8 20 1089 https://projectdaps.org/files/original/f691dc07bab9fa4b3817dfa7bda99ba6.pdf 392172ebda792a43583e606607e0c01c PDF Text Text P T A F ederation S ets W orkshop On In tegration T he Legislative C om m ittee of th e F a irfa x C ounty F ed e ra tio n of P a re n t-T e a c h e r A ssociations will conduct a w orkshop on th e S u prem e C ourt decision on segrega tio n in public schools, S aturday, A pril 30, 12:30 to 4:30, a t the Ann a n d ale E le m e n tary School. S p eakers w ill include Benjam in M use, ed ito r of th e M anassas M es se n g er a n d colum nist fo r th e W ashington P o st and T im es-H erald, who w ill sh a re a panel discus sion on “Views on Opinions in V ir g in ia ’’ w ith R everend C. E m erson Sm ith, from Richm ond, of th e V irginia Council of Churches. Dr. H ouston R. Jackson, a ssista n t S u p e rin ten d e n t of th e B altim ore Schools, will ta lk on “E xperiences in changing from a dual to a single school system .” O ther m em b e rs of this panel and speakers on leg al background of the decision will be announced late r. R o b e rt M. M angan of Vienna will discluss F a irfa x population a n d th e economics of integration. D r. H a r o l d K ennedy, F a irfa x C ounty H e a lth Officer, w ill de-1 scribe th e school and com m unity ' h e a lth program s. IJ \ i \ ") O f �IIO > ...$ 1.000 60.00 . . . 1,060.00 44.17 lank BRANCH OFFICE 6815 Lee Highway East Falls Church, Va. I ACCOUNTS ovement Loans Christmas Club 5S & INDIVIDUALS p. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Newspaper Clipping, 1955 Description An account of the resource Clipping from unnamed newspaper for April 29, 1955. Announces workshop on the Brown vs. Board of Education decision and how it is to be applied in Fairfax County. Verso has other side of newspaper page. Two pages. Format The file format, physical medium, or dimensions of the resource pdf Source A related resource from which the described resource is derived RG 18, Personal Papers of Barbara Marx Creator An entity primarily responsible for making the resource unknown Date A point or period of time associated with an event in the lifecycle of the resource 1955-04-29 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1950s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_17_3 https://projectdaps.org/files/original/c4e85dc115576897e13683e13c638d05.pdf 438cb54d8708212c089ab179388fbb86 PDF Text Text 5 \ Federation ^ Gives Stand Onlntegration The Executive Com m ittee of th e F airfax County Federation o f P-TAs y esterd ay sent letters to all local P-TA presidents and school principals stating “pre cisely” the stand the F edera tio n has tak en on the Suprem e C o u rt school segregation deci sion. Mrs. D orothy C. Gray, presi d e n t of th e Fed eratio n , said th e executive com m ittee de cided to send th e le tte rs a fte r a "workshop” on th e effects of th e Suprem e C ourt decision w as broken up la s t S aturday by an “u n ru ly group of antiin te grationists.” “ We deplore the evident dis position of outside groups to m isin te rp re t o u r approach and in te n t t o w a r d th e study of problem s arising from the de cision,” th e le tte r states. In cluded in the le tte r is an out lin e of th e inform ation the Fed e ra tio n had proposed to use as back g ro u n d m aterial fo r the workshop. Mrs. G ray said the F edera tio n has no in tention of polling th e local P-TAs or the F edera tio n on segregation. The le t t e r sta te s the F e deration is “ ribt a pressure group to advo cate e ith e r segregation or in te g ration. I t has been o u r in ten tion to bring tog eth er avail able m aterial so th a t w hatever decision is reached by Virginia, we m ay be prep ared w ith a background of understanding.” Mrs. G ray said th a t S a tu r day’s w orkshop was agreed on by the Federation a fte r the N ational Congress of P-Ts and th e V irginia C ongress of P a r e n ts and Teachers recom m end ed th a t local groups study and discuss the problem s relative to the Suprem e C ourt decision. �HHW LB. $ 1 .2 5 CAMEO lVz lb. $ 3 .5 0 CHOCOLATE � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Newspaper Clipping, 1955 Description An account of the resource Clipping from unnamed newspaper for May 5, 1955. Describes the position of the Fairfax County Federation of PTAs on school desegregation. Verso has other side of newspaper page. Two pages. Format The file format, physical medium, or dimensions of the resource pdf Source A related resource from which the described resource is derived RG 18, Personal Papers of Barbara Marx Creator An entity primarily responsible for making the resource unknown Date A point or period of time associated with an event in the lifecycle of the resource 1955-05-05 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1950s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_17_2 https://projectdaps.org/files/original/5849280f254842324fc36243707966e3.pdf 28972e374608e9dd9ed7f56cf342928c PDF Text Text Fairfax County Federation of P-TA' a Workshop on Supreme Court Decision on public schools April 30, 1955 If you want to be better informed read: FOR CURRENT DEVELOPMENTS: 1. Your daily newspapers, which carefully report developments in Washington area, plus, editorials and column comment. 2. Southern School News, a factual monthly publication of the Southern Education Reporting Service (which is financed by a grant from the Fund for the Advancement of Education, an independent agency established by the Ford Foundation). The "news beat" for SSRS consists of the 1? states and the District of Columbia affected by the Supreme Court decision of Kay 17, 1954, and developments in education arising therefrom. Subscriptions are free upon request, SERS, P. 0. Box 6156, Acklen Station, Nash ville, Tennessee. 3. The Clearing House on Public Education, edited by Mrs Charles E. Planck, a monthly newsletter reportihg developmen in Northern Virginia. Subscriptions are $1 a year from Citi zens Clearing House on Public Education, P. 0. Box 218, Annandale, Va. FOR BACKGROUND MATERIAL 1. The P-TA kit on the Supreme Court Decision with material on both specific and general problems arising from the Supreme Court Decision. The kit has been distributed to P-TA units. 2. The summary, in considerable detail, "Developments in Virginia as a result of the Supreme Court ruling against racial segregation in public schools" prepared by the Democratic Women of Mount Vernon, 167 Konticello Road, Alexandria, Va. 3. "Facts concerning segregation and integration", a study made by the Alexandria Council of P-TA'8 working with the Alexandria City-Wide Parent-Teacher Council, Mrs S. W. Livingston, chairman of the Coordinating Committee. 4. "Facts Concerning segregation and integration", issued by the Arlington, Virginia, public schools, November 1954. 5. "Progress of Colored Americans in Metropolitan Washington", a summary of accomplishments of Washington area Negroes. Copies may be had at 25$ for 5 (minimum order) at P. 0. Box 218, Annandale, Va. 6. Schools in. Transition, edited by Robin M. Williams, Jr. and Margaret W. Ryan (Chapel Hill, University of North Carolina Press, 1954). Reports of some recent experiences of twenty-four communities in states bordering the South as they have moved from racially segregated toward integrated public schools. If you really want to study integration problems: The National Conference of Christians and Jews has available many free or inexpensive pamphlets and booklets by writers of standing in their fields of science, education, and religion. Most pertinent, perhaps, among the newer materials are the ten "Intergroup Education Pamphlets", the first of which, "Readings in Intergroup Relations" by Helen F. Storen, is a selected reading list, briefly annotated. Many of the books suggested on Dr. Storen's list may be borrowed from the library of the NCOJ Washington office. Room 820, Southern Bldg 1425 H Street, N. W . , Washington, D. C. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Flyer Listing School Desegregation Reading Material, 1955 Description An account of the resource Flyer from the "Fairfax County Federation of PTA's Workshop on Supreme Court Decision on Public Schools," dated April 30, 1955. Lists sources for information on the desegregation of schools, both background material and current news. Also refers to publications from the National Conference of Christians and Jews. Format The file format, physical medium, or dimensions of the resource pdf Source A related resource from which the described resource is derived RG 18, Personal Papers of Barbara Marx Creator An entity primarily responsible for making the resource Fairfax County Federation of PTAs Date A point or period of time associated with an event in the lifecycle of the resource 1955-04-30 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1950s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_17_1 https://projectdaps.org/files/original/1c1cc55d87d7074e092850f5a6a4c1f4.pdf c883f73983e924692221b2b218df19e3 PDF Text Text IN THE UNITED STATES COURT OF APPEAIS FOR THE FOURTH CIRCUIT JOHN K . HART, e t a l . , P l a i n t I f f s -A p p e H a n t s , v. COUNTY SCHOOL BOARD OF ARLINGTON COUNTY, V IR G IN IA , e t a l . , D e fe n d a n ts - A p p e lle e s . ON APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE EASTERN D ISTRICT OF VIRGINIA BRIEF FOR CERTAIN ARLINGTON ORGANIZATIONS AS AMICI CURIAE A m ic i O r g a n i z a t i o n s : WILLIAM H . ALLEN JOHN B . JONES, J r . ARLINGTON COUNCIL ON HUMAN RELATIONS ARLINGTON EDUCATION ASSOCIATION C o v i n g to n & B u r l i n g ARLINGTON HEALTH AND WELFARE COUNCIL 8 8 8 1 6 t h S t r e e t , N.W. ARLINGTON VIEW CIVIC ASSOCIATION W a s h in g t o n , D .C . 2 0 0 0 6 LEAGUE OF WOMEN VOTERS OF ARLINGTON NAUCK CIVIC ASSOCIATION A t t o r n e y s f o r A m ic i C u r i a e NORTHERN VIRGINIA CENTER FOR SOCIAL DEVELOPMENT ( f o u r p a r i s h e s ) : OUR LADY OF LOURDES OUR LADY QUEEN OF PEACE S T . ANN'S S T . CHARLES NORTHERN VIRGINIA CHAPTER OF THE AMEPICAN C IV IL LIBERTIES UNION OF VIRGINIA PO SITIV E ACTION COMMITTEE FOR EDUCATION ROCK SPRING CONGREGATIONAL CHURCH BOARD OF SOCIAL ACTION "SUPPORT CHRISTIAN ACTION" HOUSE OF THE LITTLE FA LIS PRESBYTERIAN CHURCH �TABLE OF CONTENTS Page STATEMENT 3 ARGUMENT THE ARLINGTON COUNTY SCHOOL BOARD'S PLAN FOR DESEGREGATING THE COUNTY'S SCHOOLS DENIES TO THE STUDENTS OF THE FORMER DREW AND HOFFMAN-BOSTON ELEMENTARY SCHOOLS THE EQUAL PROTECTION OF THE LAWS BECAUSE IT LAYS UPON THEM THE ENTIRE BURDEN OF DESEGREGATION BY ELIMINATING DREW AND HOFFMANBOSTON AS ELEMENTARY SCHOOLS AND REQUIRING THE STUDENTS TO BE TRANSPORTED BY BUS TO SCHOOIB THROUGHOUT THE COUNTY WHILE NO WHITE CHILDREN ARE INVOLUNTARILY TRANSPORTED TO SCHOOIS OUT SID E THEIR NORMAL, NEIGHBORHOOD ATTENDANCE AREAS. . . . . A. 12 The F a c ts D e m o n s tra te th e I n v id io u s D i s c r i m i n a t i o n A g a in s t B la c k C h ild r e n E f f e c t e d b y t h e S c h o o l B o a r d 's P l a n ............................................. 15 D e c is io n s o f T h is C o u rt a n d O th e r C o u r ts E s ta b lis h th e U n c o n s titu tio n a lity o f th e A r l i n g t o n S c h o o l B o a r d 's D e s e g r e g a t i o n P l a n ...................... 17 T he F a c t t h a t th e S c h o o l s u l t s i n A r l i n g t o n 's N ot S c h o o l s D o es N o t J u s t i f y I t W orks A g a i n s t B l a c k C B o a r d 's P l a n R e H a v in g A ny O n e -R a c e th e D is c rim in a tio n h i l d r e n ....................................................... 24 CONCLUSION................................................................................................................................... 26 B. C. INDEX TO AUTHORITIES Cases: A dam s v . S c h o o l D i s t r i c t N o. 5 , 4 4 4 F . 2 d 9 9 ( 4 t h C i r . 197 c e r t '. " d e n i e d , 4 0 4 u T 5 T ~ 9 l2 ( 1 9 7 1 ) .......................................... A l l e n v . A s h e v i l l e C i t y B o a rd o f E d u c a t i o n , 4 3 4 F . 2 d 902 (4 th C ir . 1970) . . . . . . . . . . . . . . . . 20 B e l l v . W est P o i n t M u n ic ip a l S e p a r a te S c h o o l D i s t r i c t , 4 4 6 " F ;~ d " " i3 6 5 ( 5 t h ' C i r . l '9 7 l ) . . 22 �ii Table of Contents Continued Page B ric e v . L a n d i s , 3 1 4 F . S u p p . 9 7 4 (N .D . C a l . 1 9 6 9 ) B r o o k s v . C o u n ty S c h o o l B o a r d , 3 2 4 F . 2 d 3 0 3 21 (4 th C ir . 1963) • 6 -.— -7 ......................................................................... 6 B r o o k s v . C o u n ty S c h o o l B o a r d , 2 0 4 F . S u p p . 6 2 0 (E .D . V a . --------- T962) — . . . . . . B row n v . B o a rd o f E d u c a t i o n , 3 4 7 U.S. 4 8 3 (1 9 5 4 ) 3, B row n v . B o a rd o f E d u c a t i o n , 3 4 9 U .S . 2 9 4 ( 1 9 5 5 ) ........................... C a r r v . M o n tg o m e ry C o u n ty B o a rd o f E d u c a t i o n , 4 2 9 F . 2 d 3 8 2 ( 5 t h C i r . 1970")...... C h a m b e rs v . . . . 5 4 22 I r e d e l l C o u n ty B o a rd o f E d u c a t i o n , 4 2 3 F . 2 d --------- B IT ( 4 t i m F T ~ I 9 7 T ) — ................................................ 21 C h o c ta w C o u n ty B o a rd o f E d u c a t i o n v . U n i t e d S t a t e s , 4T 7 F . 2 d b 4 5 ( 5 t h C i r . 1 9 b 9 ) ............................................................... F e l d e r v . H a r n e t t C o u n ty B o a rd o f E d u c a t i o n , 4 0 9 F . 2 d T 0 7 0 ( 4 'th C i r 7 1 9 6 9 ) ............................ . . .......................................... 20 G o rd o n v . J e f f e r s o n D a v is P a r i s h S c h o o l D i s t r i c t , 4 4 6 F . 2 d 2 6 6 ( 5 t h C i r . 1 9 7 1 ) .......................................... ............................... 22 G re e n v . S c h o o l B o a r d , 3 1 6 F . S u p p . 6 (W .D . V a . 1 9 7 0 ) • l8 . 1 9 , 20 26 Hamm v . C o u n ty S c h o o l B o a r d , 263 F . 2 d 2 2 6 (4 th C ir. 1959) • 6 Hamm v . C o u n ty S c h o o l B o a r d , 2 6 4 F . 2 d 9 4 5 (4 th C ir . • 6 1959) H a n e y v . C o u n ty B o a rd o f E d u c a t i o n , 4 2 9 F . 2 d 3 6 4 ( 8 t h C i r . 1970-]— 7 — .................................. ........................ . 23 L ee v . M acon C o u n ty B o a rd o f E d u c a t i o n , 4 4 8 F . 2 d 7 4 6 (5th c i r . 1 9 7 1 ) . ......................................................................................... 12 , 21 Mims v . D u v a l C o u n ty S c h o o l B o a r d , 4 4 7 F . 2 d 1 3 3 0 (5 tE " ~ C ir. 1 9 7 1 )— . ". '. . ’. .................................................................... 22 S c h o o l B o a rd o f C h a r l o t t e s v i l l e v . A l l e n , 2 4 0 F . 2 d 5 9 ( 4 t h C i r . 1 9 5 b ) , c e r t , d e n i e d , 3 5 3 U .S . 9 1 1 ( 1 9 5 7 ) • * 5 �iii Table o f C ontents Continued Page Swann v. Charlotte-Mecklenburg Board of Education, ------- ’ 02 U.5Y T (1971) 4 '...................... 8, 18 Thompson v. County School Board, 144 F. Supp. 239 (E.D. Va“ 195 F) 5 Thompson v. County School Board, 159 F. Supp, 567 (E.D. Va7 195?)""aff'd, 252 F.2d 929 (4th Cir. 1958), cert. denied, 358 U.S . 958 (1 9 5 8 ) ................. ~ g Thompson v. CountySchool Board, 166 F. Supp. 529 (e T ) vaT 195^) . . . . . . ................... . .' ’ • Wanner v. County School Board, 245 F. Supp. 132 (E.n m, 1965) ”— r : . ......... . a* ■* Wanner v. County School Board, 357 F.2d 452 (4th Cir. 1 9 6 6 ) Yick Wo v. Hopkins, 118 U.S. 356 ( 1 8 8 6 ) ........ 12 , 0 7 5 14,24 3 14,23 Constitution: United States Constitution, l4th Amendment . . . . 11 Other: Muse, Virginia's Massive Resistance (1 9 6 1 ) . . 