Watson v. City of Memphis Petition for a Writ of Certiorari

    IN THE UNITED STATES COURT OF APPEALS 

TAT IPLID TT] 
i o, Of 0 re Bo RE +, 

) 

) 

VS. ) NOS. 28030 - 28042. 

) 
COLUMBIA MUNICIPAL SEPARATE ) 

SCHOOL DISTRICT ) 

MOTION TO ALTER PROPOSED 

DESEGREGATION PLAN 
  

- 

Comes now Columbia Municipal Separate School District 

district heretofore ordered in this matter in accordance with 

fe the changes shown in "Exhibit A" hereto attached and made a 

- 1a 

part hereof the same as if herein recited in full, and in sup- 

Port thereof, shows unto the Court the following, to wit: 

l. The proposed changes will result in no delay in ac- 

complishing the Court's order. 

"2. The proposed changes will produce no less integration. 

3. The proposed changes will primarily require the shift- 

ing of the fifth grade from a grouping with the sixth and seventh 

grades at one physical plant to a grouping with the third and 

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fourth grades at another physical plant. 

4. The proposed changes are necessary and desirable 

because of unsatisfactory traffic conditions at the John J. 

by the Court. Also, the buildings of the John J. Jefferson 

School need renovating in order to satisfactorily function as 

elementary classrooms, but said buildings can be used to house 

and office counselors and nurses without such extensive reno- 

vation. 

 



  

Jefferson School are adequate for all students of the district, 

but these facilities at the Columbia High School are inadequate. 

It is planned to utilize the home economics and shop facilities 

Of the John J. Jefferson School for all of the students of the 

district and in order to do this, it would be advantageous to 

shift one of the grades scheduled for John J. Jefferson School 

6. The Columbia Elementary School has a larger play area 

than John J. Jefferson School and can better provide for the fifth 

better grouped with the third and 

fourth grades than with the sixth and seventh grades. 

Respectfully submitted, 

COLUMBIA MUNICIPAL SEPARATE SCHOOL 

DISTRICT 

3 
at 

Of Counsel 

  

  

Hall, Callender & Dantin 

Attorneys at Law 

P. 0. Box 604 

Columbia, Mississippi 39429 

Attorneys for Defendant 

" FTRMTTRT nm CERTIFICATE F 

  

I, Maurice Dantin, of counsel for the defendant, Columbia 

1 Separate School District, do hereby certify that I 

have this date personally delivered a true and correct copy of 

the above and foregoing motion to Mr. Ben Craig, attorney for 

the plaintiff, at the office of the Department of Justice, 

Milner Building, Jackson, Mississippi. 

THIS the 12th day of November, A. D. 1969. 

  

  

Of Counsel 

 



    
  

  
  

  
  

  

  

  

  

STUDENTS REGULAR TEACHERS REMEDIAL TEACHERS 

Grade White - Negro Total White Negro Total White Negro Total 

COLUMBIA PRIMARY SCHOOL 

(Number of Classrooms: 17 regular, 1 portable) 

I 168 S97 265 6 3 9 0 0 0 
2 132 82 214 4 = 6 3 0 x 

Totals 300 179 479 10 B 15 3 0 i 

COLUMBIA ELEMENTARY SCHOOL 

(Number of Classrooms: 16 regular, 3 portable) 
  

    
  

  

  

  

  

3 130 80 210 5 3 8 0 2 2 
4 138 69 207 4 2 6 3 0 i 
5 3.37 92 229 oh ; 2 vi 0 0 0 

Totals 405 241 646 14 7 21 3 2 3 

JOHN J. JEFFERSON 

(Number of Classrooms: 21) 

There are eight classrooms in another building which will be used for specialists— 
nurse, counselor, remedial teachers, and Teacher Corps interns 

6 133 58 191 5 2 7 3 2 3 
7 161 65 226 5 3 8 0 0 0 

Spec, Edu. 60 30 90 _4 fas ob 0 0 0) 
Totals 354 353 507 14 7 od. 1 2 3 

COLUMBIA JUNIOR-SENIOR HIGH SCHOOL 

(Number of Classrooms: 32) 

8 140 53 201 Departmentalized 

9 119° 73 191 Departmentalized 
10 111 52 163 Departmentalized 
11 106 59 165 Departmentalized 
12 89 48 137 Departmentalized 

Totals 565 293 857 27 33 40 

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.W. Plan, the fifth grade was scheduled to go to the John J. Jefferson 
. However, due to traffic problems and the condition of one of the build- 

on the John J. Jefferson campus, we would like to place all fifth grade stu- 
Columbia Elementary School campus for the remainder of this year. 

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EXHIBIT A.