Correspondence from Lani Guinier to Kenny Johnson (Southern Regional Council)

    IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF MISSISSIPPI 

EASTERN DIVISION 

CHARLES KILLINGSWORTH and JESS JAMES 
KILLINGSWORTH, Minors, by their father 
and next friend, REV. J. C. KILLINGSWORTH 

Plaintiffs, 

VS. CIVIL ACTION 

THE ENTERPRISE CONSOLIDATED SCHOOL NO. 1302 (EF) 

DISTRICT, ef al. 

THE QUITMAN CONSOLIDATED SCHOOL 

DISTRICT, et al, 

THE CLARKE COUNTY BOARD OF EDUCATION, 

Defendants, 

QUITMAN CONSOLIDATED SCHOOL DISTRICT'S PROPOSED PLAN 
FOR DESEGREGATION OF ITS SCHOOLS 
  

Comes now, Quitman Consolidated School District, one of the 

Defendants in the above styled and numbered cause by and through its counsel 

of record and files this "Proposed Plan for Desegregation' in accordance with 

"Order as to Procedure on Remand" ordered and filed July 31, A. D., 1969. 

This plan is filed for the Defendant, Quitman Consolidated School 

District. Said Defendant, however, reserves all rights arising from the 

appeal of this cause to the Fifth Circuit Court of Appeals, Petition for Writ of 

Certiorari to United States Supreme Court or other available legal remedies 

that said Defendant might have. 

I 

Defendant attaches hereto and prays to be considered a part hereof 

as if specifically copied herein the following Exhibits: 

 



  

1 Exhibit "A" - Quitman Consolidated School District 
schools utilized in 1968-1969 showing grades housed, 
capacity and student enrollment. 

2: Exhibit "B'" - Building Information and 1968-1969 
enrollment in Quitman Lower Elementary School. 

3. Exhibit "C'" - Building Information and 1968-1969 
enrollment in Quitman Upper Elementary School. 

4, Exhibit "D'" - Building Information and 1968-1969 
enrollment in Stonewall Elementary School. 

5. Exhibit "E" - Building Information and 1968-1969 
enrollment in Shirley-Owens High School. 

6. Exhibit "F" - Building Information and 1968-1969 
enrollment in Shirley-Owens Elementary School. 

7. Exhibit "G" - Building Information and 1968-1969 
enrollment in Zack Huggins High School. 

8. Exhibit "H" - Building Information and 1968-1969 
enrollment in Shubuta Elementary School. 

[1 

After carefully studying, planning and diligently endeavoring to 

formulate a workable and feasible immediate plan for desegregation of these 

schools, taking into consideration the present physical facilities, the number 

of children and schools in the District, the close proximity of the scheduled 

opening of the 1969-1970 school year and the possibility of orderly adjustment 

to the proposed changes from its previous system to a total and complete 

desegregated system, Defendant submits the following plan: 

1969-1970 
  

1. That Zack Huggins High School remain the same 

except one-third of the total and expected enroll- 

ment in grades 10, 11 and 12 at Shirley-Owens 

High School be transferred immediately for the 
school year 1969-1970. (It is expected that this 
would cause 118 students of the Negro race to be 
housed in Zack Huggins High School whereas there 

were only 2 housed in 1968-1969. 

2: That the remaining schools for the year 1969-1970 
remain the same and be housed in the same manner 

as for the year 1968-1969. 

 



  

1970-1971 
  

i Zack Huggins High School house all students 
enrolled in grades 10 through 12. 

2. Shirley-Owens High School house all students 
in grades 7 through 9. 

3. The remaining schools be utilized and students 
housed therein as in the school year 1968-1969. 

1971-1972 
  

1: Zack Huggins High School house all students 
enrolled in grades 10 through 12. 

2. hirley-Owens High School house all students 

in grades 7 through 9. 

3. Quitman Upper Elementary School house all 
students in grades 4 through ©. 

4, Quitman Lower Elementary School house all 

students in grades 1 through 3. 

Defendant plans to furnish transportation on a non-discriminatory 

basis in SHR manner as it can determine to be feasible and economically 

sound. 

Staff members including professional staff, teachers, administrative 

officials, teacher-aids and any and all other persons employed by the School 

District are to be employed and their services utilized as nearly as possible 

to the ratio in numbers of one race to the other. 

As to classroom work and extra-curricula activities, including all 

athletic and other school activities, there will be no discrimination with 

regard to race, creed or color. 

The students transferred from Shirley-Owens High School to 

Zack Huggins High School for the year 1969-1970 as proposed herein will 

be composed of the top one-third of the 1968-1969 students in this group as 

determined by Standardized Achievement Tests now on file in Defendant's files. 

