Motion for Oral Argument

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Impact area
- Education
Topic
- School Desegregation
Matter
- Milliken v. Bradley
Case
- Milliken v. Bradley
U.S. state
- Michigan
Collection
- Case Files
Taxonomy
Identifier
- a860c763-54e9-ef11-a730-7c1e5247dfc0

Cite this item

Case Files, Milliken Hardbacks. Motion for Oral Argument, 1974. a860c763-54e9-ef11-a730-7c1e5247dfc0. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/c01a93d5-60fa-45d3-94f1-91a34302c9cf/motion-for-oral-argument. Accessed December 04, 2025.

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    WILLIAM

-vs-
RONALD

• •
IN THE SUPREME COURT OF THE UNITED STATES 

OCTOBER TERM 1973

NOS. 73-434, 73-435, 73-436

G. MILLIKEN, et al.,
Petitioners,

1. BRADLEY, et ad. ,
Respondents

______________________________________/

ON WRITS OF CERTIORARI TO THE UNITED STATES 
COURT OF APPEALS FOR THE SIXTH CIRCUIT

MOTION FOR ORAL ARGUMENT BY 
RESPONDENTS BOARD OF EDUCATION 
FOR THE SCHOOL DISTRICT OF THE 
CITY OF DETROIT, ET AL._______

GEORGE T. ROUMELL, JR.,
Counsel for Respondents, Board of 
Education for the School District 
of the City of Detroit, ei: al.
720 Ford Building 
Detroit, Michigan 48226 
Telephone: (313) 962-8255



MOTION FOR ORAL ARGUMENT BY RESPONDENTS 
BOARD OF EDUCATION FOR THE SCHOOL DISTRICT 
OF THE CITY OF DETROIT, ET AL._____________

NOW COMES Board of Education for the School District 
of the city of Detroit, et al., Respondents in the above-entitled 
and numbered causes, (hereinafter Respondent Detroit Board), 
through their counsel, George T. Roumell, Jr., and respectfully
request this Honorable Court to grant their counsel ten minutes

*

to present oral argument during the oral arguments scheduled 
for Wednesday, February 27, 1974.

The reasons in support of this motion are:

1. Respondent Detroit Board has filed a substantial 
Brief before this Honorable Court in the above-entitled causes. 
The topics covered by this Brief differ in some respects from 
the topics covered in the Briefs of other Respondents and Amici 
Curiae favorable to Respondents’ cause.

2. Respondent Detroit Board is the only Respondent 
who is an integral part of the Michigan public school system with 
a working knowledge of Michigan public school education. This 
working knowledge is reflected in the Brief of Respondent 
Detroit Board and will be of assistance to this Honorable Court, 
during oral argument, on such topics as:

(a) State control over all aspects of 
Michigan public school education;
(b) The constitutional inadequacy of a 
Detroit-only remedy;



• •
(c) The demographic characteristics of the 
metropolitan Detroit community; and
(d) The inappropriateness of a remand, as 
proposed by the Solicitor General of the 
United States.

3. The Solicitor General of the United States has 
sought fifteen minutes oral argument, in addition to that time 
previously granted to Petitioners and Respondent Ronald Bradley. 
Although the Solicitor General alleges that he does not fully 
support either the Petitioners or Respondents, his position 
is opposed to that of Respondent Detroit Board. Respondent 
Detroit Board believes that the Solicitor General, in his Motion, 
has erroneously characterized the proposed remedies as involving 
"effective consolidation" of the Detroit School System "with 
neighboring suburban school districts". Furthermore, Respondent 
Detroit Board does not agree with the Solicitor General's 
announced intention to seek a more extensive remand than that 
ordered by the Court of Appeals for the Sixth Circuit.

WHEREFORE, Respondent Detroit Board prays that this 
Honorable Court grant its counsel ten minutes to present oral 
argument during the oral arguments scheduled for Wednesday, 
February 27, 1974.

Dated: February 15, 1974.

Respectfully submitted,

BY:
GEORGE T y ROUME!

Counsel for Respondents, Board of 
Education for the School District 
of the City of Detroit, et al.
720 Ford Building 
Detrpit, Michigan 48226 
Telephone: (313) 962-8255

- 2 -

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Motion for Oral Argument

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