: I don’t know 
where the Washington and Lee authorities place their 
(R. p. 449) shop courses. It would be general prac­
tice, I think, in American education to add another 
curriculum, the vocational curriculum for youngsters 
who are taking shop work, which would make a fourth. 
At Washington and Lee whether that is included in 
the electives for the general diploma, it wouldn’t be 
good education practice to do that. It certainly wouldn’t 
be the academic or commercial and it might be well 
to ascertain. We have a youngster taking automobile 
mechanics, which is his curriculum. It would hardly 
be one of these three but I don’t recall now — I should 
have investigated that a little bit more closely.

O. Leaving out that question of the vocational 
work, there, are only three curricula that are avail- 
at Hoffman-Roston — three at Washington and Lee 
and only one at Hoffman-Boston? Is that correct?

A. That is right.
$ # # # #

(11. p. 450) Q. I think you have probably answered 
(R. p. 451) the next question I am going to ask and 
really what I wanted to get at. The question of what 
he is taught in high school has a great deal of import­
ance as to whether he can be admitted to college, 
whether he is acceptable for college work? Isn’t that 
true?

A. I want to make this clear too: This statement, 
as it reads — and I must answer your question — this 
statement I agree with as it reads but we have to under­
stand what it means. Certainly, the pattern of sub­
jects the student has has a great relationship. If no 
language is available it is not likely that the student



[ 123 ]

will become a specialist in for gem languages. If there 
is no mathematics, it is not likely lie will become an 
engineer. But what I am saying is that the measure or 
criterion of equality or inequality does not lie alone 
on the matter of whether he is going to be successful 
in college because only a relatively small percentage 
of children in these schools go to college anyway.

Q. But if the courses that are offered in a given 
school are limited, then his opportunity or his chance 
of being acceptable at a college may be affected by 
the offer? Is that correct?

A. That is right.
Q. Turning to page 66, Table 37 of the Dawson 

report which brings it up to date, have you examined 
(R. p. 452) the specific courses that are offered at the 
two schools and compared those?

A. Yes.
Q. Going to specific questions then, if you have 

made this study in the field of English alone — let 
us start with that — there are no courses in either 
speech nor journalism offered at Hoffman-Boston 
School but they are offered at Washington and Lee. 
In your opinion, does that make the course or courses 
available in English at the two schools equal or un­
equal?

A. In my opinion, they are unequal.
Q. Is it possible, in your opinion, to do an equal 

j;ob of teaching those two subjects that I have men­
tioned by organizing some extra work in the regular 
English class at Hoffman-Boston?

A. Not on the basis of inequality because once you 
do that, you have got to slough off some of the normal 
content of the course.

Q. Picking another one just at random, you have



[ 124 ]

solid geometry that is offered at Washington and Lee 
and it is not offered at Hoffman-Boston. In your opin­
ion, is this equality of offering to the two groups of 
children?

A. No.
Q. Let us assume that Dr. Dawson states that in 

his opinion solid geometry could be adequately cover- 
(R. p. 543) ed for the negro children who are attend­
ing Hoffman-Boston High School by a supervised cor­
respondence course, would you say that is equality?

A. No.
Q. Do you think it can be adequately taught that 

way?
A. It isn’t clear to me what is meant b y ----
Q. I mean in comparison with the courses the child­

ren in Washington and Lee would get?
A. The answer is no but I say it isn’t clear to me 

what is meant by the term “supervised correspond­
ence study”. I am not familiar with that. I know what 
correspondence study is but I am not clear in what 
is meant by supervised correspondence study, but even 
if it were supervised, — well, I take that back, because 
if it were supervised to the extent of the teacher act­
ually teaching the course, it might resolve itself into 
another teaching situation, with somebody else pro­
viding the textbooks. The general answer would be no.

Q. I take it you do not understand what is meant 
by the term “supervised correspondence”?

A. I don’t. It is Dr. Dawson’s.
Q. Neither one of us knows what he means by it 

and we will postpone any further questioning on that 
until after he has explained what he means by it.

A. All correspondence study is supervised by the 
(R. p. 454) institution or person in charge of the course,



[ 125]

in that sense that the person who is taking the course 
writes out his lessons and sends them back to be mark­
ed and criticized. In that case the “supervised” would 
be a redundant term. I think I know what is meant 
here but I wouldn’t want to venture an opinion on it. 
You asked me further — I think that is the extent of 
that question.

A. Just running down the list, I am going to call, 
certain, subjects here and then I will ask you a gen­
eral question about all of them: Assuming that com­
mercial arithmetic and general mathematics are offer­
ed in Washington and Lee and not offered at Lloff- 
man-Boston, that economics, world history, economic 
geography and Latin-American history are offered at 
Washington and Lee and not offered at Hoffman- Bos­
ton, that Latin is offered at Washington and Lee and 
not at Hoffman-Boston, that commercial law is offer­
ed at Washington and Lee and not at Hoffman-Bos­
ton, that business correspondence is offered at Wash­
ington and Lee and not at Hoffman-Boston, that book­
keeping is taught at Washington and Lee and not at 
Hoffman-Boston, that you have mechanical drawing 
at Washington and Lee and not at Hoffman-Boston, 
that you have courses in fine arts, music appreciation 
and art appreciation at Washington and Lee and not 
at Hoffman-Boston, that you have commercial art at 
Washington and Lee and not at Hoffman-Boston and 
then, of course, you have all of the extra activi- 
(R. p. 455) ties such as band and cadet training which 
are listed as courses in the curriculum. Would you say 
that the educational opportunities at Hoffman-Boston 
are equal to those available at Washington and Lee?

A. No, they are unequal.
Q. Are any of those courses I have listed — do you



[ 126]

consider them all courses that are proper to be taught 
to all of the citizens of the community — should be 
offered, I mean, to all of the citizens of the community, 
made available to them if any of them want them?

A. Yes.
Q. They are all standard courses for high school

study? Is that correct?
A. Well, as listed, they are commonly found in

American high schools.
Q. That is what I meant, they are commonly offer­

ed in the better high schools throughout the country? 
Is that correct?

A. Commonly and some in the poorer ones — some 
in the better high schools and some in the poorer ones, 
as well.

Q. It has been called to my attention, and I will 
ask you this question: I have named some courses 
that are offered in Washington and Lee School that 
are not offered in Hofrman-Boston. I have omitted 
some. I mentioned the choral work, music, which in­
cludes the glee club, both boys and girls and mixed, 
the special work shop to which you have already re- 
(R. p. 456) ferred, such as auto mechanics, machine 
shop, printing sheet metal work, woodworking, and 
then there is a course in retail selling, one in consumer 
buying and then, of course, I mentioned the cadets, 
both boys and girls — cadet band and the orchestra, 
and there is a course in automobile driving training, 
a course in home nursing — that course is given in 
both schools — a course in physical eudcation. Those 
courses which I did not name before are all offered 
at Washington and Lee and not offered at Hoffman- 
Boston. In view of th a t----

«? *  flf #  *



[ 1 2 7 ]

M r . Ranson: If that is true, and I am in­
formed now it is true, I correct my statement 
to that affect. Leaving out physical education 
and home nursing, both of which are offered in 
both schools, your answer is still the same as it 
was when I presented it to you before?

(R. p. 457) A. Yes, although I did not follow in de­
tail. There is, in Appendix R on page 39, a list of the 
courses not offered in the 1948-49 year and, on the 
basis of those data, my opinion would still be the same.

Q. That there is an inequality in the educational 
opportunities afforded?

A. Yes. I might qualify my answer there with re­
ference to one thing where on the report, page 68, it 
is shown that shorthand is offered, I believe, at Hoff­
man- Boston and yet the appendix shows it was not 
offered during this three-year period, so I am basing 
my response on the appendix, rather than o n ----

Q. You are going upon what was actually offered 
according to the appendix?

A. That is right.
Q. Is there any educational value in a summer 

school and the offering of courses during the summer?
A. Yes, I think so.
Q. Let us assume that an announcement is made 

to the effect that summer school will be given if any­
body wants it but no courses are set up, and where 
an actual series of studies are set up in another school, 
would you say that the two offerings are equal?

A. No, they are unequal.
Q. In other words, the courses should be there and. 

(R. p. 458) made available? Is that correct?
A. Yes.



[ 128]

Q. Is it true that there are some activities com­
monly designated as pupil activities or extra-curic- 
ular activities, which have some relation, to the ed­
ucational process in the schools?

A. Yes. All of the so-called extra-curicular activi­
ties are actually part of the pupil’s total educational 
experience to the extent that some educators don’t 
use the term “extra-curricular”. They call them co- 
curricular activities.

Q. On page 73 of the Dawson report, Table No. 
39, you will find a listing of the club and activity pro­
grams in the two schools. Do you have that before
you?

A. Yes.
Q. And you will notice, of course, the number 

stated for each school. Do you believe that the num­
ber of activities in the two schools has any relation 
at all to the size of the school — or let me put it 
another way: Shtould the number of activities be 
limited by the size of the school?

A. Logically, the answer is no for equality and 
yet, where you have a small school, it is inescapable 
that you can’t have as many activities in a school where 
there are ten pupils as you can in a school where there 
are ten thousand but that is just a matter of inequality.

(R. p. 459) Q. Let us take certain activities; for 
example, the cadet corps. Should there be any denial 
or refusal to have a cadet corps at one school because 
of the fact that there are only a few boys there or 
should they all have the benefit of that same oppor­
tunity of military training?

A. They have got to have the same opportunities 
and therefore if the facilities are to be equal, there 
must be a cadet corps for the youngsters at Hoffman-



E 129 ]

Boston School.
Q. What you are saying then is that so far as the 

opportunities are concerned to participate in these 
activities, the same opportunities should be available 
at both schools? Is that correct?

A. That is right.
Q. The mere physical size of the school or the 

school population may make some of them impossible? 
You may not have enough men to have a band?

A. Impossible or ridiculous but that is the situation.
Q. Incidentally, on that same program I want to 

call your attention to this, that there are certain subjects 
or activities marked there with asterisks which carry 
credit, academic credit toward graduation apparently. 
Is that true?

A. That is what is said here and I have found that 
to be true in 1947.

(R. p. 460) Q. And there are no such subjects 
carrying academic credit offered at Hoffman-Boston?

A. None noticed. I might point out here also that 
under Washington and Lee there are subject clubs 
and under Hoffman-Boston are noted these subject 
clubs as individual clubs, business, club, science club, 
and so on, so that I don’t know how many subject clubs 
there are now — science club, art club, and so on, 
but if those were listed, the listings for Washington 
and Lee would be considerably longer than it appears 
here, maybe twice as long.

# # # # #

Q. What is meant by the term “accreditation of 
a school” when you use it in reference to high schools 
in the State of Virginia, or elsewhere?

A. There has grown up in this country the custom



[ 130 1

of rating or accrediting schools. High schools are ac­
credited on at least two levels. I think we need to be 
concerned here with only two levels. They are accred­
ited by the State, sometimes a State university, acting 
for the State, and sometimes by regional associations. 
I will take those separately.

The general purpose of accreditation is to assure 
(R. p. 461) (1) that the school has a certain mini­
mum, meets certain minimum standards, so that there 
is a great difference in the quality of accredited schools. 
One accredited school is not necessarily as good as 
another. Accreditation, whether by the State or by 
the regional agency, simply says that this school meets 
certain minimum standards.

The other purpose of accreditation is to certify so 
to speak, that the graduates of this particular school, 
that is accredited have met certain minimum require­
ments and therefore are eligible for admission to cer­
tain institutions of higher education. That is the par­
ticular objective of the regional accrediting association.

I think there are six different regional accrediting 
associations. Virginia falls in the area of the Southern 
Association of Colleges and Secondary Schools. Wash­
ington, for example right across the river, is in another 
accrediting association, the Middle States Association.

When a school is accredited by the Southern Asso­
ciation, then its graduates may go on normally to any in­
stitution in the United States and enter without exami­
nation. I say “normally” because some of the private in­
stitutions set up qualifying examinations for anyone 
who enters. On the other hand, if the school is not ac­
credited by the Regional Association, many colleges — 
in fact, the majority of the colleges in the United States 
either will not admit the individual or will admit him



[ 131 ]

(R. p. 462) only by special examination.
Q. Then accreditation status is a thing of value to 

the school?
A. It is a thing of great value.
Q. Directing your attention to the two schools 

that we h av e----
A. Not only to the school but to the students, the

graduates.
Q. Directing your attention then to the two schools 

that we have under consideration at the present time, 
do you know whether Washington and Lee High 
School is accredited both by the Virginia State Depart­
ment of Education and by the Regional Association? I 
think you said it is the Southern Regional Association?

A. Southern Association of Colleges and Second­
ary Schools.

Q. Was Washington and Lee so accredited?
A. Yes, it was then and is now accredited by both 

of these agencies.
Q. At the time you made your examination was 

Hoffman-Boston accredited by either?
A. No, it was not.
Q. Is it accredited by either at the present time?
A. According to Dr. Dawson’s report, it is accred­

ited by the state of Virginia on a qualified accredita­
tion. I am not prepared to say what this term means — 
(R. p. 463) “qualified accreditation.” If that is the 
usual procedure for accrediting schools during their 
first year, that would be acceptable as regular accred­
itation by the State.

(,). You mean probationary?
A. That is right. If it is qualification on the basis of 

shortages at some points, then it may not be accred­
ited on an equal basis. You can ascertain that, how­



[ 132 1

ever, from some other witness. Hoffman-Boston is not 
accredited by the Southern Association.

Q. Since you say it is not accredited, are the stu­
dents who are attending Hoffman-Boston High School 
receiving or are they eligible to receive the same ad­
vantages as those who are attending Washington and 
Lee High School? By “advantages” I mean the oppor­
tunity to enter colleges without examinations?

A. Those who wish to enter colleges in the main, 
colleges either public or private, located outside the 
State of Virginia, or private within the State of Vir­
ginia, are greatly disadvantaged. It is customary, and 
I take it is true in Virginia for a State institution of 
higher education, public, to admit without qualifica­
tion graduates of the State accredited schools. Outside 
of the State not too much attention is given to the 
matter of State accreditation.

(R. p. 464) Q. You said they are at a disadvantage. 
I am not sure it is clear in the record. Which group 
is at a disadvantage?

A. The group who attended the non-accredited 
high schools because there are many institutions —- I 
cited in my own report three of the institutions at 
which students from Hoffman-Boston normally go. In 
two of those the matter of regional accrediation would 
adversely affect the student’s entrance and that would 
be generally true in colleges throughout the United 
States.

Q. In arriving at accreditation, can you enumerate 
very briefly and generally the factors that determine 
whether or not the Regional Association will approve 
or diapprove the school or accredit it?

A. I would rather not go into too much detail but 
they take up such things as the qualification of tea­



f 133 1

chers, the scope of the curriculum, and the library, the 
pay of teachers — in general, the kind of things we 
are covering in the testimonoy in this trial.

Q. Those factors apparently have not yet enabled 
this school to reach the acreditation that you men­
tioned as being an asset to the school?

A. I am not prepared to say that. The school is 
not now accredited and its students are handicapped. 
Why it isn’t accredited, I don’t know whether the 
Southern Association would accredit it or not. I doubt 
(R. p. 485) but that it is a matter of opinion.

Q. In connection with accreditation, I note from 
your report that there are certain honorary awards that 
are apparently given to schools themselves and place 
the school in a position of some preeminence in com­
parison with other schools because of the type of offer­
ings that are made there. You refer to them, on page 35 
of your report, I believe, as honorary awards such as 
the National Honor Society. Is membership of the 
school in such a society of any value to the student?

A. In my opinion, membership in the society men­
tioned, National Honor Society, is of great value. Many 
colleges will give scholarships to students simply on 
the strength of their membership in the National Honor 
Society. To explain to you, the National Honor Society 
is the scholastic equivalent of Phi Beta Kappa on the 
college level and eligible high schools, and only first 
class high schools, are eligible and may establish chap­
ters to which a certain percentage of senior students 
and, in some cases, junior students, are elected, pri­
marily on the basis of scholarship, sometimes condi­
tioned by school citizenship. The very fact of being a 
member of the National Honor Society gives the young­
sters a great deal of prestige.



t 1 3 4  1

I mentioned the matter of scholarships. In colleges 
(R. p. 486) in these days, when it is difficult to get 
into colleges, if two individuals are applying for admis­
sion and one is a member of the National Honor So­
ciety and one isn’t, that is likely to be a factor weight­
ed in favor of the individual in the National Honor 
Society. Employers certainly look at this matter of 
mebership in this national organization that has chap­
ters throughout this country.

If a girl wants a job as a typist, salesman, salesgirl, 
the fact that she is a member of this Society is a matter 
of some advantage.

The other thing mentioned here, that this school 
also confers a Rausch & Lomb honorary science award 
— and in connection with this citation is the state­
ment that by virtue of its standards this school is qual­
ified to confer this award for scholastic achievement, 
what I have said about the National Honor Society 
applies also, although not in so large a scope.

Q. One is a general scholarship and the other is 
science?

A. That is right. The fact that the youngster at 
Hoffman-Boston has no opportunity to compete for 
these awards is, in my opinion, a disadvantage to him.

Q. You have in your statements several times used 
the phrase “this school”. Those awards are available 
at Washington and Lee? Is that your statement?

(R. p. 467) A. That is right.
Q. And not available at Hoffman-Boston?
A. That is right.
Q. If you will turn to page 63 of Dr. Dawson’s re­

port there is a statement there to which I am going 
to direct your attention. It is in the second paragraph 
and I want your comment on that. It reads as follows:



[ 135 1

“In the opinion of the author of this report, no high 
school is under obligation to prepare students to meet 
the various standards, many of them supported only 
by tradition and custom, of the private colleges in the 
United States. It is sufficient if the high school grad­
uates have had an opportunity to prepare to enter the 
colleges maintained by the State in which the high 
school is located.” With that statement before you, 
and in view of what you have said about accreditation, 
do you think that that is an accurate or fairly accurate 
statement of how the schools should be judged as to 
equality; if both schools have State accreditation and 
therefore can have their students admitted to the State 
colleges, is that a sufficient criterion so as to say that 
we have equality between the two schools?

A. I may say that I don’t think this statement re­
fers to or is intended to refer to the matter of accred­
itation.

Q. I don’t think so but I am asking you in con­
nection with that.

(R. p. 488) A. Of course, this is a debatable point 
— what you want your high schools to do — but I 
think it is quite clear that if in a given community, 
such as Arlington, white children may and do attend 
a high school “prepares students to meet the various 
standards of all the private colleges in the United 
States,” and negro children attend a high school which 
does not so prepare them, then there is inequality.
I don’t think the statement is relevant in the issue in­
volved in this case. It is a general debatable point. 
The question, as I see it, is whether there is inequality 
for the youngsters in any particular community, if that 
answers your question.

Q. And in view of your examination and study of



I 136  1

these reports, what is your conclusion as to the inequal­
ity of opportunity offered to the two types of children 
that we have under consideration?

A. You mean in terms of all the factors considered?
Q. Yes.
A. There is no question whatever in. my mind that, 

considering all factors, the students at Hoffman-Bos- 
ton School are afforded a far inferior opportunity for 
educational development than that afforded pupils in 
the Washington and Lee High School.

Q. I am trying to wind up as quickly as I can now. 
I do want to develop on more problem.

(R. p. 469) There has been some question raised, 
by vitrue of the Dawson report, which seems to be 
based upon this — that because of the size of the school, 
the number of pupils attending, no harm is done to 
the child who has to attend the smaller school, the 
negro school in this case, because of the fact that any 
given course in not given to him in any particular 
sequence or in consecutive years or in other words, 
that no harm is done in alternating courses or in giv­
ing them out of sequence. Will you advise the Court 
whether that is a good academic practice or not? It 
has been called to my attention that I should say, 
when those courses are alternated they are not given 
every year. They may be given in alternate years as 
well as alternate in subject-matter. Is that an advant­
age or disadvantage to the student?

A. In my opinion, that is a decided disadvantage.
Q. Why?
A. I would like to amplify that. We all recognize 

under normal circumstances, where the question of
racial segretation is not involved, that the small high 
school for economic and common sense purposes simp­



[ 137 3

ly cant offer the kind of program and extent, scope and 
freguency that can be offered in a larger high school 
and that is why we are abandoning these small high 
schools and getting consolidated high schools. 1 mean 
that is just a common sense viewpoint. But even there, 
it is recognized that — what I am saying is that it is 
common practice in very small high schools to have 
this rotation of courses and offering courses every two 
or three years and we can understand why that is nec­
essary, when the factor of race is not involved, but 
that is a disadvantage for several reasons and three 
occur to me.

One: Many of the fields of knowledge as organized
in the curriculum must be organized on a sequential 
basis. One must have algebra 1 before one has algebra 
2, obviously. One must have algebra before one has 
trigonometry. One must have beginning French, com­
monly French 1, before he has French 2. So that for 
many subjects — not all but many — it is essential that 
we have this sequence which cannot be provided under 
this cycle.

For example, in 1947, the report I made shows that 
in Spanish — it offers an excellent example of the thing 
I am talking about. I will quote: “At the Hoffman-Bos- 
ton School all the pupils in 9B, 10A, 11 A, 11B, 12A 
and 12B are taught throughout in the same classes.” 
In die first semester 1947-48, all the pupils in these 
seven half grades took exactly the same schedule and 
were taught in general the same content, so that we 
had during the first hour all the high school students 
taking Spanish. Clearly the person has to have begin­
ning Spanish before he has his second semester or 
(R. p. 471) third semester Spanish which isn’t possible 
in this particular organization. The second thing is that



1 138 1

our subjects are organized on the basis of the matura­
tion level of students. I will explain that. It is a pyscho- 
logical term.

B y  M r . D ouglas:

Q. How do- you spell it?
A. M-a-t-u-r-a-t-i-o-n. The layman would say “level 

of maturity” but the psychologist would say “matura­
tion level”. For example, as the child grows older phy­
sically lie can comprehend material of increasing dif­
ficulty — comprehend increasingly difficult material, 
so that a child can learn addition before he is ment­
ally able to- comprehend trigonometry. The high school 
curriculum is based, in part, on this concept of matura­
tion level so that where our 9th grade youngster might 
normally understand beginning algebra, lie has not yet 
normally and typically developed enough mentally to 
understand trigonometry, so that goes through all of 
our subjects.

The second objection to this offering of courses in 
two or three-year cycles raises the question of what 
to do with the failing student. What happens when a 
student fails one of these subjects on a three-year cycle 
and then lie has to wait three years to make the sub­
ject up? I think it is fair to conclude that in any school 
(R. p. 472) which has these cycles there is a tendency 
to lower standards and not fail students because fail­
ing students bring up too many curriculum problems. 
I am not saying that that is true in this instance, al­
though it would be of great interest to learn the inci­
dence of failure in these two schools. I think certainly 
there would be that tendency.

The third objection would be in the matter of transfer



[ 139  1

students, both those transferring from within the system 
to outside or those coming from outside the system 
inside, that is, here is a family which moves in and they 
have a 10th grade youngster who has been, let us 
say, moved from Washington and who has had the nor­
mal curriculum. Granted that normally his curriculum 
would not fit exactly since he comes from another school 
system but certainly he would be greatly handicapped 
if he finds that he has had the subject they have taken 
this year and he has to wait two years or maybe three to 
get the subject he needs. Similarly, with a student trans- 
fering outside the community — and I am sure we must 
look at this as a whole in terms of the development 
of all these children — would be subject to the same dif­
ficulties. What I have attempted to point out here is 
the difficulty is there, despite the fact that whenever 
we have a small school organization it is necessary, 
but it does set up inequality clearly.

Q. And there does exist, so far as these two schools 
(R. p. 473) are concerned, that is, they have the cycle 
as you suggest necessarily at the present time at the 
Hoffman-Boston School and that same condition does 
not exist at Washington and Lee?

A. Yes.
# * # # #

( R. p. 474) Q. Then finally, Doctor, in your last sec­
tion of your report you have apparently formed some 
opinions and I want to find out if these are valid: Con­
sidering the type of education that is offered at Hoff­
man-Boston as compared with that offered at Washing­
ton and Lee, what importance or effect does it have 
upon the ability of the school to retain its membership, 
its student population, and encourage them not only to



[ 1 4 0  1

stay throughout the entire period offering at Arlington 
but to increase their education afterwards? In other 
words, I think you referred to it as holding power. 
Considering the differences, will you compare what 
normally is to be expected and, as shown from your 
studies, has happended so far as the two schools are 
concerned?

A. Well, as a generalization, the better schools 
tend to hold pupils longer than poorer schools. At the 
time that I made that — 1947-48 or 1946-47, I think 
(R. p. 475) the last time the data were available in 
my study, my report, I noted a great dropping out of 
children at high school level. It shows a peculiar thing 
which I can’t account for too well, namely, that at the 
18-year level, if we take out these several hundred — 
I don’t know how many there are but the school offi­
cials should know exactly how many of these Arlington 
people are included in the statistics; if we take them 
out we find the startling factor that there are propor­
tionately more 18-year old negroes in school than white 
and I just doubt that but I don’t have any statistics 
to show it.

Q. Normally and in normal times I believe you 
stated that the better the school the greater the chances 
are that the child will continue his education?

A. I think that is a fair generalization.
Q. What is the effect upon the school and upon 

the community in general of the children dropping 
out before they have completed this minimum educa­
tion that is offered by the Public School System?

A. Well, that would take a long lecture and I will 
simply summarize by ■—  ■

Q. As you have tried to put it here?
A. It results in under-exploitation of the natural



[ 141 ]

resources of the country, the natural resource in this 
case being the human resources because children who 
(R. p. 476) are under-educated and under-trained are 
not effective in their vocational life.

# # # # #

Q. Your answer was that it did have an adverse 
effect?

A. I will try to, in brief, say that because the stu­
dent is under-trained he is likely to get into a voca­
tion which is below his normal level of performance. 
He is likely to be among the first to be unemployed 
(R. p. 477) and therefore, to go into areas of delin­
quency and other anti-social behavior.

& # # & #

C ross E xam ination  

B y  M r . D ouglas:
# * * # fc

(R. p. 482) Q. And I believe you testified that 
courses should be made available whether any stu­
dents had indicated their desire to participate or not?

A. Yes.
* * * # *

(R. p. 488) Q. That she was denied equality be­
cause of an existing policy of racial discrimination. 
As a school administrator, would you advocate em­
ploying a faculty and organizing a school for the sum­
mer quarter at Hoffman-Boston where no student had 
indicated his desire to gain instruction in such a quarter 
or session?



[ 142 1

A. Yes. May i extend that?
Q. If you feel it is necessary to qaulify your an­

swer.
A. I said under the circumstances as they exist in 

Arlington County, the answer would be yes.
Q. And would you draw from the failure of the 

School Board to organize such a school under those 
circumstances an inference that racial discrimination 
was intended by that failure?

(R. p. 484) A. It would be very difficult for me. 
Attorney, to say what was intended. I know some of the 
men on this Board and I wouldn’t want to say about 
the intention. I would say, however, that the result is 
discrimination.

Q. What would you do, getting back to the prac­
tical level — have the teachers go over there and sit in 
their rooms, hoping that they will get a customer, even 
though no customer had indicated when he was invit­
ed to indicate that he wanted to buy what they had 
to sell?

A. That is right.
Q. About this cadet corps, how many students were 

in tire senior high school last year?
A. That is in the record. I will look. Which do you 

want? For which year?
Q. ’47-’48 or ’48-’49.
A. I think I have it. Which grades do you want?
Q. If you will look at page 4, the number is given 

as 48 for that year and 18 for the preceding year and 
12 for the year preceding that.

A. In grades 10 to 12, that is right.
Q. As an administrator, what would you do about



[ 143 ]

organizing a cadet corps among the boys and the girls,
respectively, in that group?

A. I wonder if I may comment on that question?
(R. p. 485) Q. Perhaps if I withdraw the question

you won’t have to comment on it. Would you advocate 
the organization of a cadet corps for the boys and a 
cadet corps for the girls in a group of 9 students such 
as was the case in 1946-47?

A. Yes. Nov/ I want to explain that, if I may.
Q. Go right ahead.
A. Of course, that is a ridiculous answer.
Q. I didn’t say so.
A. I said so. As an educator, I say it is rediculous 

but it is what this system of segregation brings us to. 
As I understand it, in our system we must offer the 
same opportunity for the negro child as for the white. 
Therefore, we are in the ridiculous position, it seems 
to me, of subscribing to something which is educa­
tionally unsound but which we are bound to do in ac­
cordance with the legal requirements.

Q. You have criticized the Hoffman-Boston or the 
public authority here in that Hoffman-Boston did not 
in those years have a competitive football team.

A. I did not criticize. I simply mentioned that as an 
objective fact.

Q. The fact that there was not a football team in 
any of those three years. Do you regard that fact as 
evidence from which you infer discrimination on ac­
count of race?

A. Yes.
(R. p. 486) Q. Do you draw the same inference 

from the failure of that school to maintain a band or an 
orchestra when there were twelve students in the school 
body?



E 1 4 4  1

A. Yes.
a * * * *

Q. Not quite. There is a little field at the back 
where the girls play softball but it doesn’t amount to 
much. Do you regard interscholastic competitive ath­
letics as any part of a good school system?

A. Yes, I think that is a desirable part.
Q. Suppose it were a fact that the existence of 

(R. p. 487) those activities deprived the average stu­
dent of access to play fields because those play fields 
were pre-empted by tire specialists on the teams, would 
you still regard that as being an unmixed blessing 
for the school that has them?

A. I don’t think I would accept your premise. I 
would think that would constitute bad school admin­
istration. I don’t believe that that is a necessary con­
sequence of interscholastic atheltics in any particular 
school since normally the practice for the interscho­
lastic atheltics is after the regular school day.

Q. Do you regard the vocational aspects of high 
school competitive athletics as being an asset or a li­
ability of the athletics program?

A. Well, in terms of the total program, not too im­
portant but for the individual boy it may be tremend­
ously important.

Q. May it not likewise be a great liability?
A. I don’t think so, not necessarily.

# * # # #

(R. p. 490) Q. Can you assign any reason why 
the gymnasium or auditorium at Hoffman-Boston can­
not be used in bad weather for the conduct of those



[ 145 ]

elasses that are required to be given as a part of that 
course?

A. Well, of course, it can be used and I assume it 
is used for physical education activities. You mention­
ed a while ago some of the trend in education and 
certianly one of them is to get away from the calls- 
thenic and exercise sort of thing into the functional 
kind of games which these high school youngsters en­
joy and it would not be possible in the present struct­
ure and present facility to play the so-called ballgames. 

* # # # #

(R. p. 491) Q. As an administrator, would you ad­
vocate the installation of a guidance counselor — is 
that what you call them?

A. That is one name for them.
Q. In a high school of twelve students?
A. If such a specialized counselor is available to 

white children in the community, I think that one must 
be made available for the negro children, so the an­
swer would be yes, under the conditions existing in 
Arlington County.

Q And a failure to have such a person you would 
consider evidence of discrimination?

A. Yes.
Q. Isn’t it a fact that in dealing with such small 

numbers of students the teachers are in a far better- 
position to afford that guidance than is a counsellor 
who sees them only when called upon to see them?

A. Not necessarily.
Q. You say not necessarily? Do you mean that may 

be true?
A. It depends on the training of the teachers. This 

matter of guidance takes certain specialized training



[ 148 1

which your guidance counsel has. It is just as if — 
I won’t use the example.

Q. So that your answer is what?
(R. p. 492) A. As indicated.
Q. Isn’t that person best qualified to counsel an­

other person who best knows the problems of that other
person?

A. That is only half of the story. He ought to also 
have certain technical proficiency. That is why a pa­
rent who knows his child is not always, although he 
frequently is, the best person to offer advice to the 
child.

Q, How long has this business of guidance counsel­
lor been going on in public schools?

A. The public schools of Arlington?
Q. I mean, generally in the jargon, the technique of 

the profession?
A. I think that movement gained momentum dur­

ing the early twenties in American schools generally. 
I don’t know a thing in the world about the Arlington 
practice, when it began.

# # ■ # # *

(R. p. 494) Q. In evaluating the library content 
about which you have testified, you made no examina­
tion of the books themselves as to their copyright dates 
or otherwise as to their contents, did you?

A. Yes, I did — not every book, you understand, 
but a general sampling.

Q. Can you make any general observation as to 
the relative newness of the books in the two libraries, 
as to their coypright dates?

A. I can as of 1947-48.
Q. You say you cannot?



[ 147 ]

A. I say I can.
Q. What would you have to say as to that?
A. That in general the holdings at the Washington 

( R. p. 495) and Lee library were well diversified and 
many of them have very recent copyright dates. At 
the Hoffman-Boston School the books were not at that 
time cataloged but, in looking at the actual books 
themselves, very few of them — the general picture 
was very old books, many of which had been donated 
by other libraries and which had very old dates of 
publication. I will refer to my report.

Q. I will agree with you that that is correct.
a #  #  *  *

Q. I will concede everything that you are saying 
about the books of that vintage being indicated. Do 
you know whether those books have all been replaced 
by new books since that time?

A. I don’t know .
Q. If they had been replaced by new books, would 

that have any bearing on your opinion as to the relative 
merits of the two libraries?

A. I will say this, that it would be helpful but it 
would still not be equal, according to the statistics 
(R. p. 496) presented here in the Dawson report.

Q. Which is the higher requirement or set of re­
quirements for accreditation — those prescribed by the 
State or those prescribed by the Southern Conference?

A, In general, and certainly by reputation, the 
standards of the Regional Accrediting Association, 
Southern Association, are higher than those of the State. 
Now, we may, upon analysis in particular states, find 
certain items which are more stringent than those of



I 1 4 8  1

the Southern Association hut that generalization is cer­
tainly true.

* # # * #

(R. p. 497) Q. On that question of salaries, Dr. 
Jenkins, I believe you said that the salary scale of sal­
aries paid to the white and colored teachers was ident­
ical, didn’t you?

A. That is right.
Q. And that the median or, as I could call it, the 

average, is higher among the whites because they had 
had longer service than the average colored?

A. Well, either that or training, whatever the fact­
ors are that enter. I think the differential is largely 
a matter of experience.

& #  O #

(R. p. 498) Q. And I believe you cited the schedule 
of increases which accrued from year to year in the 
salary scale of teachers based on their increasing ex­
perience as conclusive evidence, perhaps, that the
greater the experience of the teacher the more val­
uable that teacher becomes? Is that true?

A. I concluded that was conclusive evidence that 
that is what the School Board thought.

Q. You don’t agree with that?
A. I agree with that within limits. I indicated this 

morning that you might get teachers who get in a 
rut and get too old to teach but, as a generalization, 
I think that would apply to teachers as well as to at­
torneys, that with the amount of experience gained 
the individual becomes more proficient in his profes­
sion up to a certain point.

# # # # #



I 149  ]

(R. p. 500) Q. And do you entertain the opinion 
that all courses ought to be offered in all of these sub­
jects without regard to demands by qualified students?

A. If they are available to white students, yes.
Q- Do you entertain the opinion that it is the duty 

of the School Board or the public authorities to main­
tain teachers in rooms adequate for instruction in those 
subjects and with facilities necessary to teach them, 
whether there is any demonstrated demand for the 
subjects or not?

A. Yes. It may become very expensive.
Q. And do you draw from the failure of the public 

authorities to maintain such facilities for which no 
request has been made the inference that there is ra­
cial discrimination?

A. Yes.
* * * * #

R ed irec t  E xam ination  

B y M r . R a n so m :

Q. Doctor, is it a general practice among admin­
istrative officials of school systems to wait until some 
student comes around and asks them to install a par­
ticular course in the school or is the contrary true, 
(R. p. 501)that the administrator determines that there 
is a community need for a specific type of instruction 
and makes the course available to the student?

A. I believe it is the common practice for the 
school authorities, either as authorities or delegating 
that to curriculum committees of teachers or other 
people in the community, to establish the curriculum



[ 150 1

and not to wait for individual students to ask for partic­
ular courses.

# # * # #

EDWARD B. HENDERSON 

D ir e c t  E xam ination  

(R . p. 5 0 2 ) B y  M r . H i l l :

Q. Will you state your name, occupation and ad­
dress to the Court?

A. Edward B. Henderson; I am head of the Depart­
ment of Health, Physical Education and Safety, Public 
Schools, Washington, D. C. I live in Falls Church, 
Virginia.

Q. Dr. Henderson, how long have you held your 
present position?

A. As head of the department, about twenty-five 
years.

Q. What professional degrees do you have?
A. Well, I have an A. B. from Howard University, 

Master of Arts, Physical Education, Columbia Univer­
sity, and have done other studies but those are the 
(R. p. 503) two degrees that I have.

