Martin v United States Department of Justice Brief of Amicus Curiae in Support of Appellants Supporting Reversal

    FOUNDATION 
ThirtyTwo Grand Street, Hartford, CT 06106 

203/247-9823 Fax 203/728-0287 

June 7, 1995 

Ms. Michele Angers 
Office of the Clerk 
Connecticut Supreme Court 
231 Capitol Avenue 
Drawer Z, Station A 
Hartford, CT 06106 

RE: Sheff v. O'Neill, s.C. 15255 
  

Dear Ms. Angers, 

Attached please find an original and three (3) copies of the 
replacement pages you requested. 

Please call us if you need any additional items. 

Sincerely, 

pi LC a 
Martha Stone 

Philip D. Tegeler 

Attorneys for Plaintiffs 

MS,PDT/dmt 

Enclosures 

cc: Bernard McGovern, Assistant Attorney General 
All counsel of record. 

p— : fi DO 

= cv S hes if 

il / 
( | ~ /} 

hard fa ofe = Sy 

\ 

~N
\ 

 



  
    

VI. 

ii - 

A. STUDENTS’ SOCIO-ECONOMIC STATUS IN HARTFORD 
METROPOLITAN AREA SCHOOLS (Stipulations 113- 
CT RE RE a ER 

C. INTEGRATION AND ITS EFFECTS (Stipulations 
ISO EB RY oes eie siniaihiv stimu ols iiatain a x x svi es sn as 

F. DISPARITIES IN EDUCATIONAL OUTCOMES 
(Stipulations 154-202). cue ver rns ravines smmsenes 

PLAINTIFFS’ HEADING: 

HAS THE STATE BEEN INVOLVED IN MAINTAINING RACIAL, 
ETHNIC, AND ECONOMIC SEGREGATION, UNEQUAL EDUCATIONAL 
OPPORTUNITIES, AND LACK OF A MINIMALLY ADEQUATE 
EDUCATION; DOES THE STATE HAVE AN AFFIRMATIVE DUTY 
TO ADDRESS SUCH ISSUES; AND HAS THE STATE FAILED TO 

DEFENDANTS’ HEADING: 

HAS THE STATE BEEN TAKING APPROPRIATE ACTION TO 
ADDRESS RACIAL, ETHIC, AND SOCIO-ECONOMIC ISOLATION 
AND EDUCATIONAL UNDERACHIEVEMENT OF URBAN CHILDREN 

A. STATE INVOLVEMENT IN EDUCATION HISTORICALLY 

(Stipulations 203-220) «vate reevseormevnossnen 

B. STATE INVOLVEMENT IN EDUCATION TODAY 

(Stipulations 221-251)... uv ctv nnssovansonnnine 

STEPS TOWARD INTEGRATION (Stipulations 252-256)..... 

13 

16 

17 

28 

28 

30 

30 

34 

1O05Y 
= WR Shee S000 AL 

  

 



Memo nom 

Marianne Engelman Lado 

= x 29 J ; 

t A X so co 7 WE AAD VA Pp 

ww JV 

\2_a AR 

George 

) 

\\/ \Ce 0 

 



  
    

31. As of 1990, eighteen of the surrounding suburbs had less 
than 10% minority population, ten of the surrounding suburbs have 
less than 5% minority population, 18 out of the 21 suburbs have less 
than 4% Black population, and 12 towns have less than 2% Black 
population. (Pls’ Ex. 137 at 1, 7; Pls’ Ex. 138; Steahr pp. 99-101) 

32. In 1991, sixteen suburbs had less than 3% Latino 
enrollment. (Pls’ Ex. 83 pp. 18-21) 

33. Some of Connecticut’s school districts, including 
Hartford, serve higher percentages of African American and Latino 
students than others. 

34. In 1986, 12.1% of Connecticut’s school age population was 
black and 8.5% was Hispanic. 

35. 1987-88 figures for total school population and percent 
minority for the towns listed below are: 

Total School Pop. % Minority 

Hartford 25,058 90.5 
Bloomfield 2,585 69.0 
Avon 2,068 3.9 
Canton 1,189 3.2 
East Granby 666 2.3 
East Hartford 5,205 20.6 
East Windsor 1,267 8+5 
Ellington 1,855 2.3 
Farmington 2,608 37 
Glastonbury 4,463 5.4 
Granby 1,528 3.5 
Manchester 7,084 11.1 
Newington 3,801 6.4 
Rocky Hill 1,807 5.49 
Simsbury 4,039 6.5 
South Windsor 3,648 9.3 
Suffield 1,772 4.0 
Vernon 4,457 6.4 
West Hartford 7,424 15.7 
Wethersfield 2,997 3.3 
Windsor 4,235 30.8 
Windsor Locks 1,642 4.0 

36. As of 1991-92, two districts, Hartford and Bloomfield, had 
more than five percent African Americans and Latinos on their 
professional staffs. (Defs’ Exs. 14.1-14.22) 

37. As of 1990, fourteen of the state’s 166 school districts 
are home to 30 percent of the state’s total student population, 77 

(replacement page, June 7, 1995) 

  

 



  
    

-28 

V. PLAINTIFFS’ HEADING: 

HAS THE STATE BEEN INVOLVED IN MAINTAINING RACIAL, ETHNIC, AND 
ECONOMIC SEGREGATION, UNEQUAL EDUCATIONAL OPPORTUNITIES, AND 
LACK OF A MINIMALLY ADEQUATE EDUCATION; DOES THE STATE HAVE AN 
AFFIRMATIVE DUTY TO ADDRESS SUCH ISSUES; AND HAS THE STATE 
FAILED TO ACT TO REMEDY THESE CONSTITUTIONAL DEFICIENCIES? 

DEFENDANTS’ HEADING: 

HAS THE STATE BEEN TAKING APPROPRIATE ACTION TO ADDRESS RACIAL, 
ETHNIC, AND SOCIO-ECONOMIC ISOLATION AND EDUCATIONAL 
UNDERACHIEVEMENT OF URBAN CHILDREN IN POVERTY? 

A. STATE INVOLVEMENT IN EDUCATION HISTORICALLY 

203. During the Eighteenth Century, the General Assembly of 
the State of Connecticut assigned the responsibility for providing 
education to parishes, or ecclesiastical societies, the boundaries 
of which were not generally coterminous with town boundaries. 
(Collier p. 19) 

204. At the end of the Eighteenth Century, state funds for 
education were channeled to independent entities called school 
societies, the boundaries of which were at first coterminous with 
parishes. (Collier p. 20) 

205, During the first half of the Nineteenth Century, the 
General Assembly of the State of Connecticut assigned responsibility 
for providing education to approximately 1,600 small corporate 
entities called districts, the boundaries of which were not 
generally coterminous with towns. (Collier p. 21) 

206. Districts in the Nineteenth Century had their own school 
committees and were delegated the power to tax, hire teachers and 
establish textbooks, among other things. (Collier at 61) 

207. During the second half of the Nineteenth Century and the 
first decade of the Twentieth Century, the General Assembly of the 
State of Connecticut passed legislation to encourage the 
consolidation of districts under the auspices of towns in order to 
improve the condition of the schools. (Collier pp. 27-28, 39) 

208. By 1909, all but fifteen school districts in the state 
were consolidated at the town level so that school district 
boundaries except for the fifteen districts were contiguous with 
town boundary lines. (Collier pp. 28, 39, 66) 

2009. The consolidation of school boundaries in 1909 had 
nothing to do with the race of Connecticut students. (Collier, p. 
66) 

(replacement page, June 7, 1995)