Motion to Sever
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January 14, 1986
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Case Files, Sheff v. O'Neill Hardbacks. Defendants' Reply Memorandum in Support of Their Motion for Summary Judgment, 1991. 97780580-a146-f011-877a-002248226c06. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/6ac8e575-7387-4a9b-821a-304650abd815/defendants-reply-memorandum-in-support-of-their-motion-for-summary-judgment. Accessed August 19, 2025.
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Cv 89-0360977S
MILO SHEFF, et al SUPERIOR COURT
J.D. HARTFORD/NEW
Plaintiffs > NEW BRITAIN AT HARTFORD
Ye.
WILLIAM A. O'NEILL, et al
Defendants NOVEMBER 6, 1991
DEFENDANTS ' REPLY MEMORANDUM IN SUPPORT OF
THEIR MOTION FOR SUMMARY JUDGMENT
I. INTRODUCTION
Pared to its essence the plaintiffs' reply to the
defendants' summary judgment motion makes it evident that the
court has two fundamental legal questions before it which are
ripe for determination by way of this motion for summary
judgment. Those two questions go to the heart of the controversy
in this case and no amount of direct testimony, expert opinion or
further development of the facts in this case at trial will
change the resolution of these two dispositive questions.
Stated succinctly, the first question is whether a
"condition" which is not the product of unlawful state action
may, by itself, violate Article I, Section 20 and Article VIII,
Section 1 of our state constitution. The plaintiffs say "yes"
and they ask for an opportunity to convince the court that the
particular conditions which they are concerned about are ones
which the court ought to declare unconstitutional. The
defendants disagree. They contend that the courts may intervene
to correct a "condition" only when that condition is the result
of some unlawful state action, none of which has been identified
here.
The second fundamental legal question is whether Article I,
Section 20 and Article VIII, Section 1 authorize the court to
determine or to measure the appropriate legislative response to a
condition which is not the product of unlawful state action.
Again, plaintiffs say "yes", arguing that the court is the final
arbiter as to what is "appropriate" unless and until the
"condition" is eliminated. The defendants’ disagree on the
ground that so long as legislative action is properly directed
and not otherwise unlawful the general assembly is the final
arbiter of what is an "appropriate" response to existing
conditions.
Summary judgment is warranted in this case because, as is
clear from the arguments by both the plaintiffs and the
defendants, at the end of the day this case will turn on the
purely legal issues presented by this motion -- whether the State
can be held to have violated the constitution for societal
conditions that are not the product of unlawful state action, and
whether the court has the authority to supplant the state
legislature in determining how to deal with problems that are not
the product of unlawful state action.
II. PLAINTIFFS' LEGAL ARGUMENTS CANNOT SUPPORT A
DETERMINATION THAT THE STATE HAS VIOLATED THE CONSTITUTION.
In their motion for summary judgment the defendants
offer and support the following legal point:
Judgement Should Be Entered For The
Defendants Because The State Has Not Engaged
In Conduct Which Violates The Constitution
And Because There Is No Judicial Remedy
Available To The Plaintiff.
Memorandum in Support of Defendants' Motion for Summary Judgment
and Supporting Material (PART ONE), pp. 47-85.
Plaintiffs respond to this point with two basic claims. First,
they claim that the state constitution outlaws certain
"conditions" even though those conditions are not a product of
unlawful state action. Plaintiffs' Memorandum In Opposition to
Defendants' Motion for Summary Judgment, p. 6 (hereafter referred
to as Plaintiffs' Reply). Second, they claim that the
constitution makes the courts rather than the general assembly
the final arbiter of what measures are "appropriate" to address
"conditions" affecting education including those which are not
the product of unlawful state action. Plaintiffs' Reply, p. 21.
Plaintiffs' positions are not supported by the law.
A. The Constitution Does Not, As The Plaintiffs Claim, Outlaw
"Conditions" Which Are Not The Product Of Unlawful State Action.
Plaintiffs rely on the Supreme Court decision in Horton v.
Meskill, 172 Conn. 615, 376 A.2d 359 (1977) (Horton 1) and
speculation about the intentions of those who drafted Article I,
Section 20 in 1965 to support their hypothesis that the state
constitution outlaws certain "conditions" even though those
"conditions" are not the product of unlawful state action. The
plaintiffs misread both Horton I and the legislative history
behind Article I, Section 20.
Plaintiffs would have this court believe that the Horton I
decision was based upon a finding that certain "conditions" which
were not the product of unlawful state action violated the state
constitution. According to the plaintiffs' reading of Horton I,
it was "the wide variations in property tax revenues available to
the various towns" which the court declared unconstitutional.
Plaintiffs' Reply, p. 6. Plaintiffs maintain that the court was
not acting upon a finding of unlawful state action because "there
was no finding that the state created the wide variations in
property tax revenues available to the various towns". 1d. To
make this argument the plaintiffs ignore the obvious, namely that
it was the state's action in adopting and in implementing a
school financing scheme which, taken as a whole, inequitably
distributed the resources necessary to provide a basic education
which the court declared unconstitutional in Horton I.
Although this point seems rather obvious from a reading of
Horton I alone, any lingering thoughts that the Horton I court
was focusing on unconstitutional "conditions" rather than
unconstitutional state action is dispelled by Chief Justice
Peters' decision in Horton III. Horton v. Meskill, 195 Conn. 24,
486 A.2d 1099 (1985). By the time Horton III came before the
court the way the state was acting had changed. In contrast
there was little evidence that the "conditions" which were before
the court when Horton I was decided had changed. See Horton III,
195 Conn. at 39, n. 15. Focusing on the changes in the way in
which the state was acting the court ruled in favor of the state.
There is little doubt that the court would have reached the
opposite result if, as the plaintiffs suggest, the court's focus
was on "conditions" rather than unlawful state action.
Plaintiffs' reliance on the legislative history behind
Article I, Section 20 to support their claim that our
constitution outlaws certain conditions even though those
conditions are not the product of unlawful state action, is no
more justified than their reliance on Horton I. The plaintiffs
claim that the insertion of the word "segregation" into Article
I, Section 20 during floor debate over the amendment was
intended to make it clear that the constitution outlawed de facto
"conditions" of segregation as well as de jure segregation is
clearly wrong.
As adopted Article I, Section 20 reads; "No person shall
be denied the equal protection of the law nor be subjected to
segregation or discrimination in the exercise or enjoyment of his
civil or political rights because of religion, race, color,
ancestry or national origin."
If the plaintiffs' reading of Article I, Section 20 is
correct then the addition of the word "segregation" during the
floor debates was certainly an event of monumental importance.
1/ the adoption of this amendment to the constitution would have
required immediate remedial action in regard to the assignment of
children to public schools since, as is evident from Exhibit 8,
attached hereto, the de facto concentration of minorities in our
inner city schools was already a reality when Article I, Section
20 was being considered. If it was the intention of the framers
that the amendment have the force which the plaintiffs suggest it
was intended to have, one would expect that the legislative
history of the amendment would be marked with discussion of the
extraordinary consequences of adopting the amendment. However,
there is no such discussion in the legislative record.
The truth is that the legislative record makes it abundantly
clear that the insertion of the word "segregation" into the
proposal brought to the floor was not viewed as having anywhere
near the significance which the plaintiffs ascribe to that event.
Any suggestion that the insertion of the word "segregation" was
known and intended to carry with it the far reaching implications
1/ The plaintiffs' reading of Article I, Section 20 would
impose a duty on the state to prohibit even the voluntary
assemblage of people of the same religion, race, color or
national origin because such an assemblage would create a de
facto "condition" of segregation.
-F
the plaintiffs claim it has is utterly refuted by the words of
Justice Patrick B. O'Sullivan at the conclusion of the debate
over the addition of this word. Acting in his role as convention
chair Justice O'Sullivan said; "The Chair at this time will rule
that this amendment is not a substitive (sic) change and
therefore we can act upon the entire bill today." See Journal of
the Constitutional Convention, 1965, p. 696.
It seems rather clear from the debate which preceded
Justice O'Sullivan's ruling that this amendment to the proposal
brought to floor was designed to address concerns by some, but
not all, of those at the convention that the term
"discrimination" might be read in some limited fashion. Id. pp.
691-696. A review of accepted definitions of the terms
"discriminate" and "discrimination" does evidence a tendency in
common parlance to view those terms as carrying with them the
implication of being both separated and disadvantaged. On the
other hand the terms "segregate" and "segregation" seem to imply
only being separated. See Bibliography, Exhibit 9, attached
hereto. Under these circumstances there appears to have been some
validity to the concerns of those attending the Convention that a
prohibition against government sponsored "discrimination" might
not be read as a prohibition of government sponsored
"segregation". Prohibiting "discrimination" alone might leave
open the possibility that the state could segregate groups of
people on the basis of their religion, race or national origin so
long as the groups were treated equal. For those who were
concerned that Article I, Section 20 as originally drafted would
have prohibited government separation of groups of people only
when one group was disadvantaged, the inclusion of the word
"segregation" made it clear that any act of governmental
separation was prohibited regardless of whether any group was
disadvantaged. For those who did not see the word
"discrimination" as carrying with it any burden of proving that a
group was disadvantaged by that separation, the addition of the
word "segregation" added nothing to the proposal.
The words of Justice Baldwin in support of this amendment to
the proposal confirm the fact that the insertion of the word
"segregation" was intended to clarify this point rather than
carry with it the monumental implications which the plaintiffs
suggest the word has. Referring to the addition of the word
"segregation" Justice Baldwin said:
As a matter of fact we discussed this very
thing in committee and we thought that
segregation was unnecessary to put in there,
but if it will please people, then I am
perfectly agreeable to it being there as a
member of this convention.
See Journal of the Constitutional Convention, 1965, p. 692. It
is clear from this legislative history and the Bibliography in
Exhibit 9, that the common meaning of the term "segregation" is
not now and has never been sufficiently clear to allow the court
to assume that the framers meant "de facto segregation" when they
used the term "segregation" in Article I, Section 20. This
section of the constitution makes it unlawful for the state to
segregate people on the basis of their religion, race or national
origin but it does not require the state to take action to
eradicate de facto concentrations of people of the same religion,
race, or national origin.
Neither Horton I nor the language of Article I, Section 20
provide any support for the plaintiffs' claim that the
constitution outlaws conditions which are not the product of
unlawful state action. The defendants are entitled to judgment
as a matter of law because the conditions which the plaintiffs
complain about are not the product of unlawful state action.
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B. The Constitution Does Not, As The Plaintiffs Claim, Invest
The Court With The Authority To Decide What Measures Are
Appropriate To Address A Condition Bearing On Education Which Is
Not The Product Of Unlawful State Action.
The plaintiffs' legal position in this case raises a very
fundamental question about the role of the courts in litigation
relating to education. There is no doubt that the courts have
the authority to examine specific legislative action to determine
whether that action violates the state constitution as the court
did in Horton I. But here the plaintiffs are not asking the
court to enjoin inappropriate state action. In fact they boldly
admit that "plaintiffs are not complaining about what did or did
not happen in the past". Plaintiffs' Reply, pp. 10-11. Here the
plaintiffs are asking the court to do something far beyond what
was done in Horton I and something which has no precedent in the
law. The plaintiffs are asking the court to order the general
assembly to take "appropriate" action in response to conditions
which are not the product of unlawful state action.2’
2/ On page 2 of their Reply the plaintiffs describe what they
are asking for as follows: "The remedy plaintiffs seek is a
declaration by this Court that the present circumstances violate
the Connecticut Constitution, and an injunction enjoining the
defendants from failing to provide equal educational
opportunity." There is, of course, no real difference between
asking that the defendants be "enjoined" from "failing" to do
something and asking that they be ordered to do something.
all
Article VIII, Section 1 clearly places the responsibility
for choosing the "appropriate" response to conditions effecting
education which are not the product of unlawful state action in
the hands of the general assembly. The unequivocal assignment of
this responsibility to the general assembly will be completely
eviscerated if, as the plaintiffs claim, judicial oversight of
the general assembly in regard to public education goes beyond
questions of whether the general assembly violated the
constitution in the way it acted, and becomes involved with
whether the general assembly has taken "appropriate" action in
response to conditions which are not the product of unlawful
state action.