Q. I understand you to say you have been head 
of the Department of Physical Education over twenty 
years. Prior to that what were you doing?

A. Teaching physical education since 1904.
Q- And that teaching experience was in what 

type of school?
A. Except for the first year, and then part-time, 

in senior high schools.



t 1 5 1  3

Q. Have you written any work in your field or 
written any articles in your field, Doctor?

A. I have written editorials quite frequently for 
the Journal of Health, Physical Education and Recre­
ation, and for a number of other publications. One 
book, which is in the course of revision now, is The 
Negro in Sports.

Q. Do you belong to any national association re­
lating to your field of activity?

A. I served on the joint Army and Navy Welfare 
Committte during the war, the American Physical 
Fitness Committee. I served on the National Commit­
tee of the American Association of Health, Physical 
Education and Recreation. I have headed a number of 
official organizations in athletics and have been mem­
ber of a number of societies in the field of physical 
education and recreation.

(R. p. 504) M r . H i l l : I will tender Dr. Hen­
derson as an expert in physical education.

T he C o u r t : Do you desire to cross-exam ine?

M r . D ouglas: N o, not as far as I  am able
to forsee now.

T he C o u r t : L e t him  b e adm itted as such.

* # # ’ # #

B y M r . H i l l :

Q. Dr. Henderson, did you accompany us when 
we made an inspection of the Hoffman-Boston School 
and the Washington and Lee School, on August 20th 
of this year?

A. Yes.



[ 152 1

Q. The time we took several photographs and what­
not?

A, Yes.
Q. Have you made any previous visits to either or 

both of those schools?
A. On one occasion I was there at Hoffman-Bos­

ton. I think I talked to a group there but not during 
its normal classrooms, and I drive by frequently the 
Washington and Lee High School.

(R. p. 505) Q. From your observation on those 
particular days of the facilities available for physical 
education at both the Washington and Lee High School 
and the Hoffman-Boston High School, can you give 
us an opinion as to whether or not the facilities at 
the two schools are equal or at one they are superior 
or inferior to the other and, if so, please state which 
school.

A. Well, in general, the facilities for physical edu­
cation, as I conceive it, at Hoffman-Boston School are 
decidedly inferior to the facilities offered the children 
at Washington and Lee.

Q. With respect to a physical education in itself, 
aside from the competitive sports, were the facilities at 
Hoffman-Boston comparable to those at Washington 
and Lee?

A. No.
Q. From your observation in respect to those 

schools, did you note whether or not they had showers 
at one or both schools?

A. There were showers serving both gymnasia or 
the gymnasia at the Washington and Lee but I didn’t 
observe any showers related to what is purported to 
be the semi-auditorium-gymnasium at Hoffman—Bos­
ton School.



[ 153 ]

Q. Are showers essential in a secondary school or 
I should say, do they have any educational value?

A. Most programs of physical education and health 
(R. p. 506) in secondary schools are considered to be 
very insufficient unless there is opportunity for dress­
ing for physical education classes in uniforms, follow­
ing them with baths. In fact, in many of our schools 
we consider the bath very essential as an educational 
adjunct to physical education.

Q. Would the fact that one school had showers 
and the other one did not have showers in itself be an 
element of inferiority so far as the school was con­
cerned?

A. Decidedly so, in my opinion.
Q. With respect to competitive sports, do they have 

any educational value on the secondary school level?
A. Competitive athletics have become in recent 

years an integral part of the physical educational pro­
gram in most secondary schools from the point of 
view of health, increased physical vigor, character 
training particularly, and generally fitting the boy to 
meet the opportunities of American citizenship and 
life.

Q. Does the fact that competitive sports are pro­
vided at one school and not provided at the other be­
come an element of inferiority between the two schools?

A. I should think so, yes, in that in one school it 
tends to hold pupils in school probably longer and at­
tracts people to the school. We have found in our school 
systems, where there are no athletics, boys tend not to 
stay in school so long, and tend to go to school where 
(R. p. 507) is provided an opportunity for competi­
tive sports.

Q. My question sort of assumes that there were com­



[ 154 1

petitive sports at Washington and Lee. From your ob­
servation have you seen or have you actually observed 
pupils of Washington and Lee being trained in various 
sports and, if so, will you state some of the sports that 
you have observed at Washington and Lee?

A. Practically all the outdoor seasonal sports be­
cause I drive that way frequently to and from home. [ 
can’t say about the indoor sports only by reputation be­
cause I am in a system where the boys frequently play 
the boys of Washington and Lee at basketball, but I 
have seen the girls activities, such as archery; I have 
seen track in its various ramifications, jumping, shot 
throwing, and I have seen football practice and I have 
seen baseball at Washington and Lee.

Q. And you have observed a basketball court within 
the interior of Washington and Lee? Is that right?

A. Yes.
Q. Does available play space or available space as 

such, undeveloped, have any real significance so far as 
eductional programs are concerned for schools?

A. It has some. It furnishes opportunity for what we 
call free play or general moving about in activity and 
might have some advantages if there are shade trees 
( R. p. 508) around and grass but not a regular physical 
education program. It doesn’t afford that opportunity 
per se.

Q. That is what I mean. To a regular physical ed­
ucation program, does it have any particular advantage?

A. Only as space advantage is all.

C ross E xam ination

B y  Mr . D ouglas:

Q. Dr. Henderson, were you aware that there was



[ 155 1

no course in physical education given to the students 
of the 11th and 12th grade in the Washington and Lee 
High School?

A. Not before I heard it stated here.
Q. Were you aware that all students of the Hoffman - 

Boston High School are given a course, which is requir­
ed, and that they are taught by an accredited teacher in 
that subject?

A. I have heard it mentioned that they were given 
calisthenics and some activity purporting to be physi­
cal education.

Q. Assuming those two sets of facts to be true, 
would that affect your conclusion as to the comparative 
value of the courses offered in the two schools?

A. No, for the reason that without any information 
to the contrary, I can’t conceive of a reason other than 
administrative, why the period between 9 and 3 o’clock 
(K. p. 509) at Washington and Lee couldn’t afford physi­
cal education activities for all the students, in view of 
my experience with student bodies almost as large in 
the City of Washington and with smaller facilities.

(). Without dealing with the reasons why they are 
not given, if they are not given, if that course is not 
given to any substantial body of the students, those stu­
dents are getting a course inferior in that respect to the 
courses offered students who are getting that instruction? 
Isn’t that true? So that the reason why they are not 
given hasn’t anything to do with it, has it?

A. Except that I can’t conceive of the Hoffman-Bos- 
ton students getting a course in physical education, such 
as required by the State of Virginia, with the lack of 
facilities that I know to be present there.

# # * # #



[ 1 5 6  3

(R. p. 510) Q. You spoke of competitive athletics 
as related to character building in the individual, Doctor. 
Were you speaking of the individual student as a whole 
or the individual students as a whole or only to those 
who become competitors

A. I would say that all students who engage in game 
activity under good teaching supervision, who learn fair 
play and courteous treatment, one or the other, and the 
exchanges that go along, have the opportunity under 
leadership and guidance to learn those traits of character 
that we appreciate and think desirable in American cit­
izenship.

Q. I think perhaps you misunderstood my question. 
My question was — if Armstrong High School of Wash­
ington has a splendid football team, playing competitive 
games with other high schools, does the exitence of that 
football team improve the character of the members of 
the team or the character of the members of the stu­
dent body?

A. It improves the moral of the student body and 
also teaches them as spectators —■ improves the charact­
er of the boy who takes part in the game and also im­
proves character traits even in training for the game —- 
various types of traits.

Q. If that activity deprived a great many students 
of play space, even though what you call free play 
(R. p. 511) space, you think the benefits of having a 
competitive team will outweight that disadvantage?

A. May I suggest I can’t conceive of that for this 
reason, that most of our competitive athletic training 
periods and game periods are at the close of school, 
whereas most of the children have intra-mural activity 
and physical education within the school day in periods



[ 157 I

set aside for that by the administration and therefore 
the athletic program does not materially interfere with 
the normal physical education program. I might add 
that we are on a five-day week physical education pro­
gram. Two periods are in health and three in activity 
and we usually take one of the periods for intra-mural 
within the class period so those students actually get 
game experiences within their class period.

# # # *  #

Q. And the game experience for the normal student 
is the thing that is of great value?

A. It is.
Q. And the more general that experience is enter­

tained or enjoyed by the student body, the greater is 
(R. p. 512) the benefit? Isn’t that true?

A. To those who take part, yes.
# # # * &

ELLIS O. KNOX 

D ir e c t  E xamination

(R . p. 513) B y  M r . R o bin son :

Q. State your name.
A. Ellis O. Knox.
Q. Your age?
A. Forty-nine.
Q. Where do you reside, Dr. Knox? 
A. Washington, D. C.
Q. What is your occupation?
A. Professor of education.



[ 158 3

B y  M r . D ouglas:

Q. Where?
A. Howard University.

B y  M r . R o bin so n :

Q. How long have you been at Howard University?
A. Eighteen years.
Q. What other positions, if any, have you occupied 

during the eighteen-year period that you have been 
connected with that institution?

A. I was director or teacher training for the tea­
chers in the vocational work in the schools of Washing­
ton. I have engaged in surveys of different characters 
while in Washington. Those are the major types of 
positions.

(R. p. 514) Q. What are your academic qualifica­
tions, Dr. Knox?

A. I have an A. B. from the University of Cali­
fornia, and an A. M. from the University of Southern 
California, and a Ph. D. from the University of South­
ern California.

Q. Over what period of time have you been en­
gaged in the field of education?

A. Thirty years.
Q. Prior to the time that you went to Howard 

University, did you also engage in teaching on the 
high school level?

A. Yes.
Q. In what department or school of Howard Uni­

versity are you now teaching?
A. The department of education.
O. Is that in the liberal arts school or in some 

other school.



[ 159 ]

A. The College of Liberal Arts.
Q. Then, Dr. Knox, did you have any special group 

or groups of pupils whom you teach there at that in­
stitution?

A. Yes, those who are preparing largely for sec­
ondary school teaching, those who are preparing for —

Q. To teach in high schools?
A. To teach in high schools.
Q. What publication, if any, Doctor, have you 

made?
A. Several publications over a period of years. 

(R. p. 515) Would you care for titles?
Q. You might.
A. I have made a study dealing with the philo­

sophy underlying the trend in the industrial and vo­
cational education, studies dealing with tire research 
among negroes and incident to negroes, studies deal­
ing with changes in curricula patterns.

Q. What profesional societies, if any, are you a 
member of?

A, National Education Association, National So 
ciety of Philosophers of Education, the American As 
sociation of University Professors.

Q. Do you also belong to the American Teacher.1 
Association?

A. Yes.

M r . R o bin son : If Your Honor please, we
should like to tender Dr. Knox as an expert for 
puposes of testifying in this case.

M r . D ouglas : We agree.

T he C o u rt : Let him be so admitted.



[ 1 8 0  ]

B y  Mr. R o bin son :

Q, Have you had occassion to make a study of the 
Washington and Lee High School and the Hoffman- 
Boston High School in Arlington County, Virginia, on 
the basis of data supplied to you for that purpose and 
(R. p. 516) on the basis of personal observation?

A.. I have perused the data which was supplied to 
me and made a very hasty observation of Hoffman- 
Boston.

Q. Will you state for the information of the Court 
the data and information you have examined for this 
particular purpose?

A. Yes. i  examined a study prepared by Dr. Jen­
kins and the study prepared by Dr. Dawson — those 
two — all the data pertaining thereto.

Q. Did you consider, Dr. Knox, the portion of the 
Jenkins survey and also the portion of the Dawson 
survey relative to the teaching experience of teachers 
in the Washington and Lee and Hoffman-Boston High 
Schools? Did you make an examination of that data?

A. Yes.
Q. On the basis of the information contained in 

these two reports, and particularly the information 
which was set forth in Table No. 11 on page 27 of 
the Dawson report, are you able to express an opin­
ion as to whether or not the teachers who are at the 
Hoffman-Boston High School are equal or are unequal 
to those at the Washington and Lee High School in 
point of teaching experience, if you are going to de­
fine teaching experience as it is defined in in this 
table on page 27, that is, if you mean number of years 
(R. p. 517) of experience, the median teacher at Wash­
ington and Lee has a greater number of years of ex­



[ 161 1

perience than the median teacher at Hoffman-Boston.
Q. Will you state for the information of the Court 

what if any, value there is to a pupil in having an 
experienced teacher?

A, Yes, I think there is great value in having an 
experienced teacher. I think, beyond a shadow of doubt, 
we are concerned with developmental programs of the 
youth. A teacher who has been in a community and 
has been able to study that environment and gained 
varied experiences, at different times under different 
conditions, is much better qualified to give instruction 
to children in that community so that they may adjust 
and adapt themselves to varied experiences and re­
quirements than a teacher who has had less broad 
or limited opportunity to become familiar with that 
community.

Q. Dr. Knox, did you consider the portion of these 
reports devoted to a consideration of salaries, respect­
ively, paid to teachers in the Washington and Lee and 
Hoffman-Boston High Schools?

A. Yes, casually.
Q. On the basis of your examination of this data, 

considering particularly the data contained in Table 
No. 8 on page 22 of the Dawson report, will you state 
your opinion or conclusion with respect to the relat­
ive qualifications of teachers in those two schools, 
(R. p. 518) based upon that information?

A. If I address myself to the data for the year 
1948-49 for each school — and I suspect the same will 
hold true for the previous years — I find, beyond a 
shadow of a doubt, the teachers of Washington and 
Lee received — or a greater percentage of teachers — 
I will say it this way: A greater percentage of teachers



[ 162 ]

of Washington and Lee received advances in salaries 
than is the case in Hoffman-Boston.

Q. How do the teachers of those schools compare 
in that school session in terms of median salary?

A. Washington and Lee is more favorable.
» o o *  *>

(R. p. 520) Q. Will you cite Dr. Knox, the con­
nection, if any, between the matter of qualification 
of a teacher and the matter of the salary paid to that 
teacher as a general consideration?

A. In general, the profession of education, as else­
where, the better qualified demands the higher salary 
and receives the higher salary as a result of the de­
mand.

*  *  *  *  *

Q. Dr. Knox, did you have an occasion to ex­
amine the portion of these two reports having to do 
with the matter of the number of different subjects 
taught by teachers in the two schools under consid­
eration?

A. I examined that.
Q. On the basis of the information contained in 

these two reports, and particularly Table No. 14 on 
page 31 of the Dawson report, would you express your 
opinion as to whether or not the teaching staff and 
arrangement at the Hoffman-Boston High School is 
equal to or is unequal to the same at the Washington 
and Lee High School so far as concerns the matter 
(R. p. 521) of the number of different subjects taught 
by teachers?

A. It is not the same. Do you want me to explain 
that?



[ 163  ]

Q. Please,
A. I find six of eleven teachers, more than fifty 

per cent of the teachers at Hoffman-Boston, teaching 
five or more subjects. I find only two, for example, of 
the seventy-nine teachers at Washington and Lee who 
teach five or more different subjects. If I intepret 
this table correctly----

Q. Will you cite, Dr. Knox, the value or the im­
portance of the matter having a teacher teach or not 
teach a number of different unrelated, subjects?

A. It is very desirable on the secondary level for 
a teacher to teach as far as possible, only related sub­
jects. Pratices differ. Some schools desire to have tea­
chers teach the same subject only, providing the school 
is large and has a sufficient number of teachers, but 
even in larger schools there seems to be a trend in 
the direction of having a teacher teach one or two 
different subjects so as to prevent what one might 
call the blight of specialization but in no instance 
would a teacher in a school where desirable practices 
obtain be required to teach more than two subjects 
for no other reason than on the college level and 
(R. p. 522) in the teacher training institutions she has 
a major and a minor and it is highly desirable that she 
be confined to teaching those subjects which she has 
prepared in collegiate work in the area of her major 
and minor rather than in the other fields.

# # # * ft

Q. Will you state, for the information of the Court, 
the value to any given school of the courses of instruc­
tion which are contained or which are offered at that 
school?

A. Yes. The courses of instruction form the back­



[ 164 1

bone of your whole educational environmental pro­
gram — very important.

Q. Will you state whether it is a better practice 
to have a large number of varied courses or a better 
pracitce to have a smaller number of courses of in­
struction in a given school?

A. Very desirable to have a large number.
Q. What are the advantages of a course offering 

which consists in a large number of varied courses?
A. In summary, the outstanding advantage is that 

(R. p. 523) it affords the pupil a richer opportunity 
for broadened experiences.

(R. p. 524) Q. Dr. Knox, I should like to call your 
attention to Table No. 6 which is set forth on page 
9 of the Jenkins report.

A. I have it.
Q. And Table No. 36 which is set forth on page 

65 of the Dawson report.
A. I have it.
Q. And ask you to state your opinion, on the basis 

of the information contained in the respective reports 
at the respective pages and in the respective tables
which I have mentioned.

A. My opinion is that it is very difficult to compare 
the curricula at the Hoffman-Boston and the Wash­
ington and Lee, not alone because of the great dis- 
(R. p. 525) parity in the numbers at the two schools 
but because of the fact that — well, in the Dawson 
report on page 65 I find a general diploma. I find in 
there no language at all. I have been informed, I might 
say, that during alternate years sometimes languages 
are given but the Hoffman-Boston does not impress 
me as being a complete curriculum. I see some sub-



[ 1 6 5  I

ieets there under a caption of “'General Diploma” but 
there is no such thing as an unified curriculum pat­
tern or technique for determining an unified curricu­
lum pattern which seems to have been employed other 
than, I might say, prevailing practice or precedent 
or else convenience, but when I go over to the Wash­
ington and Lee it certainly appears that there has 
been employed some very skillful and competent think­
ing in regard to the establishment of that curriculum.

Take, for example the commercial diploma and the 
courses listed thereunder. They are grouped in terms 
of that which in education would certainly- effectuate 
in what one might call a very useful and practical 
and decidedly desirous commercial diploma. There 
seems to be an organization and a pattern of curricula 
which is absent in the case of the Hoffman-Boston for 
the reasons stated.

Q. In the light of the information to which you 
have just referred, would you express your opinion 
as to which of these two curricula you would regard 
as superior to the other? 1 should like to- phrase my ques- 
(R. p. 526) tion this way: As to- whether or not the 
courses of instruction, on the basis of this information, 
offered at the Hoffman-Boston are equal to or unequal 
to- those which are offered at the Washington and Lee 
High School?

A. Without doubt, the courses offered at the Hoff­
man-Boston School are inferior to those offered at the 
Washington and Lee for this basic reason, that we 
are concerned today on the high school level with 
students having opportunities which are more than in­
tellectual. Intellectual growth must be accompanied, 
supplemented and enhanced by physical growth,



[ 166 1

emotional, moral, and the traditional subjects of Eng­
lish, social science, science, mathematics, make basic­
ally for what one might call intellectual growth, while 
if we go over to Washington and Lee we find courses 
down there such as dramatics and I find courses such 
commercial law, business correspondence, languages 
especially which 1 don’t find in the Hoffman-Boston 
list.

(R. p. 527) Is it your conclusion with regard to 
the superiority of the curriculum offered at the Wash­
ington and Lee High School affected by the situation 
relative to instruction in vocational subjects at these 
two different schools, concerning which you have just- 
testified?

A. Yes. I believe that every high school should 
afford vocational training — every high school.

#  & *  *  #

(R. p. 529) Q. At this point let me ask you a few 
additional questions. A consideration of Table 37 of 
the Dawson report reveals that courses in speech are 
offered at the Washington and Lee High School which 
are not offered at the Hoffman-Boston High School. 
Will you state for the information of the Court the 
value of such a course to a high school pupil?

A. Yes. Every high school pupil needs an oppor­
tunity for remedial experiences insofar as oral and, 
for that matter written expression of the English lan­
guage and a course in speech, without shadow of a 
doubt, is the best possible opportunity to give him an 
opportunity for remedial work, improvement and de­
velopment.

Q. A further consideration of the tables reveals



f 1 6 7  1

courses In journalism taught at Washington and Lee 
High School but not at Hoffman-Boston High School. 
Do courses in journalism have any value to a high 
school pupil?

A. Yes. However, 1 want to be very well under­
stood. I am not going to place courses in journalism 
insofar as their essential character, in the same cate­
gory in which I would place courses in speech but I 
certainly think that my answer to the question, if I 
understood it, do courses in journalism, have value to 
the high school curriculum? — my answer to that 
question is yes.

Q. Looking further at the table, Doctor, I see that 
(R. p. 530) the course in solid geometry is offered at 
Washington and Lee but not at Hoffman-Boston, Will 
you state for the information of the Court the value 
to a student of a course in solid geometry?

A. Yes. Many of the students who are in the High 
School will later go into technical institutes. Those 
who do not go* to technical institutes but go even in­
to professional collegiate classes for advanced colleg­
iate classes can well profit from, and those in technical 
and somewhat professional courses will find it abso­
lutely imperative to have a foundation in solid geom­
etry or they will be impeded in their collegiate work 
and will be forced to take it on the collegiate level. 
I will grant though insofar as solid geometry it is one 
subject where in many high schools, large and small 
of the country, they fall down but the desirable prac­
tice is certainly to afford solid geometry and a school 
which affords it is superior to that extent to a school 
which does not afford it.

Q. Further reference to the tables shows that a



[ 168 1

course in commercial arithmetic is offered at Wash­
ington and Lee but not at Hoffman-Boston. Does a 
course in commercial arithmetic have value to a stu­
dent and, if so, what value or values?

A. I would characterize a course in commercial 
arithmetic as an elective. Those students who do not 
intend to pursue collegiate education and intend to 
(R. p. 531) go into any of the commercial fields will 
find it absolutely essential to pursue a course in com­
mercial arithmetic. Those who go into professions on 
the college level may not find it so essential but those 
who go into any type of college work of a general 
character could well afford to indulge in commercial 
arithmentic as an elective.

By t h e  C o u r t :

Q. What is commercial arithmetic?
A. More or less arithmetic which involves some of 

the rapid addition and rapid subtraction, division, mul­
tiplication, rapid methods of employing those funda­
mental concepts.

B y M r . Robinson:

Q. Looking further at the table, Dr. Knox, a course 
in general mathematics is offered at Washington and 
Lee but not at Hoffman-Boston. Will you state the 
value to a student of a course in general mathematics?

A. I hesitate because I can answer that question 
only if I understand the administrative reasons for 
including a course in general mathematics at Wash­
ington and Lee and, to my mind, general mathematics 
would be an exploratory course and if we have stu­
dents who are more or less deficient or retarded ment­



t 1 6 9  1

ally, or for some other reason, then I would give him 
general mathematics for exploratory purposes.

(R. p. 532) I think in any number of high school 
students you would find some who would need re­
medial work. If the course in general mathematics — 
and I am not familiar with it — at Washington and 
Lee is an exploratory course, then I certainly believe 
it has high value and any secondary school could well 
afford such course. If general mathematics at Wash­
ington and Lee, which I don’t believe is explained — 
if it has any other concept other than exploratory 
course, then I am unable to answer the question; I 
have no knowledge.

Q. Dr. Knox, referring again to tire table, courses 
in economics, world history, economic geography and 
Latin-American history are offered at Washington and 
Lee but not at Hoffman-Boston. Will you state for the 
information of the Court the value to a pupil of having 
such courses in the curriculum?

A. Yes. I think those courses are very essential. 
If you pardon the reference, since my major field of 
preparation was in the area of social studies, I would 
say that those of us who consider ourselves college 
teachers in the field of social studies, preparing high 
school teachers, definitely recommend that a high 
school teacher camiot possibly teach English — I beg 
your pardon — history, except that she is able, in her 
teaching of history, also to evidence a thorough know­
ledge of these courses. Now then, on the high school 
(R. p. 533) level we state that in order that those 
courses might have the fullest possible value, the tea­
chers should likewise afford an elective for those studies. 
In the areas of economic geography and Latin American



[ 170 1

history our whole concept of social studies is so broad 
that we are concerned with not a narrow specializa­
tion but with broaden experience in the whole field 
of international as well as inter-community and inter­
state. They have great value insofar as broadening the 
experience of youth and giving us what we understand 
the fundamental concept of social studies is.

Q. Again referring to the table, Dr, Knox, courses 
in Latin are taught at Washington and Lee but not 
at Hoffman-Boston. Will you explain the value to a 
pupil of courses in Latin being in the curriculum at­
tended by him?

A. I think Latin could well be an elective. It is 
one subject I am not a specialist in — the classics — 
and not being a classist, I certainly know that I 
would be condemned by this answer, but it is a course 
which I think has value as an elective and could be 
well afforded for those students who expect to follow 
their high school work by collegiate work which would 
require a higher type of literary specialization.

Q. Courses in commercial law, in business corres­
pondence and in bookkeeping are, according to the 
table, taught at Washington and Lee but not at Hoff­
man-Boston. Will you explain the values of those 
(R. p. 533a) courses to a pupil?

A. Yes, Every high school pupil has to have op­
portunities for some elective and, depending upon his 
goals and his economic opportunities, it is very helpful 
if the child is able to elect courses in the field of 
business and if he prepares himself, even for tempo­
rary work — let us say going to make a little money 
before he goes into college, he can find himself greatly- 
helped by having elected such courses as those to 
which you referred.



[ 171 1

Q. The table further reveals that a course in me­
chanical drawing is included in the curriculum in the 
Washington and Lee School but not in that of the 
HofFman-Boston School. Will you explain the value 
to a pupil of such a course?

A. As an elective and perhaps dependent upon the 
guidance direction which the pupil has in the high 
school, I think mechanical drawing is certainly very, 
very essential. I cannot conceive of any number of 
students, boys especially, in any high school wherein 
about one in five due to his own talent and desires, 
does perhaps expect to go into a technical field or 
technical institute and pursue high school courses pre­
paratory thereto. For such a student mechanical draw­
ing would be quite essential. To others it would be a 
very wholesome elective.

Further reference to the table shows that courses 
(R. p. 534) in fine arts and in art appreciation are 
offered at Washington and Lee but not Hoffman-Bos- 
ton. Do these courses have value to a pupil, and, if so, 
what values do they have?

A. Yes, they have value because, as I stated be­
fore — if you will pardon the repetition — we are 
concerned on a high school level with developmental 
programs. We are not concerned with students com­
ing out and narrowly prepared by specializing in cer­
tain fields, and if one is going to have a develop­
mental program one must have an opportunity to en­
gage in his experiences in the products of art and the 
products of music and art appreciation; fine arts, and 
music appreciation are very definitely desirable for the 
type of programs which we want on the secondary 
level.



[ 172 ]

(R. p. 535) Q. The curriculum of Washington and 
Lee includes music appreciation, mixed chorus and 
glee club for boys and glee club for girls. In what 
way, if any, does the inclusion of these in the curricu­
lum at Washington and Lee High School become of 
value to the pupils attending that school?

A. They afford a greater opportunity for cultural 
growth, for stimulation and appreciation of that which 
we call the cultural development of studies — very defi­
nitely.

#  e  *  *  *

(R. p. 536) Q. Dr. Knox, have you had occasion 
(R; p. 537) to inspect the facilities for vocational in­
struction for Hoffman-Boston High School?

A. I have — very hurried observations.
Q. During the course of your observation did you 

see there at Hoffman-Boston High School any facilities 
for instruction in automobille mechanics, in machine 
shop, in printing, in sheet metal or in woodwork?

A. Absolutely no facilities for teaching automobile 
mechanics or for teaching printing and very inade­
quate material, most inadequate material. I would like 
to emphasize — most inadequate materials for machine 
shop, sheet metal and woodwork, based upon the very 
hurried visit which I made. I might say I asked questions 
in regard to the facilties for teaching those and, as a 
rule, in response to the question I was shown what 
was available. If that is all that is available, then it 
was most inadequate.

Q. Did you have occasion, Dr. Knox, also to ob­
serve the photographs which have previously been of­
fered in evidence of the facilities of the machine shop,



I 1 7 3  3

the sheet metal shop and the woodworking shop at the 
Washington and Lee High School?

A. Yes, I saw those photographs.
Q. Did you see at Hoffman-Boston High School 

any facilities the same or substantially similar in char­
acter for instruction in those areas?

(R. p. 538) A. Definitely not.
Q. On the basis of this information, will you state 

the value to a pupil attending the Washington and Lee 
High School of the courses in automobile mechanics, 
machine shop, printing, sheet metal and woodworking?

A. Yes. The student at Washington and Lee is af­
forded an opportunity to gain experience in industrial 
art of a much more extensive character than the ex­
periences afforded the student at Hoffman-Boston, 
even if, as indicated by the listing here, they are given 
in a general shop, if machine shop, sheet metal, and 
woodworking are given under general shop, and I 
don’t understand — I can’t understand — how one shop 
could teach machine shop, sheet metal and woodwork­
ing in a general course and, by analogy, if you please, 
any more than I understand how one classroom could 
teach history, English and foreign languages because 
the very character of the instruction required for tea­
ching those courses is of such a nature that it almost 
prevents, to the extent of my knowledge, offering those 
courses in a sequential or even inter-related manner. 
I would have to know a great deal more about them. 
How long would this general shop extend — two years’ 
time or one years’ time or three semesters? I would 
have to know a lot more about that than I know at the 
present time.

(R.p. 539) Q. Dr. Knox, the table further reveals 
courses in retail sales and in consumer buying are of­



[ 174  1

fered at Washington and Lee but not at Hoffman- 
Boston. What, if any, values do these courses have to 
the pupils who take them?

A. Values insofar as experiences in the area of dis­
tributive education. We want our high school students, 
above all else, to be able to engage in an understand­
ing of selling and buying, salesmanship work; wheth­
er they actually become salesman or not, they at least 
are going to become husbands and wives, father and 
mothers, and they are better able to engage in an 
understanding of what we might call salesmanship 
and industrial and commercial relationships to our 
community.

Q, Dr. Knox, further reference to the table shows 
that the curriculum of Washington and Lee includes 
cadets for boys and cadets for girls, cadet hands and 
an orchestra. What, if any, values do these have to 
the pupils attending that school?

A. They have a very, very high disciplinary value 
as well and I am sure those who are better qualified 
than I am to speak would say they have values in the 
realm of health and phycial welfare as well as stim­
ulating in those boys and girls a certain type of ap­
preciation for our whole American way of life, to the 
extent to which a military atmosphere has importance 
in developing and stimulating a concept of pride in our 
(R. p. 540) American life and its existence.

Q. Dr. Knox, the table further shows that at Wash­
ington and Lee, but not at Hoffman-Boston, a course 
in driver training is offered. Will you state the value 
to the pupil of such a course?

A. I think every high school student — I don’t 
know what the law is in Virginia; you would have to 
tell me that, insofar as how old a student should be



[ 1 7 5  3

before he is able to drive an automobile, but if it is 
15 or 16 as in some states where I have lived, most 
high school students certainly have reached the legal 
age to drive a car and if they receive training of a 
directed character in how to drive a car, it is vastly 
superior to learning to drive a car in a non-directed 
manner.

Q. Dr. Knox, will you express your opinion as to 
whether a curriculum which contains courses in speech, 
in journalism, solid geometry, commercial arithmetic, 
general mathematics, economics, world history, eco­
nomic geography, Latin-American history, Latin, com­
mercial law, business correspondence, bookkeeping, 
mechanical drawing, fine arts, art appreciation, com­
mercial art, music appreciation, mixed chorus, glee club 
for boys, glee club for girls, retail sales, consumer buy­
ing, cadets for boys, cadets for girls, cadet band, or­
chestra, driver training, automobile mechanics, print­
ing and other units of machine shop, sheet metal and 
(R. p. 541) woodworking in the fashion which you 
have previously testified is superior to or is not super­
ior to a curriculum which does not contain any of 
those courses?

A. It is superior.
#  £  O #  *

Q. I should like to call your attention to pages 12 
and 13 of the Jenkins report.

A. I have it.
Q. And to Table No. 40 on page 73 of the Dawson 

report, from which you will see that summer school 
is offered at Washington and Lee but not at Hoffman- 
Boslon. Will you explain the values, if any, of a sum­



[ 176 1

mer school session to the pupils who are enabled to 
take advantage of such a session?

A. Yes. There is a well agreed upon concept among 
professional educators that we should extend educa­
tional opportunities, as far as possible, for twelve 
months during the year. Now then, there is, of course, 
an interpretation insofar as what the 11th of even the 
10th month and 11th months might include but they 
definitely state that if a child has the environment of 
the school during the summer for its disciplinary, as 
well as its instructional value, that the school services 
(R. p. 542) will be of much greater value than a 
school wherein the child is denied any opportunity 
for instructional, recreational or developmental pro­
grams during the summer.

Q. Have you, Dr. Knox, examined the portions of 
these reports having to do with the pupil activity pro­
gram at the Washington and Lee and at the Hoffman- 
Boston Schools? I call to your attention in this connec­
tion particularly, Table 80, page 15 of the Jenkins report 
and to Table No. 39 on page 72 of the Dawson re­
port. First, let me ask you to state for the information 
of the Court the value to a pupil of a well-rounded 
pupil activity program?

A. I would prefer — and I suspect that I am cor­
rect — I hope that I am — to call those what are 
sometimes called extra-curricula programs and cer­
tainly extra-curricula programs allow the student to 
express himself in a manner which permits greater in­
dependence, greater possibility for expression, free 
from the classroom discipline, and it promotes, stimu­
lates and motivates individual and social growth to a 
greater extent than can possibly be done in the conven­
tional classroom.



I 177  ]

Q. On the information contained in these two 
tables, will you state whether the student activity pro­
gram at the Hoffman-Boston High School is equal to 
or is not equal to that at the Washington and Lee High 
(R. p. 543) School?

A. I find a discrepancy insofar as the two tables to 
which you have referred me, Mr. Counsellor, i  find 
in one table that at the Hoffman-Boston there were 
only three of these activity programs and I find in 
another table that — well it looks to me like twelve 
or fifteen down here but I would say that the extent 
to which any school----

Q. Let me ask you to do this, in view of the cir­
cumstances which you have mentioned: Will you ex­
press your opinion, on the basis of the information 
which is contained in Table 80, page 15 of the Jenkins 
report, first, and then also express your opinion as a 
separate opinion on the basis of the information con­
tained in Table 39 of the Dawson report?

A. As a result of Table 8 of the Jenkins x'eport, the 
activity program of Washington and Lee is vastly super­
ior to the activity program at Hoffman-Boston the rep- 
restentations on page 72 of the Dawson report evidence 
a richer pattern of activity program offering at Wash­
ington and Lee than at Hoffman-Boston.

I must say this, that to some extent numbers in these 
tell us very little and that is one reason I am hesitating. 
On the Jenkins report we have three. It is just com­
mon sense and I think anyone would agree that three 
activities couldn’t in any manner afford the number 
of experiences which this great list of actvities affords.

(R. p. 544) I see quite an increased number in the 
Dawson report and, regardless of the fact that the num­
ber has been increased, when I check very quickly here



[ 1 7 8  1

the activities afforded at Washington and Lee which 
are denied or are not afforded at Hoffman-Boston, the 
experiences are greater for the students at Washing­
ton and Lee.

*  «  *  *  *

Q. Will you state whether or not a variety of dif­
ferent pupil activities avaiable to a pupil has value 
and, if so, what value?

A. Yes, because insofar as activity programs, we 
want the student to have an opportunity to sample 
as many possible different activities in a broad — shall 
I say horizontal set of experiences which we desire to 
afford him rather than a vertical or intensive exper­
ience in any one or two limited courses.

Q. Did you have an occasion to examine the por­
tions of these reports relative to libraries at the Hoff­
man-Boston and at the Washington and Lee High 
Schools?

(R. p. 545) A. Yes.
Q. Calling your attention to the information set 

forth in Table No. 9 on page 18 of the Jenkins report 
to that which is set forth in Table No. 30 on page 
55 of the Dawson report, will you express your opin­
ion as to whether or not the library at the Hoffman- 
Boston High School is equal to or unequal to that at 
the Washington and Lee High School in point of book 
holdings?

A. In point of book holdings it is not equal.
Q. What, if any, values result to the pupil from 

having a large collection of books and in having a 
collection of books on a large number of varied sub­
jects?

A. That, of course, I can talk about for an hour.



[ 179  1

Briefly summarizing from the American Library As­
sociation report, which is certainly accepted univer­
sally in America as elsewhere along this line, they 
state as a standard 2,000 volumes for even the smallest 
possible high school unit. All right. Now then, the 
reason therefor is that a child on the high school level 
must have a great number of opportunities for vicarious 
expenriences and the best way to afford vicarious ex­
periences is through the realm of broad literary read­
ing. Also, of course, for reference purposes, what is 
commonly called collateral reading. The greater the 
number of books, the greater the opportunity the tea­
cher will have to direct the student in library reading 
(R. p. 546) which will enable the child to learn how 
to think rather than what to think.

