Memo from Lado to Ellis with Draft Requests for Admissions

    * 

To: Ron Ellis 

From: Marianne Engelman Lado 

Date: December 11, 1990 

Re: Sheff v. O'Neill: Requests for Admissions 
  

Attached please find draft requests. Much of the work on 
these requests was performed by Mele Moreno, a CUNY student who 
was working with LDF part-time this semester. 

Although I have done a bit of editing and have made some 
additions, much work remains to be done. A more exhaustive search 
for admissions awaits the restoration of the files into the 
cabinet. We should, however, send in a batch of requests in the 
next week or so, if possible. Please review the attached and let 
me know if these seem appropriate. 

Thank you. 

 



SHEFF Request for Admissions 

1. Commissioner Mark Shedd wrote in 1979, "Eighty-nine percent of 
the minority enrollments in the state are in 30 of the state's 165 
towns. Most of those young people are in four of the state's 
largest cities: New Haven, Hartford, Bridgeport and Waterbury. 
And in each of these towns, the minority students make up a 
majority of the student population.” 

Memorandum from State of Connecticut _Education Commissioner 
Mark Shedd, 1979. (Need to check source.) 

2. Students who come from disadvantigidpackorounds are more likely 
to require additional educational programs than less needy 
students. 

The Condition of Public Elementary and Secondary Education in 
Connecticut, Fiscal Year 1977-78, Vol. 3, Trends and Perspectives, 
February 1979, p.6. 

3. In 1979, the State Board of Education reported, "At the present 
time there is no state mandated or imposed solution for correcting 
racial imbalance in the Connecticut public schools." 

Id. at p.6. 

4. In 1977, 27.3% of Connecticut's minority students attended 
schools that were at least 90% minority. 

Id. at p.s6. 

5. In 1979 under state law, some of Connecticut's school districts 
could have been considered to be racially imbalanced. Many of the 
"racially imbalanced" schools were predominantly non-minority 
schools in districts with high concentration of minority students." 

Id. at p.6. 

  

will be able to complete bibliographic information once the 
files are in order.  



  

» » 

2 

6. Section 10-4a of the Connecticut General Statutes states that 
the educational interests of the State shall include but not be 
limited to the concern that each student shall have equal 
opportunity to receive a suitable program of educational 
experiences. 

The Condition of Public Elementary and Secondary Education in 
Connecticut, Fiscal Year 1978-79, Vol. I, The Annual Report on 
Programs and Evaluations of Connecticut State Board of Education, 
February 1980, p.17. 

7. In 1980, the State Board of Education reported, "Connecticut's 
minority pupils tend to be isolated from non-minority students, and 
are found in growing numbers in school districts with larger total 
enrollments." 

Id.:.at p.74, 

8. In 1980, the State Board of Education reported, "a 
comprehensive equal education opportunities program with strong 
support from the State Board of Education and State Department of 
Education is essential for effective identification, analysis, and 
remediation of inequities, problems occasioned by isolation and 
discrimination." 

Id. at 'p.74. 

9. The Board further reported, "There is a need to develop 
incentive grants for cooperative working arrangements between 
and/or among LEAs to decrease racial isolation." 

Id. at ‘p.76. 

10. In 1980, the Board reported, "Because minority students tend 
to be concentrated in relatively few towns, the question of racial 
imbalance is moot in most Connecticut School Districts." 

The Condition of Public Elementary and Secondary Education in 
Connecticut, Fiscal Year 1978-79, Vol. 3, Trends and Perspectives, 
February 1980. p.3-4. 

11. Project Concern is a cooperative program in which inner city 
students are sent to cooperating suburban schools. Statewide 
enrollments in Project Concern grew from 935 pupils to 1470 pupils 
between 1969 and 1973, and remained at approximately the 1973 level 
through fiscal year 1978-1979. 

 



  

Id. at p.4,6. 

12. In 1980, the Board reported, "Connecticut's towns differ in 
their rates of student enrollment growth, wealth base, tax support 
of education, and concentration of needy students." 

Id. at p.é6. 

13. In 1980, the Board reported, "Towns also differ in the 
proportion of their students who receive state aid for dependent 
children -- towns with high concentrations need to generate more 
revenues to cover the more costly educational services that these 
children are likely to need." 

Id. at 'p.6. 

14. In 1980, the Board reported that there were several instances 
that higher tax rates in poor towns "could not generate enough 
revenue to provide their students with the same educational 
opportunities as students from wealthy towns." 

1d, at p.6. 

15. In 1980, the Board reported that "because of historical 
patterns," the isolation of minority students within districts, "is 
a problem in relatively few communities. Minority students, 
especially Hispanics, tend to be concentrated in the cities. In 
1978 fully 63% of the enrollments in Connecticut's five large 
cities were minorities." 

Id. at p.é6. 

16. In 1980, the Board of Education employed an "operational 
definition of racial imbalance" as "a minority concentration in 
schools that differs significantly from the proportion of minority 
students in the town itself." 

Id. at p.é6. 

17. In 1980, the Board reported that, using a standard of a 25 
percentage point deviation to assess racial imbalance, "there would 
have been 71 imbalanced schools in seven communities in 1977. In 
1978 fifteen were closed or brought into better balance. The 
schools that have remained racially imbalanced according to this 
gauge are generally non-minority schools in districts with high 

 



  

4 

concentrations of minority students." 

Id. at p.6. 

18. In 1981, the Board reported, "Each student in Connecticut's 
public schools is guaranteed an equal opportunity to receive a 
suitable program of educational experiences. Assuring a suitable 
program for each student is a responsibility of the state." 

The Condition of Public Elementary and Secondary Education in 
Connecticut, Fiscal Year 1979-80, Vol. 1, The Annual Report of 
Programs and Evaluations of Connecticut State Board of Education, 
February, 1981, p.v. 

19. In 1982, the Board reported, "Each student in Connecticut's 
public schools is guaranteed an equal opportunity to receive a 
suitable program of educational experiences. Assuring a suitable 
program for each student is the responsibility of the state." 

The Condition of Education, Connecticut Public Schools, Fiscal 
Year 1980-81, Vol. I, Annual Report, 1982, p.vii. 