The degree of judicial oversight which the plaintiffs are
asking the court to engage in will bring about a monumental shift
in the balance of power between legislative and judicial branches
of government. According to the plaintiffs' way of thinking
lawful acts of the general assembly and decisions by the general
assembly to defer action in response to particular situations are
fair game for judicial review. Despite the plaintiffs' claim to
the contrary the dramatic expansion of the power of the judiciary
which they are asking the court to accept is strikingly similar
«13
to the claimed expansion of the power of the judiciary rejected
by the Supreme Court in Pellegrino v. O'Neill, 193 Conn. 670, 480
A.2d 476 (1984). Plaintiffs Reply, pp. 25-26. As Dean MacGill
has pointed out "Any alteration in the legal landscape that
increases the types of issues or the number of cases submitted to
the judicial branch for final resolution necessarily augments the
power of that branch." MacGill, H.C., "Upon a Peak in Darien:
Discovering the Connecticut Constitution", 15 Conn. L. Rev. 7, 16
(1982). Clearly the plaintiffs are looking for an alteration of
the legal landscape that will dramatically expand the types of
issues and number of cases which can be submitted to the judicial
branch for final resolution.
The expansion of the power of the judiciary which the
plaintiffs are asking the court to engage in runs directly
counter to Article VIII, Section 1 and has no support in the
decisions of the Supreme Court. The plaintiffs' remedy is with
the general assembly -- not with the courts. Clearly the
legislature has considered and acted upon the conditions about
which the plaintiffs complain. It is not within the power of the
court to interject itself into ongoing efforts of the executive
and legislative branches of government to address the conditions
wil 3
which the plaintiffs complain about unless these conditions are
being addressed in an unlawful way.
III. THE COURT IS NOT CONSTRAINED BY THE LAW OF THE CASE
FROM DECIDING THE ISSUES PRESENTED IN THE DEFENDANTS' MOTION
FOR SUMMARY JUDGMENT.
Besides offering the court faulty legal arguments to support
their opposition to the defendants' motion for summary judgment,
the plaintiffs oppose the defendants' motion by claiming that a
ruling on the motion is procedurally barred by the "law of the
case" doctrine. Plaintiffs' Reply, pp. 2-4.
Although the plaintiffs agree that this court deferred a
"conclusive disposition" of the issues raised in the defendants’
motion to strike until a later stage of this case, the plaintiffs
suggest that the court should decline the opportunity to consider
similar issues raised in this motion for summary judgment because
the law of the case has been established. Plaintiffs' Reply, pp.
2-4. However, since the court did not conclusively resolve the
issues presented by the defendants' motion to strike in its
earlier decision, the law of the case doctrine has no bearing
whatsoever on the defendants' motion for summary judgment.
But even if it is assumed that law of the case doctrine
could be invoked here, it is not a proper basis upon which the
court should rule out the possibility that this case can be
disposed of without a lengthy and expensive trial. The law of
the case is a flexible doctrine which has not been applied in the
manner which the plaintiffs suggest that it be applied here.
Carothers v. Capozziello, 215 Conn. 82, 107, 110, 574 A.2d 1268
3/
(1990). Particularly pertinent in this case are those cases in
which the trial court was asked to consider a motion for summary
judgment raising the same issues considered and ruled on by the
court on an earlier motion for summary judgment. In Mac's Car
City, Inc. v. American National Bank, 205 Conn. 2855, 262, 532
A.2d 1302 (1987), and Barnes v. Schlein, 192 Conn. 732, 734, 473
A.2d 1221 (1984), the Supreme Court rejected arguments that the
trial court was forbidden by the law of the case from considering
the renewed motions for summary judgment. In Mac's Car City,
|
i Inc., supra, the court emphasized the importance of the summary
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3/ Ironically, the Carothers case is the only case cited by the
plaintiffs in support of their position and it is a case in which
the court concluded that the law of the case doctrine was
"patently inapplicable" to the circumstances before it.
judgment motion as a means of avoiding the delay and expense of
an unnecessary trial as a primary reason for not foreclosing
further examination of the issues presented by the consecutive
summary judgment motions. Id., 205 Conn. at 261.
If it is appropriate for a court to re-examine issues which
have already been presented to the court in an earlier summary
judgment motion on a second summary judgment motion, it certainly
is appropriate for the court to consider issues not conclusively
resolved on an earlier motion to strike when those same issues
are presented by way of a summary judgment motion which is
supported by affidavits and other documentary material the court
did not have and could not have considered when the court passed
on the earlier motion to strike.
Plaintiffs' request that the court invoke the law of the
case doctrine to further postpone resolution of the critical
legal issues raised in the defendants' motion for summary
judgment has no support in the law and makes no practical sense.
III. ALTHOUGH THE PLAINTIFFS AND THE DEFENDANTS DISAGREE
OVER THE RELEVANCY OF THE FACTS WHICH ARE MATERIAL TO THIS
MOTION FOR SUMMARY JUDGMENT, THERE IS NO DISAGREEMENT OVER
THE FACTS THEMSELVES.
“16
1 H
The plaintiffs argue that it would not be appropriate to
grant the defendants' motion for summary judgment because summary
judgment is a practice which is not favored by the courts and
because the court must resolve disputed issues of fact in order
to reach the legal questions which the defendants put before the
court. Plaintiffs are wrong on both counts.
To the extent that any trend can be identified with regard
to the degree to which the courts favor use of the summary
judgment motion, the trend is toward expanding, rather than
limiting, the circumstances under which it is appropriate to
grant summary judgment.
Until 1963, our summary judgment procedure in
Connecticut was narrowly restricted. The
1963 Practice Book, however, greatly expanded
the scope of the procedure with the adoption
of new rules substantially similar to the
procedure provided in the federal rules.
[Citations omitted.] The presence,
therefore, of an alleged adverse claim is not
sufficient to defeat a motion for summary
judgment. A party must substantiate his
adverse claim by specifically showing that
there is a genuine issue of material fact
together with the evidence disclosing the
existence of such an issue. [Citations
omitted. ]
wl?
Farrell v. Farrell, 182 Conn. 34, 38-39, 438 A.2d 415 (1980).
Undoubtedly the summary judgment motion is an important procedure
for conserving our strained judicial resources. A court should
not lightly pass up an opportunity to dispose of a case by way of
a summary judgment motion because, as one commentator on civil
practice in Connecticut has said: "To deny the motion is to deny
the summary judgment rules their usefulness in ferreting out and
disposing of cases that cannot be won." Horton, Ww. "Good Earth
and Summary Judgment", 49 Conn. Bar Jour. 411, 414 (1975).
Although most often thought of as a procedure used by
plaintiffs, the summary judgment motion is also an important
means by which a defendant can be spared the burden and expense
of an unnecessary trial. "A defendant's motion for summary
judgment is properly granted if it raises at least one legally
sufficient defense that would bar the plaintiff's claim and
involves no triable issue of fact. See 10A Wright, Miller &
Kane, Federal Practice and Procedure (2nd. Ed. 1983) § 2734."
Perille v. Raybestos-Manhattan-Europe, Inc., 196 Conn. 529, 543,
494 A.2d 555 (1985).
18
In order to oppose successfully a defendant's motion for
summary judgment, the plaintiff must offer and support facts
which contradict those facts upon which the defendant bases the
summary judgment motion. Daily v. New Britain Machine Co., 200
Conn. 562, 568, 512 A.2d 893 (1986); Farrell v. Farrell, 182
Conn. at 39-40; McColl v. Pataky, 160 Conn. 457, 460, 280 A.2d
146 (1971); Stephenson, Conn. Civil Procedure, 2nd Ed., 1982 Cum.
Supp. by Hon. Alfred V. Covello, p. 5-129. Except in negligence
cases and cases which turn on motive and intent, the courts have
not shied away from the task of looking closely at the facts
which are material to a particular case to determine whether
there is truly the kind of dispute of fact which must be put to
the trier of fact before the case can be decided. See Strada v.
Connecticut Newspapers, Inc., 193 Conn. 313, 317, 477 A.2d 1005
(1984) (Court granted defendants' motion for summary judgment
after finding that allegedly libelous facts and quotations in a
newspaper article "were true or substantially true" despite the
plaintiff's claim to the contrary.) If the factual predicate
upon which a defendant bases a summary judgment motion is not
contradicted and if the law, when applied to that defendant's
factual predicate, defeats a plaintiff's claim, that defendant's
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motion for summary judgment is properly granted. Connell v.
Colwell, 214 Conn. 242, 571 A.2d 116 (1990); Daily v. New Britain
Machine Co., supra; Rivera v. Fox, 20 Conn. App. 619, 569 A.2d
1137, cert. den. 215 Conn. 808, 576 A.2d 538 (1990). This is
precisely the case now before the court.
In the present case three facts provide the factual
predicate for the defendants' motion for summary judgment. They
are:
FACT 1: The defendants and their
predecessors have not, by affirmative act,
assigned or confined children to the Hartford
public schools based upon their race,
national origin, socioeconomic status, or
other status which might be said to put
children "at risk" of poor educational
performance.
FACT 2: There is not now, and never has
been, a distinct affirmative act, step, or
plan which, if implemented, would have
"sufficiently" addressed the conditions about
which the plaintiffs complain.
FACT 3: The general assembly has adopted and
the defendants have implemented legislation
to address the conditions about which the
plaintiffs complain.
Memorandum of Law in Support of Defendants' Motion for Summary
Judgment and Supporting Material (PART ONE), pp. 6-47. Upon
-20
close examination it can be seen that plaintiffs do not seriously
contest these three facts. What becomes evident on close
examination is that the real dispute between the plaintiffs and
the defendants is over the law and the relevance of those facts,
not the facts themselves.
A. Plaintiffs Do Not Contest The Fact The Defendants And
Their Predecessors Have Not, By Affirmative Act, Assigned Or
Confined Children To The Hartford Public Schools Based On Their
Race, National Origin, Socioeconomic Status, Or Other Status
Which Might Be Said To Put Children "At Risk" Of Poor Educational
Performance (FACT 1).
Plaintiffs have not offered a shred of evidence to suggest
that the defendants and their predecessors have, by affirmative
act, assigned or confined children to the Hartford public schools
based upon their race, national origin, socioeconomic status, or
other status which might be said to put children "at risk" of
poor educational performance. To the contrary, on page 8 of
Plaintiffs' Memorandum in Opposition to Defendants' Motion for
Summary Judgment the plaintiffs admit that defendants have not
checked the race or ethnic status of any particular child before
assigning that child to the Hartford public schools.
Consistent with their legal theory in this case the
plaintiffs contest the relevance of FACT 1, not its accuracy.
-2lw
According to the plaintiffs it is enough that the defendants had
knowledge that children of color were attending the Hartford
public schools in concentrated numbers for the court to find that
the defendants violated the law. They argue that, as a matter of
law, no intent to segregate children by race or ethnic origin or
specific state action creating this condition need be shown to
establish that the law has been violated. This is, of course,
the crux of one of the legal issues raised in this motion for
summary judgment. FACT 1 allows the court to reach this legal
issue without the need for a trial.
While FACT 1 may be irrelevant to plaintiffs' legal theory,
it is a fact which, according to the defendant's reading of the
law, makes it clear that the plaintiffs' case cannot be won. The
plaintiffs' failure and inability to offer any evidence which
contradicts FACT 1 makes FACT 1 an appropriate basis upon which
the court can grant defendants' motion for summary judgment.
B. Plaintiffs Do Not Contest The Fact That There Is Not
Now, And Never Has Been, A Distinct Affirmative Act, Step, Or
Plan Which, If Implemented, Would Have "Sufficiently" Addressed
The Conditions About Which The Plaintiffs Complain (FACT 2).
To contradict FACT 2 of the defendants' factual predicate
for their summary judgment motion, the plaintiffs had to offer
2D
the court a distinct affirmative act, step, or plan which, if
implemented, would have addressed the conditions about which the
plaintiffs complain in a manner which the plaintiffs would deem
"sufficient". They have not done so.