Q. I should also like to direct your attention, Dr. 
Knox, to Table 10 on page 19 of the Jenkins report.

A. I have it.
Q. And to Appendix B, commencing on page 10.
A. I don’t believe I have a copy of the appendix. 

What page again?
Q. Page 10, Appendix B. They show the news­

papers, magazines and periodicals in the school library 
at Washington and Lee and at Hoffman-Boston. 1 
should first like to ask you, Dr. Knox, as to whether 
the size and the variety of the library holding with 
respect to newspapers, magazines and periodicals have 
any value to the pupils attending a given school?

A. Yes, they do.
Q, Will you state what these values are?
A. We can hardly conceive of a high school youth 

maturing properly and openly into adulthood without 
having an opportunity to profit by current literature 
and in his reading of these magazines he has an oppor­



[ 180 1

tunity to acquaint himself with that which is a part 
of his current every-day contemporary existence.

Q. On the basis of the information contained in 
these two tables, would you express your opinion as 
(R. p. 547) to whether or not the library of the Hoff- 
man-Boston School is equal to or is not equal to the 
library at the Washington and Lee High School in 
point of newspapers, magazines and periodicals?

A. In the light of what the report gives, both the 
Jenkins and the Dawson — well, the two libraries are 
not comparable. Washington and Lee is so superior 
that there is no — inclusive of the material on this Ap­
pendix on page 10, a list of magazines. I might say, 
Mr. Counsellor, if you will permit, that this was one 
portion of the monograph which I studied in detail 
and there are standards published by several asso­
ciations, not only the American Library Association, 
H. O. Wilson and the Office of Education, and the list 
of magazines and periodicals listed for Washington and 
Lee measures very favorably to the recommended list 
afforded by those educational agencies. The list at Hoff- 
man-Boston by comparison is sadly lacking.

Q. Are you familiar with the portions of these re­
ports having to do with library facilities?

A. Yes.
Q. Are you in postion to express an opinion as to 

the quality or the inequality of the library facilities at 
the Hoffman-Boston Hgh School as compared with 
those at the Washington and Lee High School in point 
of such library facilities? I should like to call your atten- 
(R. p. 548) tion in this connection to Table 33 on page 
45 of the Dawson report and also to Table 29 on page 
54 of that report. On the basis of this or any other 
information which you may have relative to these



f 181 1

libraries, including the photograph thereof which you 
have previously examined, would you express an opinion 
as to whether or not the library at the Hoffman-Bos- 
ton High School is equal to or is not equal to that 
at the Washington and Lee High School?

A. I studied these tables dealing with the libraries 
as a result of what was afforded to me by counsel 
and I was very, very interested, to say the least. I 
find in the Jenkins report on page 18 two listings and 
a reference to books. I find in the Dawson study on 
page 45, dealing with the libraries, a description of the 
room. I found in the column dealing with arrange­
ments one large room, workroom. I point in Item 7 
for both Hoffman-Boston and Washington and Lee to 
the characterization as very attractive, in spite of the 
fact that the Hoffman-Boston one large workroom has 
an indicator showing that it was also used as a Prin­
cipal’s office and for a library to also be used as a Prin­
cipal’s office and still be very atractive as a library 
arouses confusion in my mind. I will be sincere and I 
find myself unable to understand that comparison. I 
can’t conceive of the meaningfulness of that which is 
given on page 45 insofar as “adequately”. I can’t under- 
(R. p. 549) stand it.

& # # # *

(R. p. 553) Q. Dr. Knox, on yesterday you ex­
pressed some difficulty in the interpretation of certain 
of the data contained in the Dawson report. Will you
explain to His Honor the nature and the source of 
your difficulties in this connection?

A. Yes. If we refer again to pages 45 and 54 of 
the Dawson report, the tables on those pages, and turn 
to 45 first, in the Dawson report I see that insofar



[ 1 8 2  3

as the Hoffman-Boston School, one large room is in­
dicated as a workroom. I am unable to determine 
the meaning of the arrangement in that large room 
since I understand that the room is also used for a 
Principal’s office and I think insofar as the Principal's 
office requiring a waiting room, requiring some space, 
at least, for the Principal’s conferences and to have a 
Principal’s office in the library confuse me insofar as 
(R. p. 554) item No. 7 which is “very attractive”.

Also, in that column I see that the ceiling height 
is 13 feet. The Washington and Lee School I see a 
ceiling height of 20 feet and I am inclined to believe 
that a ceiling height of 13 feet, relatively low, because 
of the lack of ventilation facilities, because of the 
noise — I believe this room referred to is next to the 
gymnasium. Also, I think of the fact that insofar as 
that ceiling height, which would include again the 
Principal’s office, the waiting room for the Principal, 
a conference room — those conditions tend to make 
me a little confused in regard to the listing down there 
of “very attractive” as a libraiy.

If we go over to page 54 very quickly, I find there 
that eight tables — I have understood from perusing 
the report that the Hoffman-Boston libraiy accomo­
dates all the students in that school. I believe you 
have in that building an elementary school as well as 
a junior and senior high school. From the tables, in­
cluded in this report, the enrollment of the junior-sen­
ior high school last year, if I am not mistaken, totalled 
272. I don’t have the figure for the elementary school 
enrollment. I presume, of course, that it is larger than 
the junior high school enrollment and the senior high 
school enrollment or perhaps larger than both but



[ 183 1

when I see eight chairs, eight tables, thirty-eight chairs, 
I am unable to understand in my own mind the extent 
to which those may prove adequate or inadequate un­
til I know the extent to which this particular room 
(R. p.555) services all the students at Hoffman-Bos- 
ton, both elementary as well as junior and senior high. 
My last statement in that instance would be that even 
if there were 270 junior and senior high school students 
alone serviced in that library room that the matter of 
tables and chairs might not prove adequate.

One other item there: I notice that in the Washing­
ton and Lee there was definitely a newspaper rack. 
I am very much of the opinion that libraries should 
provide adequate facilities for newspapers for the ob­
vious reason. I checked to see what facilities were pro­
vided at Hoffman-Boston and I saw no rack or other 
mentioned made of other facilities for newspapers and 
their use in tire library.

One final statement in regard to the catalog drawer. 
In my brief visits to the Hoffman-Boston I looked 
through that 24-card catalog drawer and I counted 
very carefully the number of drawers which were used 
for card catalog purposes and I found there only six 
drawers of the 24 which had any regard at present 
were being used at all for cataloging purposes.

Q. Is it necessary, Dr. Knox, that waiting facilities 
be a part of or connected with the Principal’s offce of 
a senior high school?

A. Certainly.
Q. Do you consider the arrangement at Hoffman- 

(R. p. 556) Boston where the Principal’s office is lo­
cated in the workroom of the library, a desirable ar­
rangement for a high school?

A. No.



[ 184 1

Q. Will you state your reasons for your conclusions 
in that regard?

A. The Principal’s office and library must, above 
all else, afford facilities for, shall we say, conferences 
frequently of a confidential character. A student’s busi­
ness with the Principal is of such a nature that quite 
frequently confidence is very, very desirable and nec­
essary and also the Principal must, above all else, have 
facilities for availing himself of records, reports, files, 
one might say, and perhaps some library or reading ma­
terial for the Principal in Inis office of a profesional 
nature or else of a community character. That is the 
reason for my statement.

Q. Calling attention, Dr. Knox, to the Table No. 
23 on page 45 of the Dawson report, examination will 
reveal that the library of the Washington and Lee High 
School is sound-proofed while the library at the Hoff- 
man-Boston High School is not. Would you consider 
sound-proofing of the library at the Hoffman-Bostou 
School necessary, in view of the library set up there, 
as you have testified?

A. Again, by lack of understanding of the table 
enters into the consideration. Certainly if 270 junior 
and senior high school students are to use that library 
(R. p. 557) and the square feet in the library are 1617 
square feet, we use a standard there and I think also 
the staandard of the Southern Association, as I found 
it in the appendix of Dr. Dawson’s report, would call 
for about 1625 square feet as a desirable minimum. 
Of course, the difference is very slight but the room 
would be very well filled. I arrived at that by taking 
standards which education had used, merely a room 
large enough for the largest class, and that is 45 stu­
dents in the Hoffman-Boston, plus 20, which is merely



[ 1 8 5  ]

the formula, and then 25 square feet per student and 
I find that room perhaps — 1617 square feet as against 
the desirable 1625 — the number of square feet there 
relatively negligible. However, with that number of 
square feet being occupied by junior and high school 
students, let alone the fact that perhaps the elementary 
school students at Hoffman-Boston also are required 
to use that library, certainly with that number of stu­
dents, every oppotunity for silence should be provided 
and, without any sound-proofing, at times it must be 
at least very noisy.

Q. Dr. Knox, would your conclusions in these re­
gards be at all affected, assuming that the enrollment 
at the Hoffman-Boston High School was, for the ses­
sion 1948-49, a total of 148 in grades 8 to 12, inclusive, 
and a total of 225 pupils in grades 1 to 7, inclusive?

A. It would.
(R. p. 558) Q. Would you explain in what way?
A. That total of students in grades 1 through 7 

and 8 through 12 would be of such a character that the 
square feet as indicated in this column would be cer­
tainly for below the minimum, far below the desirable 
minimum.

Q. Dr. Knox, on the basis of the information which 
is contained in the Jenkins report and in the Dawson 
report which you have examined, would you express 
your opinion as to whether or not the library facilities 
afforded pupils at the Hoffman-Boston School are 
equal to or unequal to those afforded pupils attending 
the Washington and Lee School?

A. From my perusual of the material I definitely 
conclude that the library facilities of Hoffman-Boston 
are inferior to those of the library facilities at the Wash­
ington and Lee School.



[ 186 1

Q. Dr. Knox, in the Dawson report there is in­
formation and data contained relative to the alter­
nation of courses at the Hoffman-Boston School. Would 
you express your opinion as to whether or not a cur­
riculum in which the courses are alternated is equal 
to or is unequal to a curriculum in which the courses 
are not alternated but rather the courses are taught 
each and every year, that is, each course is taught each 
year?

A. You see, the matter exigency as well as admin­
istrative reasons for the alternating enter into a con- 
(R. p. 559) sideration there in my mind. Certainly 
the desirable practice is to have courses offered each 
year. If the alternation is merely because of the exi­
gency for one particular year or one particular semes­
ter and then there is a resumption of annual offering 
of courses that would be one thing but if there is a 
regular practice of alternating the courses over the 
period of two or three years as I found indicated in 
one of the studies, that is undersirable and contrary 
to the best practices along that line.

Q. Will you state why you consider that practice 
undersirable or why it is considered undesirable?

A. Well, alternation of courses requires at least a 
greater extension of teaching on the part of the faculty- 
members. If a teacher on the high school level tea­
ches certain courses one year and if another year she 
has to teach certain other courses, it makes for addi­
tional preparation and tends to prevent the teacher 
from becoming as thorough in any one or two courses 
which we ordinarily like to think that the high school 
teacher has specialized to teach, so it is definitely a 
greater burden for the teacher to have to teach differ­
ent courses from year to year as is the case where



[ 1 8 7  1

courses are alternated; also, insofar as the student, if 
a student were to fail a course one year, it might be, 
depending upon the year- of school in which he finds 
himself when he fails a course, that the student would 
(R. p. 560) not be able to take that course again prior 
to the normal period of graduation and I think, be­
yond a shadow of doubt, finally, that it has been found 
where courses are alternated there is a tendency to 
level down instructions so as to prevent failing or 
maladjustment of students insofar as grade placement 
for the reason mentioned.

Q. Does the maturation point become involved in­
sofar as a system of alternating courses is concerned?

A. There is a question which is somewhat moot. 
We ordinarily like to think of an eighth grade level 
because it contributes to homogeneous grouping. We 
like for high school students of the same age, as far 
as possible, to be grouped in terms of age for social 
reasons. We are not only concerned with the intellect­
ual development of the high school child but we are 
concerned with his social development. Therefore, if 
there is a consideration for eighth grade grouping and if 
there is a homogeneity there, it is highly desirable. The 
maturation then of the child is certainly affected when 
he is forced, through the rotation of courses, to take 
courses with students who may be of different age 
level. It doesn’t necessarily follow that the rotation 
would bring about a readjustment of age levels but 
practice, I think, will show that only too frequently a 
rotation involves age differentials and also that the 
rotation would affect, in that case, a consideration 
(R. p. 561) of the maturation level.

# **



[ 188 ]

Q. Dr. Knox, did you have an occasion, in the 
course of your study of these two schools, to consider 
the matter of sites and exteriors and grounds, and that 
sort of thing, of the Washington and Lee and Hoff- 
man-Boston High Schools?

A. Yes. I read what was included in the two studies 
presented to me. I observed the photographs which 
were presented and also I have visited the site of each 
(R. p. 562) of the schools.

Q. Upon your visit at the Hoffman-Boston High 
School were you able to get any sort of a panoramic 
view from that school such as has been questioned 
about in the earlier testimony in this case?

A. I did not?

B y  M r . R o bin son :

Q. Did you make any effort to make such an ob­
servation from the Hoffman-Boston High School?

A. Yes.
Q. Will you express your opinion as to whether 

or not in the matter of site, in the matter of grounds 
and in the matter of exterior construction, the Hoffman- 
Boston School is equal to or is unequal to the Wash­
ington and Lee High School?

A. My response includes a consideration of the fact 
that a site .must provide at least safety facilities, some 
health conditions, something of an aesthetic character, 
and insofar as those three items, safety — because the 
(R. p. 563) fact that Hoffman-Boston is not graded, 
there are no pavements on the site which I recall — 
I hope I am not in error there at Hoffman-Boston, — 
the mud and other elements during rainy and incle­
ment weather would, of course, detract from the safety



[ 189 ]

value. Insofar as aesthetic value, it cannot be com­
pared to a site such as I saw at Washington and Lee 
which has pavements and where there is definitely 
shrubery around the school, well tended and well kept 
up.

Q. Dr. Knox, what, if any, values result to a school 
and to the instruction of pupils attending that school 
from the presence of an auditorium or auditorium fa­
cilities there in?

A. The values are certainly very, very great be­
cause we expect high school students to be able to 
participate in shared opportunities and in order to a 
maximum opportunity of a shared character.

Q. On the basis of the information which is con­
tained in the Jenkins and in the Dawson reports, will 
you express your opinion as to whether or not the au­
ditorium facilities which are contained at the Hoffman- 
Boston School are equal or are unequal to those which 
obtain at the Washington and Lee High School?

A. On the basis of information I find in the reports, 
the auditorium at Hoffman-Boston is decidedly infer­
ior.

Q. What values, if any, result from the presence 
(R. p. 564) of the gymnasium facilities in, a high 
school? By that I mean to the pupils attending that 
school?

A. Values of hygienic as well as physical character 
as well as instructional character insofar as formal 
courses in the field of physical education.

Q. On the basis of the information which you have 
considered, will you express your opinion as to wheth­
er or not the gymnasium facilities, if any, afforded at 
the Hoffman-Boston High School are equal to or are 
unequal to those which are afforded to pupils attend-



[ 190 ]

ing the Washington and Lee High School?
A, From my observation of the Hoffman-Boston 

High School there is no gymnasium. There is an au­
ditorium room wherein chairs are sometimes removed 
and sometimes the opportunity for formal calisthenics 
is provided but, regardless of what it is called, I can­
not yield to the statement that that is a gymnasium. 
There is no equipment for gymnastic exercises and, 
since games are a part of — I understand from physical 
education experts — a part of our gymnasium facilities, 
there is absolutely no room for indoor games or for 
sporting activities of that character.

Q. Please state your opinion as to whether or not 
as to this point the Hoffman-Boston is equal to or is 
unequal to the Washington and Lee High School?

A. In the light of the information I have, it is un- 
(R. p. 565) equal.

# # * # #

(R. p. 568) Q. Dr. Knox, will you, as briefly and as 
concisely as you can, state the values which result to 
the pupils from the presence of infirmary facilities in 
a given high school?

A. The provision of remedial health measures as 
well as preventive health measures.

# # * # #

O. Would you say that a school which contained 
infirmary facilities is equal? Would you say that a 
school which does not contain infirmary facilities is 
(R. p. 569) equal to or unequal to a school which does 
contain those facilities?

A. Unequal.

$ Sf «Fe



E 191 1

Q. Dr. Knox, will you state whether or not there 
are values to be derived by a pupil attending a school 
in which there is a music studio, in which there is an 
art studio for purposes of instruction in those two 
courses?

A. There are values, positive values.
Q. On the basis of the information which you have, 

would you express your opinion as to whether or not 
the facilities for instruction in music at the Hoffman- 
Boston School are equal to or are unequal to those 
which are afforded at Washington and Lee High School?

A. If I recall correctly, there are no specific class­
room provisions for a music room,, so-called, or an art 
room, providing instructional opportunities at the Hoff- 
man-Boston. I hope I do not err in my recollection. 
In that case, instruction in music and art could not 
be given as effectively in a school which does not have 
those rooms as in a school designed and constructed 
(R. p. 570) with definite rooms designed for teaching 
purposes.

Q. Dr. Knox, on the basis of the information which 
you have examined, will you express your opinion as 
to whether or not the equipment at the Hoffman-Bos- 
ton School for instruction in courses in science, includ­
ing general science, chemistry, biology and physics, 
is equal to or is not equal to the equipment which 
is afforded for instruction of those courses at the Wash 
ington and Lee High School?

A. The studies themselves — Dr. Jenkins’ study and 
Dr. Dawson’s study — both evidence the facilities for 
offering the course at Hoffman-Boston are not com­
parable to the facilities at Washington and Lee. Both 
studies evidence that.



[ 192 ]

Q. Will you state whether or not different sanitary 
facilities are necessary for pupils of elementary age and 
pupils of high school age, either junior or senior high 
school?

A. Yes. There are definite standards established 
for elementary school students, which differ from those 
established for high school students insofar as sanitary
facilities.

Q. On the basis of the information which you have 
considered, will you express your opinion as to whether 
or not a school which contains a cafeteria is superior 
in this regard to a school which does not?

A, A school with a cafeteria is certainly superior.
(R. p. 571) Q. On the basis of the information 

which you have considered, would you state whether 
or not, in your opinion, the Hoffman-Boston School is 
equal to or is unequal to the Washington and Lee 
School in point of teachers’ restrooms?

A. I think I found in the material which I studied 
that Hoffman-Boston has a restroom for women tea­
chers only, that the Washington and Lee provides a 
restroom for both men and women teachers. There 
is a principal there which is readily apparent.

Q. Are there advantages to be derived from the 
presence of teachers’ restrooms in a given school which 
are not to be found in a school which does not con­
tain such facilities or which does not contain adequate 
facilities of that type?

A. Building sttandards for high schools, without ex­
ception, to the best of my knowledge, require teachers’ 
restroooms.

Q. Are there values to be derived by tire pupils at­
tending a given school from the presence in that school



[ 193 1

of a separate band auditorium and a separate room 
for instruction in the course in bookkeeping, together 
with calculating devices avaailable in the latter class­
room?

A. Insofar as instruction in band, standards for the 
room are of character that it is desirable to have a 
room specially designed for band instruction and per­
haps other classes might be included but, at least, 
(R. p. 572) specially designed for band instruction. In­
sofar as bookkeeping — am I correct?

Q. That is correct.
A. Insofar as bookkeeping, I don’t know of any 

special design for a room. To the best of my know­
ledge, there is none, but the facilities in the room for 
bookkeeping, for the lesson units or learning situations 
which arise would certainly require special equipment.

Q. Are there values which are to be derived by a 
pupil from the presence of a distributive education 
room or office and a guidance office which otherwise 
would not be derived if those facilities were lacking.

A. Insofar as distributive education office, that 
quesiton could receive a great deal of discussion. I 
don’t want to take a position in regard to that matter 
of distributive education but I will take a very posi­
tive position insofar as the guidance question. We con­
ceive of guidance and counselling to be so essential, 
so highly specialized and so very definitely a part of 
the present day high school student s program, that 
there should be very special facilities for guidance and 
counselling.

Q. Calling your attention to the information con­
tained in the Jenkins survey and also in the Dawson 
survey relative to the accreditation status of the two



E 194 1

high schools in question, will you first express the 
value to a given school and to the pupils attending 
such school of accreditation both by a state agency 
(R. p. 573) and by a regional agency.

Q. Accreditation affords the school a knowledge of 
certain minimum standards of achievement. Accred­
itation by a State agency is usually lower that that of 
a regional agency and especially in the case where 
a State also is part of a regional agency, we find that 
membership in the regional agency is usually — the 
standards of the regional agencies are ususally higher 
than those of the State agency.

I answered that question that way because in the 
matter of accrediting associations, we know that one of 
chief values from a recognition of minimal standards 
is to allow colleges and universities to avaluate the 
high school training of applicants for matriculation and 
we know that there are certain regional agencies 
throughout the United States which establish standards 
superior to those of the states within those several re­
gions.

There is a case, however, of one s ta te ----
# # * * *

(R. p. 574) Q. Will you state the value to pupils 
attending a given school of the fact that at that school 
honorary awards for scholarship might be conferred 
upon the pupils there?

A. First, I think it has high value in building of 
morale on the part of the student; seondly, it has a 
vocational value insofar as providing a degree of hom­
ogeneity for students who have attained awards, group­
ing these together on certain occasions and benefit­
ing from the interrelationship of such grouping. It has



[ 195 1

also some economic value. A student who receives a 
high school award quite frequently is able to gain a 
scholarship in a university more readily or even to 
secure employment during the summer or after school
hours.

Q. Dr. Knox, on the basis of the information which 
you have considered in connection with the Hoffman- 
Boston High School and the Washington and Lee High 
School, would you state your opinion as to whether or 
not the educational opportunities, advantages and faci­
lities afforded pupils attending the Hoffman-Boston 
School are equal to or are unequal to the educational op­
portunities, advantages and facilities which are afforded 
pupils attending the Washington and Lee High School?

A. In view of the information which I have studied, 
the opportunities at Hoffman-Boston are inferior to the 
(R. p. 575) high school opportunities at Washington 
and Lee.

« # # # «

C ross E xamination  

B y  M r . D ouglas:

# # # # #

(R. p. 579) Q. (The question was read as follows: 
Assuming that no one had requested such courses, 
would you, as an expert in the field of school admin­
istration, advocate those courses be set up at Hoff­
man-Boston School?)

A. Yes.



[ 1 9 6  1

B y  M r . D ouglas:

Q. Would you advocate that a teacher, specially 
certifiicated for those courses, be employed and placed 
at the teaching station in that school?

A. Yes.
Q. Would you advocate that rooms be provided 

for instruction in those courses?
A. Certainly.
Q. Would you advocate that those rooms be fur­

nished?
(R. p. 580) A. Certainly.
(R. p. 586) Q. If those were facts, would you still 

say that you would advocate setting up these different 
classrooms with these different teachers when they had 
no prospective students to teach, just to be able to 
say you offered the courses?

A. When they had no prospective teachers to teach?
Q. Prospective students to teach?
A. I would have the teachers survey the demands 

and needs and if the demands and needs recjuiie that 
those courses be provided, they should be provided,

Q. I agree with that entirely, but did you not say 
a few moments ago that you would provide those 
courses without regard to the demand?

A. I did not. I said without regard to the students 
demands which is different from the demands as estab­
lished by a teacher or administrative committee study­
ing the needs. Perhaps I misunderstand what you mean 
by student demand. I am conceiving you mean the 
students go there and say, “I want this course; I want 
that course.” That isn’t the way we establish a cur­
riculum.

Q. How do you ordinarily establish the fact of



f 197  1

(R. p. 587) whether or not there are going to be stu­
dents to take a course if you give it? How do you go 
about establishing that?

A. We make a study.

B y  th e  C o u r t :

Q. Who makes the study?
A. The administration and the faculty usually. 
The Superintendent and the Principals of the 

schools?
A. Yes and, in the case of a small school, the Su­

perintendent and the Principal and in the case of a 
large school perhaps just the Principal but, of course, 
under the supervision of the Superintendent.

B y M r . D ouglas:

Q. Proceed.

T he C o u r t : I  interrupted. You said "We
proceed to do so and so.”

A. We make a study of the students population of 
previous years, a study of population trends in the com­
munity and a study of the potential needs of the stu­
dents who will matriculate in the future.

B y  M r . D ouglas:

Q. Does that complete your answer?
A  It does.
Q. Do you state that it is the duty of the Principal 

and the Superintendent, or other proper administra­
tive authorities, to make such a study in connection 
(R. p. 588) with curricula offerings?



[ 198 1

A. To make or delegate the making of such a study 
to that faculty member — definitely.

(R. p. 600) O It was testified here, Doctor, that 
if there were only eighteen students in a high school, 
including male and female students, a cadet corps 
ought to be maintained at that High School. Do you 
agree with that conclusion?

A. As I remember the reference made to that ques­
tion, the response was in keeping with a concern for 
equalization of educational facilities for all youth in 
that community, in light of that concept, if equaliza­
tion of educational facilities are to be obtained, then 
a cadet corps must be established for the eighteen, 
twelve, t e n ----

Q. Or one?
A, If equalization of educational opportunities are 

to be provided, it must be established, yea, verily, for 
one. Granted, it is absurb economically, but the whole 
cost of segregation is a luxury which economically
is very unsound.

Q. I cheerfully concede that. I think that is an uni­
form opinion but I am not speaking of the economic 
disadvantage. Is it actually practically possible to have 
a cadet corps with one or nine students?

A. For all practical purposes it is absolutely ab­
surd but it is absolutely necessary if equality of oppor­
tunity is to be given.

B y  t h e  C o u r t :

Q, You mean it is logical.
A. It is logical to have a cadet corps?
(R. p, 601) Q. I mean you indicated it is logical

if there is going to be segregation?



[ 199 1

A. If there is going to be segregation it is logical 
to have a cadet corps for nine if a cadet corps is afford­
ed elsewhere.

B y M r . D ouglas:

Q. If there is only one student in the group, is it 
logical to have a choral society?

A. That student must be afforded the same oppor­
tunities as any other student in that community and 
therefore it is logical if there is to be equality of op­
portunity insofar as choral study.

Q. When you use the word “same” do you regard 
that word as synonomous with “identical”?

A. No, I do not. I regard it to connote comparable 
opportunities for instructional growth and develop­
ment.

Q. Do the administrative school officials of Arling­
ton County have the duty of determining whether it 
is practical to establish a cadet corps under the cir­
cumstances indicated in the questions?

* # # # #

(R. p. 802) A. They have the responsibility of es­
tablishing a cadet corps.

Q. Do they have die responsibility of determining 
whether or not one should be established?

A. They have the responsibility of establishing it 
for ten students, if it is established elsewhere for stu­
dents of a comparable age-grade level.

Q. To pursue this question one step farther, I will 
ask you whether or not there is a course recognized 
in secondary education, known as the mixed chorus or 
instruction in mixed choral work?



[ 2 0 0  1

A. Yes.
Q. If there were only one student in the group, 

would the School Board have the duty of giving instruc­
tion in mixed chorus?

A. You want my response as an educator now?
Q. Yes, only as a professional man and an educa­

tor.
A. As an educator, if there is only one student in 

the group, the responsibility would be to allow that 
(R. p. 603) student to engage in mixed choral instruc­
tion where the group classroom situation is establish­
ed. As an educator, that is the only educationally 
sound statement which I can possibly conceive of.

Q. Doctor, in a very small school can guidance be 
afforded better by a specialist who comes to that ( that) 
school periodically for the purpose of guiding and 
counselling or by a teacher who is in constant touch 
with his or her group of students?

A, At all times guidance can be afforded better by 
the specialist.

Q, So that the pysehological theory of guidance 
possessed by the specialist and not possessed by the 
ordinary teacher is the important consideration?

A. Very important.
Q. What relative value do you place upon the fac­

tors of acquaintance with the child, acquaintance with 
the child’s home environment and with the child’s ec­
onomic background which the good teacher presum­
ably has? Do you accord those factors no weight?

A. Not as much weight as I would accord the fac­
tors of a professional guidance specialist any more than 
insofar as those factors, the mother and father and 
aunt and uncle and grandparents have more know­
ledge in regard to the home economic situation and



t 2 0 1  1

those things but they aren’t able to counsel as well in 
(R. p. 604) instructional matters as the teacher 
and, insofar as the child’s full development, the child 
specialist is much more competent by training, prep­
aration and experience.

Q. I take it then it would make no difference or 
very little difference whether the counsellor had ever 
seen the patient or the child before?

A. The counsellor would not give any diagnostic 
nor remedial measures upon the first — shall we say 
consultation — with the child of a firm character any 
more than a medical doctor would do so as a result of 
the first visitation. The two cases are quite compar­
able and the guidance counsellor in our field of pro­
fessional education is as highly specialized insofar as 
diagnosing and prescribing remedial measures as the 
medical official in his field of health.

Q. That would depend upon how sick the patient 
was, wouldn’t it?

A. Regardless of how sick the patient is, I think 
the medical doctor today is not concerned with the 
curing of the patent at this time but studying that 
which will prevent the patient — he is concerned with 
preventive medicine, as I understand it. I am not a 
medical man and I go to them as little as possible but 
I understand he is preventive rather than remedial.

#  # # # #

(R. p. 609) Q. It is customary to find infirmary 
rooms in very small high schools of the size of Hoff- 
man-Boston?

A. It is highly desirable to have a room for an in­
firmary in every high school, regardless of size.

Q. Is there any reason why the student couldn’t



[ 202 3

get the same or equal care in a small school if there 
was a nurse in atendance and if there were space a- 
vailable in the teachers’ restroom and accommodations 
in the restroom for the care of that student?

(R. p. 610) A. If the teachers’ restroom were so 
equipped, then the teachers’ restroom would be an 
infirmary and it would not be a teachers restroom. I 
cannot conceive of a teachers’ restroom being equip­
ped to serve adequately as a teachers’ restroom and 
at the same time as an infirmary.

Q. If it had a couch in it, it would do substantial!}’ 
the same for a child who needed that special service, 
wouldn’t it?

A. I don’t agree. My answer is no. I will be very 
glad to elaborate.

* & ** # . #

R ed irec t  E xamination

(R . p. 611) B y  M r . R obinson:

Q. If the evidence should develop, Dr. Knox, that 
the library at Washington and Lee was not sound­
proofed, would that change your conclusion that the 
library facilities afforded pupils there are superior to 
those afforded the pupils at the Hoffman-Boston School?

A. No, because I find more differentiation and 
some differentiation of greater importance than the 
sound-proofing as such. That one item you refer to, 
Counsellor, sound-proofing, would not change my con­
clusion.

B y  the Court:

Q. Dr. Knox, let me ask you this: If you were the



[ 203 1

administrator at Hoffman-Boston School, tell me just 
what you would do in ascertaining what courses should 
be included in its program or curriculum?

A. I would request the Superintendent to allow me, 
or members of my faculty to whom I would delegate 
authority, to meet with the delegated faculty members 
or Principal of Washington and Lee and, togeather 
with the faculty of my school and school and those 
of Washington and Lee, we would study this whole 
community, not in regard to any racial elements or 
(R. p. 612) racial opportunities.

Q. How would you study it? You wouldn’t go from 
house to house?

A. We would call in the parents.
Q. Parents of whom?
A. Of the children.
Q. Of the children in attendance at the school?
A. And any other interested parents, such as those 

whom we contact through our parent-teachers organi­
zation, associations, our civic groups.

Q. What would you do after you convened them?
A. We would convene them and we would more 

or less discuss with the many questions in regard to 
the addition, deletion or changes of questions which 
we didn’t have ourselves sufficient information on. Per­
haps we would ask such question as sex education, let 
us say, a question which we believe is necesary for 
the parents of that community to express themselves 
on. Most of the question regarding courses would not 
require that because prevailing practice would tend 
to allow us to determine the expediency of those courses 
but there frequently arises a question of a character 
wherein we need to give consideration to all members 
of the community, the total community.



I 204  1

Q. Would you ask their opinion, for instance, 
whether a course in Spanish should be given or is that 
(R. p. 613) too much in detail or too specific to be 
submitted to a group such as you mentioned?

A. Under ordinary circumstances we would not 
ask about a course such as Spanish or those languages; 
we would merely, by working with the faculty at Wash­
ington and Lee and recognizing the values of Spanish 
in the curriculum — you asked me if I were Principal, 
We would make provisions at Hoffman-Boston for lan­
guage courses, comparable to those which they found 
to be succesfully given at Washington and Lee.

Q. What I am trying to reach is at what point do 
logic and practice converge? Suppose, after you went 
through the procedure that you have outlined, you 
found no necessity for teaching Italian or Spanish, 
or what ever it might be, at the Hoffman-Boston 
School; would the establishment of such a course there 
be prompted by logic only, that is, on the ground, that 
there is such a course at Washington and Lee?

A. Not at all. I cannot conceive, Your Honor, of a 
group of five colored students and five white students 
having any difference insofar as need for course in 
Italian or Russian or French. I can’t conceive of it. 
At my own institution, we offer courses in Italian — 
Howard University, which is predominantly negro.

Q. I didn’t mean Italian particularly — French?
(R. p. 614) A. I can’t conceive on a racial basis — 

I don’t find any difference insofar as race.
Q. Would it be on a racial basis? Suppose you, as 

administrator, proceeded as you have outlined and 
found from this analysis of the community that there 
was no demand for French and so therefore, as an ad­



[ 205 1

ministrator, you did not put French in at the Hoffman- 
Boston School; Would you consider that would be an 
ommision due to racial reasons, only?

A. No, your Honor. If I found, after my consulta­
tion with the curriculum construction committees, as 
we call them, of Washington and L e e ----

Q. Construction committees?
A. Curriculum construction committees — they very 

definitely offer French there and are offering the French 
successfully and I find out that I have four or five 
students — I am saying five students — I believe that 
one out of every five high school students, regardless 
of their racial idenity, would profit by and themselves 
enjoy, I would s a y ----

Q. Leave the racial question out entirely. Suppose 
you were on a curriculum construction committee of 
Washington and Lee and you found no demand there 
for some higher mathematics and yet over in Hoffman- 
Boston School there was a demand for that, would you 
(11 p. 615) as an administrator, put it in Washington 
and Lee?

A. I very definitely understand your question, Your 
Honor, but you are asking me question which in pro­
bability wouldn’t operate so that I am without exper­
ience. If I had five students at Washington and Lee 
and five at Hoffman-Boston, I for the most part will 
find out their interests, as well as their needs, are quite 
parallel.

Q. You think the probabilities are that you wouldn’t 
meet any such experience as that?

A. Thank you.
Q. Tell me now about this specialization. What 

is it that keeps teachers from being driven to despair



t 206  1

through monotony of teaching the same subject year 
after year?

A. The fact that in professional education now we 
absolutely recommend, and most good administrators 
require, that teachers indulge in what we call teaching 
planning, in professional jargon and that she improve 
her lessons each and every day. If she taught the same 
course, she doesn’t teach the same material, she doesn’t 
teach the same course this year. She uses new material. 
She vitalizes, she changes, and she no longer teaches 
that other than what can be studied afresh each morn­
ing.

Q. Is there much diversity or variety that you can 
put in teaching, for instance, arthmetic?

A. A great deal. I am not a mathematician or an 
(R. p. 616) arithmetic specialist, but my colleagues 
who are have examples in such excellent universities 
as we find in New York with Columbia, which in our 
field they very definitely have given us, and teachers 
throughout the country, examples of highly vitalized 
instruction in the field of arithmetic.

Q. If that same teacher teaches year after year, 
he would, if he kept abreast of the best thought, vary 
his method of presenting the subject?

A. He would vary the content. The examples he 
would give the child in arithmetic this year might be 
examples which would have to do with understanding 
perhaps some of the matters in regard to our present 
national concept of our loans to Europe or something 
of that nature. Last year in an arithmetic problem it 
would be concerned with perhaps having to do with 
understanding the National Election, the presidential 
campaign. He just doesn’t give facts as such. He gives



I 207  ]

facts in relation to their value in the child’s every-day 
life at the time the child is living each and every day 
in the successive years that he is within the educational 
institution.

# . # # # *

JULIUS BREVARD 

Direct Examination

(R. p. 617) B y M r . M a r t in :

Q. What is your name and age?
A. Julius Brevard.
Q. Your age?
A. Fifteen.
Q. Where do you live?
A. 2900 South 20th.
Q. And in what city?
A. Arlington.
Q. You are a colored person I believe?
A. Yes.
Q. Do you know Miss Constance Carter, the plain­

tiff in this suit?
A. Yes.
Q. Is she also a negro?
A. Yes.
Q. Do you attend high school at the present time? 
A. I do.
Q. What high school do you attend?
A. Hofiman-Roston.
Q. That is Hoffman-Boston High School in Arling­

ton?
A. Yes.