4 �IN THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT No. 71-1791 JOHN K. HART, e t a l . . P la in t i f f s - A p p e lla n t s , COUNTY SCHOOL BOARD OF ARLINGTON COUNTY, VIRGINIA, et al., Defendants-Appellees. O APPEAL FROM THE UNITED STATES DISTRICT COURT N FOR THE EASTERN DISTRICT OF VIRGINIA BRIEF FOR CERTAIN ARLINGTON ORGANIZATIONS AS AMICI CURIAE The a m ici cu ria e on whose b e h a lf t h is b r ie f is file d 1 / are groups and o r g a n iz a tio n s made up e x c lu s iv e ly 1 / A rlin g to n C oun cil on Human R e la tio n s; A rlin g to n E ducation A s s o c ia tio n ; A rlin gton H ealth and W elfare C o u n cil; A rlin g to n View C iv ic A s so c ia tio n ; League o f Women V o ters o f A r lin g to n ; Nauck C iv ic A sso c ia tio n ; fo u r member p a r ish e s o f th e N orthern V ir g in ia Center fo r S o c ia l Development — Our Lady o f Lourdes, Our Lady Queen o f P ea ce, S t . Ann's and S t . C harles; N orthern V ir g in ia Chapter o f th e American C iv il L ib e r t ie s Union o f V ir g in ia ; P o s it iv e A ctio n Committee f o r E d ucation; Rock S pring C ongregation al Church Board o f S o c ia l A c tio n , and "Support C h r istia n A ction" House o f th e L i t t l e F a lls P re sb y te ria n Church. �2 o r in major p a rt o f r e s id e n ts o f A rlin g to n County th a t are concerned w ith is s u e s o f p u b lic p o lic y a f f e c t in g th e q u a lit y o f l i f e in A rlin g to n County, in c lu d in g i t s e d u c a tio n a l system . They b e lie v e th a t in i t s p lan fo r e lim in a t in g d e se g r e g a tio n in A r lin g to n 's elem entary sc h o o ls th e A rlin g to n County S ch ool Board has tr e a te d a group o f b la ck c h ild r e n (and t h e ir p a ren ts) u n f a ir ly . By way o f fu r th e r in tr o d u c tio n we add on ly th is : By th e tim e t h is b r ie f i s f i l e d , a f u l l academ ic sem ester w i l l have been com pleted under th e A r lin g to n County S ch ool B oard's p la n th a t i s ch a llen g ed h e r e . In th a t p erio d th e S ch ool B oard's d e c is io n th a t alm ost a l l the b la c k c h ild r e n who had been a tte n d in g Drew Elem entary S ch o o l and Hoffman-Boston Elem entary S ch o o l must be t r a n s p orted by bus t o oth er elem entary sc h o o ls throughout the County has been ca r r ie d out am icably and w ith good w i l l on a l l s id e s . Most o f th o se who are re p resen ted on t h i s b r ie f by membership in one or more o f th e a m ici o r g a n iz a tio n s a re w h ite ; many o f them are p aren ts o f c h ild r e n a tte n d in g th e p u b lic s c h o o ls ; and many o f th e se p a ren ts have been d e lig h te d to have th e l i v e s o f t h e ir c h ild r e n en rich ed by t h e ir a tten d an ce a t in te g r a te d sc h o o ls — some f o r th e �- 3 - f i r s t tim e . These w h ite p aren ts n e v e r th e le s s remain |o f th e view th a t th e b e n e f it s t h e ir c h ild r e n r e a liz e I from s c h o o l in t e g r a t io n cannot r i g h t ly be had a t th e expense o f th e b la c k c h ild r e n who* a lo n e among A rlin g to n p u b lic s c h o o l s tu d e n ts , are made t o t r a v e l t o sc h o o ls f a r from t h e ir homes. STATEMENT T his ca se concerns th e com p letion o f th e d e se g r e g a tio n o f th e p u b lic sc h o o ls o f A rlin g to n County more than 17 y ea rs a f t e r th e d e c is io n in Brown v . Board o f E d u cation , 347 U .S. 483 (1 9 5 4 ). The slow pace o f d e se g r e g a tio n in d ic a te d by the p assage o f so many y e a r s s in c e th e f i r s t Brown d e c is io n i s th e more d i f f i c u l t t o understand when one c o n sid e r s th a t — 1. An ex tr a o rd in a r y wartime and p ost-w ar growth o f p o p u la tio n brought about by i t s co n v en ien t n ea rn ess t o th e n a tio n a l c a p it a l has l e f t A r lin g to n , though s t i l l n oted in some sou rce books c h i e f l y as th e home o f th e f i r s t s o ld ie r o f th e C onfederacy, a community whose r e s id e n ts f o r th e most p a rt have no �- 4 - p a r t ic u la r attachm ent to th e southern t r a d it io n o f se p a r a te sc h o o ls f o r b la ck s and w h ite s . 2. Black c h ild r e n account f o r no more than 11 p erc en t o f th e t o t a l A rlin g to n p u b lic s c h o o l p opu la tio n . With some thought and care a tr u e u n ita r y sc h o o l system ab sorb in g th e s e b la ck c h ild r e n could have been cr ea ted a t any tim e in th e l a s t 17 y e a r s , and i t s c r e a t io n i^ould have caused s c a r c e ly more than a r ip p le . In deed , v i r t u a l l y a l l o f A r lin g to n 's b la ck c h ild r e n have now been absorbed in to p r e v io u s ly a ll- w h i t e sc h o o ls w ith ou t s i g n i f i c a n t in c id e n t . To be s u r e , th e slow n ess w ith which A rlin g to n County moved t o d ese g re g a te i t s sc h o o ls i s a t t r ib u t a b le in p a rt to th e s t a t e p o lic y o f m assive r e s is t a n c e th a t p r e v a ile d in th e l a t e 1 9 5 0 's . 2/ But th e r e has been l o c a l r e s is t a n c e as w e ll , and the s to r y o f i t i s w r itte n in o p in io n s o f t h i s C ourt. In b r ie f summary: 2 / To A r lin g to n 's c r e d it i t s sc h o o l board announced broad p la n s f o r d e se g r e g a tio n soon a f t e r th e second Brown d e c i s io n , Brown v . Board o f E ducation, 349 U .S . 294 (1 9 5 5 )• The l e g i s l a t u r e , caught up in th e b eg in n in g s o f m assive r e s is t a n c e , r e a c te d by ta k in g away from th e r e s id e n ts o f A rlin g to n County t h e ir p r i v i l e g e , unique among V ir g in ia l o c a l i t i e s , o f e l e c t i n g t h e ir own sc h o o l board; th e members o f th e sc h o o l board are now appointed by the County Board, th e C ounty's governing body. See Muse, V ir g in ia 's M assive R e sista n c e 24 (1 9 6 1 ). �- 5 - At th e tim e th a t Brown v . Board o f Education was d ecid ed th e sc h o o l c h ild r e n o f A rlin g to n County, l i k e th o se o f o th er V ir g in ia com m unities, were s e g r e ga ted in t h e i r sc h o o ls by r a c e . There were fou r b lack elem en tary sc h o o ls - - Kemper and, n earb y. Drew ( o r ig in a l l y known as Kemper Annex) and Hoffman-Boston in the sou th ern p a rt o f th e County, se r v in g th e County's la r g e s t b la c k r e s i d e n t i a l area; and L angston, se r v in g th e b la ck r e s i d e n t i a l area in th e n orthern p a rt o f th e County. There was a s in g le ju n io r and se n io r h igh s c h o o l f o r b la ck s from a l l p a rts o f th e County, a ls o c a lle d Hoffm an-Boston. An in ju n c tio n fo rb id d in g th e S ch ool Board in g e n e r a l terms to deny ad m ission to any o f A r lin g to n 's sc h o o ls on th e ground o f race was en ter ed by th e cou rt below as e a r ly as J u ly 3 1 , 1956. Thompson v . County S ch ool Board, 144 F . Supp. 239 (E.D. Va. 1 9 5 6 ). affirm ed th a t d e c r e e . T his Court Sch ool Board o f C h a r lo t t e s v ille v . A lle n , 240 F.2d 59 (4 th C ir. 1 9 5 6 ), c e r t , d e n ie d , 353 U .S . 911 (1 9 5 7 )- F urther l i t i g a t i o n fo llo w e d in v o lv in g r e q u e sts f o r su pp lem ental d ecrees to compel th e ad m ission �- 6 - o f p a r t ic u la r b la c k stu d e n ts to sc h o o ls o f t h e ir ch o ic e 3/ near t h e ir homes. As l a t e as 1963, fo u r y ea rs a f t e r th e m a ssive r e s is t a n c e s t a t u t e s were d ecla re d u n c o n s ti t u t io n a l and A r lin g to n was f r e e t o ch a rt i t s own c o u r se , p ro g re ss toward d e se g r e g a tio n was s t i l l measured by the number o f in d iv id u a l b la ck c h ild r e n a tte n d in g p r e v io u s ly a ll- w h i t e s c h o o ls ; th e b la ck sc h o o ls remained b la c k , and m ost w h ite sc h o o ls were u n a ffe c te d . T h is Court noted t h a t , in argu in g fo r d is s o lu t i o n o f th e 1956 in ju n c t io n , th e S ch ool Board had " c ited th e f a c t th a t 146 Negro stu d e n ts were then a tte n d in g predom inantly w h ite sc h o o ls n e a r e st t h e ir r e s id e n c e s ." Brooks v . ------------ County S ch o o l Board, 324 F.2d 3 03, 306-07 (4th C ir . 1 9 6 3 ). 3/ Thompson v . County School Board, 159 F. Supp. 567 JE.-D. Va. 1 9 5 7 ), a f f ' d , 2 5 2 F.2d 9 2 9 (4 th C ir. 1 9 5 8 ), c e r t , d e n ie d , 356 U .S . 958 (1958); Thompson v . County S ch ool Board, 166 F . Supp. 529 (E.D. Va. 19 5 8 ), a f f ' d in p a rt sub nom. Hamm v . County School Board, 2b3 F .2d 22b (4 th d ir . 1 9 5 9 ), remanded in p a rt sub nom. Hamm v . County S ch ool Board, 2b4 F .2d 9 4 5 (4 th C ir. 19t>9) • 4 / The co u rt below d is s o lv e d th e in ju n c tio n , but t h is Court ordered i t r e in s ta t e d b eca u se , among o th er t h in g s , "com pliance began o n ly l a t e l y ." Brooks v . County Sch ool Board, 324 F .2d 30 3 , 3 0 8 (4th C ir. 1 9 6 3 ) , r e v e r sin g 204 F . Supp. 620 (E.D. Va. 1 9 6 2 ) . V �- 7 - Thereafter there was further progress. First, the all-black Hoffman-Boston Senior High School, in adequate as a high school, was eliminated. Then junior high school attendance boundaries were redrawn so as to desegregate Hoffman-Boston Junior High School. 5/ In the northern part of the County elementary school lines were redrawn so as to eliminate Langston as an all-black elementary school. But progress was clouded by the enlargement and modernization in 1964 of Drew School, located in the heart of the principal black residential area, in the face of warnings that such action would perpetuate segregation. the former Kemper School. The enlarged Drew supplanted The present litigation is a legacy of the decision to enlarge and modernize Drew. This suit was instituted in 1970. The relief initially sought was the desegregation of the Drew School. Appeals to the School Board to act to this end 5 / The School Board1s plan for effecting this desegrega tion was enjoined by the court below on the complaint of white parents whose children were affected thereby. Wanner v. County School Board, 245 F. Supp. 132 (E.D. Va. 1 9 6 5 ) . This Court r e v e r se d . Wanner v . County School Board, 357 F .2d 452 (4th C ir. 1 9 6 6 ) . �- 8 - w ith ou t j u d i c i a l prodding had been u n a v a ilin g . The case d id not come on fo r t r i a l u n t i l th e summer o f 1971. By th a t tim e th e Supreme Court had d ecided in A p r il 1971 a s e r i e s o f sc h o o l d e se g r e g a tio n ca ses th a t had been pending f o r some tim e. The p r in c ip a l o p in io n was th a t o f th e C hief J u s tic e fo r a unanimous Court in Swann v . C harlotte-M ecklenburg Board o f E d u ca tio n , 402 U .S . 1 (1 9 7 1 ). With th e d e c is io n in th e C h a r lo tte - Mecklenburg ca se i t became obvious th a t Drew (and th e sm a lle r Hoffm an-Boston Elem entary S c h o o l), c r ea ted as a l l - b l a c k sc h o o ls in an era o f s ta te -r e q u ir e d se g r e g a t io n o f th e r a c e s , could not remain s o . The School Board acted promptly, quite in | contrast to the attitude of silent inaction that had characterized it for many months despite earnest citizen pleas that something be done about Drew. It acted, imoreover, quietly, announcing as a fait accompli a plan j that had not been the subject of public hearings and I that the affected parents had not otherwise participated �- 9 - in fo rm u la tin g . 6/ The p la n prom ulgated in June 1971 by th e S ch ool Board t o be ca r r ie d out in th e 1971-72 sc h o o l y ea r c a lle d f o r th e co n v ersio n o f Drew t o a 3 0 0 -stu d e n t "model sch ool" and d isco n tin u a n c e o f th e use o f Hoffm an-Boston as an elem entary s c h o o l. K indergartens would co n tin u e a t th e two s c h o o ls . model s c h o o l would have 60 b la ck s t u d e n t s . The The o th e r 700 or so f ir s t - t h r o u g h - s ix t h graders who p r e v io u s ly atten d ed Drew and Hoffman-Boston would be d isp e rsed 6/ The conversion of the School Board from an elective To an appointive body has by no means taken schools out of Arlington politics. The County Board, which appoints the School Board members, has five members who serve four-year terms. Their terms are so staggered that at least one member is elected every year, and every fourth year two seats are filled. Thus, political campaigning in Arlington is fairly continuous, and issues relating to the public schools are frequent campaign issues. The Arlington electorate is rather closely balanced between contending forces that lately have been, on the one side, a coalition of the Democratic Party and a local party that draws upon, among others, federal civil servants who otherwise would be disabled by the Hatch Act from participating in local politics and, on the other, the Republican Party. In 1971, the year in which the School Board decision now challenged was made, the coalition had a three-to-two majority on the County Board and two of the seats it held were at stake in the November election The School Board membership reflected the same division so that any School Board decision to require, for example, the transportation by bus of significant numbers of white child ren to distant schools could reasonably have been attri buted to the coalition in the fall campaign. �10 among the other elementary schools in the County in such a way as to produce, as nearly as possible, a proportion of black children in each equivalent to the proportion of black children in the County school population. The Drew and Hoffman-Boston children would be transported by bus to schools throughout the County, many of them to schools at a very considerable distance from their homes. The plan contemplated that these children would attend the junior high schools and senior high schools to which their new elementary schools feed, not the junior and senior high schools whose attendance areas include their residences. No white elementary children would be transported outside their districts save as their parents might volunteer them for the model school at Drew. (Def. Ex. 1 , App. 1 8 ) . The complaint was amended to take account of the new situation by challenging the School Board's desegregation plan. The court below after a brief trial rejected the contention that to place the entire burden of desegregation upon the black students in the �11 way th a t p lan d id v io la t e d t h e ir r ig h t t o th e eq u al p r o te c tio n o f laws under th e F ourteen th Amendment. The cou rt approved th e S ch ool Board's p la n . (App. 1 0 - 1 5 ). I t tr e a te d th e m atter as in v o lv in g n oth in g more than a d e c is io n o f th e S ch ool Board as to what th e m echanics o f d e se g r e g a tio n should b e . I t equated th e tr a n sp o r ta t io n o f th e Drew and Hoffman-Boston c h ild r e n out o f t h e ir sc h o o l a tten d an ce a reas t o th e lo n g -tim e p r a c t ic e in A rlin g to n o f p ro v id in g bus tr a n sp o r ta tio n fo r some c h ild r e n w ith in th o se sc h o o l attend ance a reas th a t are la r g e enough t o make i t in con v en ien t f o r a l l c h ild r e n t o walk to s c h o o l. And i t went so f a r as to say th a t d e se g r e g a tio n would be "accomplished w ith o u t a b o lis h in g th e neighborhood s c h o o l concept" because Drew and Hoffman-Boston would con tin u e to be used fo r sc h o o l 7/ p u r p o se s. 7 / In a d d itio n to th e u ses mentioned above, a p a rt o f The Hoffm an-Boston sc h o o l p la n t w i l l co n tin u e to be u sed , as i t has been b e fo r e , tem p orarily to house the se v en th grade o f Thomas J e ffe r s o n Ju nior High Sch ool u n t i l a new Thomas J e ffe r s o n i s b u i l t , and th e r e are p r e -k in d e r g a r te n and a d u lt c l a s s e s a t Drew. �12 ARGUMENT THE ARLINGTON COUNTY SCHOOL BOARD'S PLAN FOR DESEGREGATING THE COUNTY'S SCHOOLS DENIES TO THE STUDENTS OF THE FORMER DREW AND HOFFMAN-BOSTON ELEMENTARY SCHOOLS THE EQUAL PROTECTION OF THE LAWS BECAUSE IT LAYS UPON THEM THE ENTIRE BURDEN OF DESEGREGATION BY ELIMINATING DREW AND HOFFMANBOSTON AS ELEMENTARY SCHOOLS AND REQUIRING THE STUDENTS TO BE TRANSPORTED BY BUS TO SCHOOLS THROUGHOUT THE COUNTY WHILE NO WHITE CHILDREN ARE INVOLUNTARILY TRANSPORTED TO SCHOOLS OUT SIDE THEIR NORMAL, NEIGHBORHOOD ATTENDANCE AREAS. The p r in c ip le th a t must gu id e d e c is io n in t h i s c a se i s a sim p le one t h a t lo n g a n te d a te s the sc h o o l d e s e g r e g a tio n c a s e s and th e body o f law , some o f i t h ig h ly p a r t ic u la r and even r e c o n d ite , th a t th ey have p rod uced . Judge Wisdom, w r itin g f o r th e Court o f A ppeals f o r th e F i f t h C ir c u it in a ca se th a t posed an i s s u e v e r y s im ila r t o th a t posed h e r e , re co g n iz ed t h i s f a c t when he began h is a n a ly s is w ith th e statem en t t h a t "the eq u a l p r o t e c tio n c la u s e o f th e fo u r te e n th amendment p rev e n ts any in v id io u s d is c r im in a tio n on the b a s is o f r a c e ." Lee v . Macon County Board o f E d u cation , 448 F .2d 7 4 6 , 753 (5 th C ir. 1 9 7 1 ) . As authority for this statement Judge Wisdom cited Yick Wo v . Hopkins, 118 U .S . 