Defendant's Correction to Page 35 of Brief (Detroit Board of Education v. Bradley)

    No.72-8002

IN THE UNITED STATES COURT OF APPEALS 
FOR THE SIXTH CIRCUIT

BOARD OF EDUCATION OF THE SCHOOL 
DISTRICT OF THE CITY OF DETROIT, 
a school district of the first 
class,

Appellant,
v s .

RONALD BRADLEY, et al,
Appellees.

On appeal from the United States District Court 
For the Eastern District of Michigan 

Southern Division

CORRECTION TO PAGE 35
OF BRIEF OF APPELLANT BOARD OF EDUCATION OF THE SCHOOL 

DISTRICT OF THE CITY OF DETROIT, A SCHOOL DISTRICT 
OF THE FIRST CLASS AND OTHER DEFENDANTS * *

RILEY AND ROUMELL
*

George T. Roumell, Jr.
Louis D. Beer 
Jane Keller Souris 
Russ E. Boltz
C. Nicholas Revelos, Of Counsel 
720 Ford Building 
Detroit, Michigan 48226 
Attorneys for Appellants and 
certain other named Defendants



IN THE UNITED STATES COURT OF APPEALS 
FOR THE SIXTH CIRCUIT

No. 72-8002

BOARD OF EDUCATION OF THE SCHOOL 
DISTRICT OF THE CITY OF DETROIT, 
a school district of the first 
class,

Appellant,
vs.
RONALD BRADLEY, et al,

Appellees.
___________________________________________ /

CORRECTION TO PAGE 35
OF BRIEF OF APPELLANT BOARD OF EDUCATION OF THE SCHOOL 

DISTRICT OF THE CITY OF DETROIT, A SCHOOL DISTRICT 
OF THE FIRST CLASS AND OTHER DEFENDANTS

In doing a brief under the time constraints, there are 
bound to be some typographical errors. In our original Brief, 
there is one page in which the word,"contacts" was typed 
"contracts", which changes completely the meaning of the 
sentence. Therefore, we have included herein a new Page 35 
with the new corrected sentence which has been underlined. In 
other words, in the fifth line from the top of the page, the 
word "contacts" is now correctly typed.

Detroit, Michigan 48226 
Attorneys for Appellants and 
certain other named Defendants

ILEY AND ROUMELL

I!George Tl Roumell ,* th 
720 Ford Building

August 21, 1972.



#
In determining what part of the "substantial" but not 

principal role the Detroit Board played in causing the current 
condition or what link it had to other units of government, the 
only recourse is to the record. That record reveals rather 
limited contacts between the Board and the City Planning Commis­
sion, various model neighborhood agencies, the Urban Renewal 
Division and Department of Parks and Recreation of the City of 
Detroit, none of which involved the slightest segregatory purpose 
or effect. (Henrickson, de jure,Tr.3515-18) (App.IVa 113-116).

As to the role of the acts of the Detroit Board found to 
be v/rongful in causing the current condition of segregation 
Plaintiffs proferred to the Court their finding of fact which 
contained only the opinion testimony of several experts to the 
effect tnat all—Black and all—White schools tended to reinforce 
a feeling of separateness on the part of both races, which, in 
turn, manifested itself to some undefinable degree in the choice 
of residence in uniracial neighborhoods on the part of both races.

The mind boggles at the meaning of this assumed, unmeasured 
phenomenon against the standard of proximate cause. First, the 
findings of the District Court as to specific acts of discrimina­
tion relate to a relatively small proportion of the total school 
district: the construction of one specified elementary school, out
of a total school construction program involving a multitude of schools 
several instances of Black-to-Black busing; and the maintenance of six

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