[ 208  1

(R. p. 618) Q. Did you attend the high school 
last year?

A. I did.
Q. What high school did you attend last year?
A. Armstrong Technical High School.
Q, Is that in Washington, D. C.?
A. Yes.
Q. And in what grade are you now?
A. I am in 10-B,
Q. What courses did you take at Armstrong Tech­

nical High School last year?
A. I took a course in auto mechanics and, under 

that, drafting and blueprint reading.
Q. Under auto mechanics, drafting?
A. Blueprint reading and blueprint making.
Q. What courses are you taking at Hoffman-Boston 

High School now?
A. Right now I am taking biology, English, math, 

physical education and shop.
Q. What kind of shop?
A. It is general shop.
Q. Are you also taking typing?
A. Yes, sir.
Q. When did Hoffman-Boston High School open? 
A. It opened the 6th.
Q. On the 6th of this month?
A. Yes.
(R. p. 619) Q. Who is your Principal there?
A. Mr. Sydnor.
Q. When you entered school what did you tell Mr. 

Sydnor, if anything, with reference to the courses you 
have been taking or desired?

A. I asked Mr. Sydnor could I take auto mechanics



[ 209 J

at Hoffman-Boston High School and he said he didn't 
have them then and he didn’t know whether they would 
have them at all,

Q. Has any provision been made for you to take 
auto mechanics, blueprint reading or blueprint mak­
ing or drafting, so far as you know, at Hoffman-Bos­
ton?

A. None.
Q. And you have been attending Hoffman-Boston 

High School since it was opened?
A. Yes, sir.

# # # # &

Cross Examination

(R. p. 620) By Mr . Douglas:

Q. When did you ask Mr. Sydnor about this matter? 
A. I asked Mr. Sydnor the first day of school.
Q. On the first day of school? Where did you see 

him on that day?
A. I saw him in his office.
Q. In view of his answer, have you been back since 

to inquire whether he had found out whether such a 
course as auto mechanics would be given?

A. His answer led me to believe that he wasn’t go­
ing to try to get any of the subjects I asked for.

# # # # #

( R. p. 621) Q. Did he tell you anything as to wheth­
er or not there would be a course next year for you? 

A. He did not.
£ # # # #



[ 210 1

(R. p. 622) Q. When did you determine that you 
wanted to take auto mechanics at the Hoffman-Boston
School?

A. I had been taking a course of study for auto 
mechanics last year and I wanted to continue that 
course of study but I am forced to come to Hoffman- 
Boston School and I wanted to know whether they 
could give that course of study over there.

# # * # #

(R. p. 624) Do you still want to take that course? 
A. I do.
Q. Did Mr. Sydnor say anything to you that if you 

wanted to you would be given the opportunity to at­
tend the colored regional high school at Manassas and 
you would be furnished transportation to that school 
if you wanted to take that course?

(R. p. 625) A. He didn’t say anything about that. 
Q. He didn’t say anything about that school at all? 
A. He didn’t.

# # # # *

(R. p. 627) Did there ever come a time when any­
body asked you what you wanted to take in school this
year?

A. In Hoffman-Boston?
Q. Yes.
A. No, they haven’t.

# * # # *

R ed irec t  E xamination

(R. p. 629) By M r . M a r t in :

* # # # *



[ 211 ]

Q. If you wanted to continue taking auto mechanics 
why didn’t you continue at Armstrong Technical High 
School in Washington this year?

A. Because of the rate of tuition.
Q, You were having to pay tuition to go over there? 
A. Yes, I would have had to pay it this year.
Q. Because you were living in Arlington? Is that 

corret?
A. Yes.

# # # # #

PEGGEY COUNCIL 

D ir e c t  E xam ination

(R. p. 630) By M r . M a r t in :

Q, Tell me your name and address, please.
A. My name is Peggy Council. I live at 3458 South 

22nd Street, Arlington.
Q. How old are you?
A. Fifteen.
Q. Are you attending school this year?
A. I am.
Q. What school?
A. Hoffman-Boston.
Q. Hoffman-Boston High School in Arlington?
A. Yes.
Q. And you live in Arlington?
A. I do.
Q. What school, if any, did you attend last year? 
A. Last year- I attended Hoffman-Boston in Arling­

ton from Dunbar in Washington. That is where I came 
from.



[ 212 1

Q. How long did you attend Dunbar High School 
in Washington?

A, I only attended Dunbar a half year. I had to 
come back to Arlington because I lived here and be­
cause the tuition fee which I couldn’t pay.

(R. p. 681) Q. And then you left Dunbar in the 
middle of the term last year to came to Hoffman-Bos- 
ton?

A. I did.
Q. And you attended Holfman-Boston the rest of 

the year last year?
A. I did.
Q. And enrolled there again this year?
A. Yes.
Q. And what grade are you in at Hoffman-Boston 

now?
A. 11-B.
Q. What courses are you taking there now?
A. This year I am taking physics, civics, typing 

and English.
Q. Did you start in any other courses this year 

which you are not taking?
A. Well, at the end of school we were given an 

election sheet to sign up for Latin and shorthand but 
there is no Latin and shorthand this year and no chem­
istry.

Q. When were you given those elective sheets?
A. At the end of school, about a week before the 

end of school?
Q. You mean last June?
A. Yes.
Q. Before school was closed?
A. Yes.



[ 213 1

(R. p. 632) Q. Did you fill out those elective sheets 
that were given you?

A. I did.
Q. What did you put down on those sheets you 

wanted to take this year?
A. This year I wanted chemistry, Latin, shorthand 

and typing.
# # # * #

Q. Are you taking any of those courses that you 
applied for last year?

A. No.
Q. You put down that you wanted to take Latin this 

year?
A. Yes.
Q. Are they offering a Latin course there this year? 
A. No, they are not.
Q. I believe you put down that you wanted to take 

shorthand last year?
A. Yes.
Q. Are they offering any course in shorthand that

you could take this year?
A. No.
Q. You put down that you wanted to take chemis­

try last year?
A. Yes.
(R. p. 633) Q. Are they offering any course in 

chemistry that you can take this year?
A. No.
Q. Did you turn in that elective sheet last year?
A. I did.
Q. Are you taking any foreign languages this year’

at all?
A. No.



[ 214  ]

Q, And you are in grade 11-B?
A. Yes.
Q. Do you know whether or not it is necessary for 

you to take any other courses in foreign languages in 
order to enter college?

A. Yes, it is; it is necessary for me to take Latin.
Q. Did they offer any course in any foreign lan­

guage for you this year that you could take?
A. They offered a course in Spanish but it was an 

advanced course and the girls had been taking it a 
half year before and therefore I couldn’t enter an ad­
vanced course.

Q. That is one of those alternating courses they have 
over there I believe?

A. Yes.
Q. Are you taking any physical education?
(R. p. 634) A. We were assigned physical educa­

tion yesterday. In the class was 10-B, 11-A, 11-B, 12-A 
and 12-B.

Q. You mean all of you were taking that course to­
gether?

A. Yes, six-.
Q. Are you takiixg that course now?
A. No, I withdrew yesterday.
Q. Did anybody else withdraw with you?
A. Three other girls.
Q. You said you are taking civics now?
A. Yes, sir.
Q. Is there any other class taking civics with you?
A. 11-B, 12-A, and 12-B.
Q. All of you are taking civics in the same room?
A. Yes.
Q. You say you are taking physics?



[ 215 1

A. Yes.
Q. Any other classes taking physics with you?
A. 11-B, 12-A and 12-B.
Q. All in the same room?
A. Yes.
Q. Under the same teacher?
A. Yes.
Q. Are you taking typing?
A. Yes.
(R. p. 685) Q. Is anybody else taking typing with

you?
A. 11-A.
Q. 11-A and you are in 11-B?
A. Yes.
Q. In the same room at the same time with the

same teacher?
A. Yes.
Q. You said you were taking English. Any other

classes taking English with you?
A. 11-B, 12-A and 12-B.
Q. All at the same time in the same room under

the same teacher?
A. Yes.
Q. And you are taking typing and did you apply

for shorthand also?
A. I did.
Q. What did they tell you about shorthand?
A. Mr. Sydnor said he had considered the schedule 

of the teacher teaching shorthand and if he could he 
would work it out. I signed up for it last year and 
it should heve been worked out through the summer.

# # # # #

(R. p. 636) Q. And you are colored?



[ 216  1

A. Yes.

C ross E xamination  

B y M r . D ouglas:

Q. When did you talk to Mr. Sydnor about these' 
problems?

A. Well, at the end of school. He knows that I have 
a special program and I consulted him each time be­
fore going to any classes because most of the time my 
program has to be changed, so I let him know ahead 
of time so that he will have plenty of time to work 
out a program.

Q. When you say at the end of school, you mean 
at the end of school in June?

A. Yes, about two weeks before.
Q. You consulted him?
A. Yes.
Q. When you say you have a special program, what 

does that mean?
A. When I came from Dunbar I had signed up for 

the subjects over there and my records were sent to 
Hoffman-Boston to Mr. Sydnor. Some of the subjects 
he couldn’t offer me so therefore my program had to 
be changed all over because what the IG-B’s were 
taking then I already had in junior high school so there 
was no use wasting my time going back taking some- 
(R. p. 637) thing else.

Q. He undertook to arrange a special course adapt 
ed to your needs as a transfer student?

A. Yes.
Q. And did you get what you wanted last year?
A. No.



[ 217 1

Q, You say you have not withdrawn from the 
school?

A. No.
Q. I misunderstood you then. You said something 

about “I withdrew and three other girls also withdrew.”
A. From the physical education class.
Q. You merely withdrew from that class?
A. Yes.
Q. Isn't that compulsory?
A. Well, he said he would try to work in another 

class for us and stay out this week.
Q. He told you to stay out this week? Who told

you that?
A. Mr. Sydnor.
Q. And he was going to make some further effort 

to rearrange the schedule?
A. Yes.
Q. You say in the English class you recieve instruc­

tion with the members of classes 11-A, 12-A and 12-B?
(R. p. 688) A. 11-B, 12-A and 12-B.
Q. I wasn’t sure but you correct me if I am wrong. 

How many students are there in that English class?
A. I can’t say because I didn’t bother to take notice 

of how many there were.
Q. Approximately how many were there?
A. Approximately twenty-five.
Q. What is given in your English course? What 

subject does it cover generally?
A. We haven’t been assigned to what it will cover 

this year because we have just registered in those 
classes now. We haven’t been given the course.

Q. In your civics class you go to a class that con­



[ 218 1

sists, as I understand your testimony, of members of 
several different grades?

A. Yes.
Q. And what are those several different grades?
A. 1X-B, 12-A and 12-B.
Q. And how many approximately are in that class? 
A. Twenty-five.
Q. And you go to the physics class? Is that right? 
A. Yes, sir.
Q. And you have the same general situation there? 
A. Yes.
Q. And the typing class. What classes are combined 

(R. p. 639) in that one?
A. 11-A and 11-B.
Q. And how many students in that class?
A. About twenty-six.
Q. And you said you were in 11-B?
A. Yes, sir.
Q. So after this semester you have another full 

year?
A. Yes, sir .
Q. Isn’t the shorthand course you requested given 

in the last year of your school work? Didn’t anyone 
tell you that?

A. No.
Q. Where are you going to college?
A. I can’t say right now where I am going because 

my course has been messed up.
Q. But you do know that you will have to have 

Latin to go to college?
A. Yes.
Q. Is that true of all the colleges that you have 

considered going to or which colleges have you found



[ 2 1 9  1

required Latin as a condition prerequisite to entering? 
A, In the nursing course in most colleges Latin is

necessary.
('). How did you find that out?
A. Because when I went to Dunbar we had a 

(R. p. 640) counsellor there.
Q. Did I ask you about how many were in your

physics class?
A. Yes, I think you did.
Q. What did you say — about the same number? 
A. Yes.
Q. About twenty-five?
A. Yes.
Q. As I understand it, you have withdrawn from 

your physical education class and I don’t want to put 
any words in your mouth — you correct me if I am 
wrong — that you have withdrawn from your physical 
education class at the suggestion of Mr. Sydnor to see 
whether a rearrangement could be made to give you 
certain courses that you wanted that you haven’t been 
promised yet?

A. That is right.
Q. And did I further understand that Mr. Sydnor 

suggested that you stay home this week or stay out of 
the physical education class?

A. Stay out of the physical education class tills
week.

Q. And has he advised you yet what he has been 
able to work out for you?

A. No.
Q. Do you know what he was trying to do?
A. He was trying to work in shorthand. I think if 

(R. p. 641) he had been able to do that he would 
have worked that out during the summer.



[ 220 1

Q. That is sort of a conclusion that you reached? 
He couldn’t tell about that until he found out how 
many folks wanted to take shorthand?

A. He knew that in the summer because all of us 
children that were leaving school last summer had 
elected all the classes on which they were to elect when 
they came back this year.

Q. Don’t the students over there all take short­
hand in their last year?

A. Shorthand has never been given there before.
Q. You think he would have known from the elec­

tive list that you filled out in June.
A. Yes.
Q. You haven’t heard yet from Mr. Sydnor wheth­

er he has been able to arrange it or not?
A. No.

£ # # # #

( R, p. 643) Q. Had you had any Latin at Dunbar?
A. No, I was to take it my next year there.
Q. In order to get any credit for it on account of 

admission to college, if you do have Latin, aren’t you 
required to have two years of Latin?

A. Yes.
Q. If you only had a year and a half to go in Hoff- 

man-Boston, how were you going to get your Latin 
credit?

A. I was going to have to take a post graduate 
course for the other half.

Q. And where were you going to take the post grad­
uate course? At Hoffman-Boston?

A. No. Mr. Sydnor told me when I first entered 
Hoffman-Boston that after finishing school that he



1 221 ]

would see that I was admitted to a Washington School 
to take this post graduate course.

* # # * *

(R. p. 844) Q. He didn’t say anything about tak­
ing it at Hofiman-Boston?

A. No he didn’t.
* # * * #

Q. When they started charging tuition in Washing­
ton — there was a time when Arlington County paid 
your tuition for going to Washington?

A. Yes.
Q. And after Arlington stopped paying your tui­

tion in Washington, you came to Hoffman-Boston?
A. Yes.

# # * # #

(R. p. 645) Q. You say you were to take it at Dun­
bar. Why didn’t you take it at Dunbar while you were 
there?

A. When I came from junior high school I had to 
have another half year of French. I took it out at Dun­
bar* and the next year would have been my year to 
enter Latin.

Q. Why didn’t you enter Latin?
A. I had to leave Dunbar.
Q. You only went to senior high school a half year 

at Dunbar?
A. Yes.

Red irec t  E xamination  

Bv M r . M a r tin :

« & # # #



f 2 2 2  3

(R. p. 646) Q. And the County stopped paying 
your tuition and you had to leave and come over here? 

A. Yes.
Q. When you came over here last year did you 

advise Mr. Sydnor that you wanted to take Latin?
A. Yes, sir.
Q. And you couldn’t get it last year?
A. No.
Q. And you put it on your elective sheet in June? 
A. Yes.
Q. And you can’t get it this year?
A. No.
Q. And the County still doesn’t pay your tuition 

to Washington where you can get it?
A. No.

M r . M a r t in : That is all.

B y  th e  C o u r t :

Q. When was the last time that the civics class
met?

A. Yesterday.
Q. Was that the first meeting of the class too?
A. Yes.
Q. And there were twenty-five present?
A. Yes.
( R. p. 647) Q. Do you understand that is to be the 

final distribution of the students for that class?
A. What do you mean, that all of those classes 

are to be kept together?
Q. Yes.
A. Yes, sir.
Q. That simply wasn’t a meeting of the classes for

later separation?



[ 223 1

A. No.
Q- And
A. Yes.
Q- And
A. Yes.

#

that is true of English? 

of physics?

CHARLES J. WALSH 

D ir e c t  E xamination

B y  M r . D ouglas:

# # * # #

(R. p. 674) Q. In your opinion, do those courses 
offer adequate instruction as given at the Hoffman-Bos- 
ton School?

A. I don't make any pretense that that one single 
shop there offers an adequate vocational program but 
I do say that it is the policy of this Board to give these 
youngsters that training. If we can’t give it with the 
present facilities, the Board will pay the tuition at 
Manassas or elsewhere.

# # # *

C ross E xamination

B y  M r . M a r tin :
# # # # #

(R. p. 705) Q. You mean if a student makes a re­
quest this year for a course and if, by some circum­
stance, it is not offered this year, no record is kept of 
that aplication?



[ 224 I

A. The usual procedure on that is simply this: The 
youngster goes in to register for the course and if the 
Principal hasn’t set it up, they get in touch with us 
and we try to make some sort or arrangement about
it.

Q. There was testimony this morning that a stu­
dent at Hoffman-Boston in the 10th grade made ap­
plication at the beginning of school for auto-mechanics 
and related subjects — drafting, blueprint reading and 
making, and so forth — and was unable to obtain them. 
Does a white student in similar circumstances, attend­
ing Washington and Lee School, have to first demand 
that that course be given before he can take the course 
in auto mechanics and allied subjects?

A. No.
Q. There was testimony this morning that last year 

a student at Hoffman-Boston School made application 
for shorthand, Latin, Chemistry. Does a white student 
at Washington and Lee High School in similar circum­
stances have to make such a demand before being able 
to take that course?

A. In some cases, yes,. In some cases he is denied 
those courses. In the case of auto mechanics, he would 
be denied the course because we can only handle — 
(R. p. 706) of two thousand children, as I pointed out 
before, we are so crowded that we can only handle — 
our capacity is twenty-five children in the auto me­
chanics shop a day and therefore we probably don’t 
handle one-third of the requests on those courses.

Q. I understand, Mr. Walsh, he is denied the op­
portunity of taking auto mechanics because the class 
is over-crowded and he is unable to secure auto me­
chanics in that class at that particular time?

A. Yes.



[ 225 1

Q. He is not denied it because of his race or color,
is he?

A. No.

(R . p. 710) B y  M r . M a r t in :

Q. Is the reason you don’t permit this boy to at­
tend Washington and Lee High School because he is 
a negro and white children only are attending Wash­
ington and Lee High school.

(R. p. 711) A, Because the statute provides sepa­
rate facilities for negroes and whites and the answer 
then would be yes.

Q. The answer to it is “yes” and the same applies 
to this young girl who testified this morning with re­
ference to the course that she had applied for last
June?

A. Correct.
Q. How long has the School Board been offering 

Speech 1 and 2 at Washington and Lee High School?
A. I don’t recall without having access to the rec­

ords.
Q. Do you know of your own knowledge whether 

any white child has ever made application or has ever 
made a demand for that course at Washington and
Lee High School?

A. Not to my knowledge. I don’t know.
# # # # #

(R. p. 713) Q. Assuming that the student did that 
and then decided he wanted to take auto mechanics, 
if that were a colored school in Arlington County?

A. Well, at the present time we would offer to give



[ £ 2 6  1

him the instruction elsewhere. That is all we could
do.

Q. When you say elsewhere, you mean somewhere 
else out of the County within the State or within Wash­
ington?

A. Within the State.
Q. Somewhere within the State you would offer him 

auto mechanics?
A. Manassas Negro School
Q. How far is Manassas from Hoffman-Boston High 

School?
A. I don’t recall the exact number of miles.
Q. In what county is it?
A. Prince William County.
Q. In Prince William County.
A. I believe Prince William County.

T he C o u rt : It is about twenty or twenty-
five miles, isn’t it?

(R . p. 714) M r . D ouglas: It is about twenty- 
five miles.

B y  M r . M a r t in :

Q. And how would he get to Manassas?
A. A regular bus that takes the negro children from 

Fairfax to Manassas.
# # * * #

(R. p. 718) Q. Didn’t you testify earlier on direct 
examination that the better procedure in establishing 
courses of study for high school students is to plan 
the whole four-year program, the courses of study in 
progressive order?



[ 227  1

A. That is correct.
Q. That it is very inferior administration to put in 

one course here or there when a student demands it, 
regardless of need?

A. That is correct.
Q. Then aren’t the colored students being disad­

vantaged, the students at Hoffman-Boston School be­
ing by reason of their race and color and having to at­
tend that school?

A. Not necessarily. It simply proves my point that 
this School Board is making every effort possible to 
provide the subjects that the children in Hoffman- Bos­
ton want. I don’t say it is good practice.

Q. We are not speaking about effort; we are speak­
ing about accomplishments. Their efforts haven’t culm­
inated in the accomplishments of providing equal 
courses of study at Hoffman-Boston as are at Wash­
ington and Lee, have they?

A. I don’t say that the two schools are equal in 
(R. p. 719) any respect.

Q. You don’t say the two courses of study are equal 
either, do you?

A. No.
* # * * #

(R. p. 730) Q. One question about the library. 
Would you say that the library at Hoffman-Boston is 
or is not equal to the library at Washington and Lee?

A. It certainly isn’t equal in size.
Q. Would you say it is equal in content?
A. Nor equal in content.
Q. Then I understand your answer to be that they 

are unequal?
A. Unequal. It isn’t necessary to be.



[ 2 2 8  1

(R. p. 731) Q. Of course, I believe you testified that 
the courses of study offered at the two schools are un­
equal?

A. That is true.
(R. p. 732) Q. On tire whole, Mr. Walsh, would you 

say that the facilities available for the students, high 
school students, at Hoffman-Boston High School are 
unequal to the facilities offered at Washington and 
Lee, that is, taking into consideratioino the courses of 
study, the equipment facilities, buildings and grounds?

A. No, they are not equal.
# # # # **

R ecross E xamination  

B y  M r . M a r t in :
# # #  # *

(R. p. 735) Q. Did I also understand you to say at 
the beginning of the cross examination that, so far as 
you know, you don’t know of any time when a white 
student or student at Washington and Lee had to de­
mand a course before he could take it? Courses that are, 
being taught now?

A. That is right.
Q. And all courses except those that are listed on 

page 66 of Dr. Dawson’s report, which are taught at 
Washington and Lee, the colored children will have to 
make demand for before it is either installed or offered 
to the child either at Hoffman-Boston or at some other 
place in the State?

A. He has to register for it.



[ 229 1

(R. p. 786) Q. When you say register, he has to 
request it?

A. Yes.
Q. And a white child under similar circumstances 

does not have to do that?
A. If the course were not being offered at Wash­

ington and Lee and there were as many as eighteen 
desired the course, it would be possible to put the 
course in.

Q. I will have to ash you one other question. Since 
these courses were not requested or previously request­
ed or demanded by the student at Washington and 
Lee, how did you come to install those courses? Didn’t 
you do, as you stated, the proper method of installing 
courses is to find out the needs of the students in that 
particular area and establish the courses for those stu­
dents in that area?

A. The students indicated a desire for those courses.
(>. But you still don’t install those courses until 

you determine there is a necessity for them; I mean 
that it would be advantageous to the students to take 
them?

A. That is true.
Q. And you have found out that it was advanta­

geous for the students in Arlington area to take the 
courses offered at Washington and Lee High School? 
Is that true?

A. Well, in some cases I don’t know whether it 
would be advantageous or not, but, nevertheless, there 
was a demand for those particular courses.

(R. p. 737) Q. A specific demand, you said?
A. I say there was a general demand for the stu­

dent body of that size for those particular courses.



[ 230 3

Q. When you say it is a demand, you mean it is 
a need? You found a need for it in the community? 
That is your answer?

A. That is right.
* * * * *

(R. p. 746) Q. I understood you to say — and I want 
vou to correct me if I am wrong — that these courses are 
at present time being offered to the students at Wash­
ington and Lee and that the only reason a student at 
Hoffman-Boston does not get them is because no de­
mand has been made for them but do I further under­
stand you now to say that the student at Hoffman-Bos­
ton must not only make a demand for them or request, 
if you prefer that word, but that you investigate that 
student previous experience, courses of study, and de­
termine whether you are going to offer it to that stu­
dent at Hoffman-Boston?

A. There is always a practical situation to look over 
any student’s record. For one thing, suppose they were 
registering for physics; they might not have the math­
ematical background that would enable them to carry 
on the course successfully.

O. And that is the purpose of a guidance councel- 
lor, is it not?

A.. That is correct.
Q, And you do not have a guidance counsellor at

Hoffman-Boston?
(R. p. 747) A. That is correct, but we have a full­

time teaching Principal that devotes a great deal of his 
time to senior high school, who has a Master’s Degree 
and lias taken work in guidance and serves the same
purpose.

Q. You say full-time teaching Principal?



[ 231 1

A. We have a full-time non-teaching Principal who 
spends a great deal of his time.

# # # * *

(R. p. 754) Q, And you don’t know whether Ma­
nassas or any other schools where you might send this 
child, are able to offer the courses that von have de- 
termined desirable in Arlington County, that you offer 
at Washington and Lee? Isn’t that true?

A. Not until I would check with them.
Q. And it is your present intention to send those 

children to Manassas or some other place without know­
ing whether they can secure the other courses that are 
necessary and desirable?

A. Of course, I suspect if Manassas couldn’t, the 
Washington vocational schools would be able to give 
them more than we would be able to give them.

Q. You might find it undesirable to send them to 
Manassas, in which case you would transfer and send 
them to Washington?

A. I simply said a younster, if he couldn’t get what 
he wanted in Manassas school, the Board has sent 
children to Washington and paid their tuition and I 
am sure that they would not object to doing it again 
in a matter of satisfying the requirements of that par- 
(R. p. 755) ticular youngster.

# # » * #

(R . p. 758) B y  M r . M a r t in :
Q. You are Mr. Charles J. Walsh, Assistant Super­

intendent of Schools of Arlington County, in charge of 
personnel, who was on the stand yesterday afternoon, 
I believe?

A. That is right.



I 2 3 2  1

Q. Mr. Walsh, as I recall it, on your examination 
of yesterday you testified that the School Board of Ar­
lington County has always attempted to give to the ne­
gro children in Arlington County educational oppor­
tunities equal to those given to white children in the 
Countv and cited as an incident thereof the case of a 
young student named Davis, a citizen of Arlington 
(K. p. 759) County, that the School Board sent to Ma­
nassas and paid his tuition there, I believe?

A. I said the request came in in the form of a letter 
to the School Board. The School Board acted on it and 
agreed to pay the boy’s tuition at Manassas and, in 
addition to that, further agreed in the same motion 
to pay tuition on any negro boy or girl that wanted to 
attend the school and take a vocational course that 
couldn’t be obtained at Hoffman-Boston.

Q. I believe his applcation was based on the fact 
that he wanted to take certain courses of study that 
were not offered at Hoffman-Boston and that were 
offered at Washington and Lee and that was the basis 
upon which you agreed to pay his tuition and send him 
to Manassas?

A. I don’t recall whether he registered at Hoffman- 
Boston or not. He made the request for the payment
of tuition at the Negro Vocational School at Manassas.

Q. Since you brought in the name of that student, 
Mr. Walsh, I assume you are familiar with the outcome 
of that particular incident?

A. No, I am not.
Q. Don’t you know, as a matter of fact, that Ma­

nassas never did accept that boy as a student?
A. I was not aware of that.
Q. Don’t you know, as a matter of fact, the School



I 2 3 3  ]

(R. p. 760) Board of Arlington County never paid 
Manassas one dime for the education of that boy?

A. I know the School Board would have paid the 
boy’s tuition had any bill been rendered because it is 
a matter of record.

Q. Regardless of what the School Board might or 
v/ould have done, as a matter fact the School Board 
never did pay one dime for the education of that boy 
at Manassas, did they?

A. To my knowledge, no bill was received.
Q. And to your knowledge, didn’t Manassas refuse 

to enroll him over there and didn’t the boy come back 
to Hoffman-B os ton and graduate from Hoffman-Bos­
ton last June?

A. The Principal of the School at Manassas inform­
ed me that the boy would be admitted.

Q. Was he admitted?
A. I don’t know whether he was admited or not.
Q. Didn’t that boy graduate from Hoffman-Bos- 

ton last June?
A. I am unable to say unless I had the records.
Q. Do you have records showing the graduates of 

Hoffman-Boston School last June?
A. Yes.
Q. Will you get those records and bring them here 

today to inform the Court as to whether or not that 
(R. p. 761) boy did not register and did not attend 
Manassas School last June but did come back to Hoff- 
man-Boston and register and attend school and grad­
uate from Hoffman-Boston School last June?

The Court: Do you know that he did?

Mr. Martin: I understand that he did.



[ 2 3 4  ]

Mr . Douglas: If counsel says he did, we
will admit he did. I don't have any knowledge 
on it.

* * * * *

(R. p. 764) Q. That is assuming, as happened in 
this case, that the child is sent to a school over which 
you have no control, no jurisdiction, and further that 
you do not determine whether or not he is getting ed­
ucational opportunities required or necessary and 
which are given in Arlington County to other students 
of a different race? Do you say that is good educational 
practice?

A. The school there has the same supervision and
same control.

Q. But you don’t say as an educator, as an admin­
istrator of the schools in Arlington County, that the 
school in Manassas has the same obligation to educate 
the Arlington County children as the Arlington County 
School Board does, do you?

A. No, I would not say so.
* * * * *

St e p h e n  McCl e l l a n d  s y d n o r

D ir ec t  E xamination

By Mr. Douglas:
* * * * *

(R. p. 776) Q. Will you state whether or not you 
had tables, chairs, and other necessary physical equip­
ment to enable you to give that course at that time?

A. We had neither typewriting tables nor chairs.



L 235 1

Q. When?
A. In 1947, that was — the year of ’47-48.
Q. And what did you do about that to enable you 

to give the course?
A. Well, we used some of the desks and tables that 

we had but they were not typewriting tables nor type­
writing desks.

* * * * *

C ross E xamination

(R . p. 803) B y M r . M a r t in :

Q. On the program offering for courses to be given 
for this year was Speech 1 and 2 on your program offer- 
ing?

A. No.
Q. Was journalism, either 1 or 2, on your program 

offering?
A. No.
Q. Or solid geometry or commerical arithmetic?
A. No.
Q. Or economics, world history, economic geo­

graphy or Latin-American history?
A. Latin American history — not unless it should 

come in the total but world history and economic geo­
graphy would be considered. It may be listed as social 
subjects but the required courses fall under that.

Q. Was it in your program offering for this year?
A. I think we have history in the 11th grade.
Q. I will ask you this question: Are you at the pre­

sent time offering to students at Hoffman-Boston School 
courses in economics, world history, economic geo­
graphy or Latin American history?



[ 236 1

A. We are not offering Latin American history.
Q. Are you offering economics?
A. We are not offering economics.
Q. Are you offering economic geography?
'(R. p. 804) No not economic geography.
Q. Are you offering world history as a separate 

course?
A,. Yes.
Q. Are you offering at the present time either La­

tin. 1 or Latin 2?
A. Neither one.
Q. Are you offering at the present time commer­

cial law?
A. No.
Q. Business correspondence?
A. No.
Q. Bookkeeping?
A. No.
Q. Shorthand?
A. That will be in the offering.
Q. You said that will be offered?
A.. Yes.
Q. Mechanical drawing as a separte course?
A. No.
Q. Fine arts?
A. Yes, we are offering fine arts.
Q. You the offering a course in fine arts?
A. No, we are only offering music and art appre­

ciation and courses like that.
Q. You are offering a course in art appreciation? 
(R. p. 805) A. Yes.
Q. And you are offering another ocurse in fine arts? 
A. No, we are not.



[ 2 37  1

Q. Are you offering a course in commercial ait?
A. No, we are not.
Q. Are you offering a course in printing?
A. No.
Q. Sheet metal work?
A. No.
Q. Retail sales?
A. No.
Q. Consumer buying?
A. No.
Q. Driver training?
A. No.
Q. Do you have a cadet corps for either boys or

girls?
A. No.
Q. I believe you testifed it is your general practice 

not to offer these courses. Are you offering at the pre­
sent time auto mechanics?

A. No.
Q. I believe you stated it is not your general prac­

tice to provide a course for one or two particular stu­
dents?

A. It has been our practice.
Q. It has been your practice to offer these courses 

(R. p. 806) for any particular student?
A. It has been our practice not to before last year. 
Q. I believe you stated that Miss Campbell came 

there last year and desired chemistry but she came in 
the middle of the year and, of course, your class be­
gan at the beginning of the term?

A. Yes.
Q. And she couldn’t get in that class and it is one 

of those alternating courses so she can’t take it this
year?



I 238 ]

A. That is correct, as far as I am concerned.
Q. So she couldn’t take it last year in the second 

semester and she couldn’t take it this year and if she 
is there next year and hasn’t graduated she probably 
will be able to take it? Do I understand that to be 
your answer?

A. That would be correct, if she is there.
Q. And the same would apply to any student 

who happened to be a senior this year? Of course, if 
he were a senior this year and hadn’t already taken 
chemistry, he wouldn’t be able to take chemistry at 
all in the high school?

A. In that case it would be referred to the School 
Board.

Q. I believe you testified that the responsibility so 
far as you are concerned, for offering these courses 
would rest entirely in tire administrative department?

(R. p. 807) A. Yes. I have to let them know the 
peculiar cases and what do they think best or what 
can we do.

Q. You inform the School Board about these re­
quests?

A. Yes.
*  *  *  if  #

Q. I believe you stated that there are fifteen stu­
dents in your English classes, that there are nine 11-Bs, 
(R. p. 808) four 12-As and two 12-Bs, all of those 
taught in the same room by the same teacher at the 
same time?

A. Yes.
Q. And the civics — the same rule applies?
A. That is right.
Q. And physics?



[ 239 1

A, That is right.
Q. And typewriting?
A. Yes, it was true in typing.
Q. So the 11-B, 12-A and 12-B, so far as these 

four courses are concerned, are taking them at the 
same time and under the same teacher, and you have 
eighteen advanced students in typing, I believe you 
testified?

A. I believe Miss Carter would make the eigh­
teenth.

Q. And you testified there are more than that in 
the beginners’ class?

A. Yes, that is correct.
Q. How many typewriters do you have?
A. We have seventeen typewriters that have been 

purchased by the School Board to be used in the classes, 
with a requisition for ten new typewriters that have 
been ordered through the School Department.

Q. But have not arrived?
A. Have not been delivered. We only have seven­

teen at present.
* » * * *

(R. p. 812) So you only have twelve regular teachers 
who teach there regularly or all the time at II oilman- 
Boston?

A. That is correct.
Q. And all of those are high school teachers?
A. Yes, junior and senior, you understand.
Q. And how many classrooms do you have there 

in the high school department?
A. We have six regular size classrooms — seven, in­

cluding a room that is smaller than the regular* that 
would seat only eighteen pupils.



[ 240 1

Q. Then unless you could get the students together 
(R. p. 813) on these various electives they mentioned 
they wanted and to give up some of those electives 
or to transfer or combine some of them, it would be im­
possible for them to take all of the courses that they 
require under the present set-up as it is now?

A. I think that is correct. You mean all of the 
courses that you named to be offered, and I told you 
no?

Q. Yes.
A. No, it would be impossible to offer all of those.
Q. And it would be impossible to offer all of the 

courses that the students have requested last year and 
this year that are not now offered, would it not?

A. All of them?
Q. Yes.
A. I would say yes, it would be impossible to offer 

all of them — the ones that we have just mentioned — 
auto mechanics and one or two others.

Q. You only have one man teaching vocational ed­
ucation?

A. That is right.
# # # # #

(R. p. 815) Q. Do you recall a young fellow named 
Alfred Calvin Davis last year who went to Manassas?

A. Yes, I do.
Q. I believe he stayed there about a week and then 

came back to Hoffman-Boston?
A. I know he came to Hoffman-Boston.
Q. He graduated in June from Hoffman-Boston?
A. That is right.

# # * *



t 2 4 1  ]

WILLIAM A. EARLY

D ir e c t  E xamination

* # # # #

B y  M r . D ouglas:

(R. p. 832) Q. What, if any, arrangements have 
been made with the Superintendents of Schools in 
charge of the Manassas colored school whereby Arling­
ton County colored students are permitted to attend 
that school, Mr. Early?

A. We have made formal application to the Super­
intendent, Worth Peters, who operates the school as it 
is located in Manassas and have been granted permis­
sion to send to that school, either as day pupils, travel­
ling to and from or as boarding students — they have 
boarding facilities there — from Arlington County. 
That permission has been granted.

Q. And upon the basis of what financial arrange­
ment?

A. That Arlington County pay the cost.
# # * * *

(R. p. 836) B y th e  C o u rt :

Q. What School Board then would have direct con­
trol of the Regional School at Manassas?

A. It is made up of members of each of the School 
Boards of the three governing bodies that have put 
their capital outlay there.