20. During the fiscal year 1979-80 the legislature's Regulations 
Review Committee approved regulations to implement the state's 
Racial Imbalance Law. 

The Condition of Public Elementary and Secondary Education in 
Connecticut, Fiscal Year 1979-80, Vol. 2, Trends and Perspectives, 
February, 1982, p.ix. 

21. According to the regulations adopted in 1980 to implement the 
1969 racial imbalance law, districts with a minority concentration 
in a school that differed by at least 25 percentage points from the 
district-wide percentage of minority students in the grades served 
by that school were considered to be racially imbalanced and were 
required to submit to the Board a plan to rectify the problem. 

Id. at p.5. 

22. Between 1970 and 1979 the number of students in Project 
Concern, statewide, varied between 1,223 and 1,446. The number of 
students sent from Hartford to suburban schools during this time 
follows: 

 



19707 892 
1971: 917 
1972: 923 
1973; 1005 
1974: 936 

Id. at p.5,7,40. 

23. Between 1970 and 1979, the number of minority students in 
Connecticut's public elementary and secondary schools increased 
from 80,146, 12.2% of the public enrollment, to 94, 834, or 17.3% 
of enrollment, with yearly percentages as follows: 

1970: 12.2% 1975: 14.8% 
1971¢ 12.6% 1976: 15.2% 
1972: 13.0% 1977: 16.0% 
1973: 13.6% 1978: 16.5% 
1974: 14.2% 1979; 17.3% 

1d. at p.5,66. 

24. In 1982, the Board reported the following racial and ethnic 
background of Connecticut's College-Bound Seniors: 

School Year 

1974-75 75-76 76-77 717-78 
American 

Indian 39 40 53 72 
Black 958 946 1,014 1,159 
Mexican- 

American 11 17 27 24 
Oriental 118 101 112 150 
Puerto Rican 314 320 311 422 
Total Minority 1,599 1,578 1,715 2,090 

% of College 
Bound Seniors 

Id. at p.68. 

24. The number of "racially imbalanced" schools was 67 in 1976, 
71 in 1977, and 56 in 1978 and 1979. The number of "moderately 
imbalanced 'schools" was 82 in 1976, 75 in 1977, 83 in 1978, and 70 
in 1979. 

Id. at p.7,38.  



  

» 

6 

25. "A central premise of state law is a guarantee that each 
student in Connecticut's public schools will have an equal 
opportunity to receive a suitable educational experience. Assuring 
a suitable program for each student is the responsibility of the 
state." 

Condition of Education 1981-82, Vol. 1, Annual Report, 1983, 
at 

26. The following accurately reflects the data for the school year 
1983-1984: 

Community Data 

Children in Single Median Family Families Below 
  

Parent Families: % Income: $ Poverty level: % 
Hartford 51.0% $14,032 33.1% 

Avon 6.8 33,968 2.2 
Bloomfield 12.0 26,628 2.5 
Canton 8.8 26,679 2.4 
East Granby 10.2 25,884 2.8 
East Hartford 19.7 21,939 8.1 
East Windsor 8.3 22,935 7.4 
Ellington 7.7 25,552 1.0 
Farmington 14.0 27,143 2.6 
Glastonbury 10.0 31,304 3.6 
Granby 5.6 28,062 2.8 
Manchester 17.9 22,518 4.7 
Newington 9.5 25,160 3.4 
Rocky Hill 13.4 24,735 3.1 
Simsbury 7.6 34,470 2.2 
South Windsor 8.4 29,095 2+3 
Suffield 8.4 25,592 3.6 
Vernon 13.5 22,742 6.8 
West Hartford 10.9 29,937 3.8 
Wethersfield 9.6 26,358 4.6 
Windsor 14.2 25,993 3.2 
Windsor Locks 11.4 24,209 4.7 

District Students: Percentages 

  
  

    

Special Non-English Economically 
Minority Education Home Language Disadvantaged 

Hartford 87.6% 11.2% 42.5% 52.0% 

Avon 3.3 3.7 1.7 0.8 
Bloomfield 59.0 5.3 5.6 4.6 
Canton 1.1 S.8 3.2 l.6 
East Granby 3.0 4.8 0.6 1.5 

 



  

7 

East Hartford 14.6 5.5 5.3 8.8 
East Windsor 77 5.5 0.9 6.0 
Ellington 1.7 4.7 2.3 2+ 
Farmington 8.1 4.4 0.8 1.0 
Glastonbury 3.6 4.6 2.5 2.0 
Granby 5.4 3.6 1.2 0.3 
Manchester 8.1 5.8 0.6 4.4 
Newington 4.6 3.6 5.5 1.4 
Rocky Hill 4.3 4.7 4.6 1.4 
Simsbury 4.9 2+5 1.2 0.4 
South Windsor 7.0 3.0 1.2 Oe? 
Suffield 4.0 3.1 1.4 1.6 
Vernon 5.2 5.1 1.3 +7 
West Hartford 11.6 3.5 3.2 2.3 
Wethersfield 2.7 5.5 5.6 2.8 
Windsor 24.7 5.2 3.9 2.4 
Windsor Locks 3.1 4.8 0.0 3.5 

EERA Ninth Grade Proficiency Test Results, Fall 1983 

Math Language Arts Writing Reading 
Avg. % % Avg. % % Avg. % % Avg. % % 
Items > Items > Items > Items > 
Correct SLOEP Correct SLOEP Correct SLOEP Correct SLOEP 

  

  

