Allen v. County School Board of Prince Edward County, VA Brief for Appellees

    U nited S tates C ourt of A ppeals 
for the F o u rth  C ircuit

No. 7463

EVA ALLEN, e t  a l .,
Appellants,

v.

COUNTY SCHOOL BOARD OF PRINCE 
EDWARD COUNTY, VIRGINIA, et  a l .,

Appellees.

APPEAL FROM T H E  U N ITED  STATES DISTRICT COURT FOR T H E  
EASTERN DISTRICT OF V IRG IN IA , RICHM OND DIVISION

BRIEF FOR APPELLEES

H unton , W illiams, Gay, 
Moore & P owell 

Of Counsel

Dated September 30, 1957.

K enneth  C. Patty
Attorney General of Virginia 
Court Library Building 
Richmond, Virginia 

H enry T. W ickham
Special Asst, to the Attorney General 
State-Planters Bank Building 
Richmond, Virginia 

Counsel for the
Commonwealth of Virginia

T. Justin Moore 
A rchibald G. Robertson 
John W . R iely 
T. Justin Moore, Jr.

1003 Electric Building 
Richmond 12, Virginia

Counsel for the Prince Edward 
County School Authorities

F I L E  D

R, M. F, WILLIAMS, JR-



TABLE OF CONTENTS

Page

I. Introduction .............................................................................  1

II. Statement o f  the Ca s e .........................................................  2

III. Question P resented .....................................................................  5

IV. A rgument ........      5

1. The Broad Discretion Vested in the District Court.........  5

2. The Exercise of Discretion ............................................... 9

V. Conclusion .........          15

TABLE OF CASES

Aaron v. Cooper, 243 F. 2d 831 (C. A. 8, 1957) ...........................  13

Avery v. Wichita Falls Independent School District, 241 F. 2d 230 
(C. A. 5, 1957), cert, denied, 353 U. S. 938 (1957) ......... .......  15

Davis v. County School Board of Prince Edward County, 103 F.
S. 337 (E. D. Va. 1952), reversed, 347 U. S. 483 (1954), 349 
U. S. 294 (1955), on mandate 142 F. S. 616 (E. D. Va. 1955)

2, 3, 6, 7

School Board of Charlottesville v. Allen, 240 F. 2d 59 (C. A. 4, 
1956), cert, denied, 353 U. S. 910, 911 (1957) .......................

School Board of Newport News v. Atkins, .... ......  F. 2d .......... .

(C. A. 4, July 13, 1957) 13



I .

INTRODUCTION

In its final determination in the original school segrega­
tion cases, of which this is one, the Supreme Court rejected 
suggestions that it take forthright action to end segregation 
in the public schools at once. It recognized that local con­
ditions varied and it authorized local judges to vary the 
remedies that they authorized on the basis of local condi­
tions as they determined their relationship to the problem.

This was a broad and unfettered grant of discretion. 
Here an able judge, familiar with local conditions, has 
availed of that discretion to arrest the exercise of judicial 
power for a temporary period because of impelling cultural 
and civic factors.

The appellants pursue a relentless course. They are not, 
of course, the named appellants; they are the organized 
Negro N.A.A.C.P. lobby who appear as ever by the same 
counsel. They seek to overturn not only the District Court 
but the Supreme Court. They assert that the Supreme Court 
was sociologically wrong in thinking that local factors are 
important; they assert that immediate amalgamation is 
always the best solution (Appellants’ Brief, pp. 14-5).

We rely here on the action of the Supreme Court, and 
we rely in confidence, even if principles of sociology are to 
replace principles of law in judicial determinations. We 
accept the rule of discretion; we suggest that the only ques­
tion at issue here is whether this Court can say that, in the 
light of the school segregation decisions and the facts of 
record here, it would be unreasonable for a reasonable judge 
to hold that immediate action was not required. To state 
that issue is to answer it; the District Court should there­
fore be affirmed.



2

II.

STATEMENT OF TH E  CASE

_ This case has never been to this Court before, but its 
history is long. Although for unexplained reasons a new 
plaintiff heads the list of appellants, it is still Davis v. 
County School Board of Prince Edward County, 103 F. S. 
337 (E. D. Va. 1952), reversed, 347 U. S. 483 (1954), 
349 U. S. 294 (1955), The proceedings before that reversal 
are too familiar to require restatement here.