Q. What is the designation of that Board?
A. It is the School Board of the Negro Regional 

High School of Manassas as the Regional High School 
Joint Committee of Control.



[ 242  1

Q. It isn’t a regular city or county School Board?
A. No.
Q. It is a special board of governors for that school?
A. That is right, set up by statute.

« # * * *

(R . p. 842) B y  M r . D ouglas:

Q. Will you state whether or not the county School 
Board of Arlington has determined upon a policy of 
sending any colored student from this County, who 
may require subjects not taught in this County, to this 
school at Manassas?

A. Yes. According to the School Board’s action of 
a year or more ago, they established the policy of pay­
ing the tuition and transportation of any student, qual­
ified student, who wished to attend classes that would 
not or could not be offered at the local negro high 
school.

* * * * *

C ross E xamination

B y  M r . H i l l :
* * * * *

(R. p. 863) A. The School is administered by the 
Manassas Regional High School joint Committte for 
Control which is made up of Board Members from 
three different counties and they appoint Mr. Peters as 
their Superintendent in Charge.

Q. And the Superintendent is an ex-officio or ad­
visory member of the Board with non-voting privileges?

A. That is right.



[ 243 1

Q. And if the institution of any particular course 
requires any expenditures of funds, those funds have 
to be acquired in what manner, do you know?

A. They either come from local sources which 
would be the counties, State sources or tuition sources. 
I don’t think they have any endowment. They may 
have a little.

Q. If these funds have to come from local sources, 
(R. p. 864) then you mean that they would have to 
be jointly contributed by the three contributing School 
Boards? Is that correct?

A. That is right.
Q. So there has to be concurrent action on the part 

of the Boards of Supervisors of three different counties 
for the school fund?

A. No, from the School Boards of those counties.
Q. Each School Board in its county has to go to its 

Board of Supervisors in its county for its money?
A. Yes, but money allotted to the School Board can 

be used without recontacting the Board of Supervisors. 
# * # * *

(R. p. 866) Q. Do I understand you to mean by 
that that you are going to send all of your white voca­
tional students to the Manassas Regional School?

A. Those which can be taken care of by Manassas 
that we do not have facilities for at the present plant.

Q- Are there any negroes who fall within that same 
general category?

A. All of them.
Q. What negroes can stay in Arlington and get 

sheet metal? There has been a lot of testimony about 
that — or auto mechanics?

A. None, at the present time.



[ 244 1

Q. So the mere fact that a white pupil has to go 
out is not because he is white but just because he hap­
pens to be late in coming in the course or due to the 
(R. p. 887) normal course of operations, the class is 
filled when he arrives there? Is that correct?

A. That is correct, the same way you would be if 
you had gone to the store and the sugar had been given 
to the man ahead of you and you didn’t get any, you 
would be discriminated against.

Q. That is not discriminating. You happen to lose 
out due to the circumstances of the situation. Is that 
true with respect to negroes? Do they go out of Arling­
ton County or do you propose to send them out of 
Arlington County merely because facilities happen to 
be filled up or because of this race and color?

A. Because we do not have the facilities.
Q. Why is it they can’t compete for available places 

at Washoington and Lee Vocational School?
A. The School Board has no discretion on that. That 

is set up by the statute under the State law over which 
we have no control.

Q, And the State law says the negroes can’t attend 
schools with the white?

A. And vice versa. The white cannnot attend school 
with the negroes. In other words, the white students 
cannot enroll at Hoffman-Boston.

# * # # #

(R. p. 868) But the negro student who wants to take 
vocational training can’t enroll because he is a negro and 
because of the fact that you set Washington and Lee 
up as a white school? Is that correct?

A. That is correct, in the same sense that a five



[ 245 1

year old child cannot enroll in the schools because the 
State law says we cannot take him until he is six.

* # « » *

(R. p. 872) Q. And a better opportunity than a 
community which pays much lower salaries. Let me 
ask you one other question: Isnt the salary scale of 
Prince William much lower than Arlington County?

A. I don’t know how much it is but Arlington 
pays the best salaries in the State.

# . # * # #

(R . p. 8 8 8 ) B y  M b . H i l l :
Q. Mr. Early, coming back to this regional proposi­

tion, how do you propose to get the children to Ma­
nassas and maintain them there?

A. Either through transportation of our own or 
with arrangements with Fairfax.

Q. Have you got transportation of your own?
A. We can provide it.
(R. p. 889) Q. I am asking you do you have it

available?
A. Yes, we can provide it.
Q. What kind of transportation do you have avail­

able now?
A. Adequate transportation if we need it.
Q. What type? By airplane or what?
A. We have a car or can lease, rent or buy buses, 

either one.
Q. But you don’t have anything under your present 

control? You are merely saying you can go down and 
buy a bus or go down and buy an automobile?

A. We have an automobile that could be used for 
that purpose.



[ 246 1

Q. If during the course of this week in the rearange- 
ment of these schedules, and so forth, has been testi­
fied, Monday morning you want to send ten or twelve 
children to Manassas, how do you send them?

A. We would make arrangements with Fairfax 
County.

Q. Who controls that transportation?
A. Mr. Woodson, Superintendent of Schools, Fair­

fax County. They have the same arrangement with 
Alexandria.

(R. p. 891) Q. And all of these arrangements are 
by virtue of these argeements you have talked about 
so far and will be under the control of the Joint Com­
mittee of Joint Control, or whatever policy there may 
have — it will be that Committee that has control of 
the school?

A. That is correct.
Q. And the transportation will be the transporta­

tion under the control of the Fairfax County School 
Board?

A. That is correct.
# * * # #

HOWARD A. DAWSON 

C ross E xamination

B y  M r . M a r t in :
* # # # #

(R. p. 918) A. The fact that under my name ap­
pears the words “Director of Rural Service, National 
Education Association”, is merely to identify me. It 
does not mean that what I have to say in any way rep­



[ 247 1

resents the National Education Association. I would 
have no authority to commit the Association on any
matter of this kind.

So this report is to be contrued as a report for which 
I am wholly responsible.

# # # # #

Q. Would you say that your conclusions in this re­
port accurately reflect the opinions and beliefs of the 
National Education Association, or not?

(R. p. 919) A. I haven’t the slightest idea, because 
they haven’t expressed any opinion on it. I said this is 
my report and not the National Education Associa­
tion’s.

#  *  *  *  *

(R. p. 922) Q, Dr. Dawson, I believe you stated 
that you have a Master of Arts Degree, and also a 
Doctor of Philosophy Degree?

A. I did.
Q. Are both of those from George Peabody College 

in Tennessee?
A. That is right.
Q. Do you hold any degrees from any college any 

place in the United States other than in Tennessee?
A. I do not.
Q. Tennessee, I believe, also operates under a seg­

regated school system?
A. Yes, sir. I don’t see what that has to do with

the degree I have.
Q- I didn’t ask you that. I asked you do the schools

operate under a segregated system?
A. Certainly.

& •» # $



L 243 ]

(R. p. 929) Q. That is the beginning of your re­
port. Is your whole report here, including your appen­
dix, based upon what you consider facts, including 
this alleged fact?

In order to determine whether or not the school 
facilities are equal or can be made equal, it is nec­
essary to take into consideration or keep in the back 
of your mind that they must be handled under a seg­
regated system in Arlington County. Is that a fact?

A. Yes, and now I want to explain my answer, if I 
may have permission. I undertook to make this study to 
aid the Board of Education in improving educational 
(R. p. 930) facilities in Arlington County.

In order to do that I had to know the limits under 
which the Board of Education could work. I did not 
undertake the job of advising the Board of Education 
to do something which they legally had no power to 
do.

Segregation of schools under the laws of Virginia is 
a fact, and it was an essential fact to the study that 
I had to make. It made it necessary that I make recom­
mendations with respect to separate schools for Whites 
and Negroes.

I wouldn’t want to undertake a job of advising the 
Board of Education how to circumvent the law.

# # * # #

(R. p. 931) Q, And your report further shows in 
its preamble or preliminary phase of it that Hoffman- 
Boston is set up and operated for Negro children and 
that Washington and Lee is set up and operated for 
White children because of the segregation law in the 
State of Virginia?

A. That is right.



[ 2 4 9  ]

Q. Isn’t your conclusion to the effect that the rea­
son there are inequalities between the operation of the 
(R. p. 932) two schools for the two different races be­
cause of the segregation law in the State of Virginia?

# * # # #

T he C o u r t : As I understand it, the ques­
tion is whether or not segregation does not ac­
count for the inequalities.

M r . M a r t in : T h at is the question.

T he W it n e ss : Yes, because the segregation
law has resulted in the Hoffman-Boston School 
of necessity being a small school because of the 
small population and therein lies the answer to 
most of the problems.

# # =» # «

(R. p. 942) Q. Would you say, as far as the ex­
terior of the schools are concerned, as far as the facili­
ties for physical education are concerned, that they are 
equal, Doctor?

A. As far as an athletic program is concerned, foot- 
(R. p. 943) ball and baseball and track, they are not
comparable.

However, I pointed out in my report that the athletic 
field and stadium at Washington and Lee are support­
ed by the Athletic Association and not by the School 
Board.

Q. It is operated on School Board property, isn’t 
it, Doctor?

A. That is my understanding, sir.
Q. They have teachers paid by the School Board, 

supervised athletics at Washington and Lee?



[ 250 ]

A. I am not certain whether they are paid by the 
School Board or the Athletic Association.

As I remember it, the coach is probably paid by the 
School Board, but I wouldn’t want to make that state­
ment for certain. You will have to ask Mr. Walsh or 
Mr. Early.

Q. Doesn’t your report show that the physical ed­
ucation department of Washington and Lee is paid by 
the School Board and operated by the School Board?

A. The physical education department where you 
have gymnasium and calisthenics and that kind of train­
ing, certainly that is a direct part of the school program 
and included in the curriculum and they have such in­
struction in both schools.

* » * # »

(R. p. 951) Q. I beg your pardon.
I show you Plaintiff’s Exhibit No. 3, which is the 

auditorium at Hoffman-Boston.
A. Yes, I think that is it.
Q. And I show you Plaintiff’s Exhibit 17, which 

purports to be the auditorium at Washington and Lee?
A. Yes, I think that is it.
Q. Will you state that those auditoria are compar­

able or equal?
A. They are quite different.
Q. In what respect?
A. Well, the Washington and Lee Auditorium are 

(R. p. 951) much larger. In the auditorium at Wash- 
ginton and Lee they have stationary seats.

In Hoffman-Boston they have moveable seats because 
they do use the auditorium for certain gymnastic 
purposes.

In both cases they have a stage and in the larger au­



[ 251 1

ditorium the stage is larger than the one at Hoffman-
Boston.

For most purposes for which we want just a school 
auditorium, if we weren’t concerned with physical ed­
ucation, I would say that adequate instructional op­
portunities could be carried on at Hoffman-Boston. It 
is a little like trying to compare a rabbit to a horse to 
compare those two school buildings. They are just dif­
ferent. They serve different purposes and different 
sizes of school bodies. They are not easily made, com­
parable.

Q. Doctor, from an educational standpoint, speak­
ing about in general the opportunities for educational 
development in Aldington County, that same conclu­
sion can be reached with most of the phases of educa­
tion there in trying to compare Hoffman-Boston School 
for Colored Children, to Washington and Lee for White 
(R. p. 952) Children, that it is like trying to compare 
a rabbit to a horse, is it not?

A. Just about like it.
(R. p. 953) Q. Don’t you feel, Doctor, speaking as an 
expert from an educational standpoint, that the child­
ren attending Hoffman-Boston School just as much en­
titled to an auditorium comparable in all respects to the 
auditorium provided for other children in Washing­
ton and Lee?

A. Well, I would say yes, if I know what you mean 
by comparable.

For example, I wouldn’t say they ought to have one 
as large as Washington and Lee. I would say the}/' 
ought to have as good seats and as good stage and as 
good lighting facilities and it ought to be sufficiently 
as large to accommodate the number of students.



[ 2 5 2  1

Q. And facilities for motion pictures and other 
things that they have at Washington and Lee?

(R. p. 954) A. Sure.
Q. Do they have those at Hoffman-Boston?
A. No, they do not have facilities for motion pic­

tures.
# # * * *

(R. p. 958) Q. They have those facilities at Wash­
ington and Lee, and they do not have those, or equal 
facilities, to those at Hoffman-Boston. Then in those 
reports at least Hoffman-Boston is not equal to Wash­
ington and Lee; is that true?

A. In some respects it wouldn’t be equal, but the 
main point is that they are different.

# # # # #

(R. p. 962) Q. When they finish school they won’t 
know how to make blueprints.

A. They won’t get instruction in blueprint making 
at Hoffman-Boston and they couldn’t go to Washing­
ton and Lee to get it.

Q. And they don’t have any place to make them, 
if they had the course available at Hoffman-Boston? 

A. Not now.
Q. So in that respect the schools are not equal, are

they, Doctor?
A. In that respect they are not equal, if by that you 

mean they are not alike, or the same.
*  #  ii # #

(R. p. 971) Q. Why is it more necessary to teach a 
child a specialized course in auto mechanics or machine 
shop or sheet metal work or printing or woodworking



[ 2 5 3  1

at Washington and Lee than it is at Hoffman-Boston?
(R. p. 972) A. That is an administrative necessity.
Q. You mean economic necessity?
A. Not a matter of educational mothods of teach­

ing or efficiency; it is made necessary by the adminis­
trative situation under which you have to operate the 
two schools.

Q. That is administrative necessity based upon ec­
onomic necessity, the size of the school and the segre­
gated setup in Arlington County?

A. That is correct.
Q. What is the ultimate result of that?
A. I don’t know what results you are looking to.
Q. It is discriminating against those children at 

Hoffman-Boston, isn’t it?
A. No, I don’t think it is discriminating against 

them. You asked me personally whether I would have 
segregated schools in Arlington County if it were not 
required by law. My answer is no. I suppose that will 
surprise you, too.

Q. From your report, Doctor, I am surprised, but 
do you say that the segregation of school children in 
Arlington County, then, in certain aspects, at least, 
which we have gone over this morning, does provide, 
or culminate in the children at Hoffman-Boston getting 
(R. p. 973) an unequal education?

A. It is unequal in the sense that there are certain 
types of instruction which I have enumerated in my 
report, of which printing and automobile mechanics 
are two examples which are not offered at Hoffman- 
Boston, and they could not feasibly be offered there.

# # # # #



[ 254  ]

(R. p. 974) Q. I am not trying to make you state 
anything. I am asking your opionion on certain courses 
of study. We will get to home economics after a while. 
I am merely asking you as a result of this separation, 
segregating the forty-eight children over at Hoffman- 
Boston, if they are not getting an unequal education 
in these courses that I have mentionad this morning? 
Aren’t they getting an unequal education because of 
that separation or that segregation, or whatever you 
want to call it?

A. My answer is that they are not getting an ident­
ical education, and they probably couldn’t within the 
reasonable limits of economy, but so far as saying that 
their educational opportunities are unequal because 
they are different, I wouldn’t say that.

# # # # #

(R. p. 985) Are the students at the two schools af­
forded an equal opportunity to learn trades and busi­
nesses, based on the fact brought out here as to the 
plant facilities and equipment?

A. They are not at the two schools, of course, be­
cause in auto mechanics and printing those subjects are 
not taught. I think it was brought out that the School 
Board would arrange for students who wanted that 
kind of instruction to be sent to Manassas. It is not 
taught at Hoffman-Boston.

In those two instances I agree with your statement.
(R. p. 990) Q. Is your conclusion the same on 

other phases of the report as it is on this one, such as 
the course in automechanics, that is a colored child in 
Hoffman-Boston desires to take automechanics he ap­
plies to his teacher and his teacher applies to Wash­
ington and Lee and ultimately he may be able to get



[ 255 ]

a course in automechanics, and that is not discrimin­
ation?

A. I do not agree with that way of building a 
school curriculum. I certainly don’t advocate it and 
when you are talking about courses of study you are 
talking about one thing, and when you are talking 
about a book or magazine, you are talking about an 
entirely different thing.

I heard the testimony about the way you build up 
a curriculum. I wouldn’t build a curriculum in any 
school on the basis of folks coming around and asking 
for what they might: want. The proper thing to do is 
(R. p. 991) to make a scientific study of the needs of 
the pupils and of the community and then take into 
consideration the resourscs, financial and otherwise, 
and set up a curriculum which has been developed by 
the educational experts in consultation with the parents 
concerned, and set it up out of some inimity of agree­
ment.

I don’t know of an educational system anywhere in 
the world that could operate on the baisis of sticking 
in a course just because some parent or student came 
along and asked for it.

# # # * #

Q. And if they require a colored child to do such 
and give him a course of study based upon what he 
thinks he needs and do not put that course into the 
(R. p. 992) school until the child asks for and at the 
same time provides useful courses, whether that course 
or another course at the White school, that is at least 
some evidence of discrimination against that colored 
child, isn’t is, Doctor?

A. Not necessarily an evidence of discrimination. It



[ 2 5 6  ]

is more likely to be an evidence of trying to make a 
prudent expenditure of school funds. I think that a 
Negro child that wants to study automechanics should 
be given that opportunity, but I don’t think it has to 
be given at Hoffman-Boston. It ought to be given some­
where in accordance with state law and I certainly 
would not deny him that opportunity when that is one 
of the regularly established courses.

You will remember that at Washington and Lee they 
do not set up a course unless there are eighteen stu­
dents that want it. Obviously, if you applied that rule 
to Hoffman-Boston, you wouldn’t have any courses at 
all. So you need a different rule as to the number of 
students, but just the mere fact that a course is offered 
over at Washington and Lee and not offered at Hofl- 
man-Boston and a student comes up and asks for it, in 
(R. p. 993) my opinion, the School Board is hardly jus­
tified in spending the taxpayers’ money to set up a 
course for one pupil if they can do it otherwise. The 
pupil is certainly entitled to the instruction.

Q. That is the reason I asked you the question be­
fore as to whether or not your testimony was colored 
by your previous experiences, whether or not it is eco- 
nomicaiy feasible, economically sound for the School 
Board of Arlington to set up a separate course in auto­
mechanics because one colored child asked for it 
at Hoffman-Boston.

A. It is not economically feasible.
Q. But it is educationally unsound for them not 

to do it, is it not, if they offered the course at Wash­
ington and Lee?

A. No, it is not educationally unsound not to offer 
it at Hoffman-Boston. It would be discrimination if they



f 257 1

do not make it possible for that student to have auto­
mechanics, and it doesn’t necessarily have to mean that 
it has to be in Arlington County, according to my point
of view.

Q. You advocate that it should be a segregated set­
up somewhere else. You say that is educationally sound?

A, If a student were sent anywhere in Virginia the 
(R. p. 994) answer is obvious that it would have to 
be segregated.

Of course, I think in a situation such as Arlington 
County, where the number of Negro pupils is small, 
segregation as a necessity is uneconomic, and I told 
you before if it weren’t for the Constitution and stat­
utes —

# a # « #

(R. p. 997) Q. So, on the whole, the commercial 
department, assuming that the purposes for having a 
commercial department were the same at each school, 
at Hoffman-Boston it is not equal to that at Washing­
ton and Lee; is that true?

A. There, again, the answer is that it isn’t the same. 
What they undertake to teach is the same, although 
we could certainly say the pupils at Hoffman-Boston 
were handicapped by not having a calculating machine.

(R. p. 998) Q. They have a mimeograph machine 
at Washington and Lee which they use, don’t they?

A. Yes, they use that for general school purposes 
and, of course, the students in the commercial depart­
ment, I understand, run those sheets through the mim­
eographing machine.



[ 258  1

Q. And they don’t have any mimeograph machine 
at all at Hoffman-Boston?

A. I think that is right. They do not.
# # # * #

(R. p. 1012) Q. Don’t you feel that a group of 
children, regardless of whether they are White or color­
ed, living in a local community such as Arlington 
(R. p. 1013) County, should have an opportunity to 
take the same courses of study or the same type of 
courses of study rather than, as I understand they do 
in Arlington County, teach the White ehlidren auto 
mechanics and printing, and teach the colored child­
ren bricklaying?

A. They ought to have the educational opportunity. 
I reiterate, however, that it wouldn’t of necessity have 
to be offered at Hoffman-Boston School. At least, I 
don’t think it would be good administrative practice 
or good economy in the use of public funds.

Q. You are speaking now from economic standpoint 
and not from good educational practice, aren’t you?

A. It wouldn’t be good educational practice to offer 
those courses at Hoffman-Boston.

Q. Even though children are in the same local com­
munity?

A. If there is any other feasible way for those stu­
dents to get that training more economically, it should 
be done. The mere fact that arrangements of that kind 
happen to be matters of inconvenience has for a long 
time been decided as not being a valid consideration.

The fact that some children have to travel further to 
go to school than others is no evidence of discrimina- 
(R. p. 1014) tion, and I have never read a case in 
which it was so held.



I 259  1

$ # & * #

(R. p. 1015) Q. I don’t believe I made myself clear 
in the question. I meant assuming that all of the child­
ren are from the same local community, such as in Ar­
lington County, where the children may live next door 
to each other, or within the same block, or across the 
street from each other, asuming all of them are in the 
same local community and after completing school 
will have to compete with each other in the same type 
of vocation?

A. Unfortunately, under the Constitution and laws 
of Virginia there are two separate communities, even 
if they do live next door to each other, and what I 
said is just as applicable. You remember I pointed out 
what would happen in a county all under the same 
board of education.

In other words, you run right square into this segre­
gation business, which I can’t do anything about.

* * # # *

(R. p.1024) Q. Do you think the child who has 
successfully completed a course in journalism at a high 
school has a better opportunity to get a job as a jour­
nalist than one who does not have any credit course?

A. The chances are he would have a better oppor­
tunity to get a job, provided be was a proficient student.

(R. p. 1025) Q. Isn’t it general practice for a tea­
cher who is assigned to teach the course in journalism 
to be proficient in journalism; to have some practical 
experience in journalism?

A. I don’t know whether she would have actual 
practical experience in the way of employment. I would 
say she should have some specialized training in her



f 2 6 0  1

collegiate career in that field if she is going to teach 
journalism.

Q. The same applies to a teacher who is going to 
teach speech; is that correct?

A. Yes, except that any teacher who has majored 
in English preparing to teach had instruction in spoken 
(R. p. 1026) English, and for the pin-pose of instruc­
tion on the high school level she ordinarily will be 
qualified to teach what could reasonably be taught in 
high school.

Q. Do you have any information that the teacher 
who teaches English at Hoffman-Boston is qualified to 
teach speech and journalism, or has had any exper­
ience, either practical or otherwise, in journalism?

A. No; I have not examined the transcripts of cred­
its or talked with teachers, so I could not answer that.

What I pointed out was that the administration of 
the schools in Arlington County could organize their 
instructional courses so as to do that. Whether they are 
actually doing that or not, I don’t know.

# * * # *

(R. p. 1027) Q. On page 75 of your report, in par­
agraph 3, it states that the School Board should con­
tract with the Board of Regional Vocational and High 
School for Negroes at Manassas to accept any Negro 
pupils at Arlington County that want instruction not 
offered at Hoffman-Boston, pay the tuition and trans­
portation expense for such pupils.

I believe the testimony has been that Manassas is 
some 28 or 30 miles from Arlington.

Would you say that by sending certain of their child- 
(R. p. 1028) ren outside of the county to a school 25, 
38 or 30 miles away while permitting the others to get



[ 261  1

their education within the county was not discrimina­
tion?

A. I don’t think it is discrimination. It is an inci­
dent of this whole question of classification based on 
segregation. It is a matter of the Board doing the best 
it can to administer the school system under its limita­
tions, and with the resources it has in hand.

Q. But even assuming that the courses of study at 
Manassas were the same as those at Arlington, is it 
not the classification which puts an extra burden upon 
the children who are forced to go outside of their 
county?

A. Well, in the sense that segregation may place 
an extra burden any where, yes.

Q. That is, we are assuming that the courses of 
study at Manassas are equal.

Suppose the child who goes to Manassas to take vo­
cational courses comes back to Hoffman-Boston to com­
plete his high school education, and certain of these 
three-cycle courses were offered there last year, what 
happens to that student who is not able to take that 
(R. p. 1029) course, who has to wait two more years 
before he is able to take it?

A. It is entirely possible he would be inconven­
ienced a year.

Q. And he would not be discriminated against; 
would he not?

A. Well, I don’t know. You may have one idea of 
discrimination and I another. I do not think it is a 
matter of discrimination simply because of race or color. 
It is a fact that it incident to the situation over which 
the Board has no control because that was settled by the 
State law.



I 262  ]

They do have within their discretion the decision to 
make as to what is the best educational program and 
how it best should be afforded, so long as they conform 
to the State law and the requirements of the State 
Department of Education.

In doing what I have suggested they would have 
done both. I do not consider that a matter of discrim - 
in filiation or any intention to discriminate because of 
race or color. It is a natural concomitance of a situa­
tion that cannot be helped.

Q. What is your idea of discrimination?
* « * « *

(R. p. 1080) T h e  W it n e ss : I think, if the
School Board said “No, we won’t teach that 
course because you are a Negro,” that would be 
discrimination. If they say “We won’t teach you 
this course because it is not practical under the 
limitation of law under which we have to ope­
rate”, that is not discrimination. It is an incident 
of classification.

B y M r . M a r tin :
#  #  #  *  %

(R. p. 1033) Q. You don’t have any information as 
to whether the State of Virginia will give any credit for 
any such correspondence courses in higher mathematics 
from out-of-state- schools?

A. I do not know, but it would be easy to fnd that 
out.

Q. Did you say that a student taking a correspond­
ence course in higher mathematics is not disadvantag­
ed from one who is taking a course in a classroom with 
other students in higher mathematics?



[ 2 6 3  i

A. He may be disadvantaged in the fact that lie 
would have to do more work than he ordinarily does 
(R. p. 1034) in a class. He would not be disadvantaged 
insofar as he could master the subject, because it has 
been demonstrated that mastery of a subject in cer­
tain fields by correspondence is rather superior.

I have done some correspondence work. From the 
standpoint of work, it is a hard way to get an educa­
tion, it is a hard way to get an education, but it can 
he done, and the student can make out.

Q. And the supervision of a teacher in the class­
room?

A. He misses that even in small classes where you 
teach classes with one pupil or two or three. A cer­
tain amount of social stimulation from a group will 
necessarily be missed. One way to make up for it is 
by increased time relationship between the pupil and 
the teacher.

Q. Your answer would be the same in these courses: 
commercial arithmetic, general mathematics, referring 
to paragraph 5 of your report, page 68; would it not?

A. Yes; except that in a case like general mathe­
matics it would also be true of general science. Also, 
in a school such as IIoilman-Boston, there certainly 
ought to be classes organized. If I had to take my 
choice between, not taking general science, or not hav­
ing these specilized sciences, I would prefer to have the 
general science taught by a well-qualified teacher. That 
( R. p. 1035) subject is in a different category from solid 
geometry, for example

Q. Rut it is better to have general science and cer­
tain specialized scientific courses, is not that true?

A. That is true.



[ 264 1

Q. That is, to have a separate course for separate 
unit credits for those courses?

A. It is desirable to have both.
Q. I notice in the second paragraph of page 5 that 

it is stated that economics, world history, economic 
geography and Latin-American history are ordinarily 
taught at Washington-Lee and not given at Iloffman- 
Boston.

You state that economics and economic geography 
can well be provided in the course of civics and social 
studies. World history and Latin-American history are 
definite deficiencies that should be remidied if any 
qualified student asks for such instruction.

I understand from ths paragraph that none of these 
four courses are offered at Hoffman-Boston, although 
all were offered at Washington-Lee?

(R. p. 1036) A. Yes; I think the table shows that.
Q. Of course, that is a definite deficiency in the 

school curriculum at Hoffman-Boston?
A. As I pointed out, yes.
Q. On page 69 of your report, Doctor, dealing with 

paragraphs numbered 7 and 9 where Commercial Law—
A. I beg your pardon? What page was that?
Q. Page 69 dealing with commercial law and book­

keeping, both of which are taught at Washington-Lee, 
and neither of which is taught at Hoffman-Boston.

Did you say that they can- be offered as well to the 
students at Hoffman-Boston by a supervised corre­
spondence course as they are being offered at the pre­
sent time at Washington-Lee?

A. They can be adequately offered with the same 
(R. p. 1037) limitation that I agreed to a while ago: 
whatever is missed through the stimulation of being



E 2 8 5  ]

with other students is a factor that you would have to 
evaluate to accompany your point of view.

(R. p. 1043) Q. I believe you stated that driver 
training should be taught at the Hoffman-Boston 
school?

A. Certainly everybody who is going to drive an 
automobile would profit from that kind of instruction.

* • * * #

(R. p. 1044) Q. The so-called vocational shop and 
(at) Hoffman-Boston is taught for only one hour class 
period just as all the other class periods are taught? It 
is not a vocational shop. It is a general shop, is it not?

A. Primarily, that is what it is. Mr. Halstead has 
done a pretty good job.

According to technical information bricklaying is 
not a vocation, although actually it is.

Q. The general shop at Hoffman-Boston is not set 
up as a specialized and departmentalized unit on a 
unit basis?

A. No; it is not.
Q. Such as that at Washington-Lee?
A. No; it is not run the same way.
Q. The purpose of the vocational shop which you 

have at Washington-Lee is to teach the school children 
to he journeyman, when they come out in their particu­
lar trade; is it not?

(R. p. 1045) A. I think that is tue in some of these 
vocational schools and courses, especially automobile 
mechanics. It cannot teach them to be a journeyman, 
because you understand that a high school graduate is 
not going to get to be a journeyman in high school. He



[ 2 6 8  1

is going to have to serve an apprenticeship, The labor 
unions take care of that.

(R. p. 1046) Q. You stated a number of times that a 
lot of these courses are not specifically mentioned by 
name as being taught at Hoffman-Boston which are 
taught at Washington-Lee could well be taught in con- 
(R, p. 1047) junction with some of the courses at Hoff­
man-Boston.

I have asked about certain specific courses, but do 
you have any information, direct information from 
any of the teachers at Hoffman-Boston which will show 
that they are capable of teaching these related courses 
which you mentioned here this morning and this 
afternoon in their regular courses of study,

A. No; I do not. What I did in my report was to 
recommend to the Board of Education and the Super­
visor and administrative officals that they can make it 
their business to see that the teaching was done in that 
way.

I have little doubt that the teachers who are in Hoff­
man-Boston have the requisit training and qualifica­
tions to do the job that way.

However, I hasten to say that usually any group of 
teachers anywhere you could find, whether in a white 
school or a colored school, do the kind of thing I am 
talking about only when they have a skillful adminis­
trative and supervisory leadership.

But of necessity, the training they have in college 
gave them a knowledge of these various subject matter 
fields, which would make the kind of coordination and 
correlation I am talking about feasible.

# * # * *



E 2 6 7  1

(R. p. 1048) Q. Dr. Dawson, you have stated that 
the cause of giving a lot of these different courses in 
Washington-Lee and so few courses in Hoffman-Bos- 
ton was because of the difference in the size of the 
schools?

A. Yes, sir.
Q. You recognized the fact, of course, in your re­

port that there are differences in the courses of study 
offered?

A. Yes; and I tried to point them out specifically.
Q, And there are differences in the other equip­

ment. For instance, i don’t know whether I brought it 
out or not, but I do believe that on pages 53 and 61 
of your report it shows what I am talking about. On 
page 53, for instance, dealing with cafeterias and lunch 
services, you state chat there is an adequate cafeteria 
(R. p. 1049) and an excellent lunch program, and I 
believe that there is no cafeteria or luncheon program 
at Hoffman-Roston. 1 believe that is true; is it not?

A. Yes; that is correct.
Q. It is a recognized fact, is it not, that cafeteria 

and lunch programs are essential to a well-regulated 
high school?

A. Not essential, but highly desirable, There certain­
ly should be one for all school children in Arlington 
County, whether Hoffman-Roston or otherwise. Of 
course, I did point out here that they should have a lunch, 
program. I also pointed out 1 didn’t consider the fact 
that they did not have one over there evidence of inten­
tion to discriminate on the part of the Board of Educa­
tion, because I saw that Dolly Madison Junior High 
School for white people is one with 600 whites peoples, 
and they did not have any cafeteria, either.



[ 26S 1

I did not think it is by design that they did not have 
one. It is because the thing grew up over there like 
Topsy. They should get around to establishing cafe­
terias.

Q. I do not believe the issue here is the question 
of actual intent of the School Board as to whether or 
not they intended to discriminate or not. I believe it 
(R. p. 1050) is whether or not they are providing equal 
facilities for the two schools.

A. They did not provide cafeterias at Hoffman-Bos­
ton.

# # # # #

(R. p. 1056) I believe you state here that Wash­
ington-Lee High School is accredited both by the Vir­
ginia State Department of Education and the Southern 
Association of Colleges and Secondary Schools?

A. Yes.
Q. And up until 1948-1949 Hoffman-Boston High 

School was not accredited by the Virginia State Board 
of Education, but it is accredited at the present time 
on the probationary list?

A. Yes; that was the information I was given by
the administrative authorities.

<Q. And that at the present time Hoffman-Boston 
High School is not accredited yet by the Southern As­
sociation of Colleges and Secondary Schools?

A. It was not at the time I made this report. I have 
not checked any further.

# # * * *

(R. p. 1057) Q. Now, what is the advantage of a
school being accredited by the Association of Colleges 
and Secondary Schools?



[ 269 1

A. Well, it gives public recognization as to the qual­
ity of the school and what the teachers qualify as, and 
how well the school is operated. It gives notice to the 
public that the school is organized and it has such merit 
that it is recognized by this Association, and the states 
in that Association.

# # # * #

ELIZABETH PFOHL CAMPBELL 

Cross E xamination

By Mr . Ransom:
# # # # #

(R. p. 1080) Q. But you are still expressing your 
personal view.

My question is this: Suppose there is only one Negro 
student who wants a unit course in journalism. No 
matter whether she might get better instruction by tak­
ing it up under a teacher, but if she wanted a unit 
course, and if there are such unit courses available at 
Washington-Lee and not available at Hoffman-Boston, 
will the Board put that course in?

A. I don t think they would be justified in putting 
it in. That would be my answer. We could send her to 
Manassas if she show enough aptitude.

* # # # #

(R. p. 1082) Q. And I appreciate your views as a 
member of the Board. That is exactly what I want to
get.

Now, you have this unit course already down at 
- Washington-Lee High School. Let’s assume that we



1 2 7 0  1

have this one Negro child, and let us say, to meet your 
conditions, that after discusing it with her parents she 
has intelligently decided that she wants this course.

A. Not after discusing it with her parents.
( R. p. 1083) Q. I said after the child had discussed 

it.
A. No, not after the child had discussed it with 

her parents.
Q. Pardon me. Will you let me finish the question, 

Mrs. Campbell?
A. Yes, sir.
Q. After she had intelligently discussed the matter 

with her parents, let us say that she wanted this same 
unit course, but not as a part of this generalized in­
struction in the general course. She wanted a unit 
course, and she comes to the Board with that request.

Do I understand you to say that you would not set 
it up until after you had personally taken up time and 
decided whether or not she ought to do it?

A. I would prefer not to do it. I would prefer to 
see that she was tested to find out whether she could 
use that course, that is, whether she had the ability 
to use it, whether there was any pracital reason why 
tax money should be spent to offer one course to one 
pupil who has no reason and perhaps no ability to 
use it.

** & * # *

(R. p. 1087) A. Well, state your question again, 
would you?

Q. The one Negro child in Arlington County who 
wanted a unit course which is avaiable to all white 
children at Washington-Lee High School can not get'1 
it in Arlington County colored high school, no matter



[ 271 ]

what her ability is, whereas she could get it if she were 
white, no matter what her ability, at Washington-Lee 
High School?

Now, can you answer that “yes” or “no”?
A. I can answer it, but I don’t think you have asked

the question right.
Q. Well, will you answer it, please, and then you 

can say anything else you want to.
A. Well, no.

WILLIAM H. EARLY (Recalled) 

D ir e c t  E xamination

B y  M r . D o u g l a s :

* # * # #

(R. p. 1090 )Q. By what means are those persons 
being transported to Manassas?

A. The two girls and the one boy are transported 
by an arrangement with Fairfax County.

Then we have purchased a bus and are sending the 
forty-one or forty-two boys to Manassas in it.

Our Negro student is going on a Fairfax bus by the 
same arrangement or contractual arrangement that we 
have for the two white girls and one white boy coming 
out of the Falls Church area.