Hartford 869.2 69.8 77.7 88.2 4.6 78.9 62 89.5 

Avon 90.9 99.4 94.6 100.0 7.0 100.0 83 100.0 
Bloomfield 78.3 87.1 87.4 23.8 5.6 89.6 73 98.7 
Canton 88.3 98.9 21.6 100.0 6.7 98.9 78 100.0 
East Granby 89.9 98.3 93.7 100.0 6.6 100.0 83 100.0 
East Hartford 80.8 89.1 87.8 96.9 6.0 98.7 69 97.1 
East Windsor 79.7 94.1 87.6 95.1 5.9 97.0 73 98.0 
Ellington 83.0. 92.7 291.5 98.5 8.1 97.0 78 29.3 
Farmington 86.2 94.8 93.2 100.0 5.3 99.0 78 99.5 
Glastonbury 91.2 98.4 93.8 98.6 6.6 99,5 80 100.0 
Granby 84.7 96.9 94.0 100.0 6.7 100.0 80 99.2 
Manchester 83.5 93.2 90.6 96.9 6.14 97.7 75 98.3 
Newington 87.0 98.0 93.9 99.4 6.4 99.1 78 99.1 
Rocky Hill 86.4 97.3 92.1 99.3 6.2 99.3 78 100.0 
Simsbury 90.7. .98.7 94.7 99.7 6.7 99.5 83 100.0 
South Windsor 86.2 95.7 92.7 99.6 6.4 99.3 76 99.6 
Suffield 83.3 95.6 89.9 96.7 86.5 99.3 76 08.7 
Vernon 85.8 95.6 90.4 97.8 8.1: 97.6 76 99.5 
West Hartford 88.6 97.1 92.7 99.6 6.5 96.6 76 98.2 
Wethersfield 87.0 96.3 92.2 98.3 B8+0 97.3 75 28.3 
Windsor 85.6 96.9 92.1 20.4 6.0 95.9 78 100.0 
Windsor Locks 86.3 99.3 92.4 99.3 5.9 96.6 78 
90.3 

Town and School District Profiles, 1983-84 Data, State of 
Connecticut, Board of Education, 1985, p. 12, 22, 42, ‘74, 80, 88, 

 



¥ 
- . 

» 

  

8 

90, 98, 102,.108,°118, 138, 166, 212, 228, 234, 248, 262, 276, 234, 
296. 

27. The following accurately reflects the data for the school year 
1984-1985: 

Community Data 

Children in Single Median Family Families Below 
  

Parent Families: % Income: $ Poverty Level: % 

Hartford 51.0% $14,032 33.1% 

Avon 6.8 33,968 2.2 
Bloomfield 12.0 26,628 2.5 
Canton 8.8 26,679 2.4 
East Granby 10.1 25,884 2.8 
East Hartford 19.7 21,939 8.1 
East Windsor 8.3 22,935 7.4 
Ellington 7 25,552 1.0 
Farmington .0 27,143 2.6 
Glastonbury .0 31,304 3.6 
Granby . 6 28,062 2.8 
Manchester «9 22,518 4.7 
Newington «5 25,160 3.4 
Rocky Hill .4 24,735 3.1 
Simsbury .6 34,470 2.2 
South Windsor 4 29,095 2.3 
Suffield 8.4 25,592 3.6 
Vernon 13.5 22,742 6.8 
West Hartford 10.9 29,937 3.8 
Wethersfield 9.6 26,358 4.6 
Windsor 13.2 25,993 3.2 
Windsor Locks 11.4 24,209 4.7 

District Students: Percentages 

  
  

  

Special Non-English Economically 
Minority Education Home Lanquage Disadvantaged 

Hartford 88.3% 10.9% 44.4% 52.1% 

Avon 2.4 4.0 1.6 0.1 
Bloomfield 61.9 5.7 5.5 4.8 
Canton 4.1 4.7 1.3 1.7 
East Granby 2.6 3.9 0.5 2.1 
Fast Hartford 14.3 6.1 6+3 8.2 
East Windsor 8.5 5.4 2.0 5.3 
Ellington 2.1 5.4 0.1 1.2 
Farmington 8.1 4.0 5.3 0.9 
Glastonbury 3.9 5.0 l.1 1.8 

 



  

9 

Granby 3.5 3.7 0.2 0.2 
Manchester 9.2 5.2 2.0 4.0 
Newington 4.7 3.7 6.6 1.6 
Rocky Hill 4.0 5.0 6.9 1.1 
Simsbury 5.7 2.3 1.0 0.3 
South Windsor 6.8 3.8 3.2 0.6 
Suffield 3.5 3.2 0.3 1.4 
Vernon 5.3 4.8 1.4 6.6 
West Hartford 12.2 442 23 2.0 
Wethersfield 2.3 5.4 5.1 2.7 
Windsor 26.5 5.8 3.2 2.3 
Windsor Locks 3.4 5.6 3.3 3.8 

EERA Ninth Grade Proficiency Test Results, Fall 1983 

Math Language Arts Writing Reading 
Avg. % % Avg. % % Avg. % % Avg. % % 
Items > Items > Items > Items > 
Correct SLOEP Correct SIOEP Correct SLOEP Correct SLOEP 
  

Hartford 70.6 73.5 80.1 90.4 4.4 74.7 64 02.7 

Avon 91.1 98.8 94.5 100.0 6.3 100.0 83 100.0 
Bloomfield 79.6 87.1 86.7 93.5 5.7 93.4 72 95.1 
Canton 88.7 98.9 92.3 8.9 6.1 97.9 78 98.9 
East Granby 92.2 100.0 95.5 100.0 6.1 97.4 80 100.0 
East Hartford 81.6 92.7 87.8 96.4 5.1 92.3 72 98.1 
East Windsor 80.3 92.3 89.3 97.8 5.9 97.8 75 100.0 
Ellington 84.0 95.3 90.4 96.7 5.7 94.0 78 99.3 
Farmington 87.7 97.6 94.7 100.0 6.3 100.0 80 100.0 
Glastonbury 92.0 98.5 94.9 99.5 6.4 98.5 80 29.3 
Granby 87.5%" 100.0 $5.1 100.0 6.0 100.0 83 100.0 
Manchester 84.0 96.2 91.2 98.8 5.7 96.5 75 99.8 
Newington 88.3 99.5 94.4 100.0 5.8 98.4 78 100.0 
Rocky Hill 83.7 93.4 89.2 97.8 5.9 97.0 72 97.8 
Simsbury 89.4 97.5 93.7 98.5 6.0 98.0 80 99.0 
South Windsor 86.1 96.5 92.3 98.8 6.1 98.8 76 99.2 
Suffield 84.6 94.3 92.1 99.4 6.1 100.0 76 99.4 
Vernon 86.5 96.5 93.1 98.9 6.0 96.3 76 98.6 
West Hartford 88.5 97.7 93.3 98.6 6.1 98.2 78 29.1 
Wethersfield 87.0 94.7 91.2 96.9 5.8 97.5 76 97.9 
Windsor 85.9 95.4 90.8 97.5 5.6 96.6 76 98.8 
Windsor Locks 85.8 97.5 90.7 96.9 5.2 98.1 75 98.1 

Town and School District Profiles, 1984-85 Data, State of 
Connecticut, Board of Education, 1986, p. 12, 22, 42, 74, 80, 88, 
90, 98, 102, 104,118, 138, 166, 212, 228, 234,.248,6 262, 276, 254, 
294, 296. 