After the second Supreme Court opinion, the case came 
back to the three-judge District Court. A number of plead­
ings were filed (P. A. 1-131)- On July 18, 1955, the three- 
judge District Court entered a final decree as follows:

“That the defendants be, and they are hereby, re­
strained and enjoined from refusing on account of race 
or color to admit to any school under their supervision 
any child qualified to enter such school, from and after 
such time as the defendants may have made the neces­
sary arrangements for admission of children to such 
school on a non-discriminatory basis with all deliberate 
speed as required by the decision of the Supreme Court 
m this cause; but the court finds that it would not be 
practicable, because of the adjustment and rearrange­
ment required for the purpose, to place the Public 
School System of Prince Edward County, Virginia, 
upon a non-discriminatory basis before the commencing 
of the regular school term in September 1955 as re­
quested by the plaintiffs, and the court is of the opinion 
that the refusal of the court to require such adjustment 
and rearrangement to be made in time for the said 
September 1955 school term is not inconsistent with the 
public interest or with the decision of the SuDreme 
Court----- ” (P. A. 15)

t \ The,inilV!? f  - A. refer to the Appendix to the Brief for the Appel­
lants ; the initials A. A. refer to the Appendix to this brief.



3

No appeal was taken from that final order but the matter 
was retained on the docket. There the matter rested for 
nine months. But the appellants were restive; on April 23, 
1956, they filed a Motion for Further Relief (P. A. 15-24). 
This motion is the origin of the present appeal. The plead­
ing was a long one. It reviewed prior proceedings in the 
case. It came next to a review of action considered by the 
appellants to be relevant that had been taken by the Com­
monwealth of Virginia over the preceding nine months. It 
asserted that no additional time was necessary “in the public 
interest” in order to effect desegregation (P. A. 23). It 
accordingly requested immediate desegregation effective with 
the opening of the schools in the fall of 1956 {ibid.).

The appellees answered this pleading by a showing of 
facts (P. A. 24-7; A. A. 12-26). The pattern of State action 
was reviewed, and developments in Prince Edward County 
were detailed for the District Court. These facts must 
appear irrelevant to the appellants, for they do not present 
them to this Court along with their brief; they will, how­
ever, be found in the appendix to this brief, and they consti­
tute, of course, the factual basis for the decision on appeal 
here.

The three-judge District Court met and dissolved itself 
on its own motion since no issue of the constitutionality of 
a statute remained.2 Before any decision by the single Dis­
trict Judge, the appellees filed a further motion. In it, they 
asserted that the appellants had failed to exhaust admin­
istrative remedies provided by recent Virginia legislation 
and to seek remedies available to them under the final order 
then existing (P. A. 28). The case was then argued and 
submitted.

2142 F. S. 616 (1956).



4

The opinion of the District Court is a very careful and 
thorough one (P. A. 29-48). The Court first reviewed 
prior proceedings in the case (P. A. 29-30) and then came 
to the recent Virginia legislation. The conclusion reached 
was that, on the record as it then was, the effect of those 
statutes was not before the Court (P. A. 31-4).3 The Dis­
trict Court then passed to the propriety of granting to the 
appellants the relief that they so impetuously sought. The 
breadth of discretion permitted by the Supreme Court in the 
light of varying local conditions was made manifest (P. A. 
35-8). The Court then reviewed conditions in Prince Ed­
ward County and the problems presented for its schools 
(P. A. 40-3). It was clear from the record that, regardless 
of State statutes, the schools would be closed entirely if inte­
gration were to be required. The effect on children and 
teachers of abandonment of the public schools was weighed 
(P. A. 44-5). The conclusion reached was that the dangers 
of granting relief much outweighed the asserted losses of 
the appellants. The allowance of additional time was held 
“imperative” (P. A. 47). Accordingly, no action on the 
Motion for Further Relief was taken, but the appellants 
were given leave to renew it after a reasonable time (P. A. 
47-8).

This opinion was handed down on January 23, 1957. An 
order conforming to the opinion was entered on March 26, 
1957 (P. A. 48), and this appeal followed.

3The appellants now seek half-heartedly to object to this conclusion 
(Brief, pp. 17-18). But all of that is immaterial here. Those statutes 
have already been before this Court and are now before both the Su­
preme Court of Appeals of Virginia and the Supreme Court of the 
United States.



