Correspondence from Krasicky to Lucas with Correspondence from Porter to Krasicky

    L e o n  S. C o h a n  
Deputy Attorney General

F R A N K  J. K E L L E Y
A T T O R N E Y  G E N E R A L

LANSING 
4 8 9 1 3

February 28, 1972

Mr. Louis R. Lucas 
Suite 525Commerce Title Building 
Memphis, Tennessee 38103

Re: Bradley, et al v. Milliken, et al
Civil Action No. 35257

Dear Mr. Lucas:
Enclosed please find a copy of a letter of John W.

Porter, Superintendent of Public Instruction, responding to your 
questions addressed to the undersigned in our recent telephone 
conversation s I trust that this is the information that you desire.

I am in receipt of a copy of your letter to Judge Roth 
dated February 23, 1972. Dr. Porter informs me that the letter 
from the Center for Urban Affairs at the Michigan State University 
was received by his office on February 25, 1972 and because he was 
away on business in Washington, D. C., he first became acquainted 
with its contents on February 28, 1972. I have asked him to prepare 
a response thereto and we will communicate with you shortly.

Responding to the last paragraph of your letter of 
February 23, 1972, while the State Board of Education is a party 
to the above lawsuit, under jurisdiction of the court and subject 
to its appropriate orders, we must deny any constitutional obliga­
tion to prepare integration plans costing a quarter million dollars. 
Moreover, the State Board of Education has not been appropriated the funds so that it can perform the same.
Enc.
CC: Hon. Stephen J. Roth

Mr. E. Winther McCroom 
Mr. Nathaniel R. Jones 
Messrs. J. Harold Flannery 
Paul R. Dimona and 
Robert Pressman 

Messrs. Jack Greenberg and 
Norman J. Chachkin 

Mr. George T. Roumell, Jr.
Mr. Theodore Sachs 
Mr. Alexander B. Ritchie

Very truly yours,
A_^

Euge|ne Krasicky 
Assistant Attorney General



STATE OF MICHIGAN

JOHN W . PORTER

Superintendent o f 
Public Instruction

DEPARTMENT OF EDUCATION
Lansing, Michigan 48902 

February 25, 1972

Mr. Eugene Krasicky 
Assistant Attorney General 
Seven Story Office Building 
Lansing, Michigan

STATE BOARD OF EDUCATION
E D W IN  L. N O V AK , O.D. 

President
M ICH AEL J. DEEB 

Vice President
D R . GO RTO N  RIETHM1LLER 

Secretary
TH O M AS J. BREN N AN  

Treasurer
M A R IL Y N  JEAN KELLY 

A N N E TTA  M ILLER 
D R . CHARLES E. M ORTON 

JAM ES F. O ’NEIL
G O V . W IL L IA M  G. M ILLIKEN 

Ex-Officio

Dear Mr. Krasicky:

In response to the several questions asked of you by the attorney for the 
NAACP regarding the integration plans submitted by the State Board of 
Education, I wish to make the following responses.

As per your request, please find attached the names and addresses of the 
ten individuals who assisted our office in the development of the several 
metropolitan desegregation plans. These individuals worked on the several 
plans consistent with their background, knowledge, and with their personal 
interest regarding the various alternatives proposed.

In addition to the names of the ten individuals listed in the exhibit, 
myself, Deputy Superintendent William Pierce, Assistant Superintendent 
Ronald Edmonds, the Director of Equal Educational Opportunity, Marvin 
Tableman, Mr. Homer Smith and Mr. Larry Hackney, of our staff, assisted 
in coordinating the work of the consultants and in providing the consultants 
with Department information when such information was necessary. Mr. Edmonds, 
of our staff, assumed the major responsibility for preparing the Equality 
of Educational Opportunity and Quality Integrated Education Metropolitan 
Plan.