28. The following accurately reflects the data for the school year 

 



é 

10 

1985-1986: 

Community Data 

Children in Single Median Family Families Below 
Parent Families: $% Income: $ Poverty Level: % 
  

Hartford 51.0% $14,032 33.1% 

Avon 

Bloomfield 
Canton 

East Granby 
East Hartford 

East Windsor 
Ellington 
Farmington 
Glastonbury 
Granby 
Manchester 

Newington 
Rocky Hill 
Simsbury 
South Windsor 
Suffield 
Vernon 

West Hartford 

Wethersfield 
Windsor 

33,968 
26,628 
26,679 
25,884 
21,939 
22,935 
25,552 
27,143 
31,304 
28,062 
22,518 
25,160 
24,735 
34,470 
29,095 
25,592 
22,743 
29,937 
26,358 
25,993 

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Windsor Locks 24,209 * 

District Students: Percentages 

Special Non-English Economically 
Minority Education Home Language Disadvantaged   

  
  

Hartford 91.9% 9.5% 44.9% 51.4% 

Avon 

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Canton 
East Granby 
East Hartford 
East Windsor 
Ellington 
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Glastonbury 
Granby 
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Newington 
Rocky Hill 
Simsbury 

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il 

South Windsor 8.8 4.6 4.3 0.6 
Suffield 341 4.5 2.0 1.2 
Vernon 6.8 B.7 ey J 6.2 
West Hartford 14.3 3.5 8.8 1.5 
Wethersfield 2.7 6.4 2.5 3.3 
Windsor 30.3 5.6 3.7 2.2 
Windsor Locks 3.1 5.3 3:1 3.2 

Town and School District Profiles, 1985-86 Data, State of 
Connecticut, Board of Education, 1987, p. 12, 22, 42, 74, 80, 88, 
90, 98,%102, 104, 118, 138, 166, 212, 228, 234, 248, 262, 276, 284, 
294, 296. 

29. 1In 1987: 

A- Wealth disparities remained wide, resulting in wide 
disparities in the ability of towns to raise taxes for 
education. 

B- Large disparities in educational outcomes existed. 
For example Mastery Test scores showed low achievement 
in particular districts. 

C- Minority students were clustered in a few city school 
districts. 

Educational Equity Study Committee Memorandum to State Board 
of Education, December 2, 1987, Appendix A (Findings and 
Observation, October 20, 1987), p.5. 

30. Of the 166 school districts in the State in 1988, 14 districts 
had minority enrollments of 25% or more, 37 districts had minority 
enrollments of 5% to 25%, and the remaining 115 districts had 
minority enrollments of less than 5%. 

Draft Report on "Racial/Ethnic Equity and Desegregation In 
Connecticut's Public Schools," prepared by The Committee on Racial 
Equity, Appointed by Commissioner Tirozzi, January, 1988, p.l. 

31. In 1988, over 60% of the minority students were enrolled in 
the five largest school districts, i.e., Hartford, Bridgeport and 
New Haven, had minority enrollments that exceeded 80 percent. 

Id. at p.1. 

 



  

12 

32. In 1988, the Commissioner's Committee on Racial Equity 
reported that, "In spite of the State's racial imbalance law, most 
schools in Bridgeport, Hartford, and New Haven are predominantly 
minority." 

Id. at -p.4. 

33. The Committee further reported that, "A trend is developing 
in Connecticut's public schools that is causing the isolation of 
the races." 

Id... at p.1l. 

34. Interaction is a most important element of quality education, 
and it benefits both minority and non-minority students alike. 
Like their counterparts in predominantly minority schools, children 
in suburban districts lack cultural diversity as they are educated 
and prepared to be members of society. 

Id. at p.7. 

35. "It is a fact that 14 of Connecticut 166 school districts have 
29% of the states total student enrollment, but enroll 79% of the 
state's minority students." 

Commissioner Tirozzi, "Why We Must Integrate Our Schools," The 
New York Times, January 31, 1988, P.30 CN, (a direct quote). 

36. "It is a fact that in order to have true quality education we 
must integrate our schools." 

Id. at P.30 CN, (a direct quote). 

37. M...Schools in Connecticut's poorest cities still have the 
worst dropout rates, lowest test scores and neediest students." 

Commissioner Tirozzi, in Robert A. Frahm, The Hartford 
Courant, "Call to Aid Poor Schools Renewed," April 29, 198 , (a 
direct quote). (Need to check date.) 

38. "Quality and Integrated Education: Options for Connecticut," 
the Commissioner's 1989 report, accurately describes the persistent 

 



  

13 

racial and socioeconomic isolation of some public school youngsters 
and the schools they attend. 

39. Children who live in poverty =-- a burden which impacts 
disproportionately on minorities -- are more 1likely to be 
educationally at risk of school failure and dropping out before 
graduation than children from less impoverished homes. 

"Quality and Integrated Education: Options for Connecticut," 
A Follow-Up to the January, 1988 Report, "Racial/Ethnic Equality 
and Desegregation in Connecticut's Public Schools," April, 1989, 
at p.5. 

40. Racial and economic isolation have profound academic and 
affective consequences. Children who live in poverty -- a burden 
which impacts disproportionately on minorities -- are more likely 
to be educationally at risk of school failure and dropping out 
before graduation than children from less impoverished homes.... 
Low achievement outcomes associated with poverty are intensified 
by geographic and racial concentrations. 