 



  

During the implementation of the proposed plan herein, it is 

expected that certain building improvements, including additional class- 

rooms, are to be built in order to properly house and care for all students 

in the school system by locating them in four areas as is indicated above for 

the year 1971-1972. Defendant does not believe that, this can be accomplished 

in a lesser period of time. 

RESPECTFULLY SUBMITTED, 

TALLY DD. RIDDELL 
P..O. Box 199 
Quitman, Mississippi 39355 

A. F. SUMMER, Attorney General 

of the State of Mississippi 

\ By: William Allain, Assistant 

Wot Attorney General 
ere 

RS TY re a fg » ? Vd ~~ A 

BY /rrut:, lnc cle) 
  

ATTORNEYS FOR DE ENDANTY 
| 

   



  

CERTIFICATE OF SERVICE 11g 

  

I, Tally D. Riddell, Attorney of Record for Defendant, Quitman 

Consolidated School District, Clarke County, Mississippi, hereby certify 

that I have this day mailed by regular mail, postage prepaid, to the usual 

pe ” . 1 . 
post office address of Melvyn R. Leventhal, Esquire, 5387 North Farish 

Street, Jackson, Mississippi 39202, a copy of the foregoing Proposed Plan 

for Desegregation. 

This the 9th day of August, 1969. 

oe dh 
ahi yi Lh ~ 

™ a 30. kJ ¢ lel 2 2 At AL 

of \ 
  = yc x RIDDELL = 

 



ih S avr 

pice: /9LE8-67F Qu r 7978, Dss7ereT 
  

  

  

Capacity Students 

Name of School Ha rade Perm. ¥. Ports. N ? Comments 
  

ZACK ADEE AIS AS Do le) 700 
  

SH1pLEY- Owen's AS 700 $30 
  

  

SHIRLE Y- OWES ELEN S7¢ &6O   
Quitman DppER. Elen — 0 20 S70 
  

Quitman ivwer ELEM SH © S720 
  

SHURITA ELEM 2270 370 
  

D7 ONE WALL EW 2/0 S/O 
    

E
X
H
I
B
I
T
 

"A
" 

  

  

  

  

  

    

                                 



  

: | » 

BUILDING THFORMATION 

Name of School CD tae yu SY ii Clponzarlocn 

  

  

  

  

  

  

  

  

  

  

  

  

  

    

  

  
  

Address Lean 2D doaisoagpon 

‘Name of Principal 2 Yl. tr i 

des in School /- «/ Nundser of Permanent Teaching Stations Zl L ( / ) 

Vs) 
Youll / g 

tate Rated Capacity 49 Q Maximum Building Capacity Sr L 
: (without portables) 

Portable and Temporary Classrooms / 

Gn ye} F 

Current Student Enrollment << /f( ’ 2 J ’ A. 

White Negro : Total 

Total Student Enrollment A GG 

/ : 3 1 p47, 

Number of Teachers 2 Aa ’ 28 » ik be 

White Negro Total 

Other Professional Personnel b " Lo ’ : = 

White Negro Total 

Enrollment by Grades 
  

2nd| 3rd| 4th] Sth| 6th| 7th| 8th] 9th} 10th} 1ith 12¢hj| Total 
  

  

      
                      

                              
  

  

  
  

  

  

BO Tc I I A I A I A EE 

od 7 ep oliad lied 4 pais 

i ED Elle ie Ell og 

Number of Stucents A lL 

Age of Building 17: | - 1a of Construction rainy LL 

Number of Portable Ciaserions /L 

Number of Temporary Classrooms Id 
  

Number of Square Feet in Building 
  

Number of Acres in School Site 
  

Attach a list of the subjects or courses offered. 

EXHIBIT "B" 

 



  

  

  

  

  
  

  
  

  

  
    

  

  

  

  

    

BUILDING INFORMATION 

~ _ % Wine G A / Sy 

Name of School ALOE 2D Ll a» 
ud p Nb 

- a fo n gy ) l AS r] 

HAQUTEH8 CNL i Z J ; rd [¥ td [4 
/ 

- . oly / Ll w= 
Name of Principal Si . oil of (J 

Crades ia School o£. Number of Permanent Teaching Statioms /7 Lo. 