Rather than identify specific action which the defendants
should have taken and which would have been "sufficient", the
plaintiffs say that it is up to the defendants to decide what
should be done. Plaintiffs' Reply, p. 10. This admission is
entirely consistent with one of the underlying points of the
defendants' motion for summary judgment; i.e., the defendants’
point that it is a legislative rather than a judicial function to
determine how best to address the conditions about which the
plaintiffs complain. Not only do the plaintiffs fail to
contradict FACT 2, their position in this regard actually
supports FACT 2.
The plaintiffs do not identify distinct actions which the
defendants should have taken that would "sufficiently" address
the conditions they complain about. At the same time, however,
they add to the list of recommendations and ideas, which they
first offered in response to question 5 of the Defendants' First
“33.
Set of Interrogatories (Exhibit 1, pp. 22-29), that have, to one
degree or another, not yet been adopted or funded by the general
assembly. Plaintiffs do not, however, back away from the
statement qualifying their response to defendants' interrogatory
in which they say that they are not prepared to "claim that any
one particular recommendation was required by the state
constitution." Exhibit 1, pp. 23-24. Again, rather than
contradict FACT 2, the plaintiffs' list of ideas for addressing
the plaintiffs concerns which have not been adopted by the
general assembly supports FACT 2 since the plaintiffs are
unwilling to claim that one or more of these ideas is or was a
necessary and "sufficient" means of addressing the plaintiffs’
concerns.
There is one especially notable omission from the
plaintiffs' list of measures for addressing the conditions they
complain about. Missing from the plaintiffs list of ideas for
addressing the conditions they complain about is reference to a
plan of mandatory interdistrict student re-assignment which would
deliberately and with certainty insure the regional racial and
ethnic balance which the plaintiffs have set as the goal of this
litigation. This omission from plaintiffs list provides further
-24-
evidence of the fact that there is no distinct and "sufficient"
method for addressing the conditions which the plaintiffs
complain about that the general assembly might, arguably, have
been obliged to implement.
The Hartford Board of Education examined the possibility of
addressing concerns about racial, ethnic and socioeconomic
isolation in the Hartford area by way of a interdistrict
re-assignment plan in April of 1988. The 1988 study was updated
in April of 1990 and the April 1990 report is attached to this
4/
memorandum as Exhibit 7.
Using 1988 student data, the 1990 report concludes that in
order to bring about regional racial balance in each district in
the Hartford area equal to the mean balance of the entire area "a
total of 30,030 pupils would have to be reassigned and bussed."
The report goes on to say that "[t]lhis approach would require 556
busses at an estimated annual cost of $14,815,000." Exhibit 7,
4/ The Hartford studies made it apparent that achieving
regional racial and ethnic balance by way of an interdistrict
student reassigned plan was both impractical and unrealistic.
The defendants point to the plans which were studied by the
Hartford Board of Education only for the purpose of illustrating
that there is no simple solution to the complex conditions the
plaintiffs are complaining about.
-25.
p. 12 and Table III. The study also concludes that in order to
achieve the less formidable goal of reducing the percentage of
minority children in the Hartford and Bloomfield public schools
to 50%, 10,669 minority pupils from Hartford and Bloomfield would
have to be exchanged with 10,669 non-minority pupils from the
other area towns (for a total of 21,338 pupils). This would
require "a minimum of 376 fifty-four passenger busses at an
estimated annual cost of $10,549,000 for transportation alone."
Exhibit 7, pp. 11-12 and Table II.
Why do the plaintiffs fail to include this kind of plan in
their list of measures to address the conditions that exist in
the Hartford area? The answer is obvious. Despite the fact that
implementation of this kind of plan would achieve the goal
plaintiffs seek to obtain by this suit, the human cost involved
in the implementation of such a plan is simply to high for even
the plaintiffs to consider. In other words the plaintiffs have
engaged in the kind of balancing of competing and sometimes
conflicting interests which make it impossible to say that there
is a specific method for addressing the conditions which the
plaintiffs complain about which the general assembly was,
arguably, obliged to implement.
-26-
The kind of student re-assignment plan that the Hartford
Board of Education studied would address the conditions about
which the plaintiffs complain. However, the difficulties and
uncertainties inherent in these kinds of student reassignment
plans, and which apparently caused the plaintiffs to omit them
from their list, are the same difficulties and uncertainties
which make FACT 2 readily apparent.
C. Plaintiffs Do Not Contest The Fact That The General
Assembly Has Adopted And The Defendants Have Implemented
Legislation To Address The Conditions About Which The Plaintiffs
Complain (FACT 3).
According to the plaintiffs, FACT 3 is in dispute because
the measures which the state has adopted to address the
conditions they complain about have not been adequate. For
example the plaintiffs agree that "it is true that Hartford
receives a larger share of funding as compared to its suburban
counterparts"; Plaintiffs' Reply, p. 16; but they maintain that
"the educational resources currently provided through the
combined efforts of the state are insufficient"; Plaintiffs’
Reply, p. 17. Similarly, the plaintiffs do not dispute the fact
that the state has adopted laws prohibiting intva-oiztrict racial
imbalance which go beyond any similar effort in other states, but
37
they maintain that "[l]egislative efforts to address the specific
problem of racial isolation by the Connecticut legislature have
been dismal at best." Plaintiffs' Reply, pp. at 18-19. But
whether or not the general assembly could have done more or
different things to address the conditions which the plaintiffs
complain about is of no consequence to FACT 3. It is clear that
the general assembly has adopted and the defendants have
implemented some legislation designed to address the conditions
about which the plaintiffs are complaining. FACT 3 says no more
than this and plaintiffs do not and cannot contest this fact.
when FACT 3 is properly read it becomes apparent that this
fact supports the defendants' legal position that the court does
not have the authority to examine the general assembly's
decisions regarding the "appropriate" means of addressing
conditions which are not the product of unlawful state action.
Unless the court disagrees with the defendants' legal position
and declares itself the final arbiter of the "appropriate"
response to these kinds of conditions, the extent to which the
actions taken by the general assembly to date have successfully
addressed the conditions which the plaintiffs complain about is
irrelevant.
«28
Properly read FACT 3 gives the court the opportunity to
apply the analysis used by Chief Justice Peters when the Supreme
Court decided Horton v. Meskill, 195 Conn. 24, 486 A.2d 1099
(1985), (Horton III). As the defendants have pointed out on page
74 of their original memorandum in support of this motion for
summary judgment, the Chief Justice found the state's new
statutory public school financing system constitutional, not
because the conditions which the plaintiffs complained about had
changed, 5/ but because the new system "reasonably advanced a
rational state policy and...did not result in an
unconstitutionally large disparity." Horton III, 195 Conn. at
45. FACT 3 is not in dispute and it allows the court to reach
the same conclusion in this case.
V. CONCLUSION
There is no dispute over the facts which are material to the
defendants motion for summary judgment and the defendants are
entitled to judgment as a matter of law. Therefore the
5/ The conditions had not changed in that "significant
disparities in the funds that local communities spend on basic
public education" continued even after the GTB formula was
implemented. Horton III, 195 Conn. at 39.
-3 Ow
defendants ask that judgment be rendered for them and against the
plaintiffs.
BY:
FOR THE DEFENDANTS
RICHARD BLUMENTHAL
ATTORNEY GENERAL
sgsistant Attorney General
d10 Sherman Street
Hartford, Connecticut 06105
Telephone: 566-717
Dearie W HO kGHuy
Diane W. Whitney
Assistant Attorney General
110 Sherman Street
Hartford, Connecticut 06105
-30-
CERTIFICATION
This is to certify that a copy of the foregoing was mailed,
postage prepaid on November 6, 1991 to the following counsel or
record:
John Brittain
University of Connecticut
School of Law
65 Elizabeth Street
Hartford, CT 06105
Wilfred Rodriguez
Hispanic Advocacy Project
Neighborhood Legal Services
1229 Albany Avenue
Hartford, CT 06112
Philip Tegeler
Martha Stone
Connecticut Civil Liberties Union
32 Grand Street
Hartford, CT 06106
Wesley W. Horton
Mollier, Horton & Fineberg, P.C.
90 Gillett Street
Hartford, CT 06105
Jenny Rivera, Esq.
Ruben Franco
Puerto Rican Legal Defense Fund, Inc.
99 Hudson Street
14th Floor
New York, NY 10013
Ile
Julius L. Chambers
Marianne Lado, Esq.
Ronald Ellis, Esq.
NAACP Legal Defense Fund and
Educational Fund, Inc.
99 Hudson Street
New York, NY 10013
John A. Powell
Helen Hershkoff
American Civil Liberties Union
132 West 43rd Street
n R. Whelan Fo
sistant Attorney General
30
HARTFORD PUBLIC SCHOOLS
BACKGROUND AND DISCUSSION PAPER ON SCHOOL RACIAL/ETHNIC BALANCE: Update
APRIL 1990
HART
Ted Carroll
ORD BOARD OF EDUCATION
William E. Meagher
President
Ruthie B. Mathews
Vice President
Carmen M. Rodriguez
Secretary
Thelma E. Dickerson
Salvatore F. D
HERNAN LAFONTAINE
Superintendent
ALICE M. DICKENS
Assistant Superintendent
School Division A
iMartino III
L 2 2 2 2 22 222 0st n
DINO A. GALIANO
Assistant Superintendent
Instructional Support Services
Prepared by
Jeffrey L. Forman
Senior Assistant to the Superintendent
Addendum: April 1990
Courtney W. Gardner
Pedro Ramos
Allan B. Taylor
CHARLES SENTEIO
Deputy Superintendent
JOHN P. SHEA
Assistant Superintendent
School Division B
HARTFORD PUBLIC SCHOOLS
Hartford, Connecticut
IXTRO0ODUCTIOX
In April 1988, The Hartford Public Schools issued a report entitled
Background and Discussion Paper on School Racial/Ethnic Balance. Since October
1986, the statistics regarding the number of Caucasian and minority students in
the Hartford region have changed. In response, this addendum updates our four
hypothetical solutions for achieving numerical balance. Therefore, pages 11-13
and Tables I, II, and III have been revised with Fall, 1988 data.
Of particular note is that the population of minority youngsters in the
region has gone from 29,269 in 1986 to 30,526 in 1988, or 29.7% to 33.8%. In
the contiguous and adjacent school districts, the population has gone from 5,586
(7.8%) in 1986 to 6,410 (10.1%) in 1988.
Additionally, this document refers to the expansion of interdistrict
cooperative programs with schools in contiguous or adjacent communities to
Hartford and Bloomfield. To date, the most significant projects are:
0 Project Concern, a program by which Hartford Students attend suburban
schools. :
0 The Greater Hartford Academy of Performing Arts.
0 The Planning to Advance Quality Integrated Education (PAQIE) Committee
whose purpose is to promote and plan for integrated education in the
Greater Hartford area.
0 EQUAL, an integrated summer school program sponsored by PAQIE at the
Quirk Middle School in Hartford.
0 An interdistrict Montessori preschool program sponsored by the Hartford
and West Hartford School Districts.
0 A cooperative foreign language education project between Hartford and
Wethersfield schools.
° The Hall High School/Bulkeley High School Videolink project sponsored
by SNET which allows classes in these two schools to learn
cooperatively.
0 An Interdistrict Foreign Language Magnet Immersion Program initiated by
Hartford, West Hartford and Glastonbury Schools.
0 Sister schools. A number of Hartford public schools have initiated the
"Sister School” concept with one or more schools from contiguous or
adjacent towns.
In combination with the original April, 1988 document, one can review the
issues involved with desegregation of the students in the Greater Hartford area
as well as consider the current options for the inter-enrollment and busing of
students.
HARTFORD'S STATUS
On October 1, 1988, 91.3% of Hartford's 24,404 students
and 73.9% of Bloomfield's 2,490 students were minority pupils,
resulting in an average of 89.7% for the two cities. These
figures alone indicate the numerical impossibility of achieving
any form of racial/ethnic balance. If all of Hartford and
Bloomfield's minority pupils were evenly distributed throughout
the combined area of the two cities, every Hartford and
Bloomfield school would have 89.7% minority enrollment. On the
other hand, if the percentage of minority pupils continues to
increase, total racial isolation in almost every Hartford and
Bloomfield school is a real possibility in the not too distant
future.’