5

III.
QUESTION PRESENTED

Only a single question is in fact presented by this case:

In the light of the broad range of judicial discretion 
specifically granted to local courts by the Supreme 
Court in school segregation matters, was it an abuse of 
discretion on the part of the District Court in the light 
of the facts shown of record here to refuse to order 
immediate integration of the public schools of Prince 
Edward County, Virginia?

Clearly the answer to this question should be in the nega­
tive.

IV.

ARGUMENT

1.

The Broad Discretion Vested in the 
District Court

The appellants in essence urge in this case that immediate 
integration is the only course to be permitted in the public 
schools of Prince Edward County, Virginia. This argument 
seeks to overturn the explicit ruling of the Supreme Court 
in the school segregation cases.

In its 1954 decision in this case, the Supreme Court 
called for reargument on the question of relief. It posed 
five possible solutions to be considered by it. They were:
(1) admit Negroes forthwith to the school of their choice;
(2) appoint a special master to hear evidence and recom­

mend to the Supreme Court detailed decrees on how to 
integrate;



6

(3) formulate specific decrees in the Supreme Court for 
each case without the assistance of a special master;

(4) fix a time limit in which desegregation must be begun 
and carried forward as recommended by the Attorney 
General of the United States; or

(5) remand the cases to the District Courts to consider and 
enter further decrees in the light of local conditions.

The Supreme Court refused to take hasty or generalized 
action; it recognized that any single rule was impossible. 
It chose the fifth alternative over the opposition of the 
successful appellants there and of the United States. Its 
reasons for doing so were made clear:

“Full implementation of these constitutional princi­
ples may require solution of varied local school prob­
lems. School authorities have the primary responsi­
bilities for elucidating, assessing, and solving these 
problems; courts will have to consider whether the 
action of school authorities constitutes good faith im­
plementation of the governing constitutional principles. 
Because of their proximity to local conditions and the 
possible need for further hearings, the courts which 
originally heard these cases can best perform this judi­
cial appraisal. Accordingly, we believe it appropriate 
to remand the cases to those courts.” (349 U. S. at p. 
299)

The Supreme Court was content to give only general 
directions to the District Courts:

“In fashioning and effectuating the decrees, the 
courts will be guided by equitable principles. Tradi­
tionally, equity has been characterized by a practical 
flexibility in shaping its remedies and by a facility for 
adjusting and reconciling public and private needs.



7

These cases call for the exercise of these traditional 
attributes of equity power. At stake is the personal 
interest of the plaintiffs in admission to public schools 
as soon as practicable on a nondiscriminatory basis. To 
effectuate this interest may call for elimination of a 
variety of obstacles in making the transition to school 
systems operated in accordance with the constitutional 
principles set forth in our May 17, 1954, decision. 
Courts of equity may properly take into account the 
public interest in the elimination of such obstacles in a 
systematic and effective manner. But it should go with­
out saying that the vitality of these constitutional princi­
ples cannot be allowed to yield simply because of dis­
agreement with them.” {Id. at p. 300)

The District Court here was struck by the care with which 
the Supreme Court had acted. It referred to that Court’s 
language as to the variety of local conditions and problems 
and continued:

“Bearing in mind that the only legal issue in this 
case pertains to a right guaranteed by the Constitution, 
this language coupled with the action of the Court, takes 
on significance which can hardly be over emphasized. 
It is elementary law that one deprived of a right guar­
anteed by the Constitution ordinarily is afforded im­
mediate relief. Notwithstanding this fundamental prin­
ciple, the Supreme Court in this case has seen fit to 
specifically declare that while the plaintiffs are entitled 
to the exercise of a constitutional right, in view of the 
grave and perplexing problems involved, the exercise 
of that right must be deferred. With that declaration 
the Court used equally forceful language indicating that 
it realizes that conditions vary in different localities. 
Consequently, instead of simply declaring the right and 
entering a mandate accordingly, it has seen fit in the 
exercise of its equity powers to not only defer until a 
later date the time when the right may be exercised,



