Plaintiff's Response to Defendants' Post-Argument Brief

Public Court Documents
February 25, 1976

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Plaintiff's Response to Defendants' Post-Argument Brief preview

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  • Case Files, Campbell v. Gadsden County District School Board Hardbacks. Plaintiff's Response to Defendants' Post-Argument Brief, 1976. 0b96f304-a211-f111-8407-7c1e526962fd. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/b574d0b2-5a54-4e5f-9d0a-a5c8a1dbccc1/plaintiffs-response-to-defendants-post-argument-brief. Accessed March 05, 2026.

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    IN THE UNITED STATES COURT OF APPEALS 
FOR THE FIFTH CIRCUIT 

WITT CAMPBELL, 

Appellant, 

VS. : NO. 75-1998 

GADSDEN COUNTY DISTRICT 
SCHOOL BOARD, ET AL., etc., 

Appellee. 

PLAINTIFF'S RESPONSE TO 
DEFENDANTS' POST-ARGUMENT BRIEF 

1. The Defendant's entire "Supplemental Statement" is 

predicated on facts contained in an affidavit. There is not one 

citation to the record. This Court did not grant permission to 

the Defendant to supplement the record. 

2, Assuming arguendo that the Court allowed these facts 

into the record, they support the Plaintiff's position. What they 

show is that both Scott and Boyd were selected in 1970. The first 

time that either administered an elementary school when school was 

in session was in the fall of 1970 after the desegregation order of 

this Court. Even if there had been no vacancies in the fall of 

1970, the School Board was under an obligation to choose the one 

to be demoted from among all of its principals. How much stronger 

is the Plaintiff's position when there were principals whose only 

claim to "incumbency' was that they had been appointed before the 

Court order but had not yet served the first day with students in 

their respective schools. 

Respectfully submitted, 

L J 

Alans 
Kent ‘Spriggs 
324 West gs £ 
Tallahassee, Florida 32301 
(904) 224-8701 

Jack Greenberg 
James Gray 
10 Columbus Circle 
New York, N. YX. 10019 

Attorneys for Appellant 



Certificate of Service 

I HEREBY CERTIFY that copies of the foregoing Response have 

been furnished by mail to Mr. Richard Gardner, The Quincy State 

Bank Building, Quincy, Floxida 32351, and to Mr. Brian T. Hayes, 

P.O. Box 1385, Tallahassee, Florida this 28% day of February 1976. 

fet Spy 
Kent Spriggs Eig

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