Id, at p.1. 

41. The performance of Black and Hispanic students was 
substantially below that of Whites on the 1987 Connecticut Mastery 
Test for fourth, sixth, and eighth graders. 

Three Perspective on the Educational Achievement of 
Connecticut Students, vi. (Check full cite.) 

42. There is a dramatic drop in Connecticut Mastery test scores 
as the concentration of the factors of economic need and racial 
isolation increase. 

14. at p. vi. 

43. Only 36.0% of black students statewide met the 1987 Grade Four 
Mastery Test composite Remedial Index, compared with 73.9% of white 
students. 

1d. at p. 24, 28, 

 



14 

44. Only 5.8% of black students achieved high scores on the 1987 
Grade Four Mastery Test Composite Index, as compared with 30.9% for 
white students. 

Id. at p.24,25. 

45. The following accurately reflects the percentage of students 
below the remedial reading level, as revealed by The Mastery Test 
results, Connecticut State Department of Education, January 1988: 

% Below 4th Gr. % Below 6th Gr. % Below 8th Gr. 
Remedial Level Remedial Level Remedial Level 

  
  

  

Hartford 61 59 

Avon 5 9 

Bloomfield 23 27 
Canton 21 14 

East Granby 7 10 
East Hartford 33 30 
East Windsor 13 25 
Ellington 15 7 
Farmington 10 10 
Glastonbury 11 22 
Granby 16 18 14 
Manchester 22 21 20 
Newington 12 13 11 
Rocky Hill 11 10 21 
Simsbury 3 4 4 
South Windsor 12 11 17 
Suffield 15 20 17 
Vernon 16 21 18 
West Hartford 13 13 14 
Wethersfield 17 10 7 
Windsor 30 16 21 
Windsor Locks 12 23 19 

46. The following accurately reflects the percentage of students 
below the remedial writing level, as revealed by The Mastery Test 
results, Connecticut State Department of Education, January 1988: 

% Below 4th Gr. % Below 6th Gr. % Below 8th Gr. 
Remedial Level Remedial Level Remedial Level 

  
  

  

Hartford 38 40 26 

Avon 2 14 1 
Bloomfield 19 23  



Canton 

East Granby 
East Hartford 
East Windsor 
Ellington 
Farmington 
Glastonbury 
Granby 
Manchester 

Newington 
Rocky Hill 
Simsbury 
South Windsor 
Suffield 
Vernon 

West Hartford 

Wethersfield 
Windsor 
Windsor Locks 

47. The following accurately reflects the percentage of students 
below the remedial mathematics level, as revealed by The Mastery 
Test results, Connecticut State Department of Education, January 
1988: 

Below 4th Gr. % Below 6th Gr. % Below 8th Gr. 

Remedial Level Remedial Level Remedial Level 

  
  

  

Hartford o>
 

No
 

44 

Avon 

Bloomfield 
Canton 

East Granby 
East Hartford 

East Windsor 
Ellington 
Farmington 
Glastonbury 
Granby 
Manchester 

Newington 
Rocky Hill 
Simsbury 
South Windsor 
Suffield 
Vernon 

West Hartford 

Wethersfield 

ND
 

(6
) 

N
O
O
N
 

O
A
N
O
P
L
P
N
H
F
E
O
N
O
R
F
 

O
N
 
M
N
 

 



  

A » | 

16 

Windsor 18 14 16 
Windsor Locks 8 9 6 

48. The following accurately reflects the percentage of students 
below the remedial reading level, as revealed by the Mastery Test 
results, Summary and Interpretations, 1989-90, State of Connecticut 
Department of Education: 

  

  
  

% Below 4th Gr. % Below 6th Gr. % Below 8th Gr. 
Remedial Level Remedial Level Remedial Level 

Hartford 70 55 50 

Avon 14 4 5 
Bloomfield 23 23 19 
Canton 3 17 7 
East Granby 17 12 8 
East Hartford 23 19 15 
East Windsor 15 10 7 
Ellington 15 15 11 
Farmington 13 7 12 
Glastonbury 13 16 10 
Granby 11 17 5 
Manchester 20 18 23 
Newington 10 13 7 
Rocky Hill 15 8 14 
Simsbury 7 5 5 
South Windsor 15 12 8 
Suffield 14 8 9 
Vernon i5 12 14 
West Hartford 17 12 13 
Wethersfield 16 12 9 
Windsor 28 22 17 
Windsor Locks 15 14 10 

49. The following accurately reflects the percentage of students 
below the remedial writing level, as revealed by the Mastery Test 
results, Summary and Interpretations, 1989-90, State of Connecticut 
Department of Education: 

  

  
  

% Below 4th Gr. % Below 6th Gr. % Below 8th Gr. 
Remedial Level Remedial Level Remedial Level 

Hartford 46 39 22 

Avon 2 1 3 

 



w 

  

17 

Bloomfield 17 29 7 
Canton 4 8 0 
East Granby 18 19 5 
East Hartford 6 9 2 
East Windsor 11 33 7 
Ellington 2 6 6 
Farmington 2 8 2 
Glastonbury 8 16 2 
Granby 4 10 2 
Manchester 11 11 13 
Newington 11 13 10 
Rocky Hill 4 5 6 
Simsbury 1 8 l 
South Windsor 6 16 7 
Suffield 3 5 3 
Vernon 8 0 4 
West Hartford 4 12 3 
Wethersfield 6 9 1 
Windsor 12 20 8 
Windsor Locks 18 21 22 

50. The following accurately reflects the percentage of students 
below the remedial mathematics level, as revealed by the Mastery 
Test results, Summary and Interpretations, 1989-90, State of 
Connecticut Department of Education: 

  

  
  

% Below 4th Gr. % Below 6th Gr. % Below 8th Gr. 
Remedial Level Remedial Level Remedial Level 

Hartford 46 43 33 

Avon 1 4 5 
Bloomfield 1 13 16 
Canton 4 15 3 
East Granby 11 15 3 
East Hartford 8 10 7 
East Windsor 13 14 8 
Ellington 5 11 3 
Farmington 3 1 1 
Glastonbury 8 6 5 
Granby 3 9 5 
Manchester 10 15 13 
Newington 5 8 3 
Rocky Hill 6 7 3 
Simsbury 2 4 S 
South Windsor 8 11 4 
Suffield l 6 5 
Vernon 3 11 5 
West Hartford 9 8 6 