8

but to clearly indicate that the time of exercising such 
right may vary with conditions. A realization of the 
effect of this action on the part of the Court is of su­
preme importance to an understanding of the course to 
be pursued by the Courts of first instance. At the risk 
of being repetitious, I again recall that: Before laying 
down those principles, the Court considered and rejected 
the suggestion that negro children should be forthwith 
admitted to schools of their choice; rejected the sug­
gestion that it formulate detailed decrees; rejected the 
suggestion that a special master be appointed by it to 
hear evidence with a view to recommending specific 
terms for such decrees and adopted the proposal that 
the Court in the exercise of equity powers direct an 
effective gradual adjustment under the order of the 
Courts of first instance. Further, the Court considered 
and rejected the suggestion that a specified rule of 
procedure be established for the District Courts but 
placed upon those Courts the responsibility of consider­
ing, weighing and being guided by conditions found to 
prevail in each of the several communities to be affected 
by their decrees.” (P. A. 37-8)

The District Court then passed to a formulation of the 
rule established by the Supreme Court. This was done with 
great care as follows:

“Boiled down to its essence, in the Second Brown 
Case the Court after pointing out that the local school 
authorities have the primary responsibility of finding 
a solution to the varied local problems, proceeded to 
observe that the District Courts are to consider whether 
the actions of the local authorities are in good faith; 
and that by reason of their proximity to local condi­
tions those Courts can best appraise the conduct of the 
local authorities. It is then pointed out that in so 
appraising, the Courts should be guided by the tradi­
tionally flexible principles of equity for adjusting and 
reconciling public and private needs. To be considered



9

is the personal interest of the plaintiffs, as well as the 
public interest in the elimination of obstacles in a sys­
tematic and effective manner. During this period the 
Courts should retain jurisdiction of the cases. The 
Court has here clearly and in unmistakable terms placed 
upon the District Judges the responsibility of weighing 
the various factors which prevail in the respective locali­
ties affected. There is here a recognition of the obvious 
fact that in one locality in which conditions permit, a 
change may be effected almost immediately. In other 
localities a specified period appropriate in each case 
may be feasible and a definite time limit fixed accord­
ingly. In yet other communities a greater time for com­
pliance may be found necessary. It is clear that the 
Court anticipated the application of a test of expediency 
in such cases so that an orderly change may be accom­
plished without causing a sudden disruption of the way 
of life of the multitude of people affected.” (P. A. 
38-9)

This analysis is, we submit, a correct one. It presents a 
path to solution that is moderate and considerate; yet no 
opportunity is permitted for evasion in the end. It author­
izes the courts to take into account the welfare of the people 
as a whole and to perform the traditional function of a court 
of equity to weigh the injury to the plaintiff against the 
damage that will result from the grant of the relief 
requested.

This determination by the District Court was right. It 
was authorized by the Supreme Court. This breadth of per­
mitted discretion must not be overlooked in a review of the 
application of the rule so formulated.

2.

The Exercise of Discretion

The question faced by the District Court was to apply 
this rule to the facts of the case before it.



10

That is not the same question as the one presented to this 
Court. The question here is quite different: with recogni­
tion of the broad area of discretion given to the local Dis­
trict Courts to evaluate all factors in a particular local 
situation, can this Court say that the District Court abused 
its powers in delaying immediate integration ? Is it incredi­
ble that a reasonable judge acting within the framework so 
established by the Supreme Court could have found it proper 
to delay integration? We submit that negative answers to 
these questions are required.

To test this result, we turn to the facts. The District 
Court saw them in quite a different way from that in which 
they are presented here by the appellants. It found Prince 
Edward County to be a locality which had slowly but steadily 
made an economic recovery from the poverty which pre­
vailed there following the War Between the States. It 
found that racial relations had improved in recent years 
and that school facilities now provided for Negro children 
were equal or superior to those for the white. But public 
sentiment had changed sharply since the Supreme Court 
acted, and the school authorities had been hard pressed to 
keep open the public schools of the County. These officials 
have no taxing power under Virginia law and, while they 
prepared and submitted annual budget requests to the Board 
of Supervisors (the County tax-levying body), funds have 
been appropriated to the school authorities only on a month 
to month basis. Moreover, the Board of Supervisors has 
publicly announced its intention to cut off further appropria­
tions if the County schools are mixed racially at this time. 
More than 4,000 residents of the County have signed a 
petition supporting this position of the Board of Super­
visors ; they are elected, but the school officials are not (P. A. 
40-3). The total population of the County is about 15,000 
(A. A. 17), so the signers were more than a quarter of all



