Ephraim v. Safeway Trails, Inc. Appellant's Brief
Public Court Documents
August 14, 1964

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Legal Department General, Lani Guinier Correspondence. Correspondence from Lani Guinier to Prof. Elizabeth Bartholet, 1985. fd8c70c3-e892-ee11-be37-6045bdeb8873. LDF Archives, Thurgood Marshall Institute. https://ldfrecollection.org/archives/archives-search/archives-item/8a1da662-9984-4cbd-91e9-f6818489002f/correspondence-from-lani-guinier-to-prof-elizabeth-bartholet. Accessed August 19, 2025.
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Lesa,EDfense]H. October 25, 1985 Prof . Elizabeth Bartholet Harvard Law School Cambridge, llass . 02138 Dear BetsY: At your suggestion, I am writing to outline the basis for requlsting ; student for the January Term Internship, or the Spiing teim clinical course: I would like a student to prepare a research memoranda and to draft a complaint if ippi'optiate on behalf of tlaggie Bozeman, a black civil rights a-cti.rist and school teacher in Pickens County who was dis- missed from her job as the result of a state felony conviction by an all white jory for "iIIegaI voting." LDF_represented I'trs. Bozeman in i successful federal habeas challenge to her conviction. About two years ago a PILRAP student, Larry Lustberg, prepared an excellent memorandum on selective prosecution, ln issue in the case, prior to our filing the ilabeas petition. I attach a coPy of the habeas pgtition, the disirict judge's memorandum opinion, our brief as appellee in the court of ippeals, and the llth Circuit's opinion affirming the district judge's decision vacating her convic- tion for insufficient evidence. The student should be prepared to research both Alabama law and federal law to determine the proper forum and possible causes of action for challenging Mrs. Bozeman's discharge from, and seeking reinstatement to, her tenured teaching position. An action for damages should also be considered. I short memo on Alabama law governing the right to reinstate- ment of a public employee is attached. The memo does not discuss any rights Mrs. Bozeman may have as a black woman dismissed by an all white school board in a county that is over 40t bllck. I have included in the materials appended to this letter a newsPaper clipping reporting the school board's decision not to reinstate Mrs. Bozeman- Contributions are deductible for U.S. income tar purposes The NAACp LEGAL DEFENSE & EoUCATTONAL FUND is not part ot the National Association for the Advancement ol colore_d People although it wai founoeJui itino strares itJcommitment to equal rightb. L0F has had lor over 25 years a separate Board, program, stall, ollice and budget. o NAACP LEGAL DEFENSE AND EDUCATIONAL FUNO, INC. 99 Hudson Street, New York, N.Y. 10013o(212) 2191900 Prof . Elizabeth Bartholet October 25, 1985 Page 2 I am happy to angwer 4ny questions that you or interested students may trlve. I look forward to hearing flom you soon on this and-the other employment matter (:) we diEcussed. Thanks so much for all Your heIP. SincerelY, Lani Guinier LG/gr Encls. ., ilil(,rfrs'