356 (1 8 8 6 ), one of �13 - the great landmarks in the history of the civilizing influence that the Constitution and particularly the Civil War amendments as interpreted and applied by the judges have had upon our society. The issue there, it will be recalled, was the constitutional validity in their application of city ordinances that seemingly had the legitimate purpose of guarding against the danger of fire by prohibiting laundries in wooden buildings except as a local governing body permitted them. The vice of the ordinances that the Supreme Court perceived lay in the unbridled authority they conferred upon the governing body to choose between one applicant for permission to have a wooden laundry and another and in the fact that that authority had been used solely to exclude Chinese from the laundry business. The facts, the Court said, "establish an administration directed so exclusively against a particular class of persons as to warrant and require the con clusion, that, whatever may have been the intent of the ordinances as adopted, they are applied by the public authorities charged with their administration, and thus repre senting the State itself, with a mind so unequal and oppressive as to amount to a practical denial by the State of that equal J �- l4 - protection of the laws which is secured to petitioners, as to all other persons, by the broad and benign provisions of the Fourteenth Amendment to the Constitution of the United States." Id. at 373. So here the school authorities, pursuing the legitimate, constitutionally required, goal of elimi nating racial segregation in a school system that had been segregated by law, have chosen means to that end that are "unequal and oppressive" and deny to black students and their plaintiff parents the equal pro tection of the laws. The court below erred in treating the case as one in which the school authorities had unfettered discretion in their choice of remedies for the unconstitutional situation they had allowed to persist for so long. For the Constitution says that, whatever its goal, the School Board may not act in such a way as to create "any invidious discrimination on the basis of race." The remedy chosen by the School Board here does result in precisely such discrimination. So we shall see in what follows. �- 15 A. The F a cts Demonstrate th e In v id io u s D isc r im in a tio n A g a in st Black C hildren E ffe c te d by th e S ch ool Board's P lan . The f a c t s c r i t i c a l to d e c is io n are quicklys ta te d . 1. The b la c k c h ild r e n o f Drew and Hoffman- Boston are tra n sp o r te d by bus t o sc h o o ls o u tsid e t h e ir atten d an ce a r e a s , some o f them fa r o u ts id e . White elem entary s c h o o l c h ild r e n in th e County co n tin u e to a tten d th e sc h o o ls in t h e ir atten d an ce a r e a s , most of them w alking to g e t t h e r e . And t h is d isc r im in a tio n w i l l f o llo w many b la c k c h ild r e n through t h e ir ju n io r h igh sc h o o l and s e n io r h igh sc h o o l y e a r s; th ey w i l l be made to a tte n d h ig h e r sc h o o ls o th er than th o se th a t n a tu r a lly se rv e t h e ir neighborhoods w h ile w hite c h ild ren w i l l a tte n d th e ju n io r and s e n io r h igh sc h o o ls se r v in g th e atten d an ce a reas where th ey l i v e . 2. Two elem entary s c h o o l p la n ts in predomi n a n tly b la ck neighborhoods are abandoned as elem entary s c h o o ls . They are abandoned even though Drew, modern iz e d and en larged in 1964 and w ith an a ir -c o n d itio n e d wing and a sp a c io u s, w ell-eq u ip p ed gymnasium. �- 16 - unusual among A rlin g to n elem entary s c h o o ls , was d e s crib ed by th e S u p erin ten d en t o f Sch ools as "among the upper h a lf" o f A r lin g to n sc h o o ls in terms o f i t s s u i t a b i l i t y as an elem entary sc h o o l (Tr. 4 ) , and Hoffman-Boston was c h a r a c te r iz e d by him a s "a rea so n a b ly good sch ool" (Tr. 5 ) . 3. P lan s f o r th e d e se g r e g a tio n o f Drew and Hoffman-Boston th a t would n ot have c a s t th e e n t ir e burden o f d e se g r e g a tio n upon c h ild r e n o f th e m in o rity race by e lim in a tin g t h e ir elem en tary sc h o o ls were a v a ila b le to th e Board. These am ici tak e no p o s it io n on which o f th e s e p la n s i s most d e s ir a b le , or w hether some oth er n ot y e t advanced may be b e s t . I t i s enough to note here t h a t , as i s developed in th e b r ie f o f th e p l a i n t i f f s - a p p e l l a n t s , oth er p la n s th a t could c o n s t i t u t io n a lly have been adopted by th e S ch ool Board e x is t e d . These f a c t s a lo n e are enough to show an in v id io u s d isc r im in a tio n — a r a c i a l c l a s s i f i c a t i o n in f a c t , th e absence o f any n o n - r a c ia l j u s t i f i c a t i o n fo r i t and n o n -d iscr im in a to ry a l t e r n a t i v e s . Beyond th e se f a c t s , th e r e i s testim o n y o f record to th e adverse �- 17 e f f e c t upon th e b la ck c h ild r e n th a t th e d isc r im in a tio n w i l l h a v e. George R ichardson, th e former p r in c ip a l o f Hoffman-Boston High S ch ool and s t i l l a r e s id e n t o f th e Hoffman-Boston a tten d an ce area and w e ll-a c q u a in te d t h e r e , t e s t i f i e d t h a t , when la r g e numbers o f c h ild r e n are tra n sp o rted by bus in to o th er p a rts o f th e County, "there i s a f e e l i n g th a t th e stu d e n ts w i l l r e a liz e th a t i f th ey are th e o n ly ones d oing t h i s , th a t they are b ein g tr e a te d d if f e r e n t [ l y ] , " and p a r t ic u la r ly i f th ey "look around" in th e a reas in t o which th ey are tran sp orted and se e th a t o th er stu d e n ts a re n ot b ein g tra n sp o rted out o f them. (Tr. 5 9 - 6 0 ). In s h o r t , Mr. R ichardson s a id , th e S ch ool Board's p la n says to b la ck c h ild r e n th a t th ey are i n f e r i o r . (Tr. 6 1 -6 2 ). That would not be t r u e , he added, were th e re two-way b u s s in g . (Tr. 6 2 -6 3 ). B. D e c isio n s o f This Court and Other Courts E s ta b lis h th e U n c o n s t it u t io n a lit y o f the A rlin g to n S ch ool B oard's D eseg reg a tio n P la n . On f a c t s no more com p ellin g than th o se we have j u s t summarized t h i s Court and th e co u rts o f ap peals f o r o th er c i r c u i t s have s e t a s id e th e a c t io n of �- 18 - lo c a l sc h o o l boards In c lo s in g b la ck sc h o o ls as p a rt of p lan s f o r e f f e c t in g d e se g r e g a tio n . The d e c is io n o f t h is Court t o which we r e fe r i s th e en banc p er curiam o p in io n in Adams v . School D i s t r i c t Mo. 5 , 444 F .2d 99 (4 th C ir. 1 9 7 1 ), c e r t , d e n ie d , 404 U .S . 912 (1971) (W inston Salem /F orsyth County sc h o o ls ' p e titio n ). The o p in io n b ea rin g th a t ca p tio n covered ap p eals r e la t in g t o fou r sc h o o l d i s t r i c t s . A ll o f the ap p eals were heard a f t e r th e o p in io n s in th e C h a r lo tte Mecklenburg ca se and i t s companions had been handed down. The main d e c is io n o f th e Court was to v a ca te a l l the judgments below t o g iv e th e d i s t r i c t co u rts in v o lv ed the o p p ortu n ity to r e c e iv e from the sc h o o l boards new p lan s o f d e se g r e g a tio n th a t would g iv e e f f e c t t o the Supreme Court d e c is io n s . The case o f th e sc h o o ls o f Roanoke, V ir g in ia , one o f th e fou r sc h o o l d i s t r i c t s in v o lv e d , came up on ap p eals by both th e sc h o o l board and th e p l a i n t i f f s from a judgment o f the D i s t r i c t Court fo r th e W estern D i s t r i c t o f V ir g in ia , Green v . S ch ool Board, 316 F . Supp. 6 (W.D. Va. 1 9 7 0 ). D esp ite the g e n e r a l v a c a tio n and remand t h is Court was s p e c i f i c in a ffir m in g , on th e sc h o o l board 's a p p e a l, th e d i s t r i c t c o u r t 's d e c is io n th a t an a ll- b la c k �- 19 high school that had been marked by the school board for conversion to a vocational education center and site of special classes should be retained as a high school. 444 F.2d at 101. The board's good faith in providing for this conversion was scarcely open to question; the elimina t io n o f the black high school was recommended by con sultants from the Department of Health, Education & Welfare and initially was not objected to by the plain tiffs. However, a protest meeting brought about a change in the position of the plaintiffs, and the dis trict court similarly took "notice of tne understandably strong feeling in the Negro community against the closing of what they describe as 'their' fine school." Id. at 8. After viewing the high school in question, the court found merit in "the plaintiffs' objection that the black community should not be required to shoulder the largest part of the burden involved in the desegregation process . . . ." I d . at 10. In sum, no adequate reason for "the conversion of such a fine facility" was advanced, id. at 11, and this Court �20 a g reed . 8/ See a ls o F eld e r v . H arnett County Board o f E d u cation , 409 F .2d 1070, 1074 (4 th C lr. 1 9 6 9 ) . An e a r l i e r d e c is io n o f t h is Court, A lle n v . A s h e v ille C ity Board o f E d u cation , 434 F .2d 902 (4th C ir. 1 9 7 0 ), i l l u s t r a t e s circum stances in w hich, as th e Court put i t , i t was "unable to p e r c e iv e any in v id io u s d is c r im in a tio n in" a sc h o o l b oard 's p la n th a t i n cluded c lo s in g two b la c k elem entary sc h o o ls because th e r e were adequate n o n -r a c ia l reason s f o r th e a c t io n . Id . a t 905" That p la n covered a l l 12 sc h o o ls in a c i t y sc h o o l system , and th e r e was b u ssin g o f c h ild r e n o f both r a c e s . There remained sc h o o ls th a t had been a l l b la ck but th a t were now to be atten d ed by stu d en ts o f both r a c e s . The Court found t h a t , o v e r a ll, th e burden o f d e se g r e g a tio n f e l l d isp r o p o r tio n a te ly on b la ck ch ild r e n in th e low er grades and on w h ite c h ild r e n in th e upper g r a d e s, and in t h is th ere was no d is c r im in a tio n . 8/ In c o n t r a s t , th e d i s t r i c t cou rt approved, over th e p l a i n t i f f s 1 o b je c t io n , th e c lo s in g o f a b la ck ju n io r h ig h s c h o o l, fin d in g th a t th e sc h o o l s i t e was sm a ll and near a n o isy highw ay. Green v . S ch ool Board, 316 F. Supp. 6 , 11 (W.D. Va. 1 9 7 0 ). T his Court sa id th a t on th e remand th e d i s t r i c t co u rt might "approve th e p resen t ju n io r and s e n io r h igh s c h o o l p la n ." Adams v . S ch ool D i s t r i c t No. 5 , 444 F .2d 9 9 , 101 (4 th C ir. 1 9 7 1 ). �21 Id. a t 9 0 7 . See also Chambers v. Iredell County Board o f Education. 423 F .2d 613 (4th Cir. 1 9 7 0 ) . S im ila r ly , th e Court o f Appeals f o r th e F if t h C ir c u it has d is tin g u is h e d th o se ca ses in which the c lo s in g o f b la ck sc h o o ls i s in v id io u s ly d isc r im in a to r y and th o se in which th e r e are reasons o th er than race fo r sc h o o l c lo s in g s th a t tend to b rin g about a u n ita r y sc h o o l system . In Lee v . Macon County S ch o o l Board o f E d u cation , 448 F .2d 746 (5 th C ir. 1 9 7 1 ), from which we have quoted above (p . 1 2 , su p ra) , one p la n o f d e se g r e g a tio n th a t was b e fo r e th e cou rt fo r c o n sid e r a tio n in v o lv ed c lo s in g th e on ly two b la ck sc h o o ls in a d i s t r i c t . The sc h o o ls were good sc h o o ls p h y s ic a lly , and a p r in c ip a l reason g iv e n f o r c lo s in g them was th a t o th e r w ise w h ite stu d en ts would le a v e th e sc h o o l system . On th a t record th e Court found th e proposed c lo s in g s r a c i a l l y m otivated and th e r e fo r e in v id io u s ly d is c r im i n a to r y . Id^ a t 7 5 3 -5 4 . I t quoted , icK a t 754 n . 1 2 , from B rice v . L a n d is, 314 F. Supp. 974, 978 (N.D. C al. 1 9 6 9 ) , where th e c o u r t, a ls o r e j e c t in g a b la ck sc h o o l c lo s in g , sa id th a t t o c lo s e th e b la ck sc h o o l and bus i t s �22 stu d en ts away means th a t "the m in o r ity c h ild r e n are p la ced in th e p o s it io n o f what may be d escrib ed a s s e c o n d -c la s s p u p ils ." See a ls o B e ll v . West P o in t M unicipal Separate S ch ool D i s t r i c t , 446 F .2d 1362 (5 th C ir. 1971)5 Gordon v . J e ffe r s o n D avis P a rish School D i s t r i c t . 446 F .2d 266 (5 th C ir. 1 9 7 1 ). On th e o th er hand, th e F if t h C ir c u it, w h ile re c o g n iz in g th e r u le th a t c lo s in g s o f form erly a l l b la ck sc h o o ls "are p r o h ib ite d where undertaken fo r r a c ia l reason s o f th e type th a t may be equated w ith in v id io u s d is c r im in a tio n ," Mims v . Duval County S ch ool Board, 447 F .2d 1330, 1331 (5th C ir. 1 9 7 1 ), has approved c lo s in g s where n o n -r a c ia l reasons f o r them were found. Ibid . ; Carr v. Montgomery County Board of Education, 429 F .2d 382, 385 (5 th C ir. 1970) (w h ite sc h o o ls a ls o c lo se d ! w h ite stu d en ts a tte n d in g p r e v io u sly a l l b la ck s c h o o ls ) . In deed, in a t le a s t one case an i n e f f i c i e n t l y sm a ll, p h y s ic a lly in f e r i o r b la ck sc h o o l was ordered c lo s e d to accom plish d e se g r e g a tio n . Choctaw County Board of Education v. United States, 417 F.2d 845 (5 th C ir. 1 9 6 9 ) . �- 23 - F in a lly , words o f th e Court o f Appeals fo r th e E ighth C ir c u it in r u lin g on a sc h o o l c lo s in g is s u e a re p a r t ic u la r ly p e r tin e n t h e r e . In Haney v . County Board o f E d u ca tio n , 429 F .2d 3 64, 372 (8th C ir. 1 9 7 0 ), th a t cou rt p la ced "a heavy burden on th e s c h o o l board . . t o e x p la in the c lo s in g o f f a c i l i t i e s fo rm erly used fo r th e in s t r u c t io n o f b la c k stu d e n ts ." I t c a lle d upon the sc h o o l board in th e ca se a t hand t o r e s o lv e th e m atter o f what f a c i l i t i e s would con tin u e to be used when a dual sc h o o l system was changed t o a u n ita r y sc h o o l system "on some r a t io n a l n on d iscrim in a to ry b a s is . . . ." Here th e A rlin g to n S ch ool Board, though i t had ev ery o p p ortu n ity to do s o , has n ot been a b le to r e s o lv e th e m atter o f how th e rem aining elem en ts o f i t s d ual sc h o o l system are to be done away w ith on any " r a tio n a l n o n d iscrim in atory b a s is ." In l i g h t o f th e p reced en ts j u s t d is c u s s e d , i t i s a p p rop ria te fo r t h is Court to d ir e c t th e Board to re c o n sid e r th e m atter and come forward w ith a s o lu t io n th a t squares w ith th o se "broad and benign p r o v is io n s o f th e F ou rteen th Amendment" gu a ra n teein g t o a l l p ersons th e eq u al p r o t e c tio n o f the �- 2b - laws to which the Supreme Court referred nearly a century ago in Yick Wo v. Hopkins and which the Supreme Court, this Court and the other federal courts have invoked so frequently in the intervening years to protect the right to equal treatment of members of racial minorities. C. The Fact that the School Board's Plan Re sults in Arlington's Not Having Any One-Race Schools Does Not Justify the Discrimination It Works Against Black Children._____________ A recurrent theme in the School Board's defense of its plan is that its plan results in the complete de segregation of all of Arlington's elementary schools, and no other plan that has been offered does as much. There are two things to be said about this de fense. First, the Board's punctilious concern for complete school desegregation must seem cruelly ironic to the black parents represented by the plaintiffs and to the black parents who have gone before them. They have waited patiently for the Board to end the segregation of their children in the public schools. Disadvantaged politically as in most other respects, the black minority of South �- 25 - A rlin g to n could not arouse to a c t io n a sc h o o l board th a t n a tu r a lly c a te r s to th e in t e r e s t s o f a predom inantly w h ite e l e c t o r a t e . (See p . 