11

the people. Tentative and substantial plans have been made 
for a private school system for white pupils in the event 
of immediate integration, but no similar provision had been 
made for the Negro (P. A. 45). The District Court found 
it uncontroverted that race relations were more strained 
than at any time during the present generation (P. A. 43). 
It further found as a fact that, if the requested relief were 
granted, permanent injury to children of both races would 
result (P. A. 47). It concluded:

“A sudden disruption of reasonably amicable racial 
relations which have been laboriously built up over a 
period of more than three and a quarter centuries would 
be deplorable. At any reasonable cost, it must be 
avoided.” (P. A. 46)

This does not mean inaction for an indefinite period. The 
District Court said:

“I believe the problems to be capable of solution but 
they will require patience, time and a sympathetic 
understanding. They cannot be solved by zealous advo­
cates, by an emotional approach, nor by those with 
selfish interests to advance. The law has been an­
nounced by the Supreme Court and must be observed 
but the solution must be discovered by those affected 
under the guidance of sensible leadership. These facts 
should be self evident to all responsible people.” (P. A. 
43-4)

and it added:

“Many minds are now engaged in seeking an equita­
ble solution to the problem. . . .  It is inconceivable that 
any of the litigants or other persons affected would 
willingly see the public school system abolished or an 
interruption in the education of the children of the 
county.” (P. A. 47)



12

The District Court concluded that the appellees “have 
done all that reasonably could be required of them in this 
period of transition” (P. A. 46-7). That result of necessity 
follows because:

“It is imperative that additional time be allowed the 
defendants in this case, who find themselves in a posi­
tion of helplessness unless this Court considers their 
situation from an equitable and reasonable viewpoint.” 
(P. A. 47)

This is an impressive and thoughtful review of local con­
ditions leading to a considered conclusion. The appellants 
assert first that it is sociologically wrong and, as an after­
thought, add that it is legally wrong.

We do not propose to argue sociology to this Court. We 
note that some of the cited names (Brief, pp. 14-5) are the 
same as those of witnesses who were discredited in the 
original hearing of this case; we likewise note with interest 
the absence of the name of Gunnar Myrdal. We have no 
doubt that we could obtain or have prepared a list of articles 
equally imposing in length and expressing views diametrical­
ly opposed to those held by the cited experts. We suggest 
that facts (of which this Court may take judicial notice) as 
to events in Arkansas, North Carolina and Tennessee make 
absurd the argument that immediate integration is the only 
proper path.

This is the only case that has come before this Court (or 
any other court of which we are aware) where the uncon­
tradicted evidence shows that all public schools in the area 
will be closed if integration is ordered at the present time. 
We reemphasize that this result will occur not as the result 
of State statutes but because of united local sentiment that 
will cut off all local funds for the support of the schools. This 
is not Charlottesville, Arlington, Newport News or Norfolk



13

where other District Courts have not found that such facts 
exist. In Newport News and Norfolk, the District Court 
expressed the opinion that the schools would continue re­
gardless of the order entered. In those cases, under differ­
ent facts, the District Courts exercised their discretion to 
require desegregation to begin more rapidly and their deci­
sions have been upheld by this Court as being within the 
broad range of discretion allowed to the District Courts.4 
But the review of discretion is the same without regard 
to how it has been exercised. The same principles apply no 
matter whether or not a District Court concludes that inte­
gration should be required at the present time. The District 
Court decided here that immediate desegregation is not 
required on the basis of the facts of record before it and this 
Court’s decisions from other Virginia localities support its 
action regardless of what the appellants suggest (Brief, pp. 
10-11, 15). In the joint appeal in the Charlottesville and 
Arlington cases Chief Judge Parker, speaking for this 
Court, summarized the reasons for affirming the lower 
courts’ orders by saying:

“There is no basis for the contention that either of 
the judges below abused his discretion. . . . ” (240 F. 
2d at p. 64)

It is appropriate here to note the language of the Eighth 
Circuit Court of Appeals in the Little Rock, Arkansas, case.5 
There the District Court denied the Negro request for an 
injunction to speed up integration in Little Rock. In affirm­
ing this action the Circuit Court, speaking through Judge 
Vogel, said:

i School Board of Charlottesville v. Allen, 240 F. 2d 59 (C. A. 4, 
1956), cert, denied, 353 U. S. 910, 911 (1957) ; School Board of New­
port News v. A tkins,.....F. 2 d ....... (decided July 13, 1957).