 



  

18 

Wethersfield 4 8 3 
Windsor 14 13 1} 
Windsor Locks 5 11 8 

TED CE GHD TER GT MED TED CHP CEP CEP GED CED CO GE CNS GED OTP GND KGS GNE END MES DU GS ED WE 

51. The following accurately reflects the October Activities for 
June 1986 Public High School Graduates in the Hartford area: 

--=-Post-Secondary Education--- 
Higher Voc Other Total Pct 

Hartford 284 36 1 321 38% 

Avon 132 3 2 141 88% 
Bloomfield 133 0 0 134 66% 
Canton 48 5 0 53 62% 
East Granby 35 0 0 35 73% 
East Hartford 213 28 0 244 63% 
East Windsor 42 8 0 50 63% 
Ellington 85 6 0 91 68% 
Farmington 138 10 0 150 76% 
Glastonbury 326 14 2 343 88% 
Granby 79 5 0 84 67% 
Manchester 251 24 13 288 69% 
Newington 220 17 0 239 73% 
Rocky Hill 86 0 0 92 81% 
Simsbury 310 2 4 317 90% 
South Windsor 209 20 1 232 75% 
Suffield 90 4 0 94 66% 
vernon 203 21 0 224 73% 
West Hartford 505 7 10 526 86% 
Wethersfield 208 18 10 237 76% 
Windsor 182 14 0 196 68% 
Windsor Locks 75 4 0 79 52% 

---Career Activities--- 
Mlty 

Serv Emplyd Unemp Total — 

Hartford 46 339 40 425 50% 

Avon 2 12 1 15 9% 
Bloomfield 10 60 0 70 34% 
Canton 5 25 0 30 35% 
East Granby 3 10 0 13 27% 
East Hartford 21 110 l 132 34% 
East Windsor 6 19 0 25 32% 
Ellington 12 31 0 43 32% 

 



    

  

  

19 

Farmington 2 45 0 47 24% 
Glastonbury 5 39 0 44 11% 
Granby 5 30 0 35 28% 
Manchester 13 103 0 116 28% 
Newington 15 53 0 68 21% 
Rocky Hill 5 16 0 21 19% 
Simsbury 3 17 0 20 6% 
South Windsor 5 57 6 68 22% 
Suffield 10 36 0 46 32% 
vernon 9 62 0 71 23% 
West Hartford 18 64 0 82 13% 
Wethersfield 1 31 3 33 11% 
Windsor 18 63 11 92 32% 
Windsor Locks 3 68 0 71 47% 

Home School % 
(cont.) makr Other Misc Total Male? 

Hartford 24 6 75 851 45% 

Avon 0 0 4 160 40% 
Bloomfield 0 0 0 204 49% 
Canton 0 0 2 85 54% 
East Granby 0 0 0 48 54% 
East Hartford 2 0 12 390 43% 
East Windsor 2 0 2 79 47% 
Ellington 0 0 0 134 44% 
Farmington 0 0 0 197 44% 
Glastonbury 0 0 4 391 51% 
Granby 0 0 6 125 47% 
Manchester 2 0 12 418 45% 
Newington 1 0 20 328 51% 
Rocky Hill 0 0 0 113 44% 
Simsbury 0 0 17 354 51% 
South Windsor 3 0 5 308 47% 
Suffield 0 0 2 142 48% 
Vernon 3 9 0 307 47% 
West Hartford 0 3 3 614 48% 
Wethersfield 0 8 35 313 52% 
Windsor 0 0 0 288 49% 
Windsor Locks 1 l 0 152 42% 

High School Graduate Follow-up Report, June 1986 Graduates, 
Conn. Dept. of Ed., 1988, Appendix E. 

  

’May want to double check the meaning of the terms in this 
table before sending it to defendants. 

 



gS 

20 

52. The following accurately reflects the October Higher Education 
Activities of June 1986 Public High School Graduates for graduates 
from the Hartford area: 

In-State Higher Education 
Four-Year Two-Year 

Pub Pri Pub Pri Total 
  

  

Hartford 87 ~
 

~
 12 

oO
 Avon 

Bloomfield 
Canton 

East Granby 
East Hartford 

East Windsor 
Ellington 
Farmington 
Glastonbury 
Granby 
Manchester 

Newington 
Rocky Hill 
Simsbury 
South Windsor 
Suffield 
Vernon 

West Hartford 

Wethersfield 
Windsor 
Windsor Locks 

Po
a 

Ww 
o
O
o
 

SR
N 
J
S
 

[\)
 

©
 

O
N
D
 

0 
N
O
U
I
N
N
O
N
®
 

bo
 

_ 

CN
 

NI
 S
E
I
N
 

© 
N
N
Y
 

W
i
k
 

=
 

ND
 

W
N
 
O
d
 

0 
+
 

N
o
»
 ©
 

w
 

Oo
 

R
F
O
O
R
H
L
E
G
W
L
W
O
N
N
I
N
N
D
N
N
O
N
F
R
P
W
A
R
U
I
O
U
I
W
 

(S
J 

\V
 

S
O
 

R
P
F
E
F
E
F
M
V
V
O
F
F
O
N
O
U
I
R
P
F
N
O
A
N
W
N
O
O
K
R
E
F
O
N
 

[
 

Ww
 

(cont.) 