4 , n .2 , su p r a ). Now th e c h ild r e n o f th e b la ck m in o r ity have been fo rced upon the B oard's c o n sc io u sn e ss o n ly to be made t o pay by t h e ir d is p e r s a l the whole p r ic e o f th e com plete d ese g re g a tio n th a t th e Board b e la t e d ly s e t up as a g o a l. That i s not th e e q u a lit y o f treatm en t the b la ck p aren ts a sk ed . The o th er th in g i s t o acknowledge th a t the r e s u lt ach ieved by th e S cn ool Board i s la u d a b le — and then to ask w hether i t i s worth th e c o s t . In candor, n ot so many y ears ago th e v a s t m a jo r ity o f d e c is io n makers and a d v o c a te s, a f f e c t e d w ith a w h ite b ia s - th e term i s used d e s c r ip t i v e ly , not p e j o r a t iv e ly might not have thought v ery much about th e c o s t . But th e in c r e a sin g v i s i b i l i t y o f b lack p rid e has changed our p erc ep tio n o f r e a l i t y and our modes o f th o u g h t. No lon ger can we proceed on th e assum ption th a t what th e b la ck man wants i s m erely fo r h is c h ild r e n to be a b le to a tten d th e w h ite man's s c h o o l. I f th e assum ption ever had any fo u n d a tio n , th e fou n d ation has d isa p p ea red . �- 26 - Integration must be a two-way street, achieved with respect for the dignity and humanity of blacks as well as whites. Judge Dalton in the Roanoke case caught something of what we are trying to say here when, in a passage we have heretofore quoted, he noted "the understandably strong feeling" of the black community of Roanoke "against the closing of what they describe as 'their' fine school." The strong feeling of the members of the black community of South Arlington for their schools and for the welfare of their children has not been respected by the School Board. Disregard of that feeling is, on amici's view, too great a cost for the undoubted beneficial results of the School Board's plan. CONCLUSION These amici believe that the judgment below should be reversed, the School Board's plan of desegre gation disapproved and enjoined and the matter confided �- 27 - to th e S ch ool Board f o r fu r th e r c o n sid e r a tio n and w ith d ir e c t io n s to d e v is e , w ith th e h elp o f c i t i z e n p a r t i c i p a tio n , a p lan th a t s a t i s f i e s c o n s t it u t io n a l req u irem en ts. R e s p e c tf u lly su b m itted . WILLIAM H. ALLEN JOHN B. JONES, J r . Covington & B u rlin g 888 16th Street, N.W. W ashington, D.C. 20006 A ttorn eys fo r Amici Curiae February 9 , 1972 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Copy of John K. Hart, et al vs. County School Board of Arlington County, Virginia, et al, On Appeal From The United States District Court For The Eastern District of Virginia, Brief for Certain Arlington Organizations as Amici Curiae, February 9, 1972. 31 pages. Description An account of the resource Copy of John K. Hart, et al vs. County School Board of Arlington County, Virginia, et al, On Appeal From The United States District Court For The Eastern District of Virginia, Brief for Certain Arlington Organizations as Amici Curiae, February 9, 1972. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Attorneys for Amici Curiae Date A point or period of time associated with an event in the lifecycle of the resource 1972-02-09 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1970s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_45 https://projectdaps.org/files/original/cc51c0c672e48e685ab7b71a114a9f98.pdf 8a32b2d41902581cc02b527bcb5dac8f PDF Text Text June 2 6 , 1965 : r a . -u th Cex Civ l r u a n , r l i n g i o n C ounty 6751 S o r th 2 3 t h S t r e e t r l i u g t n , V ir ix .ic 2~~Z7 c o o l LO'jrd . -e a r i r t . Cox: ‘ I t i a w ith c o n c e rn t h a t th e le a g u e o f craon V e te rs o f ,’r lie ,::io n v ie w s t h e s i t u a t i o n a t Crew le ia e n ts r y S c h o o l. The a e r.b e ro h ip 0 / t h e L eague h a s s t r o n g l y e n d o rs e d t h e c a l l f o r d e s e g r e g a ti o n t h e r e . L o a lic iR ;- t h e t c a r e f u l p r o p . r a t i o n i s e s s e n t i a l , we a r e i n t e r e s t e d i n know ing w hat p l a n s th e Oelxool 3 o a rd h a s w ith r e g a r d t o Prew and w h e th e r t h e r e i s any way i a w hich t h e League s a y h e h e l p f u l i n c a r r y i n g o a t th e s e p la n s . u n d e r t h a g u id a n c e o f o u r C o i.r.itte e on th e 5 /e v e lo p c e a t o f i.unnn K e s .u r c s s , th e Longue hue been s tu d y in g d e s - g r e s * t i o a . S p e c i f i c a l l y , i n t h e c e s n u n i t i a s o f y r a c u c e , N . 1 . , h e rfc lc y , C a l i f o r n i a , and v a n s te n , i n i n c i s , we f i n d t h a t d e s e g r e g a tio n p la n e w ere s u c c e s s f u l b e c a u se c o a n u r i ty s u p o r t had been e n l i s t e d th ro u g h a th e u g t f u l p r o g r e a o f cooiBunity e d u c a tio n and ii.v o lv a n c n t begun w e ll i n advance o f any a tte m p t to b r i n g a b o u t a c t u a l c h an g e s i n th e s c h o o l s y e t e e s . - e f e e l t h a t ■ c o . e i d e r a t i o n o f t h e s e p la n s w ould be h e l p f u l t o tfcoae p e rc o n s i a A r lin g to n who a r e lo o k iu * f o r n s o l u t i o n t o th e r c b l e u o f i-rsw L ls s e n to r y S c h o o l. The L eague would l i k e t e o f f e r th e s e r v i e o a o f c u r C o iT s ltte e on t h e l e v c l o p a e n t o f flusen I c s o u r e e s t o a s s i s t i n any wry p o s s i b l e . . l e a s e '-reap u s i n f > re e d . T o u rs t r u l y , ( r s , K e b c rt F . C e e k lin re s id e n t c e l J r . u p :c a r ►» C a ru th e re r Jr, . a u li on r , S ra h a u * � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Letter to Ruth Cox, Chairman, Arlington County School Board from Mrs. Robert F. Cocklin, President, League of Women Voters, June 26, 1969. Description An account of the resource Letter expressing the League of Women Voter's concern at the situation at Drew Elementary School. Offers the assistance of the Committee on the Development of Human Resources which has studied successful desegregation processes in three other metropolitan area. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource League of Women Voters Date A point or period of time associated with an event in the lifecycle of the resource 1969-06-26 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1960s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_44 https://projectdaps.org/files/original/2d83a5b589320a632ced1761240b0f37.pdf 371aab0d49dd4961ccd00b54df097ce5 PDF Text Text A rlin g to n / 2il31 N> Bigewood S t. A rlin g to n , '.'a. 'S207 December 6 , 19>'>8 ■ . aimer l a m e r , p r in c ip a l r rev, aIe„ieno:iry ochool 3500 2ijth a t . S. A rlin g to n , V irg in ia s .e a r --r. r u m e r : / Ir ^ r- ” / Ih ia i s to confirm itsv tele p h o n e c o n v e rsa tio n viith you t h i s a fte rn o o n s e t ti n g up an appointm ent fo r 10 a.m . on Tuesday* Decem b e r 1750, .it h voa and the. trio v i c e - p r in c i p a l s , l a s . Black:.-.oil and L r .f Cooley. Our human Resource# Committee i s I n t e r e s t e d in fo llo w in g a l l o f tile s p e c ia l p o -rams i n th e sch o o ls which a re fin -n e e d by fe d e r a l money. Though X un d erstan d from w hat you s a id on tit* nhone t h a t th e c h ild re n in v o lv ed in th e two T it l e I p r o j e c ts (F and 5 on Vr. O u te r's summarj ) a rc n o t se p a ra te d fr< ra th e o thei-s in a v i s i b l e , geographic se n se , we Vfould l i k e to observe some o f th e s e c la s s e s and la b e ate ry work i f t h a t i s n o t d is tu r b in g to te a c h e rs o r c h ild r e n . e rr i n t e r e s t e d , to o , in numb e rs . Mr. - ite r re p o rts abcut 60 in head h t a r t a t /Ter. and io n c s to n . Of th o se a t irrew, wh_t -was th e p ro p o rtio n o f i.egro es to w h ite s? Chat mfta - c u r summer sch o l e n ro llm en t? Number w h ite s? Number Negroes? i s th e number o f th o se paying t u i t i o n and th o se n o t a v a ila b le ? . h a t i s y our t o t a l e n ro llm en t t h i s e a r? b i te s ? fcegross? and t o t a l s t a f f —w hite and Negro? iiow many c ild r e n re c e iv e f r e e lun ch es? Year b e fo re l a s t when v.e had a League m eeting devoted to th e s e f e d e r a l program s, some o f our members who had. re c e n tly moved to A rlin g to n were s u rp ris e d t o le a r n t h a t Bren was an a ll-N e g ro school. Have th e r e been any moves i n th e i r e * community in th e d ir e c tio n o f d e se g re g a tio n ? has anybody come up v.-ith any p r a c t ic a l su g g e stio n s? The commi t t e e members -who have in d ic a te d an i n t e r e s t i n the v i s i t t o Drew on th e 17th a re s Mrs. Don Winslow, chain-:an; « rs . feruce A. Beckner; Mrs. George H. Boothe; I r e . B arbara Marx. looking forward t o m eeting you, I am, Very s in c e re ly y o u rs. Mrs. l u i g i R e tru llo iluman Resources Committee �A M E R IC A N P S Y C H O L O G IC A L A S S O C IA T IO N "d ps y c h o l o g is t s O F F IC E O F T H E S E C R E T A R Y - T R E A S U R E R 2 1 7 L A R K STREET, A L B A N Y . N EW YO RK iv is io ^T o f in p u b l i c s e r v ic e � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Draft letter to Elmer Turner, Principle, Drew Elementary School from Mrs. Luigi Petrullo, Human Resources Committee, League of Women Voters, December 6, 1968. 2 pages. Description An account of the resource Page 1, Letter requesting statistics on special programs in the schools that are funded by the Federal Government; page 2, scrap. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource League of Women Voters, Human Resources Committee Date A point or period of time associated with an event in the lifecycle of the resource 1968-12-06 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1960s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_43 https://projectdaps.org/files/original/f887041b7d5e241707ea7ea56f837c55.pdf 2e641d2bea9e29ce72b587deab8692a9 PDF Text Text Page Felder v. H. Cir., 196: United States Court of Appeals County Board of Education, 409 F.2d 1070 (4th 12,19,22 FOR THE FOURTH CIRCUIT Green v. Coui.'y School Board of New Kent County, 391 U.S. 430 (1963) ....................... 8, 27 Green v. Sclx Board of City of Roanoke, 316 F.Supp. 6 (W.D. Va. 1970) ............................................ 21 No. 71-1791 Haney v. Coi. .'.y Board of Education of Sevier County, 429 F.2d 364 (8th ( 1970) ............................................ 21 JOHN K. HART, e t a l ., Lee v. Macon C ;nty Board of Education, 448 F.2d 746 (5th Cir., 1971) .................................... 21 v. Mims v. Du C.'ounty School Board, 329 F. Supp. 123 (M.D. Fla., 1971) ........................................... 2 3 ,2 4 Swann v. Cl e-Mccklcnburg Board of Education, 402 U.S. 1 (1971) ............... 2, 4, 8, 9, 10, 12, 19, 22, 27 Walton v. N F.2d 137 (: !e, Arkansas, Special School District No. 1, 401 Cir., 1969) ................... .................... 26 Wanner v. Coi (4th Cir.. School Board of Arlington County, 357 F.2d 452 >) ................... 16 Appellants, COUNTY SCHOOL BOARD OF ARLINGTON COUNTY, e t a l ., Appellees. Appeal from the United States District Court for the Eastern District of Virginia a t Alexandria BRIEF FO R APPELLEES ISSUE PRESENTED FO R REVIEW The sole issue presented for review in this case is whether or not the desegregation plan adopted by the Arlington County School Board and put into effect in September, 1971, is constitutionally valid. STA TEM EN T O F T H E CASE On May 6, 1970, plaintiffs initiated this action to com plete the elimination of racial segregation in the public schools of Arlington County (App. 5 ).1An answer on behalf 1 All references App. are to pages in the printed appendix. �2 3 of the County School Board of Arlington County and the Division Superintendent of Schools of Arlington County was timely filed (App. 8-9), and discovery procedures in volving interrogatories to defendants and requests for the production of documents were thereafter initiated by the plaintiffs (App. 1). On March 5, 1971, a pre-trial conference was held, at which time a hearing on the merits was scheduled for July 26, 1971 (R. 70).2 The hearing in this case was deliberately postponed by the District Court to await the decision of the United States Supreme Court in Swann v. Charlotte-Meck lenburg Board of Education, 402 U.S. 1, and its companion cases (App. 10). On June 28, 1971, the Arlington County School Board adopted and filed in the District Court its plan for the estab lishment of a unitary school system throughout the county, which plan was to be put into effect in September, 1971 (App. 19-28). On the morning of the hearing, plaintiffs amended their complaint to state their objections to the plan (App. 6-7, 11), which objections were subsequently overruled and the school board’s plan approved by the Dis trict Court in its memorandum opinion and order of August 10, 1971 (App. 10-15). See, 329 F. Supp. 953. On August 12, 1971, plaintiffs hied in the District Court their notice of appeal (R. 67) and on August 20, 1971 also hied an application for injunction pending appeal which was denied by the District Court the same day. Thereafter, plaintiffs hied a similar application in this Court, which application was denied on September 3, 1971. See, Record in No. 71-1792 (4 Cir., 1971). A further such application was presented to the Chief Justice of the United States, as Circuit Justice for the Fourth Circuit, and denied by him on September 4,1971. See, No. A-262,1971 Term. STATEM ENT O F T H E FAf ,TS 2 All references R. are to pages in the record. The Arlington County School Division embraces the entire county of Arlington and has an a; <a of 25.7 square ■City of Richmiles. It is less than one-half the size of . and less than mond which has an area of 63 square r. Fairfax which one-tenth the size of the adjacent count has an area of 402 square miles (App. 41 For the school year 1971-72, the total ’ mentary school be 11,233 stupopulation of the Division was estimate; dents, of which number 9,983 were wh: and 1,250 were ary schools was