Commissioner Tirozzi's report urges the development of
voluntary programs between urban centers and their contiguous
and adjacent school districts that would provide shared
educational experiences for minority and Caucasian pupils. For
many people, this translates into inter-district enrollment and
the busing of pupils. However, if the enrollment data for the
suburban districts shown in the Tirozzi report (See Table I)
are compared to Hartford and Bloomfield's, further difficulties
in achieving numerical balance become evident even if pupils
were to be moved on an interdistrict basis. A few hypothetical
scenarios demonstrate the problems.
SCENARIO I
If a 50% numerical balance is assumed to be
an ideal balance, Hartford and Bloomfield, with
24,116 minority and 2,778 Caucasian pupils in
1988, could achieve that desired ratio in three
possible ways:
A. Transfer 21,338 minority pupils to contiguous
and adjacent districts leaving Hartford and
Bloomfield with a balanced enrollment of 5,556
pupils.
B. Transfer the 21,338 Caucasian pupils into
Hartford and Bloomfield bringing total enrollment
to 48,232 pupils.
C. Exchange 10,669 minority pupils from Hartford
and Bloomfield with an equal number of
non-minority pupils from contiguous and adjacent
districts, thus evenly balancing Hartford and
Bloomfield's current enrollment.
-{2u
Option (A) and (B) do not currently appear to
be feasible. To effect option (C) with the 9
districts contiguous to Hartford and Bloomfield,
35% of the total Caucasian enrollment in those
districts would have to exchange with 44% of
Hartford and Bloomfield's minority enrollment. If
11 additional adjacent districts were included,
23% of the total Caucasian enrollment would be
replaced.
Table II shows the effect of exchanging
10,669 pupils upon the ethnic distribution of 20
contiguous and adjacent districts if the minority
pupils were assigned in equal proportion (16.8%)
to the district enrollments. The table shows (a)
the current number and percentage of minority
pupils in each district, and (b) the number of
pupils that would be exchanged with each district,
and (ec) the resulting number and percentage of
minority pupils.
Regardless of the method of distribution or
the number of towns involved, the exchange of
10,669 pupils in both directions would require a
minimum of 376 fifty-four passenger buses at an
estimated annual cost of $10,549,000 for
transportation alone.
SCENARIO II
Various means could be devised to bring about
a more equitable distribution of minority pupils
on a regional basis. A second scenario might
presume to exchange pupils so that every district
acquires the average percentage of minority pupils
as in the region as a whole. According to the
Tirozzi report, the Hartford area with 9
contiguous and 11 adjacent districts has a total
enrollment of 90,215 pupils, 33.8% of whom
(30,526) are minority. In order to raise all
twenty surrounding districts to a 33.8% minority
enrollment, a total of 30,030 pupils would have to
be reassigned and bused. Table III demonstrates
the current and resulting totals. This approach
would require 556 buses at an estimated annual
cost of $14,815,000.
oo
SCENARIO III
A third possible means of redistricting
pupils might be to assign the 30,526 minority
pupils in the region to the 22 school districts in
proportion to their 1988 enrollments and hold
enrollments constant by transferring the same
number of Caucasian pupils into Hartford and
Bloomfield. The end result, however, is identical
to Scenario II.
SCENARIO IV
On a lesser scale, the racial imbalance of
the Hartford schools might be addressed by
increasing the number of minority pupils bused to
suburban towns under Project Concern or by
exchanging minority for Caucasian pupils on a
voluntary basis.
For every 1000 minority pupils added to
Project Concern, Hartford and Bloomfield's
minority percentage would decrease by less than
one-half of one percentage point, assuming that
Hartford and Bloomfield's Caucasian enrollment
remained constant. For every 1000 pupils
exchanged with other towns, the minority
population would decrease by 3.7 percentage
points. In other words, in order to reduce
Hartford's minority percentage from 90% to 70%,
some 5400 pupils would have to exchange with
pupils in suburban towns.
TABLE 1
HARTFORD AND BLOOMFIELD PUBLIC SCHOOLS DISTRICTS WITH
CONTIGUOUS AND ADJACENT SCHOOL DISTRICTS, 1988
€3317¢d
SET
p re Pt
ELLEN
CAUCASIAN | MINORITY TOTAL
SCHOOL DISTRICT TYPE : STUDENTS | STUDENTS | STUDENTS!
HARTFORD CORE 2127 ~ OXTYT 24404
BLOOMFIELD CORE 651 1839 2490
AVON CONTIGUOUS 1954 73 2027
EAST GRANBY CONTIGUOUS 646 21 667
EAST HARTFORD CONTIGUOUS 4462 1342 5804
NEWINGTON CONTIGUOUS 3458 211 3669
SIMSBURY CONTIGUOUS 3702 169 3871
SOUTH WINDSOR CONTIGUOUS 3348 284 3632
- |WEST HARTFORD CONTIGUOUS 6260 #55 7125
WETHERSFIELD CONTIGUOUS 2854 126 2080
WINDSOR CONTIGUOUS 2886 1323 4209
BURLINGTON ADJACENT . ’ .
CANTON ADJACENT 175 26 1201
EAST WINDSOR ADJACENT 1133 121 1254
ELLINGTON ADJACENT 1838 43 1881
FARMINGTON ADJACENT 2443 143 2586
GLASTONBURY ADJACENT 4351 269 4620
GRANBY ADJACENT 1426 28 1454
MANCHESTER ADJACENT 5000 809 6808
ROCKY HILL ADJACENT 173 E103 1835
SUFFIELD ADJACENT 1740 5 1796
VERNON ADJACENT 3957 315 4272
WINDSOR LOCKS ADJACENT 1547 83 1630
TOTAL - REGIONAL 59680 30526 90215
* Belongs to a Regional School District
TABLE Il - HYPOTHETICAL REDISTRIBUTION OF PUPILS TO ACHIEVE 50% RACIAL BALANCE
| | | | |
SCHOOL DISTRICT | LOCATION _ ‘OCTOBER 1, 1988 [OTAL {i _EX/CHD _ PROJECTED ENROLLMENTS
CAUCASIAN MINORITY CAUCASIAN MINORITY
# % # % # % # %
HARTFORD CORE 2127 8.7% 22277 91.3% 24404 10075 12202] 50.0% 12202 50.0%
BLOOMFIELD CORE 651 26.1% 1839 73.9% 2490 594 1245{ 50.0% 1245 50.0% »
TOTAL-CORE 2778 10.3% 24116 89.7% 26894 10669 13447 50.0% 13447 50.0%
AVON CONTIGUOUS 1954 96.4% 73 3.6% 2027 342 1612{ 79.5% 415 20.5%
EAST GRANBY CONTIGUOUS 646 96.9% 21 3.1% 667 112 534] 80.0% 133 20.0%
EAST HARTFORD CONTIGUOUS 4462 76.9% 1342 23.1% 5804 978 3484{ 60.0% 2320 40.0%
NEWINGTON CONTIGUOUS 3458 94.2% 211 5.8% 3669 618 2840{ 77.4% 829 22.6%
SIMSBURY CONTIGUOUS 3702 95.6% 169 4.4% 3871 652 3050{ 78.8% 821 21.2%
SOUTH WINDSOR CONTIGUOUS 3348 92.2% 284 7.8% 3632 612 2736] 75.3% 896 24.7%
WEST HARTFORD CONTIGUOUS 6260 87.9% 865 12.1% 7125 1201 5059f 71.0% 2066 29.0%
WETHERSFIELD CONTIGUOUS 2854 95.8% 126 4.2% 2980 502 2352{ 78.9% 628 21.1%
WINDSOR CONTIGUOUS 2886 68.6% 1323 31.4% 4209 709 2177 51.7% 2032 48.3%
TOTAL - CONTIGUOUS 29570 87.0% 4414 13.0% 33984 5726 238441 70.2% 10140 29.8%
CANTON ADJACENT 1175 97.8% 26 2.2% 1201 202 973{ 81.0% 228 19.0%
EAST WINDSOR ADJACENT 1133 90.4% 121 9.6% 1254 211 922{ 73.5% 332 26.5%
ELLINGTON ADJACENT 1838 97.7% 43 2.3% 1881 317 1521{ 80.9% 360 19.1%
FARMINGTON ADJACENT 2443 94.5% 143 5.5% 2586 436 2007{ 77.6% 579 22.4%
GLASTONBURY ADJACENT 4351 94.2% 269 5.8% 4620 778 3573{ 77.3% 1047 22.7%
GRANBY ADJACENT 1426 98.1% 28 1.9% 1454 245 1181{ 81.2% 273 18.8%
MANCHESTER ADJACENT 5999 88.1% 809 11.9% 6808 1147 4852{ 71.3% 1956 28.7%
ROCKY HILL ADJACENT 1732 94.4% 103 5.6% 1835 309 1423{ 77.5% 412 22.5%
SUFFIELD ADJACENT 1740 96.9% 56 3.1% 1796 303 1437{ 80.0% 359 20.0% %
VERNON ADJACENT 3957 92.6% 315 7.4% 4272 720 3237{ 75.8% 1035 24.2%
WINDSOR LOCKS ADJACENT 1547 94.9% 83 5.1% 1630 275 1272{ 78.1% 358 21.9%
TOTAL - ADJACENT 27341 93.2% 1996 6.8% 29337 4943 22398{ 76.3% 6939 23.7%
TOTAL CONT + ADJ. 56911 89.9% 6410 10.1% 63321 10669 46242] 73.0% 17089 27.0%
TOTAL - REGIONAL 59689 66.2% 30526 33.8% 90215 21339 59689{ 66.2% 30526 33.8%
TABLE lll - HYPOTHETICAL REDISTRIBUTION OF PUPILS TO ACHIEVE UNIFORM REGIONAL RACIAL BALANCE
| | | | |
SCHOOL DISTRICT _{_LOCATION _ OCTOBER 1, 1988 _TOTAL | _EXCHD | PROJECTED ENROLLMENTS
CAUCASIAN MINORITY CAUCASIAN MINORITY
# % # % ft — # %
HARTFORD CORE 2127 8.7%} 22277} 91.3%} 24404 14019 16146] 66.2% 8258 33.8%
BLOOMFIELD CORE 651 26.1% 1839 73.9% 2490 996 1647] 66.2% 843 33.8%
TOTAL-CORE 2778} 103%} 24116} 89.7%} 26894 15015 17793{ 66.2% 9101 33.8%
AVON CONTIGUOUS{ 1954} 96.4% 73 3.6% 2027 613 1341{ 66.2% 686 33.8%
EAST GRANBY CONTIGUOUS 646 96.9% 21 3.1% 667 204 442] 66.2% 225 33.8%
EAST HARTFORD CONTIGUOUS{ 4462f 76.9% 1342} 23.1% 5804 622 3840] 66.2% 1964 33.8%
NEWINGTON CONTIGUOUS|{ 3458 94.2% 211 5.8% 3669 1030 2428] 66.2% 1241 33.8%
SIMSBURY CONTIGUOUS{ 3702} 95.6% 169 4.4% 3871 1141 2561] 66.2% 1310 33.8%
SOUTH WINDSOR CONTIGUOUS|{ 3348] 92.2% 284 7.8% 3632 945 2403] 66.2% 1229 33.8%
WEST HARTFORD CONTIGUOUS{ 6260} 87.9% 865) 12.1% 7125 1546 4714] 66.2% 2411 33.8%
WETHERSFIELD CONTIGUOUS|{ 2854] 958% 126 4.2% 2980 882 1972{ 66.2% 1008 33.8%
WINDSOR CONTIGUOUS{ 2886} 68.6% 1323] 31.4% 4209 101 2785] 66.2% 1424 33.8%
TOTAL - CONTIGUOUS 29570f 87.0% 4414} 13.0% 33984 7084] 22486] 66.2% 11498 33.8%
CANTON ADJACENT 1175} 97.8% 26 2.2% 1201 380 795{ 66.2% 406 33.8%
EAST WINDSOR ADJACENT 1133} 90.4% 121 9.6% 1254 303 830{ 66.2% 424 33.8%
ELLINGTON ADJACENT 1838 97.7% 43 2.3% 1881 593 1245] 66.2% 636 33.8%
FARMINGTON ADJACENT 2443] 94.5% 143 5.5% 2586 732 1711{ 66.2% 875 33.8%
GLASTONBURY ADJACENT 4351 94.2% 269 5.8% 4620 1294 3057] 66.2% 1563 33.8%
GRANBY ADJACENT 1426f 98.1% 28 1.9% 1454 464 962] 66.2% 492 33.8%
MANCHESTER ADJACENT 5009) 88.1% 809 11.9% 6808 1495 4504] 66.2% 2304 33.8%
ROCKY HILL ADJACENT 1732} 94.4% 103 5.6% 1835 518 1214] 66.2% 621 33.8%
SUFFIELD ADJACENT 1740} 96.9% 56 3.1% 1796 552 1188] 66.2% 608 33.8%
VERNON ADJACENT 3957} 92.6% 315 7.4% 4272 1131 2826] 66.2% 1446 33.8%
WINDSOR LOCKS ADJACENT 1547} 94.9% 83 5.1% 1630 469 1078{ 66.2% 552 33.8%
TOTAL - ADJACENT 27341 93.2% 1996 6.8% 29337 7931 19410{ 66.2% 9927 33.8%
TOTAL CONT + ADJ. 56911 89.9% 6410 10.1%} 63321 15015{ 41896] 66.2%] 21425 33.8%
TOTAL - REGIONAL 50689 66.2%} 30526] 33.8%} 90215 30030{ 59689] 66.2%} 30526 33.8%
STATE EFA OF 3
bi: sh RE AERR TIO Se ‘Hartford © 24 ed "ov Fi zl sk
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CONNECTICUT STATE DEPARTMENT OF EDUCATION
Bureau of Research,Statistics and Finance
THE DISTRIBUTION OF NON-WHITSS IN THE PUBLIC SCHOOLS OF CONNECTICUT
-®
In late April, 1966, the State Department of Education asked local school
officials $0 provide infarmation about the racial composition of classes in the
local public schools, Data were obtained for self-contained classes and for English
classes where the schools are departmentalized. Information wes sought also about
Spanish speaking pupils. There is general recognition of the fact that in certain
parts of the state, particularly in urban areas, there have been increases in the
numbers of non-white and Spanish speaking children in schools. There is need to
establish benchmarks so that in future years there mgy be accurate determination of
such things as the rate of change in the numbers of such pupils, the rate at which
they may be moving into or eit of urban areas, the grades in which the children ave
enroled, etce There are no school census figures on this basis; these data help to
define the problem and should be taken into sacouh in whatever actions are proposed.