Four-Year Two-Year Higher Ed. 
Pub Pri Pub Pri 3 Total   

  

Hartford 1 3 284 

Avon 

Bloomfield 
Canton 
East Granby 
East Hartford 
East Windsor 
Ellington 
Farmington 
Glastonbury 
Granby 
Manchester 
Newington 
Rocky Hill 

132 
133 
48 
35 
213 
42 
85 
138 
326 
79 
251 
220 
86 O

F
R
F
O
M
N
M
N
M
N
M
P
F
P
F
O
O
U
M
I
O
O
O
O
 

H
O
N
W
R
F
R
F
R
E
F
N
W
L
W
O
O
I
O
O
N
 

 



w
»
 

  

21 

Simsbury 55 158 1 15 229 74% 310 
South Windsor 21 43 2 15 81 39% 209 
Suffield 11 37 9 5 62 69% 90 
Vernon 0 71 0 16 87 43% 203 
West Hartford 38 261 0 15 314 62% 505 
Wethersfield 6 72 3 4 85 41% 208 
Windsor 18 55 1 6 80 44% 182 
Windsor Locks 3 21 5 6 35 47% 75 

Id. Appendix F. 

53. The following accurately reflects the October Activities for 
June 1987 Public High School Graduates in the Hartford area: 

---Post-Secondary Education--- 

  

  

Higher Voc Other Total % 

Hartford 379 36 2 417 48% 

Avon 166 4 0 174 84% 
Bloomfield 137 2 0 139 64% 
Canton 66 4 0 72 77% 
East Granby 49 2 2 53 85% 
East Hartford 240 24 0 266 59% 
East Windsor 53 2 3 58 61% 
Ellington 96 6 0 103 73% 
Farmington 169 7 0 176 83% 
Glastonbury 254 6 1 261 74% 
Granby 70 1 0 71 53% 
Manchester 317 25 7 349 77% 
Newington 238 10 4 249 77% 
Rocky Hill 98 8 0 106 74% 
Simsbury 339 5 2 347 87% 
South Windsor 167 10 0 180 67% 
Suffield 97 3 0 100 71% 
Vernon 230 16 0 246 75% 
West Hartford 525 5 26 564 86% 
Wethersfield 178 22 5 206 78% 
Windsor 206 15 i 224 74% 
Windsor Locks 75 2 0 78 53% 

---Career Activities--- 
Mlty 
Serv Emplyd Unemp Total % 

Hartford 62 302 25 389 45% 

Avon 2 15 3 20 10% 
Bloomfield 15 59 0 74 34% 

 



» » 

    

  

22 

Canton 5 14 0 19 20% 
East Granby 3 6 0 9 15% 
East Hartford 23 144 2 169 38% 
East Windsor 5 30 1 36 38% 
Ellington 5 32 0 37 26% 
Farmington 6 23 6 35 17% 
Glastonbury 11 45 1 57 16% 
Granby 9 48 0 57 42% 
Manchester 19 74 0 93 21% 
Newington 5 54 0 59 18% 
Rocky Hill 4 31 0 35 24% 
Simsbury 6 33 0 39 10% 
South Windsor 2 50 4 56 21% 
Suffield i) 22 0 33 23% 
Vernon 9 74 0 83 25% 
West Hartford 9 59 0 68 10% 
Wethersfield 7 21 0 28 11% 
Windsor 13 53 11 27 26% 
Windsor Locks 4 64 0 68 47% 

Home School % 3 
(cont.) makr Other Misc Total Male 

Hartford 22 5 41 874 41% 

Avon 0 2 10 20 43% 
Bloomfield 1 0 3 217 45% 
Canton 1 0 1 93 47% 
East Granby 0 0 0 62 50% 
East Hartford 3 0 12 450 45% 
East Windsor 1 0 0 95 47% 
Ellington 0 0 1 141 50% 
Farmington 0 0 0 211 43% 
Glastonbury 0 6 27 351 52% 
Granby 1 5 1 135 41% 
Manchester 1 1 8 452 48% 
Newington 0 0 15 323 51% 
Rocky Hill 0 1 1 143 43% 
Simsbury 0 2 11 399 45% 
South Windsor 4 0 27 267 51% 
Suffield 0 3 5 141 56% 
Vernon 0 0 0 329 52% 
West Hartford 1 13 22 658 52% 
Wethersfield 0 12 7 263 51% 
Windsor 0 0 0 301 48% 
Windsor Locks 0 0 0 146 47% 

High School Graduate Follow-up Report, June 1987 Graduates, 

  

3May want to double check the meaning of the terms in this 
table before sending it to defendants. 

 



N » 

  

23 

Connecticut Department of Education, 1988, Appendix E-1. 

54. The following accurately reflects the October Higher Education 
Activities of June 1987 Public High School Graduates for graduates 
from the Hartford area: 

rn In-State Higher Education----- 

  

  
  

  

Four-Year Two-Year 

Pub Pri Pub Pri Total is 

Hartford 90 51 121 315 277 73% 

Avon 29 8 5 3 45 27% 
Bloomfield 50 4 13 5 72 53% 
Canton 15 6 9 2 32 48% 
East Granby 7 5 3 0 15 31% 
East Hartford 76 15 88 0 179 75% 
East Windsor 12 3 13 1 29 55% 
Ellington 30 2 20 1 53 55% 
Farmington 47 10 10 3 70 41% 
Glastonbury 27 8 27 0 112 44% 
Granby 10 6 4 2 22 31% 
Manchester 93 11 85 3 A192) 61% 
Newington 99 14 30 3 146 61% 
Rocky Hill 26 11 17 2 56 57% 
Simsbury 54 8 10 4 76 22% 
South Windsor 656 4 32 1 93 56% 
Suffield 22 8 5 1 36 37% 
Vernon 89 7 47 1 144 63% 
West Hartford 122 34 27 25 208 40% 
Wethersfield 50 21 13 3 87 49% 
Windsor 59 14 34 2 109 53% 
Windsor Locks 22 8 10 0 40 53% 

(cont.) = 6vecccece—- Oout-of-State----=--=-=-- 

Four-Year Two-Year Higher Ed. 
Pub Pri Pub Pri Total % Total 

Hartford 26 69 3 4 102 27% 379 

Avon 31 79 3 8 121 73% 166 
Bloomfield 19 43 0 3 65 47% 137 
Canton 9 21 1 3 34 52% 66 
East Granby 8 16 0 10 34 69% 49 
East Hartford 35 22 2 2 61 25% 240 
East Windsor 4 12 4 4 24 45% 53 
Ellington 3 32 0 8 43 45% 96 
Farmington 23 69 2 5 99 59% 169 
Glastonbury 35 94 0 13 142 56% 254 

 



® 

Granby 
Manchester 

Newington 
Rocky Hill 
Simsbury 
South Windsor 
Suffield 
Vernon 

West Hartford 
Wethersfield 15 
Windsor 19 
Windsor Locks 3 W

H
E
F
O
W
O
V
W
O
O
M
O
A
R
L
E
M
A
P
O
W
N
W
 

Id. Appendix F. 