* * * * • . #

C ross E xamination

B y  M r . M a r t in :

ft ft ft ft ft



[ 272 ]

(R. p. 1105) Q. I believe you stated that she tried 
to take chemistry and she couldn’t get it, but that in 
all probability it would be offered next year?

A. That has been the plan, that is, alternating 
courses each year.

Q. They teach chemistry at Washington-Lee every 
year, don’t they?

A. I think so.
Q. And Miss Council tesified that she was at Hoff- 

man-Boston from the middle of the term until June of 
last year and couldn’t get chemistry last year either?

A. I believe that was a matter of choice, Mr. Martin, 
by vitrue of the fact that she could have (g)done into 
that class for a half vear, had she wanted to.

(R. p. 1106) Q. Wasn’t her testimony that that 
class had begun in September and that she couldn’t 
enter the class in the middle of the year-?

A I don’t remember.
Q. And that she can’t get it this year, and that she 

is within, at the present time, a year and a half of grad­
uating from high school, or about a year?

A. I believe it would be about a year; that is right.
Q. When do you expect her to be able to take 

chemistry in an Arlington County School?
A. It will be available for her the entire year next 

year-. You see, she is a transfer student. We set this 
school up and operate it according to the students 
that are within its borders, within its jurisdiction, at 
the time.

We have never been able, in any school I have ever 
konwn, to take care of all the variations of transferees 
that might want to come to you. You never know 
when they are going to show up.



[ 273 1

Q. Well, a white student, under the same or similar 
circumstances, whether a transfer student or living in 
Arlington County, could have taken chemistry before 
graduating from high school if that person had applied 
for it at the beginning of this school term?

(R. p. 1107) A. That is correct.
Q. And Peggy Council can’t take it because she is 

colored and is not permitted to attend a white school; 
is that correct?

A. She can’t take it because the school she is at­
tending doesn’t teach it this year.

Q. What school do you provide in Arlington County 
that she can take it in?

A. We don’t provide any in Arlington County that 
she can take it in.

Q. Now, you stated the reason she couldn’t take 
Latin is because she had only a year and a half to go, 
and she would, of course, graduate before she had a 
sufficient amount of Latin completed to obtain credit 
in college; that is true, isn’t it?

A. Yes. That is correct.
Q. But when she applied for Latin last February, 

she had only a year and a half to go and she could 
have been within a half year of completing the Latin 
course by the time she had completed her other sub­
jects; isn’t that correct?

A. Coming at the middle of the term that way, there 
are very few courses in a seven-five school that start 
(R. p. 1108) at the half year point, if any.

I am not sure of any that start at the half year mark. 
Therefore, she would have had to wait over until this 
year anyway had she wanted to take it. It was not offer­
ed by virtue of tire fact that there was no demand 
for it, particularly.



[ 274  1

O. There was one demand for it?
A. We have never been able to substaniate that 

with our records, so we won’t know.
Q. Well, regardless of whether it was a demand or 

not, the course of study in Latin, although she claim­
ed it was necessary for her college preparatory work, 
was not offered to her, while it was at the same time 
being offered to other children in the county who were 
not Negro; is that right?

A. Well, I think Mrs. Campbell brought out a while 
ago the fact that only those students whe were guided 
or were encouraged to go into that type of curriculum 
would go into it at any school. Therefore, I don’t know 
that I can answer your question by “yes” or hto”. We 
are not offering it this year because, according to our 
records, we had no requests for it.

Q. But, Mr. Early, you are speaking now as ad­
ministrative officer of the school system in Arlington 
(R. p. 1109) County while Mrs. Campbell was speak­
ing as a member of the School Board and stating what 
she would like to do as a member of the School Board 
and as a mother.

But you don’t profess to examine every Negro child 
who wants to take some course of study that is not 
offered at Hoffman-Boston but which is offered at 
Washington-Lee, do you?

A. We have to rely upon the administration at Hoff- 
man-Boston to advise us as to what they would recom­
mend, and we have done that right along.

#&



[ 275 ]

ALLEN G. BROADNAX 

D ir e c t  E xamination

B y M r . R obin son :
# # * # #

(R. p. 1124) Q. Please state whether or not you 
have had occasion to make a series of photographs of 
the Manassas Regional High School at Manassas, Vir­
ginia?

A. Yes, I had occasion to do so on September 30, 
1949.

* * * # &

(R. p. 1129) Q. Did you make an examination for 
purposes of determining whether or ont there was any 
gymnasium or gymnasium facilities at Manassas Re­
gional School?

A. Yes.
Q- Did you find any gymnasium or gymnasium fa­

cilities there?
A. No.
Q. Did you see any art room at that school?
A. No.
Q. Any band auditorium?
A. No"
Q. Any bookkeeping classroom?
A. No.
Q- Any distributive education room?
A. No, I didn’t.
Q. Any guidance office?
A. No.
Q. Any music room?
A. No.



[ 276 1

(,}. Any teachers' lounges? 
A~, N o.

* * *

W. A. EARLY 

R ed irect  E xamination

B y M r . M a r t in :

e  a  *  # *

(R. p. 1138) Q. At the present time the children 
who are attending Hoffman-Boston School now are not 
permitted to take printing, are they?

A. We have had no demand for printing.
O. Does a white child who goes to Washington 

and Lee School have to make a demand for a course in 
printing to be instituted for him?

A. That is correct.
Q. Isn’t the course already instituted in printing 

(R. p. 1139) for the children at Washington and Lee?
A. That is correct.
Q. He doesn’t have to make a demand for a course 

to be instituted?
A. That is the way it started, yes.
Q. When did it start?
A. I don’t know.
Q. It was in there when you came there?
A. That is correct.
Q. The children who entered in September at 

Washington and Lee, the white children, were able to 
take the printing and the course was available for them 
to take printing in September?

A. If there was room for them, yes.



[ 277 1

0 . And whether or not there was room for the 
children in Washington and Lee to take printing, no 
colored child could take printing anywhere under the 
supervision of the Arlington County School Board, 
could they?

A. That is correct.
* $ # ft ft

(R. p. 1142) Q. Have you been to Manassas since 
the last hearing when we were here in the first part of 
September to determine whether or not there are faci­
lities at Manassas for teaching auto mechanics, mechan­
ical drawing, machine shop, sheet metal worok, print 
shop, or wood shop or whether any of those courses are 
being offered at the present time? Have you been there 
to make an examination and inspection to determine 
whether or not those things are true?

A. No.
ft * ft ft ft

PEGGY COUNCIL (Recalled) 

C ross E xamination

B y  M r . M a r tin :
ft ft ft ft ft

(R. p. 1145) Q. You entered PIoffman-Boston 
School in September of ’48?

A. Yes.
ft ft ft ft ft

Q. What courses of study are you taking at the 
present time, Miss Council?



[ 278 ]

A. Civics, physics, shorthand, typing, home econ­
omics and English.

Q. I believe you testified at the previous hearing 
(R. p. 1146) that you were taking typing. You stated 
you were not taking shorthand and desired to take 
shorthand? Is that correct?

A. Yes.
Q. When did you begin taking the course in short­

hand?
A. It was in the early part of October.
Q. That was since the last hearing?
A. Yes.
Q. I believe you also testified that you desired to 

take Latin? Is that correct?
A. Yes.
Q. And that you were not able to do so?
A. Yes.
Q. Are you taking Latin at the present time-'?
A. No, I am not.
Q. You stated that you began attending Hoffman- 

Boston in September of last year?
A. Yes.
Q- Did you desire to take Latin at that time:
A. I did.
Q- Was it offered at that time?
A. No, it wasn’t.
Q- Were you able to take it at all last year'?
A. No.
Q And you haven’t been able to take it this year:
A. No, I haven’t.
<R. p. 1147) Q. Are you taking any type of phys

leaf education at the present time?
A. No.
Q. I believe you testified the last time you register



[ 279 ]

ed in a course of physical education but later with­
drew?

A. Yes.
Q. And why was that?
A. 9-B, 10, 11 and 12, are all taking the same course.
Q. Are they still taking the same course at the pre­

sent time?
A. Some of the other girls withdrew from the class. 

The class is still in opration but not all the girls are 
there that were there when it first started.

Q. I believe you testified at the last hearing that 
the Principal of the School told you or agreed for you 
to withdraw from that course, that other arrangements 
would be made for you to take physical education?

A. Not to take physical education but other ar­
rangements were made. The first week I was out of the 
physical education class I was assigned to study in the 
library and about the second week lie asigned me to 
home economics class.

Q. And in what grade are you now?
A. 11-B.
Q. And when are you supposed to graduate?
A. I am supposed to graduate next Febraury.
(R. p. 1148) Q. This coming Febraury?
A. No.
Q. February after this coming?
A. Yes.
Q. You have a little less than a year and a half of 

school now?
A. Yes.
Q. And I understand you requested the course in 

Latin when you entered there September before this
last?

A. Yes, I did.



[ 2 8 0  1

Q. And you haven’t been able to take it yet?
A. No, I haven’t.

* * * * *

(R. p. 1153) Q. You testified that you desired to 
take Latin. When did that desire first arise in your 
mind?

A. While I was at Dunbar we also had to fill out 
an elective sheet and I gave my desires for shorthand 
and, if I recall correctly, Mr. Sydnor received m y ----

Q. You said Dunbar. Let us get these things 
straight. It was while you were at Dunbar?

A. Mr. Sydnor received my elective sheet from 
(R. p. 1154) Dunbar and Latin was on that. At the 
close of school I also desired Latin and I haven’t gotten 
any Latin as yet.

Q. You have seen this card which is identified and 
has been admitted in evidence as Defendant’s Exhibit— 
I beg your pardon — I think you have not seen this 
card. I now show you a paper which has been intro­
duced in evidence here as Sydnor Exhibit A and I ask 
(R. p. 1155) you whether that is in your handwriting?

A. It is.
Q. When did you write out that card?
A. I wrote this card out about May and this is the 

one that was handed to Mr. Sydnor personally. I gave 
it to him myself.

# sft #  #  #

Q. What is the purpose of that writing on that card? 
A. This is an elective. There was another elective, 

as I stated in my last testimony, that was given to my 
home room teacher, Mrs. Wilson, with the class report.



[ 2 8 1  ]

Q. Is it customary to take out two such schedules 
of the courses that you want to take?

A. When I filled out this one I didn’t have the 
understanding that we were to elect our courses if La­
tin wouldn’t be offered. I didn’t have that understand­
ing when I filled this out. After I got the understanding 
that Latin would be offered at Hoffman-Boston this 
year I filled out another sheet which Latin was on.

Q. Is that why you didn’t put Latin on that card?
A. Yes, because I didn’t have the understanding it 

(R. p. 1156) was to be offered.
Q. When did you first find out that Latin would 

be offered?
A. It was in June. I don’t recall.

* # # # #

Q. If you handed the first card to Mr. Sydnor why 
did you hand the other card to someone else?

A. I handed the other card to my home room tea­
cher because she was the one that gave it to us and
we were to fill them out and hand them back to her.

* # # # #

(R. p. 1158) Q. Did anyone tell you — I believe 
you testified that you understood that you couldn’t 
complete your two years of Latin beginning at the 
point at which you found yourself last September and 
that you were going to take some post-graduate course?

A. Mr. Sydnor said I would be able to take a post­
graduate course after finishing high school in Wash­
ington without much expense from my parents.

Q. You couldn’t start the last half of the second 
(R. p. 1159) year of Latin in September in the Wash­
ington School System



[ 282 1

A. I don’t know.
Q. Wouldn’t you have to wait until February follow­

ing your graduation from Hoffman-Boston before you 
could start taking the last half year of Latin?

A. I don’t know.
Q. Have you determined in what school you are 

going to take your nursing instruction?
A. At the rate I am going now, I won’t be able to 

take any musing.
Q. Why?
A. Because I haven’t had any Latin and the way it 

looks, I won’t get any.
Q. Have you determined what school you would 

attend if you did take nursing instruction?
A. Hampton.
Q. Do you understand that at Hampton Latin 

would be required as a prerequisite for admission?
A. As I understaand it, Latin is required for nurs­

ing because most prescriptions are written in Latin.

R ed irec t  E xamination

(R . p, 1180) B y M r . M a r tin :

Q. One or two other questions. I believe you testi­
fied the last time that you also applied for chemistry. 
Are you taking chemstry now?

A. No, I am not.
Q. You haven’t been able to take either chemistry 

or Latin since you have been at Hoffman-Boston?
A. No, I haven’t.
Q. Is it your understanding that both of those 

courses are necessary for you to attend nursing school?



1 283 1

A. Yes.
Q. Has the Division Superintendent or any of the 

members of the administration offered to provide a 
course for you in either of those courses?

A. Not to my knowledge.
Q. Regardless of whether you have read this peti- 

(R. p. 1161)tion, did you apply for those courses either 
on or about the beginning of the school term in Sep­
tember of this year or before that time in Hoffman-Bos- 
ton?

A. I did.
Q. And you haven’t been able to obtain either of 

them since?
A. No.

# # # # #

C. N. BENNETT 

D ir ec t  E xamination

By Mr. R a n so m :

Q. Mr. Bennett, will you state your full name and 
address?

A. My full name is C. N. Bennett, Manassas, Vir­
ginia.O

Q. And what is your occupation, Mr. Bennett?
A. Principal of the Manassas Regional High School. 
Q. Is that the Regional High School maintained 

(R. p. 1162) at Manassas for the education of negroes? 
A. It is the Manassas Regional High School.
Q. Is it for the education of negroes?
A. Yes, it is.

* * # * #



[ 284 1

B y  th e  C o u rt :

Q. As Principal, is it one of your duties to make up 
the curriculum for the year?

A. As the Principal, it is my duty to plan cooper­
atively with the faculty and the School Board for our 
curriculum.

Q. Who makes up the curriculum finally?
A. Who makes up the curriculum finally?
Q. Yes.
A. It is planned cooperatively.
Q. It comes out of the cooperative consideration?
(R. p. 1163) A. Yes, sir.

B y  M r . R a n so m :
# # # # #

Q. Now, Mr. Bennett, I want you to examine that 
schedule of your offerings at Manassas Regional High 
School and tell me whether or not economics appears 
upon that schedule, a course in economics?

A. A course in economics does not appear on that 
schedule.

(R. p. 1164) Q, Does a course in busines mathe­
matics appear upon that schedule?

A. A course in business mathematics does not ap­
pear. 1 may say those two course do not appear due to 
the fact that they haven’t been requested.

Q. Does a course in bookkeeping appear upon that 
Schedule?

A. No, it does not appear on that schedule. It did 
appear on the first schedule but that course was made 
available but we didn’t have enough requests for that 
course.



[ 285 J

Q. You had some requests but not enough?
A. Not enough.
Q. How many requests did you have?
A. I don’t think we had over five or six requests.
Q. So you took it off the schedule?
A. Yes.
Q. Have you a course in solid geometry appearing 

on that schedule?
A. No.
Q. Do you have a course in trigonometry appear­

ing on that schedule?
A. No request was made for any of those. They axe 

(R. p. 1165) available but no requests have been made.
Q. You do not give them at the present time and 

the schedule is made up without them?
A. The first schedule was made with them on but 

the fact is no request was made for them.
Q. Is there a course in Latin on that schedule?
A. No requests were made for Latin.
Q. Does there appear upon that schedule any place 

a course in instrumental music?
A. There aren’t any courses given in instrumental 

music because of the fact that no request have been 
given up to now. May I say that instrumental music 
is available.

Q. Rut it is not scheduled there?
A. It is not scheduled because----
Q. Do you have a course in mechanical drawing 

appearing there?
A. Not on this particular schedule and that is also 

due to the fact that not enough were available for that 
particular course.

Q. Do you have an exploratory course in shop in



t 286 1

the 8th grade, or anywhere else as far as that is con­
cerned?

A. There are some exploratory courses, yes.
Q. What exploratory courses?
A. Home economics.
Q. I said in the shop?
( R. p. 1166) A. We don’t have any in shop at this 

time.
Q. One other question: Do you have a course in 

shop mathematics appearing on that schedule?
A. No requests have been made for shop mathe­

matics.
Q. I ask you does it appear on that schedule? Is 

there any provision for it?
A. No.
Q. Is that so?
A. Shop mathematics is available.
Q. It doesn’t appear upon the schedule?
A. No.
Q. You have no provision for it on this schedule?
A. Not on this schedule.
Q. So those courses I named are not available in 

the sense that they are scheduled for this current year?
A. Those courses are available.
Q. Isn’t your schedule in operation?
A. Certainly this schedule is in operation and I am 

contending that those courses are available but not 
enough requests have been made.

Q. Were there requests for any of those courses I 
named other than the ones you spoke of?

A. You spoke of bookkeeping and there were a few.
Q. Were there requests for any other courses?
A. No.



[ 2 8 7  1

(R. p. 1187) Q. That is the only one you had re­
quests for and didn’t keep on your schedule?

A. That is right.
# # # * #

By the Court:

Q. None of them that counsel has mentioned is 
being offered? Is that right?

A. May I have something to say?
Q. Answer that and make any explanation.
A. Yes, none are.

(R. p. 1168) By Mr. Ransom:
Q. I haven’t asked you for any material and I don’t 

intend to ask you for anything more except this one 
question: Do you have a student in your school at the 
present time by the name of Green — I forget his 
first name, — who is a student from Arlington County? 

A. Yes, we have.
Q. Is he the only student you have from Arlington 

County at the present time?
A. As far as I know.
Q. What course is he taking there?
A. He is taking a course in general mechanics.
Q. Is that what he applied for when he came there? 
A. That is what he told me he wanted.
Q. He told you he wanted general mechanics?
A. Yes, he did.



[ 288  1

SIMON L. ALSOP 

D ir e c t  E xamination

(R . p. 1171) B y M r . M a r tin :

Q. What is your name, please?
A. Simon L. Alsop.
Q. Where do you live, Mr. Alsop?
A. Manassas?
Q. What is your occupation?
A. Teaching.
Q. Where?
A. Manassas Regional High School.
Q. How long have you been a teacher there?
A. Since the start of the school session.
Q. In September?
A. That is right.
Q. And what course of study do you teach?
A. I am teaching a coursee in general mechanics.
Q. I show you Plaintiff’s Exhibit No. 89 which has 

been identified as the program which is at the present 
time being taught at Manassas Regiional High School 
and I notice on that program that Mr. Alsop teaches 
general metal. Does that Mr. Alsop refer to you?

A. The Mr. Alsop refers to me but since this sched- 
(R. p. 1172) ule there has been a slight change.

Q. What change?
A. Mr. Smith is general metals teacher and I am 

the general mechanics teacher. That was a typograph­
ical errror.

# # 4* # #

(R. p. 1174) Q. Do you teach any auto mechanics 
over there?



[ 2 8 9  1

A. I do.
Q. Since when?
A. Since the beginning of the course.
Q. When did the couse begin?
A. I am afraid I wouldn’t remember the date.
Q. The first part of September? When school open­

ed?
A. Not the first part but sometime in September.
Q. You began teaching auto mechanics at Manas­

sas Regional High School?
A. Yes.
Q. What equipment do you have for teaching auto 

mechanics?
A. I have hand tools.
Q. What kind?
A. You mean what trade make?
Q. I mean what kind of hand tools? What do you 

have over there to teach auto mechanics with?
A. I am afraid I don’t understand.
Q. Do you have hammers, saws, wrenches or any 

metal machinery, metal working machinery of any 
(R. p. 1175) kind? Do you have a Chevrolet car on 
which to work?

M b . M a r t in : Let the record show that the
witness hesitates, if Your Honor please.

B y  th e  C o u rt :

Q. Do you understand that question?
A. I am afraid I don’t.
Q. He wants to know if there is a Chevrolet car at 

the shop that you use in teaching?
A. There is a Chevrolet truck there.



[ 290 1

Q. Do you use that in illustrating to the students 
the different parts of the car?

A. Is it the understanding of the Court that that is 
a new course, a beginners’ class?

Q. Any class. You do have a class in auto mechanics, 
I understood you to say?

A. General mechanics and I am teaching auto me­
chanics.

Q. When you teach the students in auto mechanics 
do you show them how to use automobile tools?

A. Such tools as they have been able to use up to 
this point. What I am trying to say is that they aren’t 
trained and it will take time for them to get into au~ 
taomobile over-haul and things of that sort but things 
like changing tires and minor maintance, I am trying 
to familiarize them with that sort of thing right now.

Q. And you haven’t any students in auto mechanics 
(R. p. 1176) that are beyond* that stage?

A. At the moment, if they are, I haven’t found it 
out.

Q. How do you show them to put on tires and take 
off tires? How do you go about it?

A. Well, I have been giving them the theory I 
think necessary and then I have taken them out and 
let them change a wheel just to be changing a wheel.

Q. A wheel on what — on the Chevrolet truck or 
on some other car?

A. We have changed wheels on my car, for in­
stance.

Q. Is there a car there specially for the use of the 
students in taking off tires and putting on tires?

A. I don’t know for what purpose the truck has 
been there but I do know that we had it in the shop



I 291 1

for experimental purposes, so far as those purposes are
covered.

B y Mb . M a r t in :

Q. Whose truck is that, Mr. Alsop?
A. I am afraid I don’t know that.
Q. Is it still there?
A. It is.
Q. Was it there last night?
A. If I am not mistaken, it was there.
Q. Do you know Mr. Lester Banks sitting over

there.
(R. p. 1177) A. You mean was it in the shop?
Q. Yes.
A. No, it was not in the shop.
Q. Where was it?
A. I guess it was parked out in front. I didn’t look

for it.
Q. Whose truck is it?
A. I am sorry, I don’t know.
Q. Is it a new truck or an old truck?
A. It is a good truck.
Q. New truck?
A. I wouldn’t know if it is new or not.
Q. Do you know the year model?
A. I am afraid to say. I wouldn’t know the model 

but I know it is a late model.
Q. Are you an automobile mechanic?
A. I am.
Q. You don’t know the model of this truck?
A. If I may say, I am pretty sure that you can't 

exactly tell the model of a truck, unless you trace the



[ 2 9 2  i

engine number, just by looking at it because several 
models are identically the same and that goes for auto­
mobiles.

Q. Your boys are over there working on that track 
and changing tires and you don’t know who it belongs 
to?

A. I am not interested.
(R. p. 1178) Q. Do you know how many miles that 

truck has on the speedometer?
A. I haven’t looked at the speedometer.
Q. What kind of tools do you use when you are 

using somebody else’s truck? You say you change tires. 
What kind of tools do you give your hoys when you 
change tires on that truck?

A. I usually give them a lug wrench to change the 
wheel.

Q. I am talking about the tires now.
A. You would have to have a couple of tire irons 

and maybe a hammer.
Q. You need a jack?
A. Yes.
Q. You give the boys that jack and tire irons and 

lug wrench and have them changing tires on that truck? 
Is that it?

A. Well, you recall I believe I said I used my car 
mostly.

ft ft ft ft ft

(R. p. 1180) Q. Mr. Alsop, we have found now that 
you have tire irons, a jack and a lug wrench to teach 
auto mechanics. What other instruments do you have 
there to teach auto mechanics?

A. If I could have known I could have brought you 
a list of the instruments that I have but I am afraid it



[ 2D3 I

wouldn’t be fair to you, or me either, to try to call off 
a few that we have because 1 might miss some of them 
and I might call something we don’t have. I will be 
glad to take an inventory and bring that to you in the 
very near future.

Q. That is ali right. I understood you to say you 
had been teaching auto mechanics since the first part 
of September and I understand this is the 25th of Oc­
tober. Can't you think of any instruments or any equip­
ment that you have there to teach auto mechanics 
other than a lug wrench, jack and tire irons?

A. Well, you see, there is quite a bit of theory. I 
don’t know if you have thought about that.

Q. You teach the theory of auto mechanics, too?
A. That is right, yes, I try to.
Q. And changing tires?
A. Well, not necessarily changing tires but theory. 

* * & # #

(R. p. 1181) Q. Do you have any motor analyzers 
there?

A. No. &
Q. Do you have any practice engines there, auto­

mobile engines, other than your car and somebody else’s 
track?

A. I think there are to be or there is to be an engine.
Q. I don’t believe you understood my question. I 

asked you if there are any there now?
A. Not that I know of.
Q. Do you have a drill press there used in auto 

mechanics?
A. I do.
Q. Do you have a valve grinder?
A. No. '



I 2 9 4  1

Q. Do you have any armature lathes? 1 don’t mean 
your regular general metal lathes, but armature lathes 
for automobile mechanics?

A. As far as I know, they are on order.
Q. Do you know what an armature lathe is, Mr. 

Akop?
A. I think I do.
Q. You are not sure?
A. I am sure I do.
Q. Do you have a chain hoist there to hoist those 

automobile engines up?
A. No.
Q. Do you have any battery chargers?
(K, p. 1182) A. No, but we have generators.
Q. You don’t have a battery charger?
A. No.
Q. Do you have any air compressing machines? 
A. You mean just air compressors?
Q. Yes.
A. We are in the process of building one now.
Q. You are building your own air compressor?
A, I should have said remodeling.
Q. What do you mean — remodeling?
A. We had to repair the tank.
Q. Where did you get that tank?
A. It was the one used in the old shop, I under­

stand. I don’t know too much about the machinery.
Q. Is it in working condition at the present time? 
A. We are working on it.
Q. Do you have any speedometers there, experi­

mental speedometers, that you use in automobile me­
chanics?

A. Any what?



Q. Experimental speedometers? You know, a speed­
ometer on an automobile?

A. No, I don’t think you will find mechanics ex­
perimenting on speedometers. They are usually sent to 
speedometer specialists.

(R. p. 1183) Q. Isn’t your general mechanics 
course at Manassas primarily an exploratory course in 
(R. p. 1184) vocational mechanics?

A. Would you mind explaining?
Q. Don’t you just teach the students who come 

there in the first year, teaching them the general idea 
of mechanics and mechanical ability so they can take 
specialized courses in mechanics later?

A. I am afraid I don’t quite understand you. I 
would like to say this: The course is going to have to be 
a beginners’ course because they do not have mechan­
ical background or, I should have said, mechanical ex­
perience heretofore. They haven’t had.

Q. And you don’t have mechanical tools, either, do 
you, to teach a general course in auto mechanics?

A. I have quite a few hand tools.
Q. Do you recall talking with me about two or 

three weeks ago when I was up there one Saturday?
A. I have talked to so many people.
Q. Do you remember that day when myself and 

Mr. Robinson and Mr. Banks and Mr. Picott and Mr. 
Broadnax came up there and took pictures in that shop 
and every instrument you showed us in that shop 
and you went around with us all over that shop? Don’t 
you recall that?

A. I remember somebody taking pictures.
Q. Don’t you recall Mr. Bennett carried us over



[ 2 9 6  1

there and introduced us to you? Do you recall that?
A. I remember it.
(B. p. 1185) Q. And do you recall talking with me 

about your course of study there at that time?
A. I don’t recall talking to you concerning the 

course of study, but talked to somebody.
Q. Do you recall telling me, Mr. Alsop, in the pres­

ence of Mr. Robinson, Mr. Banks, Mr. Picott and Mr. 
Broadnax that you didn’t have any course in auto me­
chanics? Don’t you recall that?

A, I recall telling you that I had a course in general 
mechanics.

Q. And don’t you recall telling me that is all you
had?

A. I still say that I have a course in general me­
chanics.'

Q. And that is all you have got over there, isn’t it? 
A, I don’t understand what you mean — all I have. 
Q. Is the equipment to teach a course in general 

mechanics an exploratory course in general mechanics 
to give the rudiments of all of these other courses? 
Isn’t that right, Mr. Alsop?

A. You are saying I don’t have auto mechanics at 
all? Is that what you are saying?

# # # * #

(R. p. 1186) Q. Mr. Alsop, I will ask you tins ques­
tion: Do you have any facilities or any equipment to
teach transfer students, say third year- students, auto 
mechanics who came over there and wanted a course? 
Do you have any facilities or equipment or anything 
to teach them that?

A. I have some equipment.
Q. What?



1 2 9 7  ]

A. To teach auto mechanics, but I couldn’t say my 
equipment is adequate or is like it should be by any 
means but I can’t say by the same means that I don’t 
have any equipment.

* & # * #

(R. p. 1187) Q. What would be the necessary in­
struments and facilities that you would need to teach 
a second year course in auto mechanics?

A. You would have to give me a little time.
Q. You can’t think of it offhand?
A. All of the tools and equipment that I am going 

to need to set up a second year automobile mechanics 
training shop.

Q. First, second and third year? A general course? 
How many years does a general course in automobile 
mechanics last?

A. That depends.
Q. It depends on what?
A. On the set-up of the course.

# * * # #

WILLIAM HENRY BARNES 

D ir e c t  E xamination

(R . p. 1 189) B y  M r . R obinson :

Q. State your name?
A. William Henry Barnes.
Q. Your residence?
A. Manassas, Virginia.
Q. Your age?
(R. p. 1190) A. Forty-six.



[ 298 1

Q. Where do you reside, Dr. Barnes? What is your
present position.

A. I am an educator.
Q. And what postion do you occupy and where at

the present time?
A. Chairman of the Department of General Ed­

ucation at Wilburforce State College, Wilburforce,
Ohio.

Q. Please state whether or not in the past you have 
had any connection with the Manassas Regional High 
School at Manassas, Virginia?

A. For thirteen years I was Pdincipal of the Ma­
nassas Regional High School, being the first Regional 
High School in the State of Virginia.

Q. Will you state when your connectiion with that 
institution terminated?

A. My connection with the Manassas Regional High 
School terminated on August 15, 1949.

Q. Dr. Barnes, will you state for the information of 
the Court your educational qualifications?

A. Besides Bachelor’s Degree from Wilburforce, I 
hold a graduate degree in Theology from Payne Theo­
logical Seminary. I will give this in the order in which 
it occurred.

Q. You mentioned a Bachelor?
A. Bachelor of Arts, above that a Bachelor of Di- 

(R. p. 1191) vinity from Payne Theological Seminar)7, 
two consecutive summers in the School of Social Ad­
ministration at Ohio State University. I took a Master 
of Arts Degree from the School of Education at Boston 
University and two consecutive summers at Harvard 
University in the School of Education there.

Q. Do you have any honorary degrees?



L 2 9 9  ]

A. I have an honorary degree, Doctor of Laws.
Q. What institution?
A. Wilburforce University.
Q. Please state for the information of the Court 

what if any, affiliation or connections you have with 
organizations or institutions in the field of education.

A. For seven years I was connected with the Hender­
son Institute at Hendreson, North Carolina, as the As­
sistant Principal there. I came from there to the Manas­
sas School where I was Principal. I have been President 
of the Virginia State Teachers Association. For three 
consecutive summers I was instructor at the Laboratory 
School of Boston University, located at Hillsboro, New 
Hampshire. Only white students were in attendence 
there.

Q. Please state whether or not you have in the past 
had any connection the Denny Commission?

A. I was also a member of the Denny Commission, 
one of the sub-coommittees.

M r . R obin son : We desire to tender this wit-
(R. p. 1192) ness as an expert for such questions 
of expert testimony as we may desire to elicit 
from him. His examination apparently will con­
sist in non-expert testimony but I want him for 
the purpose if we should desire to go into matters 
of expert opinion.

T he C o u r t : All right.

M r . D ouglas: No questions.

B y  M r . R obinson :

Q. In his testimony Mr. Broadnax made reference



[ 3 0 0  ]

to a dining room at Manassas Regional School. Is that 
a permnent affair there, so far as you know?

A. The dining room at Manassas is in connection 
with the residence project. Since I have been away, 
since August 15th, I understand now that it is being 
used as a cafeteria. It is of small space and the ques­
tion is whether or not it would be adequate as a cafe­
teria because it could only seat about forty pupils, 
maybe fifty — let us say fifty pupils comfortably.

(R. p. 1193) Q. Where is the auditorium of that 
institution, located?

A. The auditorium is located, as was testified here, 
in the attic of the Carnegie Building.

Q. And for what purpose is it?
A. On the third floor.
Q. For what purpose is that bulding used?
A. The Carnegie Building is generally conceived of 

as the classroom building.
Q. Is it a fireproof building?
A. The building is not a fireproof building.
Q. How many exits do you have to this auditor- 

iujn?
A. There are three exits, one in the front and one 

on either end.
#  *  #  *  #

Q. When were you the last time at the Regional
School?

A. My home is right off the campus and I see it 
(R. p. 1194) practically every day.

Q. When was the last time you saw there?
A. This morning when I left home.
Q. In your previous testimony and in your testi-



[ 3 0 1  1

mony to follow have you and will you be testifying as 
to conditions as of the present time?

A. There are conditions that I can only testify as 
of August 15th when I left.

Q. Will you state, in connection with your subse­
quent testimony, whether the testimony which you are 
giving relates to conditions as of August 15th or as of 
the present time.

A. I will.
Q. Let us check back for a moment. The auditor­

ium — are they the present conditions there or as of 
August 15th?

A. I only know as of August 15th.
Q. The cafeteria?
A. As of August 15th.

(R. p. 1195) Q. Are there any locker facilities for 
the pupils at Manassas or were there as of August 15th
of this year?

A. As of August 15th of this year in the classroom, 
there are no locker facilities. In the new shop building, 
however, there are locker facilities.

Q. Will you state for the information of the Court 
the last time you made an inspection of the new shop 
building?

A. I asked the Principal’s permission on Friday, this 
past week, after I had arrived home, if he would per­
mit me to look around and I went in the new shop 
building at that time.

Q. Did you inspect it throughout?
A. I did.

&  #  #  #



[ 302 ]

Q. Dr. Barnes, I show you Plaintiff’s Exhibit Nos. 
77, 78 and 79 which are in evidence in this case and 
I will ask you to examine them and state for the in­
formation of the Court whether they show all or sub­
stantially most of the equipment in the three shops 
which those photographs portray?

A. Exhibit No. 79, general carpentry, that is all that 
is in the shop, as I saw it on Friday.

Q. Would you examine Exhibit 78?
A. Exhibit 78 is the masonry shop, the general ma­

sonry shop with the exception of some brickwork that 
was put up there on Friday where probably the class 
in instruction had been carried on. Everything is there 
with the exception of the brickwork.

Q. Plaintiff’s Exhibit No. 77?
A. That is the general mechanics shop. That was 

(R. p.1197) all the equipment that I saw in the shop on 
Friday.

& *  *  #  #

(R. p. 1199) Q. Do you know whether or not the 
course in general mechanics or the course in general 
carpentry or general masonry or general metals, or 
either of those courses, is what is known as an explora­
tory course?

A. The course in general mechanics — may I say 
this? A study was made of the Washington and Lee, 
not knowing that this would be brought in at this time, 
in May, of the Washington and Lee vocational set-up.

Q. Who conducted that study?
A. I conducted that study in company with the four 

shop teachers who had worked with me for a number 
of years.

Q. And for what purpose was that study made?



[ 3 0 3  ]

A. That study was made in order to set up an ad­
equate shop program for the instruction of negro youth 
at Manassas in view of the fact that we were going in­
to a new shop.

Q. To he modeled after the set-up of vocational 
subjects at Washington and Lee?

A. Certainly. I was referred by the State Board of 
Education to see Washington and Lee set-up because 
they had a model set-up for the State, I understand 
one of the best set-ups for vocational training in the 
State of Virginia.

O. Are you thinking of Washington and Lee High 
(R. p. 1200) School in Arlington County?

A. Washington and Lee High School in Arlington 
County, I am speaking of.

Q. Will you proceed?
A. We came over and made a study of that pro­

gram. Mr. Ormes, who is head of the shop, was very 
courteous and all of the instructors — in conference 
with all of the instructors of that shop they explained 
to us the system that they had and it having been re­
commended by the State Board of Education, we set 
out a program. This program was revised in order to 
meet the needs of the pupils in this area and it was 
presented in the Board Meeting to the Joint Commit­
tee for Control for approval in the April meeting.

Q. Dr. Barnes, do you have a copy of your report 
as Principal, made to the Joint Committtee for Control 
of Manassas Regional School at its April meeting?

A. I have it before me.
Q. Is that report now a part of the official records 

of that institution?
A. The minutes will show that the report of the Prin-



[ 304  1

cipa! was accepted and filed as a part of the minutes of 
the meeting.

Q. Will you state whether or not the paper which I 
now hand you is a copy of the report which you have 
just mentioned?

(R. p. 1201) A. This is a copy of the report which 
I have just mentioned.

Q. Will you state for the information of the Court 
whether in this report you went into a proposed set­
up for vocational courses to he offered at Manassas 
Regional High School?

A. This report is a proposed set-up for the Regional 
High School, including the equipment necessary to im­
plement the courses that were proposed.