No information was sought to explain the distribution of pupils. Same
local people pointed out that in some cases, concentration of non-whitcs was cosod by
housing patterns and neighborhood school policies; others pointed out that children
itn similar learning problems or pupils who had chosen certain curricula or courses
v Woe grouped together.
oH Most school systems of the state supplied the data as requested; a few
school systems did not wish to participate in the survey. In some cases, the data
arrived too late to be processed and included in this report.
Some towns or school districts report no non=whites or Spanish speaking
children enroled; these districts are listed first, in Table I.
Some towns have few non-whites; summary data for these towns are presented
separately in Table II, These summaries show the mmber of schools, the numbers of
children enroled, the total mmber of classes, the number of classes ar grades which
have non-whites in then, and the mmber of non-whites in each class which has
non=-whites in it.
* »
-2-
For larger towns, we present, in Table III, summary data for each grade; we
. show the number of whites, the mmber of non-whites, the mmber of "don't knows" and
the mmber of Spanish speaking pupils. In this table combination classes have been
listed with She lowest grade included in the class.
v More detailed data which present information for each class in each school
are on file in the Bureau of Research, Statistics and Finance of the Connecticut State
Department of Education. The data are available for inspection and use by those who
may be interestede The anonymity of individual teachers will be maintained.
The covering letter and the survey form used are included in this bulletins
It is hoped that these data will be useful as citizens and educators consider the
problems of quality and equality in education for all children.
Maurice J. Ross, Chief
Bureau of Research, Statistics and Finance
How to Read Table II
The name of the town is given.
The grades included in the district or town are shown in column G which has farrdigits.
The first two digits indicate the lowest grade included; the last two digits indicate
the highest grade included. The digits or codes have the following meanings:
N « Pre-kindergarten
K « Kindergarten
Ol = Grade 1
02 - Grade 2
03 = Grade 3
etc,
12 = Grade 12
U = Special or unclassified sections
Column T indicates the total mmber of sections or classes reported by the school
district.
Column B indicates the mmber of sections or classes which had one or more non-whites
in them.
Column W indicates total number of whites in all classes reported.
Column C indicates the total mumber of non-whites in all classes reported.
Column D indicates the total mumber of pupils reported as "Don't Know" in all classess
i * ~3k, i
Column F indicates the total mummber of Spanish speaking pupils. These pupils are
dncluded under Columns W, C, and/or De
. Column S indicates the mmber of sectiéns or classes each having the mumber of
non-whites shown in the corresponding row of Column N.
S$ NM
28 3
: 7. 4
- This town had 28 classes or sections each of which had 1 non-white in them,
&
and 7 classes or sections each of which had 4 non-whites in them.
How to Read Table III
The name of the town is given.
Columns T, Sy, C, Wy, D, N, and F have the same meanings as in Table II; but for each
grade reported. The totals for the town are also shown.
le
TABLE I
.@
TOWNS WHICH REPORT NO NON-WHITES OR SPANISH SPEAKING PUPILS
a -
vs ya
Tes x
a I=
Andover
Barkhamsted
Beacon Falls
Bolton
Bograh
‘Burlington
Canterbury
Colebrook
Cornwall
Darien
East Lyme
Easton
Franklin
Hampton
Harwinton
Kent
Lisbon
Lyme
Middlebury
New Fairfield
New Hartford
Oxford
Plainfield
Pomfret
Roxbury
Sherman
Sprague
Sterling
Thomaston
Thompson
Voluntown
Warren
Washington
Willington
Woodbury
Regional District #6
FAGE 5
TABLE V4
SUMMARY FOR TOWNS WHICH REPORT
FEN NON WHITES OR SPANISH
SPEAKING PUPILS
ANSON! A
hen GR T S W Cia op F
a BO zs 381Fi1e TIRE 438.4 5
S N
1 15
1 14
1 13
1 10
2 9
4 8
5 7
9 6
11 5
14 4
“ 18 3
A 2D 2
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ASHFORD
GR T S w gD F
GO: 08 11 3 549 3
S N
GR
00 iz
GR
00 06
GR
00 13
PAGE 6
AVON .
T S Ww
70 352742
S
=
BERLIN
T S W
128 90 29%2
S
9
BETHANY
T S W
22 e 512
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BETHEL
§ S W
80 41 2041
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00 08
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GR
00 08
GR
00 11
PAGE 9
BETHLEHEM
v
15
S w
r 348
S
3
BRANFORD
v
161
S vi
42 3939
31
BRIDGEWATER
S Vi
2 221
S
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BROOKF IELD
2
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PAGE 10
COVENTRY
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PAGE 12
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PAGE 13
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PAGE 14
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PAGE 16
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PAGE 17
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PAGE 18
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PAGE 19
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PAGE 20
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PAGE 21
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PAGE 23
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PAGE 24
SEYMOUR
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PAGE 285
SOMERS
T S W C
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PAGE 27
TORRINGTON
T 8s. W
£204 45 B119
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TRUMBULL
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UNION
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PAGE 28
LJ
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PAGE 269
WATERTOW¥N
T S W C
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PAGE 30
WESTPORT
T S W
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PAGE 31
WINDSOR
T S w
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WINDSOR LOCKS
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PAGE 32
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PAGE 33
-@ .
AMITY HIGH
T S Ww
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T S Ww
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PAGE 35
TABLE 1 ||
DISTRIBUTION OF<*NON WHITES AND SPANISH
SPEAKING PUPILS BY GRADES
= 'N CERTAIN TOWNS
BRIDGEPORT
T S C W D N F
N t4. 012 200 79 279 2 4
K 3 de ig 728 1902 2630 156
01 109. 84 £98 1758 5 2661 208
02 83 & 70 741 1418 % pa sn 132
03 85 67 731 1462 2193 1%
04 68 56 615 1259 4 1878 14%
05 69 56 573 1250 2 1825 54
06 61... 45 500! "12073 2 17.04 60
C7 60 46 428 311965 1623 38
08 50 48 439 = 14713 4 1616 42
09 70... 66 43 Titpiy 3 1655 39
10 63 58 3227 1052 1.379 23
14 89 43 191 950 1 34d 4
12 40 43 180 98 4 1164 13
TOT 936 765 6994 16895 cl 23910 1023
PACE 35
TABLE 1]
DISTRIBUTION OF NON WHITES AND SPANISH
SPEAKING PUPILS BY ‘GRADES
2
4 IN CERTAIN TOWNS
: BRISTOL
T S C W D N F
: N 3 18 18
K 46 16 30. 1040 2 1062 8
01 40° a5 5. 975 | 996 5
02 36° 18 1:4 879 893 3
03 26 35 33 937 970 6
04 ~ 32EN413 20 830 i 851 5
05 29 8 10 806 816 5
06 si 10 1.2 743 755 5
07 66 1d 37 703 740 2
08 25 5 10 658 668 1
09 31 5 6 783 7809 1
- 10 28 & 9 7382 7.41
13 31 4 4 74:4 2 747 1
: 12 25 4 A 625 631
TOT 415 124 202 10470 5 10677 4 2
<
DISTRIB UT
TOT
SPE
T S
9 9
22
32 25
27 19
27 21
25 16
23 17
23 16
20 15
20 14
25 17
27 319
24 13
23 12
8 6
346 241
PAGE. 37
TABLE 1
VON OF NON W
AKING PUPILS BY
IN CERTAIN
DANBURY
C
101
645
Ww
57
747
67 4
625
623
600
566
529
S518
500
565
590
521
530
7 2
7731 7
HITES AND SPANISH
GRADES
TOWNS
D N F
4 187 1.2
2 811 9
gt 777 12
681 7
2 68 4 19
647 9
2 612 17
3 573 4
2 550 6
1 524 i
59 4 1.1
622 6
543 4
546 6
1 90 3
19 8381 118
TOY
PAGE
+
DISTRIBUTION OF
407
SPEAKING
[M
Y
[R
Y
O
v
O
M
C
0
OH
OO
«J
AP
NO
“
N
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0
"
©
b
e
ile
FN CE
GREENW
C
212
38
ASLE |
“NON w
PUPILS
RTAIN
i CH
96 39
11 TES AND SPANISH
BY GRADES
TOWNS
9855 20
TO
DISTRIBUTION OF
358
PAGE
I
SPEAKING
iN CF
GROTON
S C
2 6
eB 78
=31 83
26 6 6
2 69
e3 67
35 47
19 49
is 4 2
g 25
14 25
i5 30
13 24
10 J
5 12
248 650
38
ABLE |
«NON W
PUPILS
RTAIN
8138
Hi1iTES AND SPANISH
BY GRADES
TOWNS
5
pt
pa
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ps
28 8816
2
N
N
N
On
.
=
.