Negro. Thus the racial ratio in the elen 89°/o white and 11% black (App. 15, 2 _ . which ratio is substantially identical to that for the pr< ding years. See, Answers to Interrogatories (R. 19). A t the beginning of the 1969-70 sch year, the high schools and junior high schools of the c< tyrhad been de segregated, while the elementary schools \. being operated on the basis of geographic attendance z established for each school. Under this arrangement, i «f the twentynine elementary schools in the system—I and HoffmanBoston—were attended solely by Xcgr .dents, as the geographical boundaries of those school .compassed allNegro residential areas, while eleven of tl •nty-nine were attended by all, or virtually all, white stu - (App. 15, 35, ■ 42). The Hoffman-Boston school also ho: i seventh grade students, of which some 70% were white icients bussed in from other districts in the county (App. . On December 18, 1969, the school board adopted a i 'ution directing the Division Superintendent and his staff prepare a staff study of the various alternatives available { r desegregating the Drew Elementary School (App. 29-3 . This resolution suggested consultation with appropriate al agencies, a step which had already been taken by the vision Superin- �4 o tendent who (1) had discussed the matter generally with representatives of the Department of Health, Education and Welfare (HEW) earlier in the month (2) had caused data requested by HEW to be compiled by his staff and sub mitted and (3) was awaiting return of specific suggestions from HEW for consideration by his staff and the school board (App. 43). In the interim, the Division Superintend ent directed his research department to begin its own study of the problem in line with the school board’s resolution (App. 43). No response was ever received from HEW, and shortly after the research department had assembled its own data and begun a consideration of alternatives, the instant suit was filed (App. 44). Thereafter, the school board was ad vised of the pendency of the Charlotte-Mecklenburg litiga tion which would in all probability shed light on the prob lem the board was considering, and the board decided to await the outcome of that litigation before determining the method of desegregating Drew Elementary School (App. 44). No attempt was made by the plaintiffs to seek a hear ing of this matter for the 1970-71 school year. On April 20, 1971, the Swann case was decided. There after the school board and its staff returned to a consider ation of the Drew school situation, but this time did so in the larger context of establishing a unitary school system throughout the county in compliance with Swann (App. 44). On June 10, 1971, while these deliberations were going on, this Court decided a series of cases under the style of Adams v. School District No. 5, Orangeburg Co., S.C., 444 F.2d 99, specifically emphasizing for district courts and school boards various aspects of Swann and Davis v. Board of School Commissioners of Mobile County, 401 U.S. 33. Some two weeks after Adams, the school board adopted and filed in the District Court its plan the operation of a unitary system in Arlington County (App. 19). As stated by the Division Supcrin . ! -nt, the purposes of the school board’s plan were “first of a . primarily to elimi nate all vestiges of a dual system, to . , ve to establish a true unitary system throughout the cor. . to provide and to establish racial balanced schools, and I think, then, to get on with the primary purpose of the ’ ool system which is the education of young people.” (. . 40). These objec tives would be accomplished by con.-. ting both the Drew and Hoffman-Boston schools to spec '.ad pre-kindergarten and kindergarten facilities. In addition, the Drew school would also house an experimental r; 1 elementary school to be conducted on an integrated b and utilizing imagi native new approaches to elements iucation, as well as for adult education and other schoi lograms. The Hoff man-Boston school would also be : /ed, as in previous years, for the integrated seventh gra- ■f the Thomas Jeffer son Junior High School (App. 10. iO). Former Drew and Hoffman-Boston students in s one through six would be assigned to other element: hools in the county in accordance with the following crit App. 21): A. The added students wouh t cause the receiving school to have an enrollment ( ding its established rated capacity by more than 5^. B. The ratio of black to wh ipils in each school would be as close to 11 % as pra a I, within a range of 7% to 15%, with the excepti : of four elementary schools whose current enrolli: :it already exceeded 15% (i.c. 18% to 22%). C. Family groupings would 1 < taken into account in • assignments to a particular sch !. .-> that family units 0 would not be broken up. D. Transportation would be vided as needed. �6 7 Under the school board’s plan, all one-race schools in Arlington County are eliminated—there remain no one-race white schools and no one-race black schools. Moreover, stu dents advancing from an elementary school will attend the junior high school serving that elementary school and, in turn, will advance to the high school serving that particu lar junior high school (App. 20, 24). This feeder system insures that for the 1971-72 school year, and for every school year thereafter, every child in Arlington county will receive his elementary and secondary education in an integrated facility (App. 39-40). In addition, nineteen of the twentythree elementary schools affected by the plan will have racial ratios which fall within the 7% to 15% range established by the board as a target deviation from the 11% racial ratio of the system as a whole (App. 15, 22). Indeed, seven teen of these nineteen schools fall within one percent of the 11 % racial ratio in the system as a whole (App. 15). Finally, faculty desegregation is achieved by establishing a ratio in each school as close to the ratio of black to white teachers in the school system as a whole, as is practical (App. 25). In no case is there more than a 4% deviation from the sys tem wide ratio (App. 25). The longest bus ride (in terms of lapsed time) for the former Drew and Hoffman-Boston pupils is 29 minutes, while the average bus ride for such children is 22 minutes (App. 12, 40-41). Similarly, the average bus ride for ele mentary children in the system as a whole is also 22 minutes (App. 41). The additional transportation costs involved in the school board’s plan is approximately $11,000 per year. Adoption of an alternate plan to achieve the same degree of integration would involve busing 90% of the Drew and HniTman-Boston students to other schools and replacing them with an equivalent number of white students from other schools and would entail an initial cost of $206,000 and an additional cost of $130,000 per year thereafter for transportation. Thirteen new buses, plus drivers, would be required for such an alternative “90 "Ut 90% in” plan (App. 12, 45-48). See also, Brief for 0: Appellants, p. 17. No alternate plan submitted by the V.tiffs would elimi nate all one-race schools in the count_. i r achieve as much actual desegregation as the school b—.. i' s plan (App. 50, 64). ARGUM ENT The Desegregation Plan Adopted And 1 : Into Effect By The Arlington County School Board Is C titutionally Valid. Plaintiffs in the case at bar are N< • children who had been assigned to the Drew Elemen y School when this suit was instituted and the parents or rdians of such chil dren. Asserting that all, or virtually al the pupils assigned to the Drew Elementary School \u . Negroes, plaintiffs alleged that the Arlington County S .! Board had failed to adopt and execute a plan “to c < ' tely convert said public school system to a unitary nor * ial system.” (App. 4). (Emphasis supplied.) They soul . :■ an order from the District Court requiring the defend school board “ta adopt and forthwith implement” sue plan (App. 5). Even before this suit was filed, the school board had been aware of the Drew situation and had, formal resolution, directed a staff study to be made of v ous alternatives for desegregating the Drew School. The i >olution, however, did not specifically embrace the Ho. oi-Boston Elemen tary School, the only other all-Negro .ol in the county, nor did it envision the desegregation < • eleven all-white, or virtually all-white, elementary sci - ols in the county school system. After the study contemplated by th olution had been initiated and prior to the date set by t: District Court for a �8 hearing of this matter (July 26, 1971), the Supreme Court decided the Swann and Davis cases, supra, (April 20, 1971), and this Court decided the Adams cases, supra, (June 10, 1971). Because of the existence of Adams, no independent analysis need now be made of Swann and Davis, nor of their progenitors, Brown, Green and Alexander.3 In Adams, this Court remanded a series of school desegregation cases to their respective district courts with instructions to receive from the various school boards “new plans” which would give effect to Swann and Davis. Id., at 100. During the course of its opinion, this Court spelled out what is now required of district courts and school authorities in the fol lowing explicit language (444 F. 2d at 100-101): “ It is now clear, we think, that in school systems that have previously been operated separately as to the races by reason of state action, “the district judge or school authorities should make every effort to achieve the greatest possible degree of actual desegregation, taking into account the practicalities of the situation” Davis, supra at ...., 91 S.Ct. at 1292. We remand these cases because the respective district judges did not have the benefit of the Supreme Court mandate that adequate consideration be given “to the possible use of bus trans portation and split zoning ” Davis, supra at ..... , 91 S.Ct. at 1292. Wherever schools are “all or predomi nately of one race in a district of mixed population (there will be required) close scrutiny to determine that school assignments are not part of state-enforced segregation.” Swann, supra a t ..... , 91 S.Ct. at 1281. Although the existence of “some small number of onerace, or virtually one-race, schools within a district is not in and of itself the mark of a system which still 3 Brown v. Board of Education, 347 U.S. 483 (1954) 349 U.S. 294 (1955); Green v. County School Board of New K ent Comity, 391 U.S. 430 (1968); Alexander v. Holmes County Board of Education, 396 U.S. 19 (1969). 9 practices segregation by law,” Swann, supra a t ..... . 91 S.Ct. at 1281, both the school author: y and the district judge must nevertheless be concei,i i with the elimi nation of one-race schools. The school authorities and the ; consider the use of all techniques f cluding pairing or grouping of sc!: attendance zones, restructuring of tramp ortation of pupils.” (Italics si ;ct court should segregation, in . noncontiguous levels, and the lied.) Emphasizing the imperative nature of • commands itali cized above was (1) the specific aut! ization conferred upon district courts to employ indep lent educational experts at the expense of any local schr jnard which sub mitted a plan that did not comply “w die directions set forth in this opinion . . .” and (2) the r . ement that any district court which approved a plan ; ! ving less actual desegregation than would be achieved r an alternative plan must find facts that made imprac c the achieving of a greater degree of integration “espec y if there remain any schools all or predominantly of on ice.” Id., at 101. (Emphasis supplied.) With the prescriptions of Swann and iris thus focused in the commands of Adams, it was obvi< :Fat any plan for the establishment of a unitary school cm in Arlington County which contemplated the desc gation of Drew School only—and which left another mentary school with an all-Negro student body and elev her elementary schools with all-white, or virtually all-v . student bodies —could not possibly survive judicial ap al. If a unitary system was to be established, all of the mentary schools comprising that system would have to :* considered and . desegregated if reasonably possible. Cor : y to appellants’ �10 11 assertion, this was not a “self-imposed objective” of the defendant school board; it was a judicially imposed impera tive. See, Brief for the Appellants, p. 16. The command that the Arlington County School Board must “be concerned with the elimination of one-race schools” could hardly be complied with merely by passing a resolution expressing such concern and taking no other action, especially when the elimination of all one-race schools in the county was not only possible, but feasible. Adams, supra, at 101. In this setting, the school board adopted and submitted to the District Court a plan which (1) achieved the greatest possible degree of actual desegregation, taking into account the practicalities of the situation (2) eliminated all one-race schools, both white and Negro (3) insured that every child in the Arlington school system will receive both his elemen tary and secondary education in an integrated facility (4) established in substantially all of the elementary schools a student racial ratio which reflects the racial ratio of the system as a whole (5) racially balanced the faculties in each elementary school in the county so that the ratio of white to black faculty members in each school is substantially the same as the ratio of white to black faculty members in the system as a whole and (6) established in Arlington County a unitary school system which has neither “white” schools nor “black” schools—just schools. Achievement of the above stated objectives in compliance with the prescriptions of Swann and Davis and the com mands of Adams was possible in only two ways. One method —that adopted by the school board—entailed the conversion of the Drew and Hoffman-Boston schools from traditional elementary facilities to other educational programs and the establishment within the all-Negro geographic areas of those schools of a series of “satellite” zones by which elementary pupils formerly assigned to Drew and Hoffn: m-Boston would be assigned to various all-white, or pre :nantly white, schools in the county in accordance \v.: i criteria which would not only integrate every elemental hool in the system, but would indeed racially balance sintially all of such schools. Bus transportation would be p vied by the school board for all the pupils thus reassign . 