55. In 1988, the Department of Education reported that the racial 
composition of students graduating from local public high schools 
had remained relatively stable for the five years in which racial 
data had been collected. For 1987, 85.9 percent of all local public 
school graduates were white, 8.8 percent were black and 3.9 percent 
Hispanic. 

High School Graduate Follow-up Report, June 1987 Graduates, 
Connecticut Department of Education, 1988, p.4. 

56. The following accurately reflects the percentage of students 
graduating from Connecticut public high schools: 

1983 1985 1987 

i ———— r———— 

White 86.0% 86.1% 85.9% 
Black 9.2% 9.0% 8.8% 
Hispanic 3.4% 3.6% 3.9% 

Id. at p.4. 

57. The following accurately reflects the percentage of students 
graduating from Connecticut vocational-technical schools: 

1983 1985 1987 

White 
Black 
Hispanic  



Id. at p.4. 

58. Statewide, Connecticut's graduation rate for white students 
is consistently higher than for Blacks and Hispanics. The 
graduation rate for white students rose 1.4% points from 1986 to 
1987 to 82.5%. The corresponding rate for black students fell 3.2% 
from 1986 to 1987 to 61.1%, as follows: 

1986 1987 

Sr rar— ——— 

White 81.1% 82.5% 
Black 64.3% 61.1% 
Hispanic 49.2% 48.2% 

Id. at p.6. 

59. In 1985, the statewide graduation rate of 77.9% for 
Connecticut public high schools was essentially unchanged from the 
two previous years. The following is a true and accurate 
representation of the percentage of both black and white students 
graduating from Connecticut's public high schools: 

Year Overall % White % Black % 
graduation 

  

  

1985 77.9% 82.5% 61.7% 
1984 77.8% 82.4% 61.0% 
1983 77.9% 81.2% 50.8% 

Report on The Condition of Education in Connecticut Elementary 
and Secondary Schools, "Meeting The Challenge," State Department 
of Education, 1986, p.23. 

60. The gap between the SAT scores of white students and those of 
black and Hispanic students has narrowed since 1975-76, but there 
little change in the years 1981-1982 through 1984-1985. 

College Bound Senior Report on SAT's, Statewide Data, 
Connecticut Department of Education, 1984-1985, p.vii. 

61. In its report on college bound seniors of the 1985-1986 school  



  

26 

year, the Department of Education reported that the gap between 
Connecticut's Black and White students on the verbal and 
mathematical SAT is wide. 

College Bound Senior Report, Statewide Data, Connecticut 
Department of Education, 1985-1986, p.vii 

62. The verbal average for black students in 1985-1986 was 97 
points below the average for white students. This was the first 
time the gap had been less than 100 points. 

Id. at .p.7. 

63. The document attached hereto as schedule 3-A is a true and 
complete report of the statewide average SAT score's by ethnic 
group from 1975-1976 through 1985-1986. Figure 3 and 4 represent 
the average verbal and mathematical scores, respectively. 

64. In its report on the SAT scores of Connecticut's College Bound 
Seniors in the 1987-1988 school year, the Connecticut Board of 
Education reported that the gap between Connecticut's black and 
white students on verbal and mathematical SAT is wide. 

College Bound Seniors Report 1987-1988, State of Connecticut 
Board of Education, 1989, p.vii. 

65. The Connecticut mathematical SAT average of 568 was 214 points 
above the mathematical SAT average of 374 for black students. 

Id: at p.6,7,9. 

66. The Connecticut mathematical SAT average of 482 for white 
students was 107 points above the mathematical SAT average of 374 
for black students. 

14. at Pp 6,7, 8. 

67. The Connecticut verbal average for black students in 1987-88 
was 95 points below the white average. 

Id. at p.6. 

 



  

27 

68. The document attached hereto as schedule 2-A is a true and 
complete copy of the statewide average SAT score by ethnic group 
from 1978 through 1988. Figure 3 and 4 represent the Connecticut 
average verbal and mathematical scores, respectively. 

Id. at p.7 

 



  

  
White 

    

—— 

  

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e
 
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Sc
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  |} 1 1 RJ T 1 T 1 ¥ I 

78 79 80.81 82 83 84 85 86 87 

Year of Graduation 

Figure 3 
Scholastic Aptitude Test 

Verbal Scores by Ethnic Group 

  

  

  

  

  
  

  

  

  

  

  

  

  

  

  

  

  

  Av
er

ag
e 

Ma
th

em
at

ic
al

 
Sc
or
e 

eo Hispanic 

  

  

  

  

  
  

      
  1 

82 86 

Year of Graduation 

Figure 4 

Scholastic Aptitude Test 
Mathematical Scores By Ethnic Group  



  

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A
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e
 

o oO 

  

  

  

  

  

      
Yeor of Croduation 

Figure 3 
Scholastic Aptitude Test 

Verbal Scores By Ethnic Group 

The average verbal score for blacks increased for the third consecutive 
year and now stands at 350. This is 24 points above the 1980-81 low and 13 
points above the 1975-76 level. Their current mathematical average of 368 
is 18 points above the 1975-76 low, and one point from the high set last 
year. The differences between the black and white verbal and mathematical 
averages have narrowed since they were first recorded in 1975-76. The 
verbal average for black students in 1985-86 was 97 points below the white 
average, an improvement from the 115 point difference that existed in 
1975-76. This is the first time the gap has been less than 100 points. The 

  

r= FELT 
510 Nt Ne - et Or10 AG mm] 

490 

480 te White 

470 

  

  

  

  

  

  

  

  

  

  

  

  

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76 77 78 78 B80 81 B82 83 84 85 Bs 

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Figure 4 
Scholastic Aptitude Test 

Mathematical Scores By Ethnic Group