# # # * *

Q. Will you state whether or not the recommeda- 
tions set forth in your report were followed by the au­
thorities responsible for the conducting of the school?

A. Up to August 15th that report had not been ac­
cepted.

Q. Have you upon other occasions made recom­
mendations and requests to the Committee for Joint 
Control of that school, which recommedations have 
not been followed?

A. I have.
Q. Do you have copies of the reports containing 

those recommendations?
(R. p. 1202) A. I do.
Q. Dr. Barnes, I hand you three papers purporting 

respectively to be copies of, first, a report on the status 
of the Manassas Regional High School dated January 
16, 1946; secondly, a copy purporting to be a copy of 
the Principal’s report to the Joint Committee for Con­



f 305  1

trol at the February meeting and a copy purporting to 
be a copy of the Principal’s report to the Joint Com- 
rnitte of Control at the March meeting and I ask you 
to examine them and state for the information of tire 
Court whether they are the reports, or some of the re­
ports, to which you have referred?

A. These are the reports to which I have referred.

(R. p. 1203) Q. Will you state for the information 
of the Court the year?

A. Of course, there is one report that dates back to 
January, 1946.

B y  t h e  C o u r t :

Q. What is the date of the other report?
A. February and March meeting.
Q. Of this year?
A. Of this year.

* # # # #

( R .  p . 1206) B y  M r . R o b in s o n :

Q. Were you familiar with the Joint Committee 
for Control pursuant to which the Regional School for 
Manassas was operated?

A. I am, Mr. Counsel, and the fact that this was 
the first Regional School and all of the legilation----

T he C o u r t : He asked you if you were fam ­
iliar with it.

B y  M r . R o b in s o n :

Q. Will you state for the information of the Court 
what general policy is pursued relative to teachers’ sal­



[ 306 ]

aries, relative to instructional program, and the other 
(R. p. 1207) phases of the educational process there?

A. The school is operated by the Joint Committee 
for Control according to legislative enactment. It is 
made up of representatives from the County School 
Boards that have equity in the property there.

Q. Would you name those, those School Boards?
A. Fauquier, Fairfax and Prince William. Two 

members of each of those County School Boards are on 
it and then the Superintendents are also consultants or 
ex-officio members of the Board. The Board elects its 
Chairman and appoints an Executive Officer.

Q. Will you state for the information of the Court 
whether or not the Committee for Joint Control of the 
Manassas Regional School follows any general policy 
with respect to its activities in the conducting of that 
school?

A, It is the general policy of the Joint Committee 
for control to operate in conformity with the policies 
of Prince William County in which the school is lo­
cated.

Q. Do you have any written evidence of that de­
claration of the policy by the Joint Committee for Con­
trol?

A. Yes, I do.
Q- Will you state for the infomation of the Court 

what evidence in that connection you have?
A. I have a report that I presented to the Joint 

Committee for Control after laboring with the people 
(R. p. 1208) of this area and finding out their dis­
satisfaction as to the manner in which — I pointed 
out to the Board of Control in which they had passed 
a certain resolution which placed the operation of the



[ 307  I

Regional School under the administrative polices of 
Prince William County and in this report dated June 
10, 1949, I called attention to that fact and asked that 
some consideration be given in not confining the op­
eration of the Manassas Regional School to the policies 
of Prince William County but take into consideration 
the needs and interests of taxpayers in Fairfax and Fau- 
quir County and any other County that was partici­
pating in this project, should they come in later on.

Q. Is this the report?
A. That is the report.
Q. Will you state whether or not this was a report 

submitted to the Committte for Joint Control by you 
as Principal of that institution?

A. The report of the Principal, June 10, 1949, to 
the Joint Committee for Control of the Regional High 
School.

# # # # #

Q. In what ways or in what different phases of the 
educational process there has that policy been pursued? 
For example, has it been pursued with reference to the 
(R. p. 1209) amount of teachers’ salaries to be paid?

A. By the way, that was the thing that brought 
about that resolution — the matter of teachers’ salaries. 
The teachers felt, since they were teaching Fairfax 
County chlidren----

B y  t h e  C o u r t :

Q. The question was — was it followed in respect 
to salaries?

A. It was followed in respect to salaries. Did you 
ask for any reason?



[ 308  ]

B y  M r . R o b in s o n :

Q. Dr. Barnes, did that policy cause you any diffi­
culty as Principal of that institution in securing com­
petent teachers?

A. It did.
Q. Will you state for the information of the Court 

how it caused you difficulty?
A. Teachers remained very much dissatisfied and, 

as Principal, I realized the best education could not be 
received by these children with dissatisfaction in the 
staff and for that reason I brought it to the attention 
of the Board.

Q. How did and how do the average salaries paid 
to teachers in Prince William County compare with the 
averages in Fauquier and Fairfax Counties?

A. According to my recollection, I think Prince Will­
iam County has the lowest salary scale of any of the 
(R. p. 1210) participating counties in the Regional 
High School plan.

Q. Please state whether or not pursuant to this
policy any dissatisfaction arose with reference to the 
institution of a twelve-year program at Manassas Re­
gional School?

A. The reports which have been submitted as evi­
dence will show that in 1948 a request was made, or 
thereabouts, according to my recollection, for the 
institution of a twelve-year system because Fairfax 
had a twelve-year system. Prince William did not have 
a twelve-year system and hence the Board would not 
institute a twelve-year system until Prince William 
County School Board decided that it wanted the twelve 
year system and could afford it, and hence, in March, 
1949, which I think that report will show, they, the



[ 309 3

Prince William County School Board, decided on a 
twelve-year system for the Regional High School,

Q. Dr. Barnes, will you state the policy of Prince 
William County with reference to gymnasium facili­
ties and gymnasiums at the high schools in that county?

A. There is no gymnasium at the Regional High 
School. There are gymnasiums used by the Osborne 
High School and also I don’t thnik there is over at the 
Vocational School itself, being used as a gymnasium. 
I think the crowded condition makes that a classroom.

Q. Will you state for the information of the Court 
whether there was any delay in the construction of the 
(Ft. p. 1211) new vocational building at Manassas 
which has been the subject of considerable testimony 
here?

A. Yes, I will.
Q. There was delay.
Q. Will you state briefly what the occasion for that

delay was?
ft ft ft ft ft

A. The occasion was that the $75,000.00 remained 
in Richmond over a period of two or three years before 
it was used to construct the shop building.

ft ft ft ft ft

Q. I have a couple of further questions to ask you. 
(R. p. 1212) Are you familiar with the value of science 
equipment at Manassas Regional High School as of the 
date you left?

A. I think so.
Q. Will you state for the information of the Court 

the approximate value of the science equipment there?



[ 310  1

A. Well, I would estimate the approximate value 
as being less than a thousand dollars.

Q. Do you recall the number of magazines and 
newspapers subscriptions at that institution as of the 
date that you left there?

A. I do.
Q. Will you state the figures in that connection?
A. In my last school year we had approximately a 

subscription of 48 magazines. Will you permit further 
comment?

Q. Make it brief, please,
A. That 48 magazines were not supplied by the 

School Board; they were supplied out of funds that 
the citizens of Northern Virginia assisted the librarian 
in subscribing to magazines for the school.

Q. Dr. Barnes, what if any, amount of indoor space 
is available at Manassas Regional School for physical 
education?

A. There is no indoor space provided at Manassas 
Regional School for physical education.

# # # # #

J. RUPPERT PICOTT (Recalled)

D ir e c t  E xamination

B y  M r . R obinson :
*  « # # it

(R. p. 1214) Q. Mr. Picott, please state whether or 
not you have had an occasion to make an inspection of 
the Manassas Regional High School for negroes at Ma - 
nassas, Virginia?



[ 311 1

A. I visited it once since the hearing here in Sep­
tember.

Q. Did you make an inspection or examination of 
facilities at that institution?

A. Yes, I did, in company with several other per-
(R. p. 1215) sons.

Q. Do you recall the date on which that examina­
tion was had?

A. I recall the latter part of September, 1 think 
it was. I am not sure of the exact date.

Q. And I believe you previously testified that you 
had also made an examination of the facilities at Wash­
ington and Lee High School in Arlington County, Vir­
ginia?

A. Yes.
Q. Mr. Picott, please state whether or not upon 

your examination you saw at Manassas Regional 
School any gymnasium or gymnasium facilities or art: 
rooms or band auditorium, bookkeeping classrooms, 
distributive education rooms, guidance office, music 
room or teachers’ lounges?

A. I do not recall seeing any of those facilities.
Q. Please state whether or not, in your opinion, the 

auditorium facilities, cafeteria facilities, library faci­
lities, athletic facilities, classrooms, corridors, lavatories 
and science rooms at the Manassas Regional School are 
equal to, unequal to or equivalent of the same facilities, 
respectively at the Washington and Lee High School?

A. It is unequal. I can enlarge on that.
Q. Is it your opinion that each of these facilities is 

unequal to the same facility at Washington and Lee 
High School?

A. As last mentioned, as called by you, yes.



[ 312 3

(R. p. 1216) Q. When you say unequal, will you 
state whether or not you mean inferior or superior?

A. The word is inferior. If I might give an explana­
tion of one of them, I think it would serve for the others.

Q. Confine yourself to that.
A. For example, the auditorium at Manassas is on 

the third floor and the day we were there it was ter­
ribly crowded, most inaccessible and I think inadequate 
and unattractive in appearance, whereas just the op­
posite was true of Washington and Lee School.

# # # # #

(R. p. 1217) Q. Upon your inspection in Septem­
ber of the facilities at that institution, did you see your­
self any equipment or any facilities for instructor! in 
vocation courses other than those which have been 
testified to on today?

A. No, I did not. Let me answer it in the affirma­
tive — I did not see it.

C ross E xamination  

B y  M r . D ouglas:

Q. The day you were over there I understand there 
was an assembly of the school in the auditorium?

A. Yes, there was before we left.
* * « # #

(R. p. 1218) Q. The auditorium was pretty well 
crowded at that time?

A. Quite.
* * * # #

( R. p. 1221) Q. Let me ask you about the laboratory



f 313 J

facilities over at Manassas. Did you examine those?
A. Yes, I did.

* * « * *

Q. I show you a photograph identified as Plaintiff’s 
Exhibit 83 and ask you to state whether or not that in­
dicates space for individual students working by the 
research method?

A. This picture shows this space for working was 
in usch dilapidated shape —- and I mean just that — 
(R. p. 1222) that I asked the person who was in the 
room was it ever used. The bottles were in the comer, 
as you see, and the picture adequately portrays it and 
the answer which I recieved from one of the teachers 
was that as of the time we were there it had not even 
been used. As a matter of fact, I doubt if it had been 
cleaned.

# # & # &

Q. You were there last September, the latter part 
of September?

A. Or the first of October.
Q. Was Carnegie Hall then being fully remodeled?
A. No, Carnegie Hail is in bad shape. The flooring 

is in bad shape. As a matter of fact, what Carnegie Hall 
needs perhaps is not a remodeling job but a much more 
drastic approach to it.

* * * * #

Red irec t  E xamination

(R . p. 1224) Q. B y M r . R obin son :

Q. In your professional opinion are the facilities



[ 3 14  1

which are afforded at Manassas Regional School for 
education of a pupil who desires a vocational course 
equal to or unequal to or comparable to the facilities 
available at Washington and Lee High School for a 
(R. p. 1225) pupil who desires to attend there for a 
vocational course?

A. I must base my answer on the last visit when 1 
was there and, as of that time, they were not, in my 
opinion.

DR. MARTIN D. JENKINS (Recalled)

Direct E xamination

(R. p. 1226) B y Mr . Ransom:

Q. Dr. Jenkins, you were in court yesterday when 
Dr. Dawson testified?

A. A large part of the time.
Q. Did you hear him testify to the effect that he 

made his examination of Hoffman-Boston School his 
first examination on the last day of the school term 
and went back once, I think, during the summer when 
school was not in session?

A. I certainly heard him make the first statement. 
I don’t know about his visit during the summer.

Q. When did you make your examination of the 
(R. p. 1227) school?

A. The specific date I don’t recall but I visited 
both the Hoffman-Boston and Washington and Lee 
Schools in the middle of the year when schools were 
in regular session and regular class work was being 
conducted.



[ 3 1 5  ]

Q. And observed the comparative efficiency and 
activities of the school while they were in actual op­
eration?

A. To the extent that I indicated in my previous
testimony.

Q, Dr. Jenkins, are you familiar with the entrance 
requirements of universities throughout the country and
particularly, let ns say, Howard University?

A. I am.
Q. Let us assume, sir, that a student applying at 

Howard University, for example, with, among her cred­
its for admission from graduation from high school, 
one year of Latin, would that student be admitted to
the University?

A. I may say that I am going to describe the prac­
tice at Howard which I will say would be general in 
American imiversitiees. Howard will require two years 
of a foreign language, Latin being defined as a foreign 
language. If a student were to present only one year, 
the student would be admitted on condition and then 
would take the equivalent of the second year of Latin 
in college and be given entrance credit for it rather 
than college credit, so that a student who presents one 
year of Latin is in a better position than one who has 
(R, p. 1228) no language credit to present.

Q. At my request I had an assistant examine cer­
tain volumes or publications dealing with education, 
particularly with the problem of the values or efficiency 
of large and small secondary schools. Have you at my 
request examined the excerpts from these books?

A. I have.
Q. I am going to offer these to you and ask you to 

identify them and read what you consider to be the



f 8 1 6  I

pertinent portion. Will you tell the Court what that 
volume is and refer to the section from which you 
read?

A. This is The Encylopedia of Educational Re­
search prepared under the auspices of the American 
Educational Research Association. The editor is Walter 
S. Monroe who is Professor of Education at the Univer­
sity of Illinios. This book, which was prepared actually 
by several hundred experts in the field of education, 
is an authoritative summary of the status of research 
in various fields and general practice in education. 
When you want to learn what is going on in a particu­
lar area, you first have access to this volume to get a 
summary.

There is a statement here relative to secondary ed­
ucation. This summary was prepared by Dr. Arwood 
Northby of the University of New Hampshire, and I 
will quote. This is under the general heading “Secon­
dary Education,” under the sub-heading “Organiza­
tion,’' and under the further sub-heading, “Size of 
School,” and, as I indicated, this does not express Dr. 
:N ortliby’s opinion necessarily, except conclusions 
(R. p. 1299) drawn. This represents a summary of the 
research in this field.

(R . p. 1230) B y  t h e  C o u rt :
Q. D oes that express your opinion, too, Doctor?
A. Yes.

M r . D ouglas: I will withdraw the o b jed
tion.



[ 317 1

A. I am quoting on page 1079: “Investigations 
concerning the effect of school size upon school organ­
ization and administration may be classified into two 
groups. In the first are the surveys of small high 
schools and in the second the comparative studies of 
schools of different sizes. Both types of investigations 
reveal that the small secondary school possesses num­
erous limitations such as, for example, a limited, nar­
row curriculum and over-burden teaching staff and an 
inadequate plant and equipment. The comparative 
studies show that an increase in school size is usually 
accompanied by decrease in school costs and increase 
in the curricular and extra-curricular offering and an 
increase in the number of desirable organizational and 
administative procedures. On the basis of the criteria 
employed, these investigations indicate a minimum, en­
rollment of from fifty to sixty pupils per grade for 
effective school operation.”

(R. p. 1231) I want to insert a comment at that 
point. The definition “fifty to sixty pupils per grade”, 
means fifty to sixty pupils in the 12th grade, 111 h 
grade, 10th grade, and so on, in each of such grades. I 
am now continuing the quotation:

“Increase in school efficiency continues with increases 
in school size until enrollments of from 150 to 200 pupils 
per grade are reached. Beyond this point improvements 
attributable to school size are few.
“When school size is expressed in terms of the size of 

the teaching staff, results of investigation based upon 
present standards for the scope and organization of the 
curriculum for teaching load indicate that from 8 to 
10 teachers as the minimum necessary for the opera­
tion of an efficient school. Size of a school enrollment



[ 3 1 8  ]

operates as a conditioning factor regardless of the type
of organization.”

# # # # #

(R. p. 1232) Q. Dr. Jenkins, will you comment upon 
that quotation you just read?

A. The comment is that this shows clearly enough 
for most any professional educator, at least, that the 
preponderance of research evidence indicates that the 
small high school does not yield as good educational 
(R. p. 1233) outcome as the large high school up to 
the point of largeness as indicated in the article.

*  #  $  #

( R.p 1236) Q. Under the problem of administra­
tion in small schools is it your opinion that financial 
problems arising from one or more of the following 
factors — insufficient State aid, inadequate support of 
high schools, excessive cost of the small high schools, 
low assessed valuation, high per capita costs, the varied 
ability of the district to provide funds and the reluct­
ance of the School Board to provide funds for services, 
coupled with fixed budget, all tend to make adminis­
tration in a small school more difficult than in a large 
school?

(R. p. 1237) A. That problem exists.
Q. Is there another problem such as the fact that 

the plant and equipment usually are inadequate or are 
poorly planned for functional program and that there­
fore there are limited instructional aids as a problem 
of administration?

A. It is.
Q. Is it likewise a problem that because of the 

smallness of enrollement there is a prohibition against



[ 3 1 9  1

the divesity of elective offerings which may prevent 
class stimulation and which makes for a lack of com­
petition in the classes? Is that another problem of ad­
ministration?

A. Yes, that is another problem,
Q. Does the very fact of the smallness of the ad­

ministration unit effect the administration?
A. Yes.
Q. Are there organizational problems in the small 

school which affect administration which are not ex- 
istant or, at least, not as extensive in a large school 
which again affect the administration?

A. Yes.
Q. As to the program of the school, would the re­

stricted curriculum offering, the tendency to adhere to 
traditional curricula the domination by colleges over 
the question of curriculum with an insufficient recogni­
tion of the importance of building the curriculum in 
terms of the problems and in the opportunity found in 
(R. p. 1238) the immediate environment and of the 
needs of the youth — will that in a small school create a 
problem so far as programs are concerned?

A. Yes.
Q. The fact that in a small school you can have 

very little or no special services such as health and 
guidance — does that again affect the program adver­
sely?

A. Yes.
Q. The fact that there has to be necessarily limited 

pupil activity — is that an adverse factor insofar as 
your program is concerned?

A. Yes.
Q. And in a small school, because there can be



t 8 20  1

very limited or no vocational educative program, does 
that affect your general program?

A. Yes.
Q. And, finally, insofar as your staff is concerned, 

the fact that often in small schools you find inexper­
ienced teachers who are inadequately prepared or are 
ineffective or without understanding of the rural pro­
blems, the fact that there may be a shortage of good 
teachers available to small schools and teachers who 
are not as well trained or not well trained by teacher 
education institutions — is that an adverse factor so 
far as your staff is concerned?

A. In small schools generally.
(R. p. 1239) Q. And in a small school, because you 

have a small staff, plus your inability therefore to em­
ploy sufficient supervisory personnel and specialized 
teachers — is that an adverse factor?

A. Yes.
# # # * #

(R. p 1240) Q. In view of the factors that I have 
(R. p. 1241) named, would you say that your opinion 
as to the relative effectiveness or efficiency of the small 
school against the large school which you have earlier
expressed is still the same?

A. Yes. May I amplify that? What I am doing here 
is expressing an opinion about large schools and small 
schools generally without reference to any particular 
large or small school. I would also like to point out, 
however, that in this publication which has been pub­
lished after my original survey of these two schools that 
many of the points mentioned there as problems were 
mentioned in my survey or study as problems of the 
Hoffman-Boston School,



[ 321 ]

Q. And when you expressed that opinion which you 
have just expressed now, you are adopting the opinion 
that appears in a bulletin, an official bulletin, of the 
Federal Security Agency, Office of Education?

A. I wouldn’t quite like to put it that way, Mr Ran­
som, because I had expressed that opinion before this 
was published. They are concurrent opinions.

Q. I will hand you this document and ask you to 
identify it.

A. This is from the Bulletin of the State Board of 
Education, published in Richmond, Virginia, a Study 
of the Efficiency in Relation to Size of High School by 
M. L. Combs, who was with the Division of Research 
and Surveys. This is a study in which the State Depart- 
(R. p. 1242) ment of Education was concerned with 
the effect of size on efficiency of schools.

« # £ #

(R. p. 1244) A. May I add this?

By Mr. Ransom:

Q. Complete your answer.
A. I wanted simply to substantiate the opinion 

mentioned by the Court that this is not a statement of 
policy, The State Department may have arrived at a 
policy after a study of this kind but this is a study 
which was issued by the State Department of Educa- 
tion.

Q. Yesterday the statement was made in examina­
tion —

A. I would like to add that there is an additional 
statement of policy, however.

Q I am glad you called my atention to it. Will 
you identify this document?



t 322 1

A, This is a mimeographed document by the State 
(R. p. 1245) Board of Education entitled “A Compre­
hensive Program of Education for Virginia Schools”, 
and I would interpret this as a statement of policy by 
the State Department of Education. To point out the 
distinction, this study is a study which is published by 
the State Department. This is, in my opinion, a state­
ment of policy.

$  *  «  *  *

(R. p. 1247) Q. The statement was made by Dr. 
Dawson that it is the general agreement among edu­
cators that the great majority — it was a question ad­
dressed to him on page 841: “That is your personal be­
lief, but it is the general agreement among educators, 
that is, a great majority of educators, that they believe 
that a large school is a much better school, more effi­
cient in all respects than a small school.” His answer 
was: “No; among people who specialize in the admin­
istration of schools of medium and small size, that cer­
tainly would not be true.”

Is that a true statement as to the majority view, in 
your opinion?

A. I think there is no question but that the majority 
view among educators is that a large school is superior 
to a small school in its educational outcome and pos­
sibility for development of children and in economy. 
They are defining a large high school in terms of a high 
(R. p. 1248) school of, let us say, 800 or 1,000 pupils 
and they are thinking of small high schools as being 
high schools even larger than Hoffman-Boston, so I 
would say that Dr. Dawson’s comment certainly flies 
in the face of the literature and of the excerpts which 
were read.



L 3 2 3  1

B y  th e  C o u rt :

Q. Regardless of wliat the majortiy opinion is, wliat, 
in your opinion, is the better thought on the subject?

A. I have already expressed that, that my own. op­
inion is that a large high school as defined, not too large 
a high school, is superior to a small high school. I was 
addressing my comment to the question you asked 
about Dr. Dawson's statement about what the majority
of educators thought.

& & # #

C ross E xamination

B y  M r . D ouglas:

Q. You speak, in giving your opinion as to the 
question asked you — you are qualifying that by saying 
you are speaking of a large high school but one that 
is not too large. What number would you put on the 
large high school by way of defining the maximum 
(R. p. 1249) enrollment beyond which the peak of 
efficiency would be passed?

A. I would think that these large metropolitan high 
schools with three, four, five, six or seven thousand 
pupils would be too large. I would think a high school 
of two thousand pupils would not be too large, al­
though, larger than optimum.

Q. Larger than optimum but not too large?
A. That is right.

ELLIS O. KNOX (Recalled)
D ir e c t  E xamination

B y  M r . Ne w s o m :

Q. Dr. Knox, you have testified previously in this



[ 324  1

case and qualified as an expert. Assuming that it were 
testified yesterday by Dr. Dawson, beginning on page 
722 — I will not read all of the question but there is 
a quotation addressed to the Doctor from his own re­
port that “The chief result of having to maintain seg­
regated schools in Arlington County is the difference 
in the size of the two schools under consideration.”

Going on. over to the following page and a continu­
ation of that question, it is asked whether or not it 
(R. p. 1250) would be possible for the student in the 
smaller school, such as Hoffman-Boston, to get an ed­
ucation — comparable educational opportunities and 
facilities to one in a high school having a total popu­
lation of 1881. The answer is, “It would be possible for 
a student in the small school to get a comparable 
education within the limits of the minimum standard 
of education required by the State. They could not 
get identical educational opportunities. Of course, there 
are certain courses in large schools that are uneconom­
ical to offer in. a small school and there are differences, 
to be sure.”

I do not know whether you have expressed an opin­
ion on that before. I wasn’t able to find it in the record. 
I wanted to ask you what is your opinion. Should there 
be any difference in the opportunity to get an educa­
tion, to get equal education, without any difference at 
all because of the size of the schools where they are 
segregated because of race or color?

A No, there should be no difference because of 
size, regardless of the cause of the size.

Q, I want to direct your attention to another quota­
tion of yesterday on which I have not had your opinion 
before. There is an answer made yesterday: “Eduea-



[ 325 J

tion is always supposed to be adapted to the pupils 
being educated in the community in which they lived 

(R. p, 1251) Going on down — “That is the broad 
general purpose of education,”

On that, if the school’s purpose is to adapt or to 
furnish the education to the needs of the community, 
should there be any distinction in the type of education 
offered where the pupils are segregated on the basis of 
race?

A. No, there should be no distinction. The educa­
tional opportunities, if I may expend it, should be equal 
to every child in the community regardless of race and 
every child should have an equal chance to profit from 
and participate in the opportunities of that community, 

Q. Suppose that it was said that “Unfortunately, 
under the Constitution and Laws of Virginia there are 
two separate communities, even if they do live next 
door to each other, and what I said is just as applicable. 
You remember I pointd out what would happen in a 
county all under the same Board of Education. In other 
words, you run right square into this segregation busi­
ness, which I can’t do anything about.” If that answer 
were made to a question as to whether or not it was 
wise Or economically unsound to offer courses in one 
school because of the fact that it couldn’t be offered 
in another school because of the fact that the school 
was small or that it was economically unsound, would 
you say that is sufficient justification for saying to one 
group of children, “You can’t have the type of educa- 
(R. p. 1252) tion that is being offered to us?”

# # # * #

(R. p. 1253) Q. Do you agree or disagree with that 
statement?



1 328 1

A. I disagree with the statement and I would like 
to explain the reason why I disgree, because whenever 
we have schools operating in communities subject to 
laws such as those in the State of Virginia, the whole 
matter of economy must be redef ined and must be dealt 
with in light of educational opportunities for children.

Q. When you testified before I asked you to com­
ment at that time upon the statement made in Dr. 
Dawson’s report to the effect that certain courses which 
are given at Washington and Lee School and which are 
not given at Hoffman-Boston could be effectively given 
at Hoffman-Boston under a system of supervised study. 
(Pi. p. 1254) I believe at that time you were unable 
to answer because of the fact that you did not under­
stand the meaning of “supervised correspondence 
study.” Assuming that Dr. Dawson explained that yes­
terday as follows: “The lessons are prepared in serial, 
ordinarily by a qualified teacher of solid geometry, 
based upon a textbook, and including exercises de­
signed to enable the student to master the subject. He 
studies that subject more or less on his own time, or 
sometimes it is assigned to him in school, and he is 
given such direct or also incidental assistance from 
a teacher in the school as he may need. You simply do 
not have a formal recitation of, say, fifty-five minutes, 
five days a week. He is graded and his papers are sent 
in to the school that offer's the course. He is graded, 
the papers are returned to the teacher. When he has 
completed the course, he receives a high school unit 
of credit just as if he had taken it in a regular class 
in high school.”

Skipping the portion as to the number of courses so 
taught, “It has been demonstrated it can be done very 
well.”



[ 327 1

Previous to that this statement was made: “It Is call­
ed ‘supervisoury’ because it is under the supervision of 
a teacher and, by the way, it is sometimes supervised 
by a teacher who is not a specialist in a given subject 
matter.”

Will you give the Court the benefit of your opinion 
( I t  p. 1255) on the efficacy of that type of education 
and whether or not it constitutes equality of teaching 
with that given in a school where the students are 
taught in a formal class by a regular teacher.

A. It is my opinion that that type of education, if 
that Is what is meant by “supervisory extension work”, 
is certainly not as efficient as instruction given in the 
classroom and that it certainly is of a lower level of 
value than courses offered students on the secondary 
and, for that matter, any other level where there is op­
portunity for direct contact between the teacher and 
the student for the basic reason that any such exten­
sion work places a premium upon written expressions 
and the interpretation of written material on the part 
of the instructor, while at a classroom situation there 
is opportunity for judging both oral and written expres­
sions with the concommitant intellectural and emo­
tional values which are a part of grading any pupil for 
his classroom instruction.

Q. Assuming that courses are given at one school 
in a regular class and because under a system then in 
vogue persons who happen to be members of the negro 
race are required to attend another school where those 
same courses are not given and the course is given to 
that student who desires it by this supervised corres­
pondence method, would you say that is discrimination 
On account of race?



[ 328 3

&

R. WORTH PETERS 

D i r e c t  E x a m in a t io n

( R .  p . 1256) B y  M r . D o u g l a s :

Q. Will you state your full name and address?
A. R. Worth Peters, Manassas, Virginia.
Q. What is your profession?
A. I am Superintendent of Schools in Prince Will­

iam County.
Q. Plow long have you held that office?
A. A little over three years.
Q. And by virtue of your office are you the Super­

vising Director or do you have within your system the 
Regional Vocational School at Manassas about which 
there has been testimony here today?

(R. p. 1257) A. As Executive Officer of the Board 
of Control, I have the responsibility for the supervision 
of that school, yes.

* * * * *

(R. p. 1261) Q. Do you have a course in sheet 
metal work?

A. As a part of general metals.
Q. You don’t have a course in sheet metal work?
A. No.
Q. Do you have a course in printing?
A. No.

* * * * *

(R. p. 1264) Q. Do you know who owns that Chev­
rolet truck they were talking about this morning?



f 329 1

A, No, frankly, I don’t know. I don’t know what 
Chevrolet truck they are referring to.

Q. Do you have any experimental automobile there 
for the students to use in the automobile shop?

A. The policy in the conduct of auto mechanics 
shop, so far as Prince William County is concerned, 
including the Regional High School, is to utilize what­
ever equipment is available for instructional purposes, 
regardless of whether it is owned by the school or by 
private individuals. We quite often take a private car 
under certain conditions into a shop for instructional 
purposes and do overhaul or other jobs on it, but, as was 
testified this morning, the students of this class are 
not yet advanced to the point that they can do an 
overhaul job or a major repair job. They have much 
yet to learn of basis fundamentals of mechanics before 
they can go on.

Q. On what are they going to learn basic mechan­
ics?

A. They will Ieam on the engines and motors in the 
available cars and trucks and tractors and farm ma­
chinery that will be made available and is there now. 
We have a tractor on the farm that is available for 
them to use for instructional purposes at the present 
time; we have additional farm machinery as a part of 
the mechanics course.

Q. As a part of the mechanics course?
A. General mechanics course, including auto me­

chanics.
Q. What type of farm machinery do you have for 

the mechanics course?
A. We have available to the mechanics course for 

repair and maintenaance and operation and study such 
(R. p. 1266) things as the hayrake, the mower, manure



[ 330  1

spreader — such things as that — the normal farm ma­
chinery.

# 0 * * &



Excerpts From

“A Report On 
A Comparison of the 

Washington-Lee and Hoffman-Boston 
High Schools,

Arlington County, Virginia”

By Howard A. Dawson

And Appendix Thereto



TABLE XXX

cq
8

Number & T itles of Books under E ach Classification in L ibraries of W ashington-Lee and Hoffman-
Boston Schools, Arlington County, Virginia

Dewey-Dec.
Number

000
100
200
300
400
500
600
700
800
900

WASHINGTON LEE
Classification No. Vol.

General Works 423
Philosophy 81
Religion 52
Sociology 939
Language 112
Science 563
Useful Arts 877
Fine Arts 422
Literature 1000
History, Travel, Biography 2013
Fiction 2200
T otal-7 -1 2  Grades 8682
Elementary

HOFFMAN-BOSTON
Dup. No. Vol. Dup.

128 7
d 10
bSo 4
S 134 13Q
ft* 40o 52 4
ocr 109 9ft-P 45
B' 54 13
BoCTQ 112 3
B 389 13
aC/3 1077 62

211



t 3 3 3  J

TABLE XXXVII

Courses a Student Has an Opportunity to 
Take in a Three-Year Cycle, 

Washington-Lee and Hoffman-Boston 
Senior High Schools,

Arlington County, Virginia

Washington-Lee 
English IIs 
English IIIs 
English IVs 
Speech I 
Speech II 
Journalism I 
Journalism II 
Trigonometry *
Algebra IIs 
Plane Geometry®
Solid Geometry 
Commercial Arithmetic 
General Mathematics 
Civics2
Problems of Democracy2 
American History® 
Economics 
World History 
Economic Geography 
Latin American History 
Chemistry®
Physics®
Biology®
Latin I 
Latin II 
Spanish I®
Spanish II®
French I3®
French IF®
Commercial Law 
Business Correspondence 
Bookkeeping

Hoffman-Boston 
English II®
English III®
English IV®
American History*
Civics and Social Problems2 
Physical Education1*

(Each year)
Biology*
Chemistry*
Physics*
General Science — Advanced 
Algebra I 

(Each year)
Algebra II®
Plane Geometry® 
Trigonometry®
Spanish I®
Spanish II®
French I*
French II®
Social Studies2 
Home Economics I 
Home Economics II 
Home Economics III 
Shop I*
Shop II*
Bricklaying
Typewriting*
Shorthand
Music* (Each year)
Art* (Each year)
Home Nursing®

(Continued on next page)



[ 334 ]

(Table XXXVII, concluded)

W ashington-Lee Hoffman-Boston
Shorthand’*
Typewriting*
Mechanical Drawing 
Fine Arts 
Art: Appreciation 
Commercial Art 
Music*
Music Appreciation 
Washington-Lee 
Mixed Chorus 
Glee Club — boys 
Glee Club — girls 
Shop — Special*
Shop — General*
Auto Mechanics 
Machine Shop*
Printing 
Sheet Metal*
Woodworking*
Retail Sales 
Consumer Buying 
Home Economics I*
Home Economics II*
Home Economics III*
Cadets — boys 
Cadets — girls 
Cadet Band 
Orchestra 
Driver Training 
Home Nursing*
Physical Education* 1 2 3 4

1. No credit toward graduation in the subjects.
2. Civics and Problems of Democracy are in reality covered in Social 

Studies and Civics and Social Problems.
3. Only one year of French was offered in 1948-49.
4. Units in this work are taught in the Hoffman-Boston School ta 

the general shop to fit the needs of individual students.



TABLE XXXIX
Club and Activity Programs in W ashington-Lee and Hoffman-Boston High Schools, Arlington County,

Virginia, 1948-1949
W ashington-Lee 

* Boys’ Glee Club 
“Gills’ Glee Club 
“Mixed Chorus 
“Junior Girls’ Glee Club 
“Orchestra 
“Band
“Boys’ Cadet Corps 
“Girls’ Cadet Corps 
Honor Society 
Student Council 
Student Newspaper Staff 
Year Book Staff 
Dramatics 
Hi-Y Organizations 
Tri-Y Organizations 
Bible Club 
Various Subject Clubs 
Football 
Basketball 
Baseball 
Track 
Crew 
Golf
“Important: Curricular subjects

Hoffman-Boston  
Student Council 
Student Safety Patrol 
Junior League
Music Club (Vocal and Band)
Dramatic Club 
Athletic Club 
Honorary Society 
Science Club 
Arts and Crafts Club 
Business Club 

NOTES:
1. These clubs were sponsored by separate teachers.
2. They were operated during the activity period.
3. The small number of clubs is in keeping with 
the small enrollment.

in the schedule. These subjects carry credit.



TA B LE  X X X X

Summer Programs of Instruction, W ashington-Lee and Hoffman-Boston Senior High Schools,
Arlington County, Virginia, 1948-49

W a s h in g to n -L e e
English at all levels for Sr. High School 
Mathematics at all levels for Sr. High School 
Civics
Problems of Democracy
World History
Economic Geography
Biology
Spanish
Shorthand
Typewriting
American Historv

Hoffman-Boston
No senior high school pupil expressed a desire to 
enroll for summer school classes.



APPENDIX H
1, L ist of Subjects T aught by Grades and Number of Pupils E nrolled in E ach Subject, W ashington

Lee and Hoffman-Boston Senior High Schools, Arlington County, Virginia, 1948-49.

No. of Pupils
Subject Grade 10

46- 47- 48-
47 48 49

English 658 686 710
Speech
Journalism

16 24 50

Trigonometry 
Solid Geometry
Algebra, Adv. 
Geometry, Plane 396 433 439
Comm’l. Arith. 213 211 223
Gen. Math. Adv. 
Civics

32

Prob. of Democracy 
American History 
Economics
World History 83 108 115
Econ. Geography 
Latin Amer. Hist.