704 in number, and no such pupil would be required t ■bused for as much as one-half hour to reach his new;/ assigned school. Indeed, since Arlington County is only s •■ miles •n long and slightly more than three miles wide, t ( average bus ride for such children would be the same as t for ele mentary pupils in the county generally. Care was ven to insure that no family groups would be disturbed by -he new plan, and a feeder system was adopted to insui iat the racial balance achieved in the elementary school lid be preserved, and even heightened, over the years. No overcrowding results under the school bo plan, and the additional transportation cost incurred Id be approximately $11,000 per year. In addition, th . n enablcs the school board to utilize the existing i ■w and Hoffman-Boston facilities for other innovative i highly desirable educational programs designed to incr ease the already outstanding excellence of the Arlington - ml systern. In this connection, it should be emphasized that the Drew and Hoffman-Boston schools arc not being <losed or removed from the public school system or com ited to administrative or non-educational uses. On the itrary, these facilities have been reprogrammed under ; school board’s plan to serve exclusively educational fui ' ns in the emerging fields of pre-kindergarten instructio: r children three and four years of age, model element: i school experimentation in ungraded education and for . t edu- �12 13 cation. In this setting, appellants’ assertion that the school board’s plan must be examined as if the Drew school was being “used to store furniture” is surely wide of the mark. See, Brief for the Appellants, p. 24. Essentially the school board’s plan for establishing a uni tary system of elementary schools in Arlington County tracks that utilized for the junior high schools in the CharlotteMecklcnburg school system in Swann, which was subse quently approved by this Court and the Supreme Court. As stated by the Supreme Court (402 U.S., at 9 ): and replacing them with an equal number of white students drawn from the various predominantly white schools in the county. Mathematically, such a plan would i quire (a) re moving 102 of the 114 Negro elementary p at HoflmanBoston, leaving 12 Negro pupils there to i i ined by 102 replacement white students from other sch< i in the county and (b) removing 530 of the 590 Negro ( ntary pupils at Drew, leaving 60 Negro pupils there : • be joined by 530 replacement white students also cir from other schools throughout the county. Such a plar. (1') would sub stantially double the amount of busing ne< ary to achieve a unitary system (2) would entail an initi; i expenditure of $206,000 (including thirteen new buses) far the first year and an expenditure of $130,000 per yea: ; :creafter and (3) would, by unnecessarily continuing Dr. nd HoffmanBoston as traditional elementary schools, ct :ve the school board of facilities for its pre-kindergarten . del elemen tary school and adult education programs. By contrast to the plans described abo1 is manifest at a glance that neither of the plans espou y the appel lants in their brief even remotely appro; < compliance with the controlling constitutional require: :s. See, Brief for the Appellants, Appendix A. The first. . esc plans en visions the desegregation of Drew Scho< : by pairing or clustering it with five other elementary sr . nis in the vi cinity, and is based upon a working paper .pared by the staff of the defendant school board pursue lo the resolu tion previously mentioned. While the pla : effectively de segregates the Drew school, it falls far short stablishing a unitary school system in Arlington County. tier this plan, the elementary portion of the Hoffman-! m school re mains an all-Negro facility, while four otl. schools in the county (Custis, Jamestown, Madison and udmont) rc- “The Finger plan for the junior high schools employed much of the rezoning plan of the board, combined with the creation of nine “satellite” zones. Under the satel lite plan, inner-city Negro students were assigned by attendance zones to nine outlying predominantly white junior high schools, thereby substantially desegregating every junior high school in the system.’’ (Italics sup plied.) In addition, the feeder system aspect of the school board’s plan (1) counters the specific objection expressed by this Court in Felder v. Harnett County Board of Education, 409 F. 2d 1070, 1075 (4 Cir., 1969) that the plan there under consideration did “not eliminate the possibility that what ever feeder system is adopted to effect this transition will not recreate a dual system at the high school level” and (2) further evidences the school board’s awareness of, and intent to comply with, the teachings of the decisions of this Court in school desegregation cases. The only other plan which would achieve the results of the school board’s plan and honor the prescriptions of Swann and Davis, as well as the command of Adams, would be one which entailed assigning 90% of the black students in Drew and Hoffman-Boston to other schools in the county �14 15 main all white, five other schools (Barcroft, Jackson, Nott ingham, Page and Tuckahoe) remain 99% white and two schools (Key and Maury) remain 98% white. Thus, twelve of the twenty-nine elementary schools in the county would remain one-race, or virtually one-race, schools under this plan (App. 16, 38-39). The appellants’ suggested plan for the desegregation of Hoffman-Boston is even more inadequate. It is the result of “hasty preparation” by Mr. Richardson, a witness for the plaintiffs, and manifestly represents an effort to bring this case within the scope of Brice v. Landis, 314 F. Supp. 974 (W.D. Cal. 1969) by attempting to show that a reason able alternative to the school board’s plan exists. It contem plates pairing Hoffman-Boston with three other elementary schools in the vicinity. While effectively desegregating the Hoffman-Boston Elementary School and the previously allwhite Custis Elementary School, it makes no provision for the Drew school which would remain all-black, nor for ten of the eleven all-white, or virtually all-white, elementary schools mentioned in the preceding paragraph, which schools would retain their 98-100% white status (App. 17, 62-63). Moreover, utilization of both of these plans simultaneously would not discharge the school board’s obligation to establish a unitary system. Combination of the appellants’ suggested plans would indeed eliminate all one-race black schools; however over one-third (ten of twenty-nine) of the county’s elementary schools would still remain 98-100% white. And no racial balancing of the county’s elementary schools would even be attempted, much less achieved. Obviously, even if combined, the plans which appellants put forth as alter natives to the school board’s plan (1) would not achieve a unitary system (2) would not eliminate all one-race, or virtually one-race, schools (3) would not achieve the greatest possible degree of actual dese: i ration taking into account the practicalities of the situati mid, accordingly, ann and Davis would not honor the prescriptions oi nor comply with the commands of Ad. . It is also inter esting to note that 1,664 pupils would be bused under these alternative plans which do noi : et constitutional standards, while only 704 pupils would de bused under the school board’s plan which does meet tl standards. If the defendant school board had adopted bud if the appellants’ suggested alternatives, we submit that 1 would have been 1 required, as were the various school bo ,ds in Adams, to prepare a “new” plan which wouki “ 1 effect to Swann and Davis” by according adequate con-1 ation to the “use of bus transportation and split zoning. ' Adams, supra, at 100- 101. In light of the legal deficiencies in the . Hants’ suggested alternatives and the demonstrated dra> . rks of the “90% out 90% in” plan, it is difficult to co due how the plan adopted by the school board can be s. i d to be invidiously discriminatory. In this connection, c< udn aspects of the case at bar must be emphasized. First diis case does not involve the closing of any school, mer he conversion of facilities from one type of educational t ram to another. Second, this case does not involve even; gestion of “white flight,” and neither that term nor th. t concept was ever mentioned by any party at any point i n diese proceedings. Third, this case does not involve any rt 1 wnce on the part of the school board to assign and bus kite children to formerly all-black schools located in aid r predominantly, Negro neighborhoods. On the contrary , the record discloses that a majority (70%) of white stud i ts have for years been transported to the formerly all-bin..:; Hoffman-Boston �16 17 Junior High School (Jefferson Annex) located in that com pletely Negro residential area (App. 42). See, Wanner v. County School Board of Arlington County, 357 F. 2d 452, 456 (4 Cir., 1966). Moreover, the plan adopted by the School Board envisioned the enrollment of a majority of white students in the model elementary school to be housed in the converted Drew facility which is located in an allNegro residential area, and that feature of the school board’s plan is even now in effect. See, Brief for the Appellants, p. 7. Significant in this context, is the decision of this Court in Chambers v. Iredell County Board of Education, 423 F.2d 613 (4th Cir., 1970). Under consideration in that case was a school desegregation plan in which one school, Unity School, remained all black with 285 students. That facility was to be replaced the following school year by a new school which was then under construction. When completed, the new facility would absorb Unity’s 285 black students and some 475 white students from three other schools, at which time the formerly all-black Unity School would be closed. Plain tiffs there alleged that the decision to close Unity was racially motivated “because it arose out of a disinclination to put white pupils into a previously all-black school.” Id., at 616. Rejecting this contention, this Court stated (423 F.2d at 616): school is not indicative of racial motivation when a school board has integrated another previously all-. :: school in the same system, then the mere conversion < a previously all-black school to a different educational p am and the enrollment of a majority of white students in that identical facility, coupled with the previous assignment < a majority -f of white students to another formerly all-bla. school, can not be said to be racially motivated. Even more nearly in point and controllin: - the decision of this Court in Allen V. Asheville City Boa* Education, 434 F.2d 902 (4th Cir., 1970). In that ca> . he Asheville School Board decided that it was ncccssa: y to close two formerly all-black elementary schools and on formerly allwhite elementary school to achieve racial . ounce. After plaintiffs objected to the proposed plan on ! basis of the closing of the two all-black schools, the sch 1 toard modi fied the plan to provide for the continued < : tion of the formerly all-white school, with the two fo1 y all-black schools remaining dosed. During the court its opinion, this Court stated the plaintiffs’ objection to t h plan and the reason therefore in the following language ( 1 . i F.2d at 905, 906): “This contention is not persuasive in light of the fact that the school board has already integrated Amity School, which was previously all-black and is now twothirds white. There appears to be no pattern of simply closing black schools because they have been black.” Similarly, in the case at bar, the Arlington County School Board long ago integrated the Hoffman-Boston Junior High School “which was previously all-black and is now twothirds white.” We submit that if the closing of an all-black “Able counsel for plaintiffs are unal ‘ - to fault the Board’s plan other than a complaint wii i expect to the closing of two previously all-black sclu and the im pact of their closing, in the context of : a rest of the plan, upon black students. * * * “Plaintiffs insist, however, that the sch i : board’s true reason for selection is undisclosed and is imply its ‘re luctance to send primary grade white children into traditionally all-black schools located in . black neigh borhoods.’ ” �18 19 Rejecting plaintiffs’ contention that the Asheville School Board had unfairly discriminated against black students in the closing of the two schools there in question, this Court enunciated the following principles governing such situ ations (434 F.2d at 905, 906): elementary schools, or if they were recou- tituted as such, 90 pcrcent of the black students formerly in •?ach school would have to be moved out into other schools ; ; .1 this 90 percent replaced by white students. Moreover, •’ ; purpose of the implement the school board’s plan here is not merely Brown I I principle, but also to implem :nt Swann, Davis and Adams. That the plan “effectively ieves that end” is acknowledged even by the appellant ■ c, Brief for the Appellants, p. 19. In addition, the schoi a rd ’s plan is the plan that will only demonstrably rational and praci comply with the requirements of Swann. .Oavis and Adams. ' In Chambers, this Court expressed < mbt that many school systems had achieved a higher c: ee of integration than then prevailed in Iredell Count . Subsequently, in Allen, this Court stated that Asheville v ■ “at or near the pinnacle of arithmetical desegregation i America.” Id., at 903. So far as we are aware, Asheville ; ill near the pincrica: however, nacle of arithmetical desegregation in .1 desegregation we submit that at the pinnacle of arithm in America is Arlington County. Here in, it should be pointed out that this distinction was ach i without closing any school, while in the Chambers and n cases, the all black facilities there under considcratioi. ure selected “for extinction” and were removed from the :c school system. upra, at 905. Allen v. Asheville City Board of Educati None of the cases relied upon by ay; Hants derogates .ibers and Allen from the principles enunciated in the ( cases. In Felder v. Harnett County B nd of Education, supra, the basis of this Court’s decision was the complete failure of the school board to discstalA . an entrenched dual school system in which only 4.3% « ’ e black children were attending previously all white sc' s. Moreover, in that case there was not the slightest ass : . ice of achieving In the first place, we think the mechanics of integra tion, where the purpose is obviously to implement the Brown I I principle and effectively achieves that end, is ordinarily a matter within the discretion of school ad ministrators. The question is no(whether we might have selected different schools for extinction, nor even whether substantial evidence supports the Board’s deci sion, but is instead whether the Board’s decision is so plainly unfair that it clearly amounts to invidious dis crimination in violation of the equal protection clause. ■X* # "A * .. . Moreover, the situation of which plaintiffs complain cannot possibly be changed except at the cost of in creasing the transportation of pupils approximately 40 percent. This is so because if the two black schools that have been closed were reopened, 70 percent of the black students formerly in each school would have to be moved out into other schools and this 70 percent re placed by white students. * * * It is urged upon us that even so, both schools that were closed are newer and physically better than most of the other schools retained. We agree that this is a relevant factor. But neither alone nor in context docs it establish invidious discrimination. Such a factor is only one of many that enter into a school closing decision. We repeat that we do not sit to review state adminis trative decisions beyond the very limited reach of the Constitution. (Italics supplied.) Similarly, in the case at bar, as previously pointed out, if Drew and Hoffman-Boston had been retained as traditional �20 a unitary school system and the selection of the schools for closing was therefore suspect. See, Allen, supra at 906. In Green v. School Board of City of Roanoke, 316 F. Supp. 6 (W.D. Va. 1970), the closing of the formerly all black high school there under consideration would have caused overcrowding in the three remaining predominantly white high schools in the city. In the face of this circum stance, no adequate reason was advanced by the school board, in terms of its desegregation plan or otherwise, to justify discontinuance of the school in question. Brice v. Landis, 314 F. Supp. 974 (N.D. Cal. 1969) states nothing to the contrary. In that case, the closing of a 99% black school, pursuant to the school board’s plan would have resulted in overcrowded classes and distorted pupil-teacher ratios at the three remaining predominantly white schools in the system. Id., at 977. Other “options, alternatives and courses of action” were available to the school board. Id., at 978. Pointing out that a particular desegregation plan “when not reasonably required under the circumstances” could be discriminatory, the District Court observed (314 F. Supp. at 978): “Whether the plan, as here presented, is a good faith, reasonably adequate implementation of constitutional principles involved, must be determined in the light, among other things, of the alternative options and courses of action available to the District.” (Italics supplied.) Commenting upon this decision in Allen, supra, this Court succinctly stated (434 F.2d at 907): “We are advertent to Brice v. Landis (N.D. Cal., Aug. 8, 1969), 314 F.Supp. 974, which held on the peculiar facts of the case that the closing of a Negro school was invidiously discriminatory and subject to in- 21 junction. We think it means no more than that and agree there may be such a case. ! it think it is not this one. If it is read to imply that is ordinarily for the district courts to determine whit k rhools shall be closed rather than for the school boatd, ne reject the propo sition.” (Italics supplied.) Even less apposite is Lee v. Mact . b ounty Board of Edu cation, 448 F. 2d 746 (5 Cir., 1971 . that case, the Court of Appeals for the Fifth Circuit r ed a decree of the district court which would have 1 ac effect of leaving over 45% of the school district’s Nc ,'tudents in all-black, or virtually all-black, schools. Id., 748, 753. Moreover, the justification advanced by the s< ■ board for the pro ! posed closing of two formerly all-bl 1 schools was (1) that whites would resist going to school <ilitics formerly used by blacks, and (2) that otherwise v.! < students would flee ■ 750, 754. In light of the school system altogether. Id., these circumstances, the Court of . als directed the dis trict court to require the school bo. "forthwith to consti tute and implement a student assign u plan that complies with the principles established in S: ■v. Charlotte-Mecklenburg Board of Education.” Id., . 