A SE YN : 

State Rated Capacity © & 0 Maximum Building Capacity So 
(without portables) 

Portable and Temporary Classrooms 

at J 
wy 

4 4 itv 

Current Student Enrollment HAE ’ ol 3 v I, 

White Negro Total 

Total Student Enrollment WFR 

Number of Teachers a ; ro A on Z 
White Negro Total 

Other Professional Personnel 4 , i ae ie 
White Negro Total 

Enrollment by Grades 
  

|_lst] 2nd| 3rd| 4th| S5th| 6th] 7th| 8th] 9th] 10th] llth} 12¢hlj Total 
IWIN WIN WIN WIN WIN/WIN WIN|WIN|WINIWINIWIN]WIN] 
  

    
  

  

                          

                          
) z ANd « o) { £ 4 ) ; /, ' § 4 [44 5 “’ 

LJ 

- ry re ] 7 

ak / 4 [2 Yo JG 4 
  

Number of Students Transported //) 
EL 

ro pod A oe P| 2 . / ; - 

Age of Building /7Z&-/. Type of Construction {17 bili 

  

  
  

  

Number of Portable Classrooms 
  

Number of Temporary Classrooms 
  

Number of Square Feet in Building 
  

Number of Acres in School Site 75 
  

Attach a list of the subjects or courses offered. 

EXHIBIT "C" 

 



RG ; | : » 

BUILDING THFORMATION 

  

Nama of School I GE day ’ i - 1 

AVA MAS a SAE FS Lidy 
  

  

  

  

  

  

  

  

  

  

  

  

  

  

  
  

Grades in School /- 4 Number of Permanent Teaching Stations il 

State Rated Capacity  / 74 Maximum Building Capacity a 

(without portables) 

Portable and Temporary Classrooms L 

Current Student Enrollment SAL ‘3 / " ar 

White Negro : . Total 

Total Student Enrollment _ LE le 

Number of Teachers in ’ / ’ 

White Negro Total 

ther Professional Personnel z ’ é ’ 

White Negro ‘Total 

Enrollment by Grades 
  

  

  
    

  

  

                          
  

  
  

                                  

1st! 2nd| 3rd] &eh| Sth| 6th] 7th] 8th] 9chl 10th 11th| 12th} Total 

NTR WIN WIN WIN IN Nw NWN WIN]WINL WING WLR, 

| 2d pret ploipliA lol 42 

Tofi- 

af ci rel os] 3 Lic 

Number of Students Transported Ji 
  

Age of Building _ /. J/ Type of Construction__ Lath   
  

  

  Number of Portable Classrooms 2 

Number of Temporary Classrooms J 
  

Number of Square Feet in Building   

Number of Acres in School Site id 
  

Attach a list of the subjects or courses offered. 

EXHIBIT "D" 

 



: ! A 

TITY NTN ERITINTIASA YTON 
BUTLD LN } Lr UR A LUN 

  

  

  

  

ar £ Cpa) 5, Gl Ra Jl SUR OR , i 2A, 
Name of School ads ot LX Lat l a 

a @ 
LJ ) / 

KOLTess 
5 vi LANL ~ x « 

. 4 £ Dard dtd r (La 
Nae Ox Principal ’ ¢ "i \ 

y . 
or ; i ] J 

Grades ia School © - Number of Permanent Teaching Statioms__. . _[7/ 
  

  

” 

  

  
State Rated Capacity [f+ / Maximum Building Capacity of 

) (without portables) 

  

  

  

  

  

    

  

  
  

Portable and Temporary Classrooms 4 

Current Student Enrollment / , fe 4 Lo > -Y —— 

White Negro Total 

Total Student Enrollment C&L 

Number of Teachers Jf s os > i. 

White Negro Total 

a +f 
Other Professional Personnel / 3 4 ’ i 

! 
White Negro Total 

Enrollment by Grades 
  

  

  

                                                          
  

  
  

  

  

| 3st] 2nd| 3rd| &eh| Seh| 6th] 7th] 8th] Sch} 10th] 1leh} 12¢h Total 
WI NI WI NWN] WINIW NI WIN WI NI WINI WIN] WINIW|N|WINIWIN 

J ’ 2) } Ly 

od "yn Obed 0 by JIM ER wi na 

Totj- ' : Joris li fry 

al prt psy orl pga liad ng Nae 

Number of Students Transported iE 

Age of Building___ / 75 ¢ Type of Construction Arai. LLL 

Number of Portable Classrooms oh 

Number of Temporary Classrooms { 
  

  
Number of Square Feet in Building 

Number of Acres in School Site i 
  

Attach a list of the subjects or courses offered. 

EXHIBIT "BE" 

 



  

Ayr NENG TNTORMATTON 
BUILDING INFORMATION 

  

  

  

  

  

  

  

  

  

  

  

  
  

Name of School ania ETA Lae % 

. Sh oo J iano / TE ‘ 

Address rg I ddd SAY iy y 

° . ) ; J ' ’ 
Name of Principal fried : 

Grades ian School /- ¢ Number of Permanent Teaching Stations /¢ (7) 4 

State Rated Capacity 7 2» Maximum Building Capacity r= 
(without portables) 

Portable and Temporary Classrooms ™ 

) EE ) / = 4 Current Student Enrollment 7 . S&L ' niin 
White Negro : Total 

Total Student Enrollment wikia 

Nhe wowed £m - 7 ” : . > = oy Number of Teachers : 4 ’ eX ’ . 