149 168 115

Chemistry
Physics

SHINGTON-LEE 
No. of Pupils No. of Pupils

Grade 11 Grade 12
46- 47- 48- 48- 47- 48-

47 48 49 47 48 49
496 425 594 437 470 481

17 24 48
10 6 12 10 7 13

28 30 49
54 51 86

402 302 335

224 227 239
175 228 244

367 536 632
53 47

22 17 29
202 183 228

136 120 149
(Continued on Next Page)

HOFFMAN-BOSTON 
No. of Pupils No. of Pupils No. of Pupils

Grade 10 Grade 11 Grade 12 
48- 47- 48- 48- 47- 48- 46- 47- 48-

47 48 49 47 48 49 47 48 49
2 14 31 1 5 18 9 1 5

2 1 18 9 5

14 5 1
1

13 5

18 5



APPENDIX H-Ccmtinued
1. L ist of Subjects T aught by Grades and Number of Pupils E nrolled in E ach Subject, W ashington-

Lee AND HOFFMAN-BOSTON SENIOR HlGH SCHOOLS, ARLINGTON COUNTY, VIRGINIA, 1948-49.

WASHINGTON-LEE HOFFMAN-BOSTON
No. of P upils No. of P upils No. of P upils No. of Pupils No. of Pupils N o. or P u p ils

Subject Grade 10 Grade 11 Grade 12 Grade 10 Grade 11 Grade 12
46- 47- 48- 46- 47- 48- 48- 47- 48- 4 6 -  47- 48- 46- 47- 48- 4 6 -  4 7 - 4 5 -

47 48 49 47 48 49 47 48 49 47 48 49 47 48 49 47 48 49

Biology 418 533 536 14 5 1
Latin 186 146 179 20 20
Gen. Science, Adv. 31
Spanish 170 221 229 19 8 1
French 45 27 44 20
Cormn’i. Law 28 24 33
Business Corresp. 30 30 26
Bookkeeping 88 76 125 30 23
Shorthand 157 107 131 30 40 40 22 22 15
Typewriting 235 289 342 130 116 114 22 20 15 2 14 21 5 10 9 1 7
Mechanical Draw’g. 70 13 99 30 13 20 35 26 12
Fine Arts 70 88 23 19
Art Appreciation 5 4 8 5 4 8 5 4 8
Comm’l. Art 36 36 50
Music 13 14 14 12 13 14
Music Apprec’n. 6 10 15 5 7 9 6 6 9 £ A
Mixed Chorus 20 10 15 30 20 28 33 13 21 8 5 4

Glee Club, Boys 4 5 7 14 15 14 16 15 15
(Continued on Next Page)



WASHINGTON-LEE HOFFMAN-BOSTON

APPENDIX H—Concluded

1. L ist of Subjects T aught by Grades and Number of Pupils E nrolled in E ach Subject, W ashington-
Lee and Hoffman-Boston Senior High Schools, Arlington County, Virginia, 1948-49.

No. of Pupils No. of Pupils No. of Pupils No. of Pupils No. of Pupils No. of Pupils
Subject Grade 10 Grade 11 Grade 12 Grade 10 Grade 11 Grade 12

46- 47- 48- 46- 47- 48- 48- 47- 48- 46- 47- 48- 46- 47- 48- 46- 47- 48-
47 48 49 47 48 49 47 48 49 47 48 49 47 48 49 47 48 49

Glee Club, Girls 20 20 19 15 16 17 15 14 15
Shop, Special 5 3
Shop, General 4 9 5 5 3 1
Auto Mechanics 20 18 £1 17 14 18
Machine Shop 13 27 21 8 24 18
Print Shop 14 15 15 10 14 15
Sheet Metal 16 15 15 14 14 14
Wood Shop 16 13 17 11 13 14
Retail Sales 26 43 26
Consumer Buying 38 70 71
Home Economics 40 30 70 19 11 7 5 6 2 10 10 I 4 6
Cadets, Boys 50 45 40 65 67 68 60 63 52
Cadets, Girls 15 17 12 30 31 21 30 27 19
Cadet Band 10 8 9 16 13 15 14 10 13
Orchestra 6 7 12 6 8 9 6 7 8
Driver Training 16 14 9 12 10 7
Home Nursing 24 12
Phys. Eduea’n, 485 488 872 2 14 31 1 5 18 9 1 5



[ 3 40  J

Excerpt From Plaintiff’s Exhibit 94

' “REPORT OF PRINCIPAL, JUNE 10, 1949”

To The Joint Committee For Control of (Manassas) 
Regional High School

Page 1:

1. A resolution passed at the regular meeting of the 
Committee in April has met with disfavor on the part 
of both teachers and citizens in the adjoining coun­
ties. I was instructed in a letter dated April 7, 1949 to 
pass this resolution on to the teachers. The resolu­
tion follows: “Re it resolved by the Manassas Regional 
High School Joint Committee for Control that the gen­
eral policies for the administration of the Manassas 
Regional High School are in conformity with the pol­
icies of the Prince William County School Board in its 
operation of schools located within the same county as 
the Manassas Regional High School and that these 
policies specifically dictate that the salary schedule of 
the Manassas Regional High School shall be the salary 
schedule of the Prince William School System.

E xc er pt  fr o m  P l a in t if f ’s E xh ibit  99

“A Comprehensive Program of Education for 
Virginia’s Public Schools”

Pages' 6 -7 :



1 341 J

* * * * *

Optimum Size o f High School

From an analysis of the comprehensive program of 
high school education, it is accepted that the breadth 
and variety of offering required for this comprehensive 
program and the staff needed to administer and teach 
it can be provided with maximum efficiency and econ­
omy both educationally and financially in a high school 
of approximately 600 to 1,200 pupils. As enrollments 
decrease within the range from 1,200 to 600, the finan­
cial ability of most counties and cities is such that the 
gradually increasing per capita costs of education can 
be met. In the small high school man power is wasted, 
and it becomes impracticable to provide a comprehen­
sive offering both from an educational and economical 
point of view. As enrollments fall below 600, the evi­
dence shows that the per capita costs of comprehensive 
programs increase in about the same proportion that the 
enrollments decrease, resulting in limited offerings, at 
excessive per capita costs. This is illustrated graphically 
in the chart on page 6-a.

It seems clear that the larger the school up to 1,200 
the better the opportunity to provide an adequate pro­
gram, and the advantages of the 600 to 1,200 pupil 
high school are obvious; however, it is recognized that 
in some smaller counties and in other counties on ac­
count of topography and distribution of population, as 
well as present locations of substantial buildings, ex­
ceptions to the enrollment goals above will be necessary 
and under these conditions smaller high schools should 
be operated.



[ 342 1

It should be noted, however, that the costs of com­
prehensive offerings in high schools of small enrollments 
— for example, from 200 to 300 or 400 — are such that 
limited programs will result. It is recognized, never­
theless, that some of the smaller counties even after 
consolidations will have high schools in this enroE- 
ment range on account of the factors presented in the 
foregoing statements. While these schools will be in 
aH probability unable to provide complete comprehen­
sive offerings, they can provide greatly improved pro­
grams over the existing offerings in the smaller high 
schools.

* *



1 343 1

(R. p. 1277-1301)

OPINION OF THE COURT.

The complaint here is that in their operation of the 
public schools the School Board and Superintendent 
of Schools of Arlington County, Virginia, have discrim­
inated against Negro students by failing to provide 
them, solely on account of their race or color, with 
facilities and opportunities for high school education 
equal to those furnished the white students. It is a 
class suit — on behalf of all Negroes of high school age 
residing in the county — and jurisdiction of the Fed­
eral court is predicated on an averred denial of the due 
process and equal protection clauses of the Fourteenth 
Amendment. Appropriate relief is prayed by way of a 
decree declaratory of their rights and an injunction 
restraining a continuance of the alleged deprivations.

This action was commenced on September 4, 1947, 
but for good cause, on agreement of the parties, it was 
continued from time to time and the trial was not com­
menced until September 6, 1949. By the original com­
plaint, as amended October 15, 1947, Constance Carter, 
the plaintiff, alleged that she was a person of African 
descent, a resident of Arlington County, State of Vir­
ginia, and an infant of school age required by the laws 
of Virginia to attend the public schools. She charged 
that in September 1947, being eligible to enter, she 
sought registration in the high school designated for 
Negro pupils in Arlington County and requested en­
rollment, in addition to the required courses, for the 
elective courses of Spanish, Civics III, Typewriting and 
Physical Education, but that she was advised by the



[ 344 ]

principal of the high school that no course in Spanish 
or Civics II was offered, that typewriting could not be 
offered because, though machines were available, there 
were no tables or desks for the purpose, and that no 
course in physical education was provided. Thereupon, 
she avers, she applied to the high school in Arlington 
County set apart for the white children, to take the 
courses desired by her and then afforded there, but 
that she was denied admission by reason of her race or 
color only, pursuant to the mandate of the Constitu­
tion and statutes of Virginia segregating the races in 
the public schools. The defendants, who are the legal 
authorities for the establishment, maintenance and 
operation of the public schools in Arlington County, 
are charged with pursuing, and having over a long 
period of years pursued, a policy, custom and usage 
discriminatory against the negroes, solely on account 
of their race or color, in providing educational facilities 
for colored high school pupils in the County.

The defendants deny any difference in the facilities 
for the white and colored high schol children, they 
deny any discrimination whatsoever, and they especial­
ly deny that any disparity in the facilities is due to 
race or color, or to an intent, purpose or policy of 
discrimination. They traverse categorically the allega­
tions that Constance Carter was refused any of the 
courses she sought; they say she was expressly told 
that the coures mentioned in her inquiry would be 
taught, and that any other course would be given as 
and when qualified students required them.

During the course of the trial Constance Carter mar­
ried and withdrew from school. With the consent of 
die defendants, intervention was permitted of two in-



[ 8 4 5  ]

fanfc colored high school students, Julius Brevard and 
Peggy Council, both residents of Aldington County, 
Virginia. Their petition simply nominated the inter­
veners as specific plaintiffs to prosecute the suit for 
the class and sets forth their own experiences in un­
successfully seeking courses of instruction at Hoffman- 
Boston. Brevard averred that he desired to take auto 
mechanics in the colored high school but that it was 
refused him as not offered, although it was available 
in the high school for white children. Peggy Council 
says that she asked for courses in Latin, Chemistry and 
Shorthand Reporting, but that they were not obtain­
able, although taught in the white school.

Generally the discrimination is charged in the phys­
ical equipment, such as buildings, teaching tools and 
recreational areas, as well as in the curricular offer­
ings and the qualifications of the intructional staffs. 
We pass to a consideration of each of them.

C omparative H igh School Population

Perhaps the outstanding fact in this case is that for 
the last three sessions the white high school has had an 
average of 1800 students and the colored high school 
26.

There are but two high schools in Arlington County. 
The white high school is the Washington-Lee High 
School and the colored is the Hoffman-Boston High 
School.

Both house junior high school classes in addition to 
the senior high school, the latter comprising Grades 
10, 11 and 12. Hoffman-Boston also includes element­
ary classes, but the total school population there, for 
elementary, junior and senior high school, is less than



[ 3 4 6  J

300. Washington-Lee has no elementary pupils and its 
total population, junior and senior high school, is 
about 2300. These figures are the school populations 
for the sessions 1946-47 and 1947-48. There was no 
substantial change in the 1948-49 session in the white 
school, but for that year the high school at Hoffman- 
Boston increased, from 12 to 18, in the two prior school 
years, to 48, of whom 13 were boys and 35 were girls, 
but during the two previous years there were only 3 
boys in high school.

School P lants

The photographic exhibits placed in evidence are 
accurate and most informative. Their accuracy was con- 
armed by a personal inspection by the judge of this 
court of the buildings, rooms and grounds of each 
school.

Hoffman-Boston is a two-story brick building erect­
ed in 1923 with additional class rooms added in 1930, 
and a separate temporary structure for elementary 
classes was put up in 1948. A vocational building, a 
few yards distant from the main building, was con­
structed in 1941.

Washington-Lee likewise consists of a brick build­
ing and a separate shop building. The main building 
is of three stories and was put up in 1925. Additions 
came in 1932 and 1935. The separate shop building 
was not available until 1942.

Hoffman-Boston has grounds of about 6 acres, for its 
300 students, and Washington-Lee has approximately 
12 acres for 2300 pupils. The latter is located in or 
near the commercial zones of Arlington County (an 
almost urban county) and consequently is adjacent to



[ 3 4 7  1

streets and business traffic arteries. Hoffman-Boston is 
in the southern end of the County adjoining the golf 
links of the Army-Navy Country Club, removed from 
business and industry, and is sited on an eminence 
overlooking the Shirley Highway and the approaches 
to the Pentagon Building and the City of Washington.

The buildings of both schools are in good repair and 
condition and are well maintained.

C om pa ra tive  E xpenditures

While it is not a decisive factor because of the great 
divergence in the population of the two schools, the 
per pupil expenditures for the two schools is signifi­
cant in a search for discrminatory neglect.

For the sessions of 1946-47 and 1947-48 more than 
twice as much was expended, per senior high school 
student, for teachers’ salaries, in the Hoffman-Boston 
than in Washington-Lee. During these sessions the 
amount paid per pupil for the operation and mainten­
ance of Hoffman-Boston was 2M or 3 times that for 
Washington-Lee. During the last session, 1948-49, tire 
difference was not so great in the per pupil teachers’ 
salaries, because of the increase in tire number of Negro 
students in the high school, but iir that year the main­
tenance of the schools per pupil was $3.52 for Wash­
ington-Lee and $76.67 for Hoffman-Boston.

The expenditures for other facilities is worthy of 
note. In 1947-48 Washington-Lee received for library 
books $912.00 against $150.00 for Hoffman-Boston, 
while in the school year just past the expenditures for 
the same purpose were $1038.00 at Washington-Lee 
and $735,000 tor Hoffman-Boston. For shop and similar 
equipment $800.00 and $2200.00, respectively, was laid



[ 3 4 8  1

out in each of the last two sessions for Washington-Lee, 
and at Hoffman-Boston, $200.00 and $1500.00. For 
commercial instruction equipment at Washington-Lee 
$500.00 was expended in 1947-48 and $250.00 at Hoff- 
man-Boston. Moreover, the capital investment figures 
at each school shows an average for the last three 
sessions for each high school pupil to be $721.00 for 
the colored and $417.00 for the white student.

I n terio r  F a c il it ies  o f  B uildings

The class rooms of the two schools are comparable 
in every way. Inspection was made of all the lavatories 
and toilets, and they were found to be sanitary and 
modem in both schools.

Each school has an auditorium. The one at Wash­
ington-Lee is much larger but it will seat at one time 
only about half of the student body. Because of the 
permanency of its seating arrangement, it can be used 
for no other purpose. At Hofiman-Boston the auditor­
ium is not as extensive and is simpler in design, but 
is well appointed and apparently quite adequate. It 
will accommodate at one time all of the junior and 
senior high school students of the school. It is none­
theless interior because its seats are not fixed theatre 
seats but are movable. Indeed, it is for this reason more 
valuable, being convertible to other and numerous 
purposes requiring unoccupied floor space.

At Washington-Lee there are two gymnasiums. One, 
used by Lie giris, is a recessed extension of the stage 
ot the auditorium, but equipped with sliding parti 
tions between tnem. It was planned so as to allow oc­
cupants ot trie auditorium to witness activities on the 
floor of Lie gymnasium, but this has not proved prac­



1 S49 1

ticable. The level of the auditorium seats is too low 
to permit a full view of the gymnasium. Separate and 
simultaneous use of the gymnasium and the auditorium 
is not possible because the noise from the gymnasium 
interferes with the program on the stage of the audi­
torium. The gymnasium floor is not large enough to 
allow room for a regulation basketball court, but is 
used for basketball and affords space for gymnastic 
equipment. There are showers for the participants. The 
other gymnasium is used by the boys and is sufficient 
for basketball or similar games, although not large 
enough for a regulation basketball court.

At Hoffman-Boston there is no separate gymnasium. 
The auditorium, by the removal of the seats, is convert­
ible for use in calisthenics and such other uses as 
the small high school student body could make of 
a gymnasium. Mats and other gymnastic equipment 
are furnished. However, the structural columns in the 
room interfere with ball games and it contains no courts 
for them. There are no showers. It does not have the 
advantage of giving an area for recreation and phys­
ical education every day to all the students, which is 
not obtainable by the Washington-Lee students, as its 
gymnasiums can receive not more than haif of the 
students each day, and only half of the students can 
receive physical education. However, the Hoffman-Bos­
ton gymnasium is not adequate and will be discussed 
again.

Home economics instruction facilities are far better 
at Hoffman-Boston than at Washington-Lee. Indeed, 
at the latter no real provision is made for this course in 
respect to sleeping, living and dining-room facilities.

Washington-Lee has a room for choral music, accom-



[ 3 5 0  3

modating 63 persons, and one for instrumental instruc­
tion, having a capacity of 50 students, while Hoffman - 
Boston music classes meet in its auditorium for choral 
and instrumental music, and some music classes are 
held in a small class room, formerly occupied as an 
office by the principal. The auditorium and. class room 
in Hoffman-Boston provide accommodations equal to 
the special rooms in Washington-Lee, and considering 
again the difference in the number of students, the ad­
vantage is in favor of Hoffman-Boston.

Library space and equipment in each school are most 
acceptable. The space at Washington-Lee is more ex­
tensive that that at Hoffman-Boston, but still again 
the smaller demand at Hoffman-Boston gives each of 
its students greater opportunity to use the library.

The libraries of both schools contain general works, 
and books on history, sciences, biography, and other 
appropriate subjects. Both have current periodicals and 
newspapers. Washington-Lee has far more volumes in 
number, and a greater variety of newspapers and per­
iodicals, but the defendants are ready to provide any 
book, newspaper or periodical required or desired at 
Hoffman-Boston.

Perhaps the facility most disputed is the shop room 
space and equipment. Each school has a separate build­
ing for the teaching of the industrial arts. Washington- 
Lee has separate shop rooms for automobile mechanics, 
machine work, and printing as well and woodwork. 
Hoffman-Boston has all of this, save automobile me­
chanics and printing, in one shop. It is in a separate 
building, and is well equipped and capably staffed 
Bricklaying is available at Hoffman-Boston but not at



[ 3 5 1  1

Washington-Lee. We will later discuss the absence of 
auto mechanics and printing at Hoffman-Boston.

A cafeteria exists at Washington-Lee, while none is 
at Hoffman-Boston. This may well be accounted for 
by the difference in the demands therefor by reason 
of the disparity in the school populations, and it is 
doubtful that a cafeteria is needed. There is none in 
one of the county’s latest white junior high schools.

E xterio r  F a c ilities

Hoffman-Boston has no football field or baseball dia­
mond, stadium or running track. Its student body of 
3 boys in the sessions 1946-47 and 1947-48, and 13 in 
the session 1948-49 would not support such teams. It 
does have outdoor basketball courts, soft ball diamonds, 
horseshoe pitching grounds and areas for other play. 
The grounds of one school compare favorably with that 
of the other in appearance and maintenance, but the 
grounds at Hoffman-Boston should be further graded 
and trimed.

H ea lth  Supervision

Each school has the services of a health nurse. Wash­
ington-Lee has an infirmary, but Hoffman-Boston none. 
The latter has dental inspections while Washington- 
Lee has none, and each school provides for physical 
examination, and sight and hearing tests.

T eachers

Teachers’ salaries in Arlington County are among, 
if not, the highest in the State. The compensation of 
teachers of white and colored teachers is on the same 
basis. If the teachers of the white school are paid more



[ 352  J

than in the colored school, it is because the former 
have experience. They are not selected because of 
greater experience, but greater experience is more read­
ily found among white teachers because the Negroes 
have devoted their time to this profession from as 
early a date as have the white population.

As to the respective qualifications of the white and 
Negro facilities, it is to be observed that in the Negro 
schools no teacher is without a baccalaureate degree, 
while in the Washington-Lee High School almost 10% 
of the teachers are without such degree. Each white 
teacher must daily instruct about 15% more pupils than 
the colored teacher.

In Washington-Lee nearly all teachers instruct in 
but a single subject. At Hoffman-Boston a teacher may 
give two or three subjects. Sound argument can be 
made for the advantages of both. For the first, specia­
lization is said to lead to expertness; for the latter, co­
ordination of the several subjects is said to be gained. 
This difference in method has not been shown to result 
in a difference in teaching results in the two schools.

N atural Scien ce  F a c ilities

Each school teaches biology, chemistry and physics. 
Washington-Lee has a greater quantity of equipment. 
It has several science rooms. Hoffman-Boston has am­
ple equipment and, although it is in a single science 
room, it affords facilities equivalent to those at Wash­
ington-Lee.

Curricula

The course of study offered in each school at the 
present time is such as to place them both on the ac­



[ 353 ]

credited list of the Virginia Department of Education. 
The Hoffman-Boston School was not so accredited un­
til the session of 1948-49. The Southern Association of 
Colleges and Secondary Schools, a voluntary organiza­
tion setting up standards of education, has approved 
the Washington-Lee diploma. This body has not yet 
approved the Hoffman-Boston School and application 
has not been made for such approval. Apparently it is 
now eligible for approval.

There are many subjects taught at Washington-Lee 
that are not taught at Hoffman-Boston. However, the 
evidence conclusively shows that there are no courses 
requested or desired at Hoffman-Boston which have 
not or will not be provided. The method of ascertain­
ing what subjects should be taught at Hoffman-Boston 
is practical and approved by educationists. It includes 
a survey, made in the spring of each year, to ascer­
tain what subjects will be desired for the following 
session. This survey is accomplished by issuing inter­
rogatories to the students then in attendance asking 
what will be desired by them for the next session, by 
inquiring of the curricular demands through public 
meetings of parents, such as parent-teacher associa­
tions and similar organizations, and by making inquiry 
in any other known fields.

Any course found needed is provided. The school au­
thorities have adhered to this practice in the past and 
now vouch in this case their willingness to meet in 
the furture any demand for any high school course.

The specific demand made by the named-plaintiffs 
may well now be discussed.



[ 3 54  ]

Applica tio n  o f  C onstance C a rter

According to her mother’s testimony, Constance Car­
ter, the original plaintiff, applied in September 1947 
to take Spanish, civics III, typewriting and physical 
education at Hoffman-Boston but was told they were 
not available to her. Actually, all of these courses were 
given in the session 1947-48. The principal denies that 
she was in fact refused them, but he says she would 
have been refused civics III because it was for advanc­
ed students only. Although present in court, Constance 
Carter did not testify to corroborate her mother. The 
principal says that he understood the application to 
include physics III (and the complaint here first alleg­
ed physics III)  and he advised that the physics course 
was not available. She then matriculated in a Wash­
ington, D. C. school, for the first semester so she could 
take the desired courses, but she seems not to have 
taken them there. She returned to Hoffman-Boston for 
the second semester.

Applica tio n  o f  Peggy C ouncil

This intervenor entered Hoffman-Boston as a 11-A 
student in February 1949. She says she unsuccessfully 
applied, on September 6th of this year, to take Latin, 
chemistry, shorthand, and typing. She was then an 11-B 
and eligible to take three of them only. There was a 
teacher ready and qualified to teach Latin, but as Peg­
gy Council had not signified her intention, upon the 
interrogatory given her for the purpose last May, to 
take Latin this session, and as no other student had 
asked for it, Hoffman-Boston did not intend to give 
Latin, and for these reasons the principal informed her 
it was not available. Shorthand and typing both are



t 355 ]

being given. Typing has been offered for several years. 
On the first day of school it was thought that short­
hand should not be given until the students had com­
pleted their typing courses. However shorthand is now 
offered. Chemistry is given in alternate years. It was 
given last year, but this year instead there will be bio- 
logy, botany and physics. Although chemistry was list­
ed as available for this year, Peggy Council did not 
check it as desired when last May she made out a card 
of the courses she wished this session. At Washington- 
Lee no course is offered unless as many as eighteen stu­
dents ask for it.

Applica tio n  o f  J ulius B revard

This young man testified that on the second day of 
this trial, which was the second day of school, he ask­
ed the principal of Hoffman-Boston if he could take 
auto mechanics and was told it was not to be had. The 
principal testified that the inquiry was made of him 
casually “in a transit period”, when he was moving 
from the classrooms to the office, and the request was 
never pressed seriously or discussed with him in his 
office, and he had had no opportunity to discuss the 
matter with Brevard so as to give a final decision. The 
Assistant Superintendent stated that the principal could 
not give the final answer on such a question and it had 
not been brought to his office by the student or his 
parents. Apparently the request was never seriously 
pressed. No other student had ever sought the course. 
It cannot be said that this course has been denied Bre­
vard.



I 356  ]

P a s t  R e c o r d  o f  O fferin g s

As demonstrating the fulfillment by the Hoffman- 
Boston School of the real demands of its students, the 
following uncontroverted testimony is enlightening,

Hoffman-Boston's Negro principal was questioned 
and answered as follows:

“Q. I now ask you whether or not you have 
ever received a request from any qualified student 
for any course that you have not been able to 
give prior to the current years teaching, that is 
to say, the year that began this week, and, if there 
are any exceptions, you may state the exceptions,

“A. I may not remember all but I think there 
has been one. I know there has been one,” (He 
then named electrical engineering as having been 
asked and refused, no high school offering it as 
a course.)

The Assistant Superintendent of Schools testified:

“Q. With the exception of the Davis case which 
you have just mentioned, will you state whether or 
not any course has been denied to any qualified 
colored student who requested it in the Arlington 
County school system, if that course was available 
in the white schools?

“A. Up until today, not to my knowledge.”
Davis’ was a request for a vocational course not given 

at Hoffman-Boston and he was placed at the Manassas 
Negro Vocational School in accordance with his wishes.

Explanation was made that, with the instant suit 
on trial and the school authorities in court during the



[ 357  ]

first days of the session, the final curriculum at the 
schools of the county had not been finally settled for 
the session 1949-50 at the time the witnesses testified 
or when students Council and Brevard registered.

Offering With No Applica tio n s

The plaintiffs take the postion that if there are to 
be two high schools in Arlington County, one for the 
white and the other for the colored children, then 
constitutional equality demands that the colored school 
offer every course available in the white school, wheth­
er or not there are applicants for it. Therefore, they 
urge that it is discrimination if Hoffman-Boston does 
not make available every item of the Washington-Lee 
curriculum. This view is likewise advanced as to facili­
ties.

In respect to both courses and facilities it is press­
ed to the extent of earnestly contending that the same 
and identical courses and facilities must, to avoid dis­
crimination, be provided at each school, and that they 
must be offered although there may be no applicants 
for their study or use. For instance, that a faculty and 
organization for a summer school should have been 
provided at Hoffman-Boston, although its students 
were actually invited to register for the summer quarter 
and none applied; that teachers for such a summer 
course should have been sent to the rooms, and waited 
daily, until a possible student presented himself; that 
a teacher and a room should be ready at Hoffman- 
Boston for every course taught at Washington-Lee, no 
matter no pupils; that there should be a cadet corps 
at Hoffman-Boston High School, because there is one 
at Washington-Lee, although Hoffman-Boston High



[ 358 ]

School students consisted of only 3 boys and 9 girls in 
the 1946-47 session, 3 boys and 15 girls in 1947-48 and 
13 boys and 35 girls in the session of 1948-49; that the 
failure to have a football team among the boys during 
those years was evidence of discrmination, as was the 
failure to maintain a football field and stadium. These, 
it is said, are logically the burdens unseverably attach­
ing to segregation.

The Court does not believe that the failure of Hoff- 
man-Boston to make empty offerings is discrimination. 
Deprivations falling within the prohibition of the Four­
teenth Amendment must be actual as well as logical.

RECAPrruLATioN o f  Advantages and D isadvantages

The evidence shows that each school has some ad­
vantages over the other, and each school has disad­
vantages not suffered by the other, but a summary of 
them discloses that Hoffman-Boston and Washington- 
Lee give substantially the same treatment to each of 
their high school students.

Washington-Lee offers courses in auto mechanics and 
printing; Hoffman-Boston does not. Hoffman-Boston 
gives a course in bricklaying, Washington-Lee does not. 
The home economics instruction facilities at Hoffman- 
Boston far exceed the correponding facilities at Wash­
ington-Lee.

Hoffman-Boston offers physical education to all of its 
high school students, but none is offered at Washing­
ton-Lee to the students of the 11th and 12th grades; 
some 900 in number.

Washington-Lee is so overcrowded that its corridors 
must be made into one-way-traffic arteries; study hours 
there must be spent in the rear rooms then being used



[ 359  ]

for class instruction; Hofiman-Boston has no such over­
crowding.

At Hoffman-Boston two teachers of physical educa­
tion are provided for 375 children, while at Washing­
ton-Lee four must handle 1100 children.

The library at Hoffman-Boston will accommodate 
all of its senior high school at one time, while at Wash­
ington-Lee only 6% or 7% of its students may be so 
accommodated. Thus the student at Washington-Lee 
has very limited library access, but the Hofiman-Bos­
ton student has easy and unrestricted enjoyment and 
benefit of the library.

Again, the sizes of the classes at Hoffman-Boston are 
far more favorable. As an average Hoffman-Boston has 
between 20 and 25 to a class; at Washington-Lee a 
great many of the classes contain more than 35.

As we have already explained, the location of Hoff­
man-Boston is by far the better, having no constant 
traffic hazards as does Washington-Lee. The grounds 
are more spacious at Hoffman-Boston for each student, 
the available play ground greater.

It is fair to say that in classroom instruction the op­
portunities and facilities offered to the high school stu­
dent at Hoffman-Boston are greater than those provid­
ed at Washington-Lee. This is because, with the phys­
ical equipment equal, the Hoffman-Boston boy or girl 
receives a more individual instruction, enjoys a closer 
personal relationship to the teacher, is subject to a clos­
er study by the teacher for counsel and guidance, and 
receives instruction under coordination and corre­
lation of subjects, rather than through a department­
alized form of instruction too often delaying the real­
ization of the relationship of all subjects of study. Then,



[ 360  ]

too, at Hoffman-Boston the individuality of the pupil 
is not “lost in the crowd”. These are but the usual ad­
vantages to be gained from a school where the scholars 
are few.

No D iscrim in a tio n  E xists

Upon a review of all the evidence, as clarified by a 
view of the various faciliities of the two schools, the 
Court finds there is no discrimination. Certainly none 
has been proved by a preponderance of the evidence.

Segregation  as D iscrim in a tio n

It is said that, if the high school students of Hoff­
man-Boston were not forbidden by segregation to at­
tend Washington-Lee, they would not be denied the 
opportunities of a large-populated school, such as a 
cadet corps, football, baseball and other activities de­
pendent on numbers in a student body; that they are 
entitled to the opportunity whether or not availed of; 
and that the absence of opportunity due to size of 
school population, is actually due to segregation, which 
in turn Is based on race or color and therefore uncon­
stitutional.

We do not have to pass upon the question whether 
segregation is in itself discrimination, because as we 
have already pointed out, no discrimination in fact is 
found. A fortiori, none is based on race or color. Indeed, 
the advantage is with the Hoffman-Boston student for 
educational opportunity in the classroom. There are 
differences in the schools but they are only differences 
and nothing more. 1’hey exist between any two schools, 
whether for white students only, or for colored stu­
dents only, or for both races. They could spring from



[ 361 ]

a variance in size of schools, in the location of schools, 
or in the methods or manner of instruction, but such 
differences are not the discriminations outlawed by the 
Fourteenth Amendment.

The Court recognizes that neither the State constitu­
tion’s mandate of segregation, nor economy to avoid 
the greater expense arising from the duplication of 
facilities necessary for segregated education, can excuse 
discrimination. Equality of treatment is uncondition­
ally enjoined upon the State government by the Four­
teenth Amendment in favor of all its citizens. All citi­
zens must receive from the State in equal measure its 
protection and benefit. But neither the same nor simi­
lar treatment is commanded by the Amedment. Equal 
in its eyes means equivalent. It is obvious that identi­
cal treatment would not carry to every citizen equal 
protection or equal benefits under the law. The State 
has never been proscribed by the Fourteenth Amend­
ment from using different groups of its citizens, or 
from varying the form of its benefits, that every citi­
zen’s share may be equal in value.

However, if we must pass on the legal validity of seg­
regation, we find that segregation in the public func­
tions of the State, including education in public schools, 
is exclusively a State matter, and under the present 
decisional law of the Supreme Court, is not question­
able save to assure equality. The United States Court 
of Appeals for this Circuit has quite recently said so. 
Corbin et al v. County School Board of Pulaski (No­
vember 14, 1949).

Needs at H o ffm a n -B oston

Returning to the facts of the instant case, and it is



[ 362 ]

wholly factual, we say that undoubtedly the gymnas­
ium at Hoffman-Boston should be improved, showers 
put in, sufficient rest rooms for the male teachers in­
stalled, its corridor walls should be painted, its grounds 
improved, and perhaps a cafeteria added. It is per­
tinent here to notice that in November 1948, at the 
instance of the School Board, an issue of bonds was 
voted by the people of the county containing an item of 
$250,000.00 for the construction of a gymnasium, ad­
ditional shop facilities, infirmary, cafeteria, showers 
and rest rooms. This money will be used in accordance 
with plans already in hand for the erection and instal­
lation of these improvements.

But these, and similar inadequacies, are deficiences 
rather than discriminations. They are matters within 
the jurisdiction of the administrative branch of the 
state or county government. They are inadequacies or 
omissions that might be found existing in any school. 
They are not the result of discrimination. Such con­
ditions are to be corrected by appeal to the administra­
tive authorities.

It is clear from the evidence that there has been no 
intent, purpose or policy on the part of the defendants 
to neglect or discriminate against the colored schools 
of Arlington County. The unchallenged testimony that 
the elementary colored children are housed better than 
the white children of that class reveals an entire ab­
sence of intent to discriminate between the races in 
the schools. While “no intent” will not excuse actual 
disparity of treatment, if traceable to race or color, still 
just as truly, every inadequacy or insufficiency of pro­
vision in educational opportunities or other public fa­
cilities, is not discrimination, or evidence of discrimina­



[ 363 ]

tion, as denounced by the Fourteenth Amendment, A 
difference in provision may exist between the white, 
between the colored citizens, or between the white 
and colored citizens, without fouling the Amendment, 
if it is the result only of unattentive stewardship or 
faulty judgment or shortsighter planning by the respon­
sible authorities. These are defects of administration for 
administrative correction, not constitutional offenses for 
judicial interference.

R egional School at  M anassas

The defendants showed that the Regional Vocation­
al School, which is maintained by the Counties of Prin­
ce William, Fairfax and Fauquier, at Manassas, Virgin­
ia, some 20 or 25 miles from Hoffman-Boston, had en­
tered into an agreement with Arlington County to 
accept for matriculation in its vocational courses stu­
dents from Arlington County the evidence was that 
this arrangement would take care of both white 
and colored students desiring to undertake vocational 
courses not available in the Arlington County schools. 
By virtue of this agreement approximately 40 or 50 
white students have been entered there by Arlington 
County, and the defendants state that any student at 
PIoffman-Boston, not provided with the desired voca­
tional study, will be given the courses, at the entire 
expense of Arlington County, in the Regional School 
at Manassas. For the transportation of the students to 
and from the School the County will operate conven­
ient buses.

The plaintiffs contend that this is not an equal op­
portunity in respect to the course of auto mechanics 
and similar omitted courses, for the reason that the



[ 364 ]

courses are actually offered at Washington-Lee and only 
the overflow of its students are sent to Manassas, 
while at Hoffman-Boston no such courses are offered, 
even for one student.

Although the judge of this court visited and in­
spected the facilities for the Negro students at the Ma­
nassas School, and finds them to be equal to those at 
Washington-Lee, it is unnecessary to pass upon this 
question, because there has been no showing of a de­
nial by the Arlington County authorities of any such 
course to a Negro student.

In conclusion, we find that the evidence does not 
make out a case of discrimination. The complaint will 
be dismissed. This opinion is adopted by the Court as 
a statement of its findings of fact and conclusions 
of law.

#  *  #  *  *

(R. p. 1302-1303)

FINAL DECREE.

This cause came on to be heard upon the complaint, 
and amended complaint, of Constance Carter, and 
upon the intervening petition of Peggy Council and 
Julius Brevard, and upon the answer of the respond­
ents thereto, as well as upon the evidence offered by 
all of the said parties, and was argued by counsel.

Upon consideration, the Court, for the reasons set 
forth in its written opinion dated December 7, 1949 
and filed in this cause, finds that the allegations of 
the said complaint, as amended, and the said petition 
are not sustained by the evidence, and, therefore, it is



[ 365 ]

ORDERED by the Court, upon the findings of fact 
and conclusions of law made and stated by the Court 
in said opinion, that the said complaint, as amended, 
and the said petition be, and they are hereby, dismiss­
ed, that the defendants recover of the plaintiffs and 
petitioners their costs herein, and that this cause be 
stricken from the docket,