Memorandum in Support of Appellees Proposed Order

    IN THE UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

NOS. 28030 and 28042 

  

UNITED STATES OF AMERICA APPELLANT 

VS. 

HINDS COUNTY SCHOOL, BOARD, ET AL APPELLEES 

BEATRICE ALEXANDER, ET AL APPELLANTS 

vs. 

HOLMES COUNTY BOARD OF EDUCATION ET AL 

APPELLEES 

AND ALL, CASES INCi.UDED IN THE COURT'S 

ORDER OF JULY 3, 1969 AS SUPPLEMENTED 

MEMORANDUM IN SUPPORT OF 

APPELLILEES PROPOSED ORDER 
  

In support of the proposed order and the desegregation plan 

contained therein, the appellee, Madison County School District, 

respectfully shows unto the Court:  



  

    

iE. 

A. Background Information 
  

1." That the appellee school district consists of that part 

of Madison County, Mississippi lying outside of the Canton 

Municipal Separate School District and results in the matural 

division of appellee into three geographical zones. (See the 

map attached as Exhibit ""A' hereto). 

2. Zone One or the Eastern Zone, has three schools lo- 

cated within it as follows: Velma Jackson, grades 1 through 12; 

Luther Branson, grades 1 through 8; and Farmhaven, grades 1 

through 8. 

3. Zone Two or the southern area of the district also has 

three schools located within it: Rosa Scott, grades 1 through 12; 

Madison-Ridgeland, grades 1 through 12 and Ridgeland Elementary, 

grades 1 through 6. 

4. Zone Three or the western zone has two schools located 

within it: East Flora, grades 1 through 12 and Flora, grades 1 

through'12. 

5. The locations of the schools and the zone lines are indi- 

cated on the map attached. 

DB. Similarities Between HEW Plan 

and Avpellees Plan 
  

1. Zone I is identical with the HEW Plan except that the 

appellees contemplate that the Farmhaven School will remain 

open during the 1969-70 school year but would be discontinued 

  

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ee RE = re i me aE 

during the 1970-71 school year. This is deemed advisable by 

the appellee for transportation and administrative reasons. The 

plan will produce the following statistical results: 

    

  

School White Negro Total 

Velma Jackson 25 (HEW Lat) 1109 1134 

Luther Branson 0 473 473 

Farmhaven 52 6 58 

School White Negro Total 

Velma Jackson 2H(IEW Let) 11109 1134 

Luther Branson 52 479 821 

Farmhaven Discontinued 

2. The appellee’s plan for Zone Il is similar to the HEW 

Plan in that the zoning provision for Ridgeland Elementary School 

is the same. These plans differ in that the HEW Plan is based 

on pairing while appellees is based on zoning. Appellees plan 

will produce the following statistics and will comply with the con- 

stitutional requirements of unitary school system: 

School White Negro Total 

Madison-Ridgeland 301 180 401 

Ridgeland Elementary 253 10NHEW Est) 362 

Rosa Scoit 256 668 924 

3. The appellees' plan and the HEW Plan differ for Zone 

III (or the western zone) in that the HEW rests on pairing and the 

appellee's rely on zoning. Appellees' plan will produce the fol- 

lowing statistics.  



  

TE Top wy TE Rr oT ATSC ERI PE, © 

  

Shae Rs mm, 

  

School White Negro 'T otal 

Flora 235 131 416 

Fast Flora 141 619 760 

NOTE: These figures are estimates based upon present and 

past enrollment figures and are accurate assuming that there 

1s no mass migration from the district and attendance remains 

constant. 

GC. The Appellees Plan Can Be 

Implemented With The Least 

Amount of Delay, and Confusion. 
  

It is readily apparent that the transition fo a zoning plan 

as proposed by appellees can be accomplished with the least 

amount of confusion. Transportation routes require less change, 

class rooms require less rearranging and the reassignment of 

students faculty and staff can be facilitated. 

SUMMARY   

It is submitted that the proposed order of the appellees be 

accepted by the Court. 

Respectfully submitted 

MADISON Sng POAOOL DISTRICT 

2 if or dr 
Its Attorney 
  

R. L.. Goza 

114 W. Center Street 

Canton, Mississippi 39046 

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