White Negro Tote 

Other Professional Personnel rd ’ / ' / 
  

  

Enrollment by Grades 
  

  

  

                          

|_1st| 2nd| 3rd] &th| Seh| 6th| 7th] 8th| 9th] 10th] 11th] 12thi| Total 
WIR WIN WIN WIN WIN WIN WN WINIWINIWINIW| NJ WINJWIN 

3 /) Te rr) A /; (> oe 

WAR bola WAR 724 Wk B71 WAR MA WR Vii W/V c 4 —— 
"ne. af 

+0 . , i” ra 
al 22) ATE ALG WIL                               

Number of Students Transported 477   

  
  

  

  

— - 

“ 
: : 

Age of Building / 744 Type of Construction Ls Lill 

Number of Portable Classrooms 2 

Number of Temporary Classrooms L   

Number of Square Feet in Building 
  

of Acres in School Site 5 Va 
  

a list of the subjects or courses offered. 

EXHIBIT "F" 

 



  

PETTY TYEE TRIAD NA MTN 
BUILDING IWFORMATION 

) 

  

  

  

  

  

  
  

  

  
    

  

  

  

  

    

  

    

y , J . 

Name of School Do lghe wile aon Ralls tam of 
m- 

: Address id / Fann 

. : ke 45 PSEA BY 
Name of Principal lind i 

4 

Grades in School /. = Number of Permanent Teaching Stations ~ ¢ { 

f ! . 4. 2A 

State Rated Capacity “ff i Maximum Building Capacity Zl go 
(without portables) 

Portable and Temporary Classrooms AL 

Current Student Enrollment ~~ =/ > bi > an 
White Negro Total 

Total Student Enrollment ill 

nL Ll Pa lg} : rd i 2 

Number of Teachers A ir ’ ZL. ’ CL 

White Negro Total 

* ; / 
ther Professional Personnel H ’ L " / 

White Negro Total 

Enrollment by Grades 

|_ist| 2nd| 3rd| &eh| Sth] 6th] 7th! 8th] 9th] 10th] 11th 12thl] Total 
B13 

[ WIN WIN[WIN{ WIN WIN WN WIN WIN WINIW NI WINJWIN 
  

  
  

                          

                                
  

  
  

  

  

  

  

Number of Students Transported TA 

Age of Building /¥ s.0-/ = Type of Construction ni ; 

Number of Portable Classrooms 7 

Number of Temporary Classrooms é 

Number of Square Feet in Building 

Number of Acres in School Site a lf 
  

bh) 

Attach a list of the subjects or courses offered. 

EXHIBIT "G" 

 



  

BUTY DTNG VR ORMATTON 
DULL LNG La 'ORMAT LON 

asp A 

  

  

  

  

  

  

  
  

  

  
  

  

  
    

  

  
  

  

  

  

                                

AVGLALS WV wea s VU A ro 4 

Address a 7 Zs ‘ 

RT = ove my EE Pord on Loven Li 2 d 2100 ey j A172 
ANGAMAS ok FTLUCLD de bid / F { xe fs 4 _— 

’ 

 » Fa 

rades in School /-— /- ermanent Teaching Stations g 

” 4 PE * y hilt, > 

State Rated Capacity .. 5 ¢ Maximum Building Capacity Now 

Za (without portables) 

Portable and Temporary Classrooms Z 

cud E / “grid at pi 
Current Student Earollment / ’ A Ly » RRL 

White Negro Total 

r SP | be 0 2 4 do ty om am ot % ; 
Total Student Enrollment A 

ny : em A, VS SR 
Number of Teachers 74 > ZL > Enbianinciont 

White Negro Total 

Ld ~~ 
va 

Ps 
2) 

Other Professional Personnel Zz ’ L " L 

| White Negro Total 

Enrollment by Grades 

: . g 9 v e | ’ ’ |_ 1st] 2nd| 3rd] 4th] 5th] 6th| 7th| 8th] 9th| 10th} 11th} 12¢h}] Total 
omen wa sanesracin, Jo - 

IWIN wiNI WIN/WIN WIN WIN WIN/WIN WINIWINIWI NIWINJWIN 
I | 
| ," ! ! 7 15" 3 ar 7 Wr, 

Tot- = ny 
gl 7 JP 1 4 7 by A WA                         
  

  

hb \1 3 Oe 3 Ly : 2 U Number of Students Transported JV 

Id < { of : 

Age of Building / Z«¢ Type of Construction /[  csollas odin lo 
  

  

  

  

  

  

Number of Acres in School Site ) 
  

Attach a list of the subjects or courses offered. 

EXHIBIT "H"