Defendant's Correction to Page 35 of Brief (Detroit Board of Education v. Bradley)
Public Court Documents
August 12, 1972

3 pages
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Case Files, Milliken Hardbacks. Defendant's Correction to Page 35 of Brief (Detroit Board of Education v. Bradley), 1972. 6915ce68-53e9-ef11-a730-7c1e5247dfc0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/a0167ab0-3e1c-47fd-94d2-2c1138d9efe5/defendants-correction-to-page-35-of-brief-detroit-board-of-education-v-bradley. Accessed July 06, 2025.
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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 -35-