2
0
0
0
)
i5
PAGE 40
TASLE 1 vi
DISTRIBUTION OF NON WHITES AND SPANISH
£0 SPEAKING PUPILS BY GRADES
> IN CERTAIN TOWNS
oh HAMDEN
: T S C W D N F
N 2 2 12 19 31
K 41 7 22 814 2 838 1
01 37. 312 28 739 1 768 i
02 35 5 31 728 759 2
03 245 1 33 743 1 777
04 30 8 29 643 672
05 30 7 38 642 680
06 33 5 16 728 1 745
07 YS, ) 27 583 610
08 24 9 27 622 649
09 26.1 10 27 618 645
". 10 205. 16 26 655 1 682
og 1) 52+ 40 14 535 549
iz 19 8 11 442 453 1
u 4 1 4 2. 31
TOT >291 122 348 -B538 6 8889 5
PAGE 41
TASLE 111
DISTRIBUTION OF NON WHITES AND SPANISH
¥ SPEAKING PUPILS BY GRADES
pe IN CERTAIN TOWNS
: HARTFORD
o T S c W D N F
N 8 7 47 45 g2 14
kK 105 67 A127 1693 2 2821 295
OL 198. 96 1400 1688 7.4 3035 4377
02 91" 63 1088 1195 6 2259 245
03 90 60° 1002 1834 2 2239 194
04 847 -.60 934 1096 1 2031 182
05 77 55 827 1133 3 1961 1832
06 72S 47 EE 1077 1834 119
07 82 65 840 1043 1 1884 125
08 7a. 485 608 96 4 +872 52
09 103 75 £04 41500 1 21032 280
. 10 66 48 507 918 8 1433 33
11 59 45 360 854 1 1215 25
: 12 B40 zg 287 916 3 1206 20
TOT 1090 769 10356 15293 sie. osead. R190
PAGE 42
TABLE 41)
DISTRIBUTION GF NON WHITES AND SPANISH
I SPEAKING PUPILS BY GRADES
Has IN CERTAIN TOWNS
MERIDEN
. T S c W D N F
K 39 17 25 1045 3 1073 45
01 35 0 17 36 812 848 46
02 30 Ed 26 739 A ames 33
03 31 "1 32 822 854 30
04 gig 13 32 78 3 815 "3
05 28 un 33 721 ane" vs
06 26. 14 22 720 742 19
07 B17 Sit 29 734 1 764 25
08 28 "10 18 719 iy am 12
09 gE. 14 16 676 692 16
10 8:12 17 627 Pap 646 9
el 333 25 8 9 610 619 9
12 25 7 1. 636 647 3
T07 374 166 306 9644 f 4 99 57 300
PAGE 43
TABLE | 11
DISTRIBUTION OF "NON WHITES AND SPANISH
SPEAKING PUPILS BY GRADES
IN CERTAIN TOWNS
MIDDLETOWN
F
x
4
;
3
1
2
3
2
PAGE 44
prim TABLE V1
DISTRIBUTION OF NON WHITES AND SPANISH
Be SPEAKING PUPILS BY GRADES
Li IN CERTAIN TOWNS
A MILFORD
an T S c W 0 N CF
: K 50 8 11 +1058 1 1070 1
01 47 6 7.5 109% 1 1103 3
02 41 8 14: 1066 1077
03 39 7 5 98 3 991
04 39 7 8 110002 1010
05 37 6 7 953 960
06 38. 11 14 890 904 1
07 37 6 ” 947 954
08 32 ” 9 855 864 1
09 35 2 2 870 872 3
10 33 6 7 718 722 1 ;
. 11 29 5 6 632 3 639
12 26 6 6 60 2 1 609 3
TOT 483 85 $03 11665 2 11772 13
PAGE 45
TASLE 31
DISTRIBUTION OF NON WHITES AND SPANISH
J SPEAKING PUPILS BY GRADES
if IN CERTAIN TOWNS
NEW BRITAIN
Tap T S C W D N F
N 4 2 3 23 26 3
K 65 39 153 1403 3 1559 87
01 61 40 146 1301 5 1452 69
02 50 32 89 1159 10 1258 6 0
03 46 28 87 $127 6 1220 45
04 46 28 96 1126 2 1224 40
05 44 26 03. 1159 1 1251 36
06 39.20 73 "1041 3 +3115 23
07 39 32 80 916 996 36
08 385. o9 66 789 855 2 4
09 33 2 4 61 800 aE 861 22
- 10 44. 2% 48 834 2 8-8 4 15
N 11 35 1.20 36 827 2 865 4
12 32 18 34 80 4 1 839 4
TOT 570 3257 1061 13309 25 14405 468
T0Y
PAGE. 46
TABLE t 1
DISTRIBUTION OF NON WHITES AND
& SPEAKING PUPILS BY GRADES
go IN CERTAIN TOWNS
NEW HAVEN
T S c W D
2 1 23 7
71 56 943 1807 14 2
3685 13432 1094 22 2
9% 64 930 91 3 14 1
66°. 55 750 879 10 1
60 50 740 760 12 1
88 50 622 800 5 1
45 za 50 2 670 1
82" “ug 593 710 1
49 ag 568 698 1
52. 49 491 713 1
52 “ay 377 848 1 1
83 i 53 332 751 1 1
42 «38 217 75 5
25 Bq 177 152 1
704 693 BeOB8 10957 8 0 19645
SPANISH
N F
30 1
164 81
459 104
857 56
639 42
512 34
427 30
172 21
303 26
266 Bo}
204 20
226 11
084 5
972 1
330 2
445
PAGE 47
YABLE + bo
DISTRIBUTION OF NON WHITES AND SPANISH
#4 SPEAKING PUPILS BY CRADES
INCCERTAIN TOWNS
NEW LONDON
xy T S C Ww D N r
K 85 29 125 617 542 13
01 oT RO gy 132 407 539 15
02 18 15 26 338 434 6
03 Lar 13 1073 280 383 13
04 38 "15 103 286 389 , 'Y8
05 14.0 10 96 301 397 9
06 1.3: 2 11 89 260 349 11
07 T2510 8 3 291 2 376 £
08 1716 59 28 4 7 350 15
09 1°40 .18 80 237 | 247 5
10 20. 19 50 390 : 440 4
11 1:7 14 48 391 20 439 5
12 17 cul? 31 340 371
TOT 221 186% 1095 4202 29 5226 118
PAGE 48
TABLE 411
DISTRIBUTION OF NON WHITES AND SPANISH
Ay SPEAKING PUPILS BY GRADES
Fe IN CERTAIN TOWNS
gk NORWALK
hi T S C W 0 N Lr
N 9 8 81 37 118 7
K 64 39 216 1415 5 1636 40
01 62 57 270% 1318 3 1600 33
02 54 49 507- 122% 3 1431 29
03 46 45 195 1385 3 1583 40
04 355.35. 164 o58 1119 19
05 38 35 511. 1558 1769 23
06 19 17 75 522 597 3
07 69. "50 307 1297 1604 37
08 33. 21 80 820 900 3
09 34°17 47 744 ; 791 6 .
“ 10 41 21 119 770 3 892 2
7 11 3% DE 93 772 865 5
12 37) 24 74 685 759
u 8 8 32 56 8 8 3
707 586 4628 2177:13558 17 4157882 250
of
»
PAGE 49
- TABLE 4A
DISTRIBUTION OF NON WHITES AND SPANISH
SPEAKING PUPILS BY GRADES
PERC Ma $e
IN CERTAIN TOWNS
: NORWICH
e T S C W D N F
: K 28" 13 35 750 785 )
01 25 14 38 688 726
Cz 24: uz 38 665 1.7 704
03 22 8 25 633 658
04 22 9 21 581 602
05 Bd wt 37 59 4 1 632
06 20° 10 24 601 vera 628 1
07 234 14 gE Bd 897. 1
08 83. 11 18 554 572 3
u 5 3 4 76 80
TOT 213 1105 266 5713 5 5984 6
PAGE 50
YABLE |)
DISTRIBUTION OF NON WHITES AND SPANISH
Ww
TOT
3
81
66
62
63
58
57
52
47
46
47
52
41
43
16
731
SPEAKING PUPILS BY GRADES
S
41
29
30
36
30
23
25
23
26
25
37
36
27
14
402
IN CERTAIN
STAMFORD
c W
325 1648
352 1366
27% 1306
gO3 13473
587° 135%
£227 12861
POE 1P1B
189 ° 1183
195: 11890
163 1095
162 967
120 846
97 939
57 103
2946 15732
TOWNS
22." 1899
354
DISTRIBUTION OF NON WHITES
ie
NT
iy.
TOT
378
PAGE 51
TABLE |
SPEAKING
AJ
1
149
Cc
51
63
46
67
49
43
45
35
37
43
41
26
16
562
PUPILS
IN CERTAIN TOWNS
STRATFORD
w
16
80 4
702
645
609
625
685
513
647
695
730
681
715
689
8856
SPANISH
BY GRADES
9427
HE
H
N
D
M
D
B
r
Om
14
V Wr.
PAGE 52
. TABLE I 11
CISTRIBUTION OF NON WHITES AND SPANISH
> SPEAKING PUPILS BY GRADES
a IN CERTAIN TOWNS
. WATERBURY
; T S c W D N i
N 3 3 13 49 62 2
K 49 24 284 18311 2 1797 70
0a 230.40 5. 500 4257 age 81
02 61 34 312. 1179 1 1492 68
03 67 . 35 349 1215 2 1566 © 84
04 58 38 287. 109% 11 1390 62
05 84° 28 £288 1139 1" wane 51
06 50 24 228° 10869 1 1208 . 42
07 S84 2p 218 1050 2 1270 34
08 45 = zo 160 "i003 1187 18
09 S34 42 172 "1159 5 1332 14
oi 30 44. 36, Bazo 1004 1 1144 9
. 11 29 394 91 945 2 1038 12
: 12 380.94 67 859 1 927 7
TOT 692 403 2988 14547 oS 17564 5583
PACE 53
TABLE “4 4)
DISTRIBUTION OF NON WHITES AND SPANISH
> SPEAKING PUPILS BY GRADES
Toy
>
IN CERTAIN TOWNS
WEST HAVEN
C
42
65
47
50
38
34
aa
dt
ie
le
|
ph
d
G
e
:
BR
EW
d
e
OA
S
E
E
E
S50
40
25
48
Sl
14
1.3
PAGE 54
TABLE 4 1)
DISTRIBUTION OF NON WHITES AND SPANISH
+ 5 SPEAKING PUPILS BY GRADES
LF 2
a IN CERTAIN TOWNS
. WINDHAM
T S c W D N LE
“Ss N 4 40 40 |
K 7 2 2 183 185 10
01 11 3 4 232 EZ6w As :
02 15 5 6 327 333 15
;.03 12 5 7 261 1 269 6
0 4 13 5 8 276 284 12
05 10 6 5 222 231 10
06 9 5 6 210 216 10
07 9 5 7 209 216 3
oe 9 1 3 220 223 5
09 19 3 3 417 420 2 :
: 10 10 3 4 259 263 1
Yr aa 14 3 3 381 384
$ 13 14 6 6 284 290
TOT 156 52 6 8 3521 3 2590 990
a
~~
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™ CONNECTICUT STATE DEPARTMENT OF EDUCATION
Hartford
April 15, 1966
Series 1965-66 io
Cir. Istter 0-12
T0: , Smperintendents of Schools
he
FROM: William J. Sanders
Camnissioner of Education
RE: Race Survey of Connecticut Schools
At the request of the Connecticut Civil Rights Commission, a study of the radial
composition of public school classes in the state is being conducted. Because infor-
mation is desired on the basis of classrooms, the enclosed forms are designed for use
by teachers of self-contained classes, including kindergartens, and for teachers of
English in departmentalized schools and parts of schools.
The superintendent's office will provide the information necessary to code the upper
part of the form. The superintendent will announce that the count is as of
April 22, 1966 or the closest prior date. Assigned town, county and school code num-
bers are on the enclosed State list. A teacher number should be assigned to each
teacher involved in this survey by numbering the teacher of a self-contained class
and/or English class, The class sections for each teacher should be numbered con-
secutively beginning with one. A copy of this master list should be returned to
this office with the completed forms. Be sure the master list shows the name of the
town, name of the school, name and number assigned to each teacher of a self-contain-
ed and/or English class, and the number for each class section taught by each teacher.
No teacher will be identified by name in any report; the identifying data are merely
to enable us to ask questions if any data appear to be inaccurate, incamplete or
inconsistent.
It may be necessary for the teachers to use their judgment in classifying pupils as
white or non-white, or, as primarily Spanish speaking.