53. In short, Lee is a school closing, racially motivated, v te-flight, non-unitary, non-Swann school desegregation ca . Not one of the abovelisted considerations obtains in the e. at bar. Haney v. County Board of Edit- ■■ of Sevier County, ''on 429 F. 2d 364 (8 Cir., 1970) is cqu. inapplicable. In that case, the district court decreed the ; xation of a small all black school district in the count y a larger all-white school district and, in addition, d ed that the facilities of the larger all-white school distri uld be utilized and, only if these facilities proved inadeo . would those of the formerly all-Negro district be used. re was nothing in the record to explain the closing of th lities formerly used �22 for the instruction of black students. After referring to this Court’s decision in the Felder case and Brice v. Landis, supra, the Court of Appeals observed (429 F.2d at 372): “The matter of utilization of available facilities is with in the province and discretion of the school board. There is a statement in the record that the class rooms of the former Sevier District are not of sufficient size to meet current state standards. These details, of course, are subject to many variations and much can be done within the existing framework of operation to suffi ciently utilize existing facilities. This is not a matter for court consideration but rather should be resolved on some rational non-discriminatory basis by the local school board.” (Italics supplied.) Throughout their briefs, both appellants and amici curiae make only glancing references to Swann, pay no respect to Adams and do not even mention Davis at all. Indeed, refer ence is made to Adams only for its one line affirmance of the district court’s retention of the Addison School in Roan oke; so far as appellants and amici are concerned, the rest of what this Court said in Adams does not even exist. Thus do they seek to avoid any consideration whatever of the school board’s clear obligation to eliminate one-race schools and achieve the greatest possible degree of actual desegre gation as required by Swann, Davis and Adams. Thus, too, do they seek to insinuate that the school board in this case can get by with something less than full compliance with the commands of these decisions, even though full compliance can be had, as demonstrated by the plan which the school board adopted and put into effect last September and which this Court and the Chief Justice of the United States refused to enjoin. In addition, both appellants and amici persist in pressing the illusion that there “may” be other plans which would 23 meet the prescribed constitutional standards. See Brief for the Appellants, p. 17; Brief for Amici Curi, ■ p. 16. How . ever, both are careful to avoid stating that the- o “is” such a plan or informing this Court of the detain. or even the outlines, of such other plan. The reason for 17 equivocation is quite obvious—both appellants and amici k : w full well that there is no plan other than that adopt■ y the school board which rationally and practically acr dishes what this Court said in Adams must be done. The assertion that the school board’s pi: fairly bur dens the Negro students of Drew and Hoff : Boston will not bear scrutiny. For years pupils at the chools have attended a “walk-in” facility and have not i • • o required to . be bused (App. 48-49). If attendance at . ‘walk-in” fa cility can be deemed a convenience, it is ; which these students have enjoyed for years while tht ds of other children in Arlington County have been b: (App. 13). To require them at this late date to forego onvcnicnce so that a racially balanced, unitary schot em can be established can hardly be considered unfai . iiis, we sub mit, is especially true when one remembers he bus ride they arc asked to take is, on the average, 1 ten minutes longer than the time it would take them walk to the Drew and Hoffman-Boston facilities, and t: ilk to those facilities had to be made in all weather cor ■ >ns through out the school year (App. 39). Finally, wh i i d i e Drew and Hoffman-Boston students arc now bused w her schools, over 40% of the Negro elementary studr - in Arlington County still attend their neighborhood scl (App. 15). In Allen, a similar contention was reject y this Court in language subsequendy deemed contrnllii 1 quoted at length in Mims v. Duval County School Bot ’29 F. Supp. 123 (M.D. Fla., 1971). In Mims, approving , i segregation �24 plan which involved the closing of seven black elementary schools, the district court observed (329 F. Supp. at 132133): “In their second argument plaintiffs seek to have this Court require the School Board to bus white children to the core city for all elementary grades, not just to sixth grade centers, so to achieve equal busing of the races. The United States Court of Appeals for the Fourth Circuit resolved the same argument in Allen v. Asheville City Board of Education [434 F.2d 902, 907 (4 Cir., 1970)] with these words: We are asked to decide whether the district court, in approving the plan, unconstitutionally placed ‘the burden of desegregation’ upon black pupils in the school system. It is urged upon us that the plan ap proved by the district court ‘places an unfair, racially discriminatory burden upon black children’ in that black children in grades 1 through 5 who previously attended all-black Livingston and Herring Elemen tary Schools will be required to travel as much as five or six miles in order to attend previously all-white schools. This is said to be an unfair allocation of the ‘burden’ of integration, and it is suggested that the Constitution requires that an equivalent number or proportion of white children in the same grades be required to travel an equivalent distance to enter schools outside their previous attendance zones. Wc hold that such a pattern of assignment imple mented by free school bus transportation does not violate the equal protection clause of the Fourteenth Amendment. The rationale in the Second Circuit is essentially the same. In Norwalk Core v. Norwalk Board of Education, [423 F.2d 121, 124 (2 Cir., 1970)] the Court noted: Plaintiffs would eliminate what they call unequal treatment by having, in effect, one white child bussed 25 out of his neighborhood for every black child bussed out of his—in other words, deprive as many whites of neighborhood advantages as bla s are deprived by being bussed to schools predomi: :. ly white. But the problem is not as simple as a >. black, one white ratio. It is a question of the Boa o . with the facilities available having ‘acted in the u: : good faith, in a nonarbitrary and deliberate ma; r, in order both to insure racial balance and to ;■ ;de high quality education.’ * * *” Nor will it do to assert that the sell 1 board's plan sug gests to black children that it would be .gcrous if “blacks make up more than 15% of the enrol tit of any school.” See, Brief for the Appellants, p. 15. T h: .- rtion is instantly blunted by the fact that four element; y schools in Arling ton County already had black studer ii excess of 15% when the school board’s plan was ado d. Moreover, the alternative arrangements for the Drr\ ool espoused in plaintiffs’ brief would limit black enrol to 21% in each of the schools affected. Does this arra: :ent suggest that any number of black students in excess ■ i % in any school is dangerous? Was any such message ; it or implicit in the racially balanced plans approve : y this Court in Chambers and Allcn'l Neither, we sir, , it, dries the plan adopted by the school board in the ca at bar carry such an inference. It is, of course, primarily the obligati; . the school board to frame and put into effect a plan wl establishes a uni tary school system, and, as pointed out >airis, supra at 37, the “measure of any desegregation pla : its effectiveness.” From Brown II to Adams, the dcci confirming this principle have been legion and r< iw-tr: - stated in Brad ley v. School Board of City of III I: mot :5 T. Supp. 828. 832-833 (E.D.Va. 1971): �26 “A second principle guiding the Court—almost as ob vious as the doctrine of precedent—is that it is primarily the School Board’s duty to run the schools, and not this Court’s nor the plaintiffs’ . . . Because both expertise and responsibility are the School Board’s, it is to their proposals that courts look first for a legally sufficient plan. . . . When they assume the ‘responsibility which Brown II placed squarely on the School Board,’ Id., 442, 88 S. Ct. 1696, courts will not presume to dictate a selection between equally effective desegregation plans.” Wanner v. County School Board of Arlington County, 357 F. 2d 452, 436 (4th Cir. 1966). (Italics supplied.) Echoing these observations are those of Judge Bryan in his special concurring opinion in Adams, supra, at 102: " . . . I think the only pattern the school authorities and the Courts must observe is one honoring the prescrip tions of Swann and Davis. So long as it is in keeping with these decisions, my understanding is that formu lation of a plan is entrusted to the discretion of the school authorities. . . ” (Italics supplied.) We submit that in the case at bar the obligation resting upon the Arlington County School Board has been fully dis charged by the adoption of a desegregation plan which honors the prescriptions of Swann and Davis, complies with the commands of Adams, and is therefore constitutionally valid. CONCLUSION In Walton v. Nashville, Arkansas, Special School District No. 1, 401 F. 2d 137, 144 (8 Cir., 1969), Judge Blackmun, speaking for a court which sustained the non-reemployment of certain Negro teachers in a school desegregation case, made the following observations: 27 “We are conscious in this case, as we have been in earlier ones, that the process of sc hool integration is not easy and that there will be hurts and disappointments as integration is accomplished. Certainly, under the precepts of the Brown clecisi it has been too long delayed at Nashville. But we w told that it has now been fully accomplished liter, . That fact should be a source of satisfaction for all < ns, white as well as black.” (Italics supplied.) In the case at bar, this Court is ; . >informed that inte gration has now been fully accompi 1d in Arlington Coun ty. It is so informed by the plan f, which is currently before this Court and was adopted i carry out the following policy of the school board (App. 4 : “The purposes that the board 1 was. first of all, pri marily to eliminate all vesti. of a dual system, to move to establish a true unitaiy . stem throughout the county, to provide and to c-: ash racial balanced schools, and I think, then, to _ in with the primary purpose of the school system s a is the education of young people.” It is similarly informed by the a' iants who admit tha: the plan is one “which unqurstion docs away with the last vestiges of school segregation r lining from the legis latively imposed dual school systc:, and who further ac knowledge that it “is undisputed t- the Arlington School Board has put into effect a plan th: illy complies with the primary mandates laid down in” E : n, Green and Swann. See, Brief for the Appellants, pp. 1.1. Finally, this Court is so inf umed 'he District Court in the following language of its opinb . 29 F. Supp. at 955956 (App. 14): “The Arlington Conn's Scl complied with the Sun ; ( Hoard has now fully decision in Brown I �28 —A unitary school system as required by Green and Alexander has been established—Arlington will have neither black nor white schools—just schools.” In light of the foregoing, and for the reason heretofore stated, we submit that the decision of the Distirct Court is clearly correct and should be affirmed. Respectfully submitted, J a m e s H. Sim m o n d s G r e g o r y U. E v a n s 1500 North Courthouse Road Arlington, Virginia R. D . M c I lw a in e , I I I P.O. Box 705 Petersburg, Virginia Counsel for Appellees CERTIFICATE I certify that two copies of the within brief for appellees were mailed, with first class postage prepaid, to S. W. Tucker, Esquire, 214 East Clay Street, Richmond, Virginia 23219; to Robert M. Alexander, Esquire, 2011'South Glebe Road, Arlington, Virginia 22204; to Allison W. Brown, Jr., Esquire, Suite 501, 1424 Sixteenth Street, N.W., Washing ton, D.C. 20036; to Lawrence J. Latto, Esquire, 734 Fif teenth Street, N.W., Washington, D.C. 20005; and to Jack Greenburg, Esquire, Suite 2030, 10 Columbus Circle, New York, New York 10010, counsel for plaintiffs; and to William H. Allen, Esquire, and John B. Jones, Jr., Esquire, 888 Six teenth Street, N.W., Washington, D.C. 20006, counsel for amici curiae, this 10th day of March, 1972. R. D. M c I l w a in e , III � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Copy of John K. Hart, et al vs. County School Board of Arlington County, Virginia, et al, Brief for Appellees, March 10, 1972. 15 pages. Description An account of the resource Copy of John K. Hart, et al vs. County School Board of Arlington county, Virginia, et al, Brief for Appellees, March 10, 1972. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Counsel for Appellees Date A point or period of time associated with an event in the lifecycle of the resource 1972-03-10 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1970s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_28 https://projectdaps.org/files/original/d8e7d3e53031e3995feda27319b1bb22.pdf d4cb141cd63e24e5867cc3e5b997f9bc PDF Text Text ( p M \1 4969 'lock 3- r ln - load I r lln g ta n , v a . 22207 25 Juno 1969 K rs . l u t h 0 'D o l l c^x. Chair-non A r l l n to n iohool j o - r d 4751 N. 25 S t . A r l l n t o n , V . 