5 Aaron v. Cooper, 243 F. 2d 361 (C. A. 8, 1957).



14

“Appellants cite to us several cases where Federal 
Courts have used their injunctive powers to speed up or 
effectuate integration. Willis v. Walker, D.C.W.D. 
Ky. 1955, 136 F. Supp. 177; Thompson v. County 
School Board of Arlington County, D.C.E.D. Va. 
1956, 144 F. Supp. 239; Clemons v. Board of Educa­
tion, 6 Cir., 1956, 228 F. 2d 853, certiorari denied 1956, 
350 U. S. 1006, 76 S. Ct. 651, 100 L. Ed. 868; Booker 
v. State of Tennessee Board of Education, 6 Cir., 1957, 
240 F. 2d 689. These decisions serve only to demon­
strate that local school problems are 'varied’ as referred 
to by the Supreme Court. A reasonable amount of time 
to effect complete integration in the schools of Little 
Rock, Arkansas, may be unreasonable in St. Louis, 
Missouri, or Washington, D. C. The schools of Little 
Rock have been on a completely segregated basis since 
their creation in 1870. That fact, plus local problems 
as to facilities, teacher personnel, the creation of teach­
able groups, the establishment of the proper curriculum 
in desegregated schools and at the same time the main­
tenance of standards of quality in an educational pro­
gram may make the situation at Little Rock, Arkansas, 
a problem that is entirely different from that in many 
other places. It was on the basis of such 'varied’ school 
problems that the Supreme Court in the second Brown 
decision remanded the cases there involved to the local 
District Courts to determine whether the school author­
ities, who possessed the primary responsibility, have 
acted in good faith, made a prompt and reasonable start, 
and whether or not additional time was necessary to 
accomplish complete desegregation.” (243 F. 2d at pp. 
363-4)

We believe that subsequent events in Little Rock have 
proved the wisdom of this decision.

Those who are familiar with conditions in Prince Edward 
County or who have read the record in this case will immedi­
ately realize that conditions there are difficult in the extreme.



15

The District Court has weighed the factors that it was 
instructed to weigh by the Supreme Court. These factors 
include the right of Negro children to attend integrated 
schools as soon as feasible, the overall public interest in­
volved, the necessity for adjustment in attitudes, and the 
planning required to devise an integrated system. It very 
properly concluded that integration should not come here 
at once. This is not due to any fault on the part of the school 
authorities. Indeed, they are responsible community leaders 
who have had to fight to keep the public schools of the 
County open in any manner. This fight has had to be car­
ried on without tax-levying powers and within the frame­
work of State law. Who could have done more? Who in 
Prince Edward County can finally bring about integration 
if these men cannot ? The District Court wisely exercised its 
discretion in favor of allowing them more time for the 
moment.6 Its decision should be affirmed.

V.
CONCLUSION

In the rural area of Prince Edward County, the continu­
ance of public education hangs on the decision in this case. A 
wise judge, familiar with local affairs, has exercised the 
broad discretion conferred on him by the Supreme Court to 
defer compulsory immediate integration. The choice pre­
sented by the appellants here is a limited one: they say that,

. 81?, this connection the Court’s attention is invited to the interest- 
mg dissent filed by Judge Cameron in the recent school case of Avery 
v. Wichita Falls Independent School District, 241 F. 2d 230 (C. A. S 
1957), cert, denied, 353 U. S. 938 (1957), where he states:

The Supreme Court has recognized as imposed upon the 
District Courts responsibilities of statesmanship in addition to 
the duty to pass upon legal points.”



16

without regard to the excellent schools that they now have, 
the schools must either integrate or close. The choice is 
not so radically narrow, as the District Court pointed out. 
Its action should be affirmed.
Dated September 30, 1957.

Respectfully submitted,

K enneth  C. P atty
Attorney General of Virginia 
Court Library Building 
Richmond, Virginia 

H enry T. W ickham
Special Asst, to the Attorney General 
State-Planters Bank Building 
Richmond, Virginia 

Counsel for the
Commonwealth of Virginia

H unton , W illiams, Gay, T. Justin  Moore
Moore & P owell A rchibald G. Robertson

0} Counsel John W. R iely
T. Justin Moore, Jr.

1003 Electric Building 
Richmond 12, Virginia

Counsel for the Prince Edward 
County School Authorities