Take extreme care to follow instructions. Fill in the appropriate baxes and matching
columns below each bax. Optical scanning equipment, which reads the column entries,
will reject the form if there is no mark or more than one mark in any column. Please
ask the teachers to check the forms after completion to be sure there is one, and
only one mark in each column. Mark geros for data that do not apply. Please see
that forms are neither folded nor stapled.
The forms are to be collected by the principal of each school, checked for complete-
ness and obvious errors and then forwarded to the office of the superintendent of
schools. The superintendent's office should ascertain that all forms for each school
have been returned to his office. Keep the forms for each school together. Send
all forms in one package to the Bureau of Research, Statistics and Finance, Connecti-
cut State Department of Education, Bax 2219, Hartford, Connecticut 06115, before
April 29, 1966.
Thank you for your cooperation.
WJS:rb
-
STATE OF CONNECTICUT RACE SURVEY OF CONNECTICUT SCHOSRS~ ~~~ *
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i > | fio i I ollie i ° | I | lo i ° | 0 I STAT-70 (3-66) (Taken in cooperation ‘with Connecticut Civil Rights Ganrpleglon)
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hide | Bl | Bib :
TE non LR dT ee DIRECTIONS: Use @ #2 pencil te make entries. Erase errors thoroughly. Muse @ number or sere in »
HE HE BH Ha HE H2 20 each bex, and fill in the corresponding marking location in the thet ben. Be swre
there is © number or ere in each bex; and that ene, and enly ene, lin smc column
wo ononou IN is ll Ig "oH Safiafia] hos @ mark in it, @s shown in the example at left. Make ne stray marks ef
CODE FOR CLASS: Pre-K=90, K=00, 1=01, 2202, 3=03, etc. Por sighngbdh uses, enter one of
" " " " " " " " 0" " " " " " " " 0" " these codes in the first twe columns and enter zeroes in the second twe avbaiien. EXAMPLE: Grade 1
Hanae ia ia Hala an Ha Heelan is entered as 0100. For multi-grade classes, enter the lowest grade in the frst two columns ond
os hs LSE ft GRE NTE he a the highest grade in the second twe columns. EXAMPLE: A class containing grades 1-3 is entered es 0103.
[TTC TITY HTT Jfloltiofs) SECTION: Bach teacher will mumbar her classes for thi survey in the seder In which they ecew dur »
ing the week, and will enter this number in the first column wnder “Section.” In the second cel-
" " " " " 0" " " " " " " " " " " " " umn, enter 1 for a self-contained class, ond 2 for an English class. EXAMPLES: # the dass le the
is is i S i is } HE BH is i sisi i} si gigs h" third English closs of the week, it will be entered as 32. Mest self-contained classes will be en-
LSE ay a a a Lr LAE fn tered as 11; a second self-contained class eg. Kindergarten would be entered 21.
Heileile:l ied ie 16:16:86: ei 666i PUPIL COUNT: Use membership as of date anneunced by Superintendent. Include pupils obsent on thet
uy Eo i ey 4s En bth i SR day. Count each pupil once only, either as white, nenwhite, or “‘den’t knew.” Check your totals.
i thin LE JN LS noon "THT SE The count of S i g pupils Is separate frem the racial count. Pupils in this greuvp ere
iy + ? i 7 4 HRT nro i 7 i 747 i i 7 3 i 7 i 7 i 7 i alse included In the white, nenwhite, and ‘‘don’t knew’’ categories and in the total enreliment.
" 1" 0" " " " " i" " " " " " RACIAL CLASSIFICATION: Classify ofl pupils possible td) white or nonwhite, keeping ° “don’t new”
4 he Yl Hees Heil HE RIE RIE Bt te a minimum. Ceunt Spanish-speaking en basis of language used, te best of your knowledge, et heme
“" “o " " " "” " " " " or with peers.
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EXHIBIT 9 IN SUPPORT OF THE DEFENDANTS’
MOTION FOR SUMMARY JUDGMENT
A. Bibliography of Definitions of "discriminate",
"discrimination", "segregate" and "segregation".
1. Webster, Noah, by William G. Webster and William A. Wheeler.
A Common-School Dictionary of the English Language. New
York: Ivison, Blakeman, Taylor & Co. 1867.
Discriminate. v. t. To distinguish; to separate.
Discrimination, n. Act of discriminating.
Segregate. v. t. To separate; to set apart.
Segregation. n. Separation from others.
2. Webster's Collegiate Dictionary. Third Edition. 1922
| Discriminate. a. [L. discriminatus, p.p. of discriminare
to divide, deriv. of discernere to discern.] 1.
Distinguished by certain tokens; distinct. 2. Marked by or
showing discrimination.
--(-nat), v.t.;-nat'ed-(-nat'ed);-nat'ing. 1. To mark as
different;differentiate. 2. To separate by discerning
differences;distinguish.--Syn. See distinguish.--v.i. 1.
To make a difference or distinction; distinguish. 2.
To make a difference in treatment or favor (of one as
compared with others).
Discrimination. n. 1. Act of discriminating; a state of
being discriminated. 2.A distinction, as in treatment; esp.
an unfair or injurious distinction. 3.Quality of being
discriminating; acute discernment. 4.That which
discriminates; mark of distinction. --Syn. Penetration,
clearness, acuteness, acumen, judgment, discernment,
distinction.
segregate a. [L.segregatus, p.p. of segregare to separate;
se-aside + grex, gregis, flock, herd.] Set apart; separate;
select.--(-gat), v.t.;--gat'ed(-gat'ed);-gat'ing. To
separate or cut off from others or from the main body;
set apart. v.i. Chem., Geol., etc. To separate from
the general mass and collect together, as in
crystalization or solidification.
segregation n. Act of segregating, or state of being
segregated; also, a segregated portion or mass.
Universal Dictionary of the English Language. George
Routledge & Sons, Ltd. 1932
discriminate vb. intrans. & trans. [l. diskri-minat;
2. diskrimineit], fr. Lat. discrimin-at(um), P.P. type of
discriminare, 'to divide, separate'; fig. 'to distinguish;
to distribute, apportion', fr. discrimen, 'an intervening
space, interval; distinction,difference; critical moment,
turning point,crisis; danger,hazard', fr. dis- & *cri-men,
fr. Aryan base *(s)krei-, *(s)kri-, 'to divide, separate’.
Cp. Gk. krino, 'to separate, distinguish' (see critic); Lat.
cernere, 'to divide, separate; to recognize, perceive’
(see concern, certain); Lat. cribrum, 'sieve' (see
cribriform, riddle(111.)). The base *(s)k(e)rei-&c. is an
expansion of the base*(s)ker-, 'to cut'. See cortex, carnal,
scribe. A. intrans. 1. To perceive differences, distinguish
(between): to discriminate between A and B. 2. To
distinguish by different treatment; mark out, select, for
special treatment; make distinctions, treat differently: to
discriminate in favour of A, against B. B. trans. 1. To
distinguish carefully, mark differences in: to discriminate
A from B. 2. To serve as a distinction, distinguish: his
great stature discriminated him from his followers.
discrimination, n.[1l. diskriminashun; 2. diskrimineifen].
discriminate &-ion. 1. The act of discriminating.
2. Capacity for discriminating; ability to perceive subtle
distinctions; perception.
segregate (1), vb. trans. &§ intrans. 1. segregat; 2.
segrigeit]; pedantically [l. segregat; 2. sigrigeit] on
account of Lat. se-; fr. Lat. segregat-(um), P.P. type of
segregare, 'to set apart, separate from others', fr. se- &
greg-, stem of grex, 'a flock'. See gre-garious. 1. trans.
To cut off, separate from others or the main body or mass;
to set apart, isolate. 2. intrans. To become separated from
LY.
a main body or mass, specif. (of crystals &c.) to separate
and collect round a nucleus or line of fracture.
segregation [l. segregashun; 2. segrigeifen], fr. Lat.
segregation-(em). See prec. & -ion. a Act, process, of
segregating; b state of being segregated; c segregated group
of persons or objects &c.
New Practical Dictionary of the English Language,
Britannica World Language Dictionary. Funk & Wagnalls Co.
1956.
discriminate: 1. to note the differences between; observe
a difference. 2. to set apart as different; differentiate;
distinguish. 3. To make a distinction; treat unequally
or unfairly.
discrimination, n.1l. The act or power of discriminating;
the discernment of distinctions. 2. Differential treatment.
3. The state or condition of being discriminated;
distinction; sometimes, unjust distinction.
segregate: 1. To place apart from others or the rest;
isolate or make into an isolated group. 2. To separate from
a mass and gather about nuclei or along lines of fracture,
as in crystallization or solidification. 3. To undergo
segregation. adj. separated or set apart from others;
select.
segregation, n.l1. The act or process of segregating; esp.
in genetics the separation and distribution of inherited
characters in the off-spring of cross-bred parents.
Webster's New International Dictionary of the English
Language. Second Edition. From Volumes II and IV. 1957
discriminate, adj. [L. discriminatus,
past part of discriminare to divide, separate, fr.
discrimen division, distinction, decision, fr. discernere.
See Discern; cf. criminate.] 1. Having the difference
marked; distinguished by certain tokens; distinct.
2. Marked by discrimination; carefully distinguishing.
--discriminately, adv.--discriminateness, n.
discriminate(-nat), v.;-nated (-nated); -id; 119);
=3-
-nating(-nat'ing). Transitive: 1. To serve to distinguish;
to mark as different; to differentiate. Now rare. 2. To
separate (like things) one from another in comprehension
or use by discerning the minute differences.
--,Intransitive:1l. To make a distinction; to distinguish
accurately; as, to discriminate between fact and fancy;
also, to use discernment. 2. To make a difference in
treatment or favor (of one as compared with others); as,
to discriminate in favor of one's friends; to discriminate
against a special class. Syn. --See distinguish.
discrimination, n. (LL. discriminatio
the contrasting of opposite thoughts.] 1. Act of
discriminating, or state of being discriminated.
To make an anxious discrimination between the miracle
absolute and providential. Trench.
2. That which discriminates; a mark of distinction.
3. The quality of being discriminating; faculty
of nicely distinguishing; acute discernment. 4. A
distinction, as in treatment; esp., an unfair or injurious
distinction. Specif., arbitrary imposition of unequal
tariffs for substantially the same service; a difference in
treatment made between persons, localities, or classes of
traffic, in respect of substantially the same service.
A difference in rates, not based upon any corresponding
difference in cost, constitutes a case of
discrimination. A.T. Hadley. :
5. The perception of a difference.
Syn.--Discernment, penetration, distinction, acumen.
segregate, adj. [L.segregatus, past part. of segregare to
separate, fr. se- aside & grex, gregis, a flock or herd.
See Gregarious.] Apart, or separated, from others of the
same kind; set apart; separate; select.
segregate, n. That which has segregated; specif.: a.Biol.
An individual of a class resulting from the separation
of characters during segregation (sense 4). b. Bot. & Zool.
A species separated from an aggregate species.
segregate, v.: seg're-gat'ed (-gat'ed; -id;119);
segregating (-gating). Transitive: 1. To separate or cut
off from others or from the general mass or main body; to
set apart; to isolate; to seclude. 2. To cause to
segregate.
----,Intransitive: 1. To separate from the general mass, and
collect together or become concentrated at a particular
place or in a certain region, as in the process of
crystallization or solidification; hence, to separate or
withdraw as a group from a main body, as from a nation.
2. Biol. To separate, as alleomorphic genes or characters,
during meiosis.
segregation, n. [LL. segregatio.] 1. Act of segregating, or
state of being segregated; separation from others or from
the general mass or main body. 2. Specif.: a Obs. Secession
from an ecclesiastical body; schism. b. Obs. Dispersion.
Shak. c¢ Isolation or seclusion of a particular class of
persons, as of foreign or defective school children or of
the colored or Oriental population of a city. 3. A
segregated portion; formerly, a schismatic group. 4. Biol.
The separation of allelomorphic genes or characters,
typically during meiosis. See Mendel's Law. 5. Ceramics. The
condition of a surface having more than four spots,
blisters, or pinholes in any pottery square.