In regard to the transportation costs contained in the several metropolitan 
desegregation plans submitted, our specialist in school bus transportation 
concluded that it would be erroneous to assume that the statewide per pupil 
average transportation cost of $56.27 could be used to estimate the cost 
of transporting pupils in the metropolitan area. Staff then undertook to 
calculate what reasonable costs might be for transporting students in the 
metropolitan area.

As you will note, a comprehensive set of transportation figures are contained 
in the One Way Student Movement and Reassignment Plan. It was concluded 
that the per capita cost of such transportation would be approximately 
$104 per student. This figure was based upon the assumption that no 
vehicles were available, and therefore included the cost of acquisition 
as well as maintenance and operation. (See Exhibit B)



+
Mr. Eugene Krasicky
February 25, 1972 
Page 2

Second, you asked if staff had made any recommendations that were not 
included in the several metropolitan plans. The staff did not make any 
other recommendations in regard to the six metropolitan plans. The 
consultants who prepared the Metropolitan School District Reorganization 
Plan did propose a comprehensive financing structure for that plan which, 
as you are aware, the Board deleted. The reason that section of the plan 
was deleted was that it created some legal complications which could not be 
satisfactorily resolved by the State Board of Education. No other 
recommendations were made by staff or by consultants which were deleted 
from the document.

In regard to your third question as to whether other plans were considered,
I can assure you that no other plans were considered, since it was the 
belief of those consulted that all of the possible conceptual alternatives 
operational at this time throughout the United States had been identified.

In regard to your final question concerning other supporting data, this 
is to advise you that all supporting data is contained in the six documents 
submitted. No supporting data was excluded. Some Board members felt that 
maybe some of the data should not be transmitted, but it was the consensus * 
of the Board that all information developed be transmitted. Several 
computer runs were developed for the Board's consideration, which simply 
illustrated the effect of the application of a number of options to the 
several plans. These were not included because they were not germane to 
the principles of the plans.

In this regard, I think it is important that I call to your attention that 
these six documents should not be considered as mutually exclusive. By 
looking at all of them "in toto" one acquires a rather comprehensive appre­
ciation of the statistical data provided to support metropolitan desegregation. 
For example, the One Way Busing Plan, although in the minds of some not a 
desirable alternative, does provide comprehensive and detailed statistics 
regarding student movement and the cost of such movement, which can be applied 
equally well to the other five plans. Conversely, the Metropolitan Racial 
Proportion Plan, although not as comprehensive as some others, does provide 
a uniform and specific method for distributing students on a racial proportion 
in all schools of a given area.

Thus, when one reads all of the proposals, one might conclude that the State 
Board of Education submitted a metropolitan school desegregation plan which had 
five different modifications which could be used, either in concert or 
independently, and such a metropolitan plan was buttressed by the fact that 
there was need, regardless of the plan adopted, for an equality of educa­
tional opportunity support system before any such plan would be successful.



Mr. Eugene Krasicky 
February 25, 1972 
Page 3

I trust that this communication is responsive to your request

Sincerely yours.

JWP:fc

Attachments



CONSULTANTS WHO ASSISTED IN THE DEVELOPMENT OF 
DESEGREGATION PLANS

In addition to Department staff, the work has been performed by:

Mrs. Judith A. Winston, Acting Director, Equal Educational 
Opportunities Project, the Council of the Great City Schools

Mr. Samuel B. Husk, Associate, Equal Educational Opportunities 
Project, The Council of the Great City Schools

Dr. Lloyd M. Cofer, Professor of Administration and Higher Educatioi 
Michigan State University

Dr. Richard L. Featherstone, Professor of Administration and 
Higher Education, Michigan State University

Dr. Lawrence LeZotte, Assistant Professor of Educational 
Psychology, Michigan State University

Professor John Mogk, Professor, Law School, Wayne State University

Dr. Larry Hillman, Associate Professor, Educational Administration,
. Wayne State University

Mr. David Mcndes, Assistant to the Dean, School of Education, 
University of Michigan

Mr. Norward Roussel!, Mott Fellow, Wayne State University

Mr. B ill O 'Neil, Mott Fellow, Wayne State University