Webster's New Twentieth Century Dictionary of the English
Language. Second Edition. The World Publishing Company.
1964
discriminate, v.t.; discriminated, pt., pp.; discriminating,
PpPr. [L. discriminatus, pp. of discriminare, to divide,
distinguish, from discrimen, a division, distinction,
interval, from dis-, apart, and crimen, verdict, judgment. ]
1. To distinguish; to observe the difference between; to
select from others.
When a prisoner first leaves his cell he is unable to
discriminate colors or recognize faces. - Macaulay.
2. to constitute a difference between; to differentiate.
In outward fashion. . . discriminated from all the
nations of the earth. - Hammond.
discriminate, v.i. 1. to see the difference (between
things); distinguish. 2. to make distinctions in treatment;
show partiality (in favor of) or prejudice (against).
discriminate, a. 1. distinguished; distinct. 2. involving
discrimination; distinguishing carefully.
discrimination, n. 1. the act of distinguishing; the act
i,
of making or observing a difference; distinction; as, the
discrimination between right and wrong. 2. the ability
to make or perceive distinctions; penetration; judgment;
perception; discernment.
Their own desire of glory would . . . baffle their
discrimination. - Milman.
3. the state of being discriminated, distinguished, or
set apart; a showing of difference or favoritism in
treatment.
There is a reverence to be showed them on the account
of their discrimination from other places.
Stillingfleet.
4. that which discriminates; mark of distinction.
Take heed of abetting any factions, or applying any
public discriminations in matters of religion. Gauden.
Syn.--discernment, penetration, clearness, acuteness,
acumen, judgment, distinction.
segregate, a. [L.segregatus, pp. or segregare, to set apart,
lit., to set apart from the flock; se-, apart, and grex,
gregis, flock.] set apart from others; separate; segregated.
segregate polygamy; in botany, a mode of inflorescence,
when several florets included within an anthodium or a
common calyx are furnished alsc with proper perianths.
segregate, v.t.;segregated, pt.,pp.; segregating, ppr.
to set apart from others or from the main mass or group;
to isolate.
segregate, v.i. 1. to separate from the main mass and
collect together in a new body; said of crystals. 2. to
separate from others; to be segregated. 3. in biology,
to separate in accordance with Mendel's law; to undergo
segregation.
segregation, n. 1. a segregating or being segregated.
2. a segregated part, group, number, etc. 3. in biology,
the separation of allelmorphic genes or characters, as in
meiosis.
Random House Dictionary of the English Language. 1966.
discriminate (v. diskrim e nat; adj di skrim e nit)
v., -nated, -nating, adj. --v.i. 1. to make a distinction
in favor of or against a person or thing on the basis of
wa
|
|
1
!
|
{
the group, class, or category to which the person or thing
belongs, rather than according to acutal merit: He
discriminates against foreigners. He discriminates in
favor of his relatives. 2. to note or observe a difference;
distinguish accurately: to discriminate between things.
--v.t. 3. to make or constitute a distinction in or between;
differentiate: a mark that discriminates the original from
the copy. 4. to note or distinguish as different: He can
discriminate minute variaions in tone. --adj. 5. marked
by discrimination; making nice distinctions: Discriminate
people choose carefully. [L discriminat(us) separated, ptp.
of discriminare. See Discriminant, -ate]
discrimination, n. 1. the act or an instance of
discriminating. 2. the resulting state. 3. treatment or
consideration of, or making a distinction in favor of or
against, a person or thing based on the group, class, or
category to which that person or thing belongs rather than
on individual merit; racial and religious intolerance and
discrimination. 4. the power of making fine distinctions;
discriminating judgment: She chose her colors with great
discrimination. 5. Archaic. something that serves to
differentiate. [L discrimina-tion-(s. of discriminatio)
a distinguishing.
segregate (v. segregat;' n. segregit, -gat). v.,-gated,
-gating, n. -v.t. 1. to separate or set apart from others
or from the main body or group; isolate: to segregate
exceptional children; to segregate hardened criminals.
2. to require, often with force, the separation of (a
specific racial, religious, or other group) from the
general body of society. --vi.i. 3. to separate,
withdraw, go apart; separate from the main body and
collect in one place; become segregated. 4. to practice,
require, or enforce segregation, esp. racial segregation.
5. Genetics. (of allelic genes) to separate during
meiosis. --n. 6. a segregated thing, person, or group.
[ME segregat / L segregat(us) (ptp. of segregare to part
from the flock), equiv. to se- se- + greg- (base of grex
flock) + -atus -ate; see gregarious].
segregation, n. 1. the act or practice of segregating.
2. the state or condition of being segregated: Segregation
was most evident in the wealthier parts of the town.
3. something segregated. 4. Genetics. the separation of
allelic genes in different gametes during meiosis, resulting
in the separation of their characters in the progeny.
[/ LL segregation- (s. of segregatio), equiv. to
segregat (us) (see segregate) +-ion- -ion]
The American Heritage Dictionary of the English Language.
William Norris, Editor. Published by American Heritage
Publishing Co., Inc. & Houghton/Mifflin Co. 1969.
discriminate: To make a clear distinction; distinguish;
differentiate. 2. To act on the basis of prejudice.
-tr. 1. to perceive the distinguishing features of;
recognize as distinct. 2. To serve to mark; differentiate.
Adj. Discriminating. [Latin discriminaire], to divide,
distinguish, from discrimen, distinction.
discrimination: 1. The act of discriminating, 2. The ability
or power to see or make fine distinctions; discernment.
3. An act based on prejudice.
segregate: -tr.l. To separate or isolate from others or from
a main body or group. 2. To impose the separation of (a
race or class) from the rest of society. -intr. 1. To become
separated from a main body or mass. 2. To practice a
policy of racial segregation.
segregation: n. 1. The act or process of segregating or the
condition of being segregated. 2. The policy and practice
of imposing the social separation of races, as in schools,
housing and industry; especially, discriminatory practices
against nonwhites in a predominantly white society.
3. Genetics: The separation of paired alleles in meiosis.
World Book Dictionary - A-K. Edited by Clarence L. Barnhart,
Robert K. Barnhart. Published by Doubleday & Co., Inc. 1986.
discriminate: 1. To see or note a difference between.
2. To constitute a difference between; differentiate.
adj. 1. having discrimination; making careful distinctions.
Archaic: distinguish; distinct.
discrimination: 1. The act of making or recognizing
differences and distinctions. 2. The ability to discriminate
accurately between things that are very much alike; good
judgment. 3. Making a difference in favor of or against.
~G
4. Obsolete.
World Book Dictionary - L-2Z.
segregate: 1. to separate from others; set apart; isolate.
2. to separate or keep apart (one racial group) from another
or from the rest of society by maintaining separate schools,
separate public facilities, etc.
v.i. 1. to separate from the rest and collect in one place.
2. Genetics: to undergo segregation.
segregation: A separation from others; setting apart;
isolation. 2. the separation of one racial group from
another or from the rest of society, especially in schools,
theaters, restaurants, and other public places and public
places of meetings, especially social gatherings. 3. a thing
separated or set apart, isolated part, group, etc.
Webster's Third New International Dictionary.
(Merriam-Webster). 1986.
discriminate. adj. Archaic: having the difference marked:
distinguished by certain tokens: distinct. 2. marked by
discrimination: carefully distinguishing.
discriminate. [L discriminatus, past part of discriminare
to divide, distinguish, fr. discrimin-, discrimen
division, distinction, decision, fr. discernere to
separate, distinguish between -- more at discern]
vt la : to mark or perceive the distinguishing
or peculiar features of: recognize as being different from
others: distinguish between or among. b: to serve to
distinguish: distinguish, differentiate. c: to make out;
analyze, discern, demarcate. 2: to distinguish (as objects,
ideas, or qualities) by discerning or exposing their
differences; esp: to distinguish (one like object) from
another by discerning or exposing the minute differences.
vi la: to make a distinction: distinguish accurately. b: to
use discernment or good judgment. 2: to make a difference
in treatment or favor on a class or categoricel basis in
disregard of individual merit. syn see distinguish.
discrimination: n -s [LL discrimination-, discriminatio act
of contrasting opposite thoughts, separation, distribution,
fr. L discriminatus + -ion, -io, -ion] la: the act or an
Ox
instance of discriminating: as (1): the making or perceiving
of a distinction or difference (2): recognition, perception,
or identification esp. of differences: critical evaluation
or judgment b: psychol: the process by which two stimuli
differing in some aspect are responded to differently:
differentiation. 2 archaic: something that discriminates: a
distinguishing mark. 3: the quality of being discriminating:
the power of finely distinguishing (as in respect to
quality): good or refined taste: discernment. 4: the act,
practice, or an instance of discriminating categorically
rather than individually: as a: the according of
differential treatment to persons of an alien race or
religion (as by formal or informal restrictions imposed
in regard to housing, employment, or use of public
community facilities) b: the act or practice on the part of
a common carrier of discriminating (as in the imposition of
tariffs) between persons, localities, or commodities in
respect to substantially the same service.
segregate. adj [ME, fr. L segregatus, past part, of
segregare to segregate]: Segregated.
segregate/"/ n -s 1: an individual or class of individuals
differing in one or more genetic characters from the
parental line usu. because of segregation of genes 2: a
taxonomic unit separated out from another of the same rank.
segregate. vb -ed/-ing/-s[L segregatus, past part, of
segregare to set apart, segregate, fr. se-apart (fr.
sed, se without) + greg-, grex flock, herd -more at
idiot, gregarious] vt 1: to separate or set apart from
others or from the general mass or main body :isolate.
2: to cause or force the separation of (as races or social
classes) from the rest of society or from a larger group.
3: to remove nondrying components from (a fatty oil) by
winterizing or other methods * vi 1: to separate or
withdraw (as from others or from a main body) 2: to practice
or enforce a policy of segregation. 3: to separate during
meiosis - used esp. of allelic genes.
segregation. n. -s often attrib [LL segregation-,
segregatio,fr.L. segregatus (past part of segregare to
segregate) + -ion-, -io -ion] 1 a: the act or process of
segregating or the state of being segregated. b obs:
Dispersion. 2: the separation or isolation of individuals
-10=
or groups from a larger group or from society: as a: the
separation or isolation of a race, class, or ethnic
group by enforced or voluntary residence in a restricted
area, barriers to social intercourse, divided educational
facilities or other discriminatory means.
-- see Apartheid b: the separation for special treatment
or observation of individuals or items from a larger
group. c: the separate confinement of individuals or
groups. 3: the tendency of individuals or units to
separate from a larger group or society and associate
together on a basis of similar characteristics. 4: a
special cell or cellblock for the confinement of persons
separated from the rest of the inmate population in an
institution. 5: the separation of allelic genes that
occurs typically during meiosis -- see Mendel's Law.
6: a nonuniform distribution of particles or aggregate
throughout a quantity of concrete, mortar, or plaster
7: the concentration of alloying elements in specific
parts of a metallic alloy.
2s The Random House Dictionary of the English Language.
Second Edition, Unabridged. 1987.
discriminate: v.i. 1. To make a distinction in favor of or
against a person or thing on the basis of the group, class
or category to which the person or thing belongs rather than
according to actual merit; show partiality. 2. To note or
observe a difference; distinguish accurately.
v.t. To make or constitute a distinction in or between;
differentiate. To note or distinguish as different.
discrimination: n. 1. An act or instance of discriminating.
2. Treatment or consideration of, or making a distinction
in favor of or against, a person or thing based on the
groups, class, or category to which that person or thing
belongs rather than on individual merit. 3. The power of
making fine distinctions; discriminating judgment.
segregate: to separate or set apart from others or from the
main body or group; isolate. 2. To require, often with
force, the separation of. (a specific racial, religious, or
other group) from the general body of society. -v.i. 3. To
separate, withdraw, or go apart; separate from the main body
and collect in one place; become segregated. 4. to practice,
Fy Be
require, or enforce segregation, esp. racial segregation.
segregation: n. 1. The act or practice of segregating. 2.
The state or condition of being segregated. 3. Something
segregated.
Bibliography prepared by:
Laraine Z. Baker
Paralegal Specialist
-} De