2207 ? Deer l i r a . Cox: I hove r e e d I n th e newspaper t h a t t h e p r o o l d s n t of tho Drew Elem e n t " ry School ITA ho 9 retrod the A r l i n g t o n Soho 1 jo - rd f o r h e lp I n daaogi' the Drew S chool. as • concerned o l t l z o n a n d mother of 4 c c h o o l- a g e c h i l d r e n , I a l n o a r o ly hope t h a t the A r l in g to n School Board w i l l a c t quloYLy xx on t h i s r a q u o o t. T > For a number o f y e a r s no-' I t hoc been the law of the l e n d t h a t aohoola sh o u ld be do 0 0 r a t e d . I n- aware t h a t f t r l l n ton has made c r nges In I t s ochoolo t o o a r r v o u t d e s a g r a t l o n . I t l e I m p o r t a n t n o t only t h a t we c o n tin u e to comply w i t h th e la w , o u t t h a t we show our b e l i e f In e q u a l e d u o t l o n ’l o p p o r t u n i t y f o r - 1 1 our o l t l z c n c by J o 30(7^t i n ; tha Prow ic h o o l. In stu d ylr. tha story o f joliool o e g r e g -tlo n in t. a 00 u n it ie s o f B e rk eley , C a lifo r n io ., Evanston, I l l i n o i s , V raou ae, aw orb, you fin d t h - t the sch ool io -tIh o f those c i t i e s were behind doaogrs -tlo n -ri'-ns, -nd put c a r e fu l thought In to lo n : -range 1 1 i j for thscBU -.1 d is t r ib u t io n of m inority stu d en ts throu, out tbs ehool 0 voter.. Co— u n it - r s i’U M BCBtt fgB from v r l o u s or--—«i_- t l iij arid o cc u r " tl >ns helped - la n th e d e e e g r a tle n md works t the b ’ak in . o f the ooanunlty as a w hole. Of p a r '" i9 u n t c o n c e r n ’t o th e s e o_- • un* t i e s was the f o o t t h '- t American s o c i e t y w i l l neve r be a b le to l i v e I n pouoo nd u n d e r u ta n d in u n l e s s b io ok • i l w h ite poroons s t u d y , work n i ploy t o g e t h e r throughout t h e i r school y e a rs. lha U.3. C o i n l s s l o n on l v l l 11 h t s , In I t s c a r e f u l l y documented stu d y on " H a d s l I a o l a t b n I n tho P u b lic d o h o o lo " , hi 1 shown t h a t d is a d v a n t a g e d s t u d e n t s a c h ie v e c r e a t o r -endemic g a i n s I n i n t e g r a t e d soho: 1 3 . Thi3 was ce rt- I n ly borne o u t I n the anno of ichool d e eogre " t l o n I n l y r a o u e e , N . F . , where th e q u a l i t y o f t Lo d i d n o t o t e r l o r a t o when t ay were I n t e g r a t e d , n o r d id th e ac h ie v e iont l e v e l s of the p u p i l s . Mush oxtr1 m t i n t o tho d e s e g r e g a t i o n p l a n s , so t h a t t h e r e would be a minimum o f c o n f u s io n and a l o u n d o r n t - .. l i n g . A r l i n g t o n I s f o r t u n - t o a t tho moment, to have a e?i% ste o f enough r o e l s l u n d e r s t a n d i n g to c a r r y o u t desegrn a hr-r-nonlouely. But I b e l i e v e we must s t a r t to c t now, f o r I t lo - r r e n t t h a t th o r e I s g r e a t m o l ' - l u n r o o t i n America, and we - u - t show our d e s i r e and f i r e . I n t e n t to o u t th e g o a l o f eq u a l e d u c a t i o n a l 0 o r t u n l t y I n t o e o n o r e te n o t i o n . The A r l in g to n Johool Board has a r a r e ep- o r t u n l t y t o le a d I n ti l e v i t a l a r e - , -nd I b e l i e v e I t must ta k e thl-> r c a n o n a l b l l l t y e a r l o u a l y •nd eo--n. l a t h e r t ’vm he pushed i n t o t h i s a c t i o n by ■ c o u r t o r d e r . I t woul 1 be ao much >ett :> f o r fud* fce no u n i t y r e t tlo n * I f f i e • 6^ V ' �oohool board should taka the le a d In oe i n A p la n n in g fo r draw's d a a eg ra ea tlo n . Sincer-aly y o u rs. (tirs. George I . lootli) I nboosaary � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Copy of letter to Ruth Cox, Chairman, Arlington County School Board from Mrs. George H. Booth, June 25, 1969. 2 pages. Description An account of the resource Copy of letter urging the School Board to Act on the request of the Drew PTA for help in desegregating Drew School sent to Barbara Marx for her information. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Joanne Booth Date A point or period of time associated with an event in the lifecycle of the resource 1969-06-25 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1960s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_27 https://projectdaps.org/files/original/cfce54230ccb5d7c3e1562278d0e7fa7.pdf 45388aa0bd625ce31410d025487c14a9 PDF Text Text � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Envelope to Barbara Marx from Mrs. George H. Booth, June 25, 1969. Description An account of the resource Envelope to Barbara Marx from Mrs. George H. Booth, June 25, 1969. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Joanne Booth Date A point or period of time associated with an event in the lifecycle of the resource 1969-06-25 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1960s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_26 https://projectdaps.org/files/original/8d87e48e9b73159357ab653e29349bb1.pdf a849484627974abb27d4c8edb1a1ee9e PDF Text Text Plans of the "Synagogue of Satan” “For Esau is the end of the world ( system ); and Jacob is the begin ning of i t that followeth.” ( // Esdras 6:9.) For Free Distribution—obtainable from BRITISH ISRAEL ASSOCIATION OF GREATER VANCOUVER 1238A SEYMOUR STREET VANCOUVER. B.C. �PLANS OF THE 'SYNAGOGUE OF SATAN' “A report from Europe carries the following speech of Rabbi Emanuel Rabinovich before a special meeting of the Emergency Council of European Rabbis in Budapest, Hungary, January 12, 1952: “Greetings, my children; You have been called here to recapitulate the principal steps of our new program. As you know, we had hoped to have twenty years between wars to consolidate the great gains which we made from World War II, but our increasing numbers in certain vital areas is arousing opposition to us, and we must now work with every means a t our disposal to precipitate World W ar I II within five years. "The goal for which wo have' striven so concertedly for three thousand years is at last within our reach, and because its fulfilm ent is so ap parent, it behoves us to increase our efforts and our caution tenfold. I can safely promise you th a t before ten years have passed, our race will take its rightful place in the world, with every Jew a king and every Gentile a slave. (Applause from the gathering.) You remember the suc cess of our propaganda campaign during the 1930’s, which aroused anti-American passions in Germany a t the same time we were arousing antiGerman passions in America, a campaign which culminated in the Second World War. A similar propaganda campaign is now being waged in tensively throughout the world. A war fever is being worked up in Russia by an incessant antiAmerican barrage while a nation-wide an ti comm unist scare is sweeping America. This cam paign is forcing all the smaller nations to choose between th e partnership of Russia or an alliance with the United States. “Our most pressing problem a t the moment is to inflame the lagging m ilitaristic spirit of the Americans. The failure of the Universal Mili tary Training Act was a great setback to our plans, but we are assured th a t a suitable measure will be rushed through Congress immediately 2 after the 1952 elections. The Russian, as well as the Asiatic peoples, are well under control and offer no objections to war, but we must wait to secure the Americans. This we hope to do with the issue of anti-Semitism, which worked so well in uniting the Americans against Germany. We are counting heavily on reports of anti-Semitic outrages in Russia to whip up indignation in the United States and produce a front of solid arity against the Soviet power. Simultaneously, to demonstrate to Americans the reality of antiSemitism, we will advance through new sources large sums of money to outspokenly anti-Semitic elements in America to increase their effective ness, and we shall stage anti-Semitic outbreaks in several of their largest cities. This will serve the double purpose of exposing reactionary sec tors in America, which then can be silenced, and of welding the United States J n to a devoted antiRussian unit. (Note—Protocol of Zion No. 9, para. 2, states th a t anti-Semitism is controlled by them. They have already commenced their campaign of antiSemitism in Czecho-Slovakia). (Printed in No vember 1952). “W ithin five years, this program will achieve its objective, the Third World War, which will surpass in destruction all previous contests. Israeli, of course, will remain neutral, and when both sides are devastated and exhausted, we will arbitrate, sending our Control Commission into all wrecked countries. This war will end for all time our struggle against the Gentiles. “We will openly reveal our identity with the races of Asia and Africa. I can state with as surance th a t the last generation of white children is now being born. Our Control Commissions will, in the interests of peace and wiping out inter racial tensions, forbid the whites to mate with whites. The white women m ust cohabit with members of the dark races, the white men with black women. Thus the white race will disappear, for mixing the dark with the white means the end of the white man, and our most dangerous enemy will become only a memory. We shall embark upon an era of ten thousand years of �peace and plenty, the Pax Judaica, and our race will rule undisputed over the world. Our superior intelligence will easily enable us to retain mastery over a world of dark peoples. “ ‘(Question from the gathering: Rabbi Rabino vich, w hat about the various religions after the Third World W ar?’) "Rabinovich: “There will be no more re ligions. Not only would the existence of a priest class rem ain a constant danger to our rule, but belief in an after-life would give spiritual strength to irreconcilable elements in many countries, and enable them to resist us. We will, however, retain the rituals and customs of Judaism as the mark of our hereditary ruling caste, strengthening our racial laws so th a t no Jew will be allowed to m arry outside our race, nor will any stranger be accepted by us. (Note: Protocol of Zion No. 17 para 2, states: “Now th a t freedom of conscience has been de clared everywhere (as a result of their efforts they have previously stated) only years divide us from the moment of THE COMPLETE WRECK ING OF THAT CHRISTIAN RELIGION. As io other religions, we shall have still less difficulty with them .”) “We may have to repeat the grim days of World W ar II, when we were forced to let the Hitlerite bandits sacrifice some of our people, in order th a t we may have adequate documenta tion and witnesses to legally justify our trial and execution of the leaders of America and Russia as war criminals, after we have dictated the peace. I am sure you will need little preparation for such a duty, for sacrifice has always been the watchword of our people, and the death of a few' thousand Jews in exchange for world leadership is indeed a small price to pay. “To convince you of the certainty of th at leadership, let me point out to you how we have turned all of the inventions of the white m an into weapons against him. His printing presses and radios are the mouthpieces of our desires, and his heavy industry manufactures the instruments which he sends out to arm Asia and Africa against him. Our interests in W ashington are greatly ex- tending the Point Four Program for developing industry in backward areas of the world, so th at after the industrial plants and cities of Europe and America are destroyed by atomic warfare, the whites can offer no resistance against the large masses of the dark races, who will m ain tain an unchallenged technological superiority. “And so, with the vision of world victory be fore you, go back to your countries and intensify your good work, until th at approaching day when Israeli will reveal herself in all her glorious des tiny as the Light of the World.” (Note: Every statem ent made by Rabinovich is based on agenda contained in the "Protocols of Zion.”) Note—This address by Rabbi Rabinovich was published in the U.S. publication “Common Sense” and republished in the September 1952 issue of The Canadian Intelligence Service. Mr. Eustus Mullins, well informed authority on the Marxist conspiracy whose writings appear in several pattriotic publications, presumably made this m a terial available to “Common Sense,” as a foot note to the speech reads “This transcription of Rabinovich’s speech was given to me by a former Bulgarian diplomat who broke with the Com munist regime and reached Budapest. Hungary, where he hid out with anti-Communist friends until March. While there, he obtained a copy of this speech, and was then smuggled to Ham burg, Germany, finally making his way to this country. A gentleman in Hamburg gave him my name, and he m et me and urged me to dis tribute this speech a t once. I sincerely hope th at it will give the American people a better pic ture of the force arrayed against them.”—Eustus Mullins. 4 6 �"He That Sitteth In the Heavens Shall Laugh: The Lord Shall Have THEM In Derision." (Psalm 2:4) The preceding speech is by a leading Zion ist Rabbi. Of the Zionists, Professor Lothrop Stoddard, the eminent Ethnologist, states th a t FROM THEIR OWN RECORDS, 82 per cent are Ashkenazim, socalled Jews, with round skulls (Brachycephalic) and with “typical Jewish noses” (which they now alter by plastic surgery,) and th a t they are of TURKO-MONGOL blood, and are NOT SEMITIC. On the other hand, he states th a t the true Semitic Sephardim Jews are long skulled (Dolicocephalic) and have fine cut noses, and “are an harmonic type.” He further states th a t the Ashkenazim false Jews are of the Alpine Race whilst the true Semitic Sephardim Jews are of the M editerranean Race, and th at from an Ethnological standpoint, these two types are as far apart as the North and South Poles. (Vide, “The Forum,” March, 1926). Prof. John Beaty, formerly a Colonel in the U.S.A. Intelligence Service, states in his recentbook, “The Iron Curtain Over America,” (Wilkin son Publishing Co., Dallas, Texas) th a t the Zion ists are the Khazars of Russia, who are of Turko-Mongol blood, and who became converts to Judaism only a few hundred years ago, but are NOT Semitic, nor of Jewish or Israel blood. Further he states th at their religion is th a t of the terrible Babylonian Talmud, (Note: based on Baal-(devil) worship) and is not on the Mosaic Talmud of the Bible. He demonstrates by docu mentation th a t it was they who organized the Russian Communist Revolution of 1917, and that, they still control the present Russian Communist government there. This is corroborated by the U.S. Army Intelligence report on the Russian Revolution of 1917, and which gives the names of those financiers (Kuhn. Loeb & Co., of New York) who financed it. and of the 30 Zionists in Russia, who engineered it there. Prof. Beaty also demonstrates th a t these Zionists obtained con trol of the Democratic Party in the United States 6 of America, and have installed policies to break down the power of America, and to supplant it by Internationalism , through the Zionist-con trolled U.N.O. Further, Major Robert Williams, United States Intelligence Officer, in his book, ■Know Your Enemy,” (Box 868, Santa Anna, , Calif.) gives the names of their leaders in the U.S.A., and by documentation shows th a t Judge Felix Frankfurter, Senator Lehman, and Henry Morgenthau, Jr., are those in charge, and under whom are Dean Acheson, and many others in the State Department. Now the Jewish Encyclopaedia, 1925 edition, Vol. 5, Page 41, states: “Edom is in modern Jewry,” which is corroborated by Encyclopaedia Biblica, Vol. 2, Col. 1187. But we are told: “Esau is Edom” (Genesis 36:1) and Edom means “RED” (Gen. 25:30). Hence we have their Red propaganda and alien poisoned doctrines, which are invented by them, and not by the true Semitic Jews, the leaders of whom will have nothing to do with political Zionism. A study of the m atter shows th a t these Edom ite so-called Jews are descendants of the Herodians of C hrist’s day (Matt. 2:16, etc.) who were Idumeans of Turko-Mongol blood. Th? Lord re fers to the Idumeans as “The People of My Curse,” (Isa. 35:5-8) as they were descendants of Amalek (Exodus 17:16) with whom He had sworn to have war from generation to generation. Yet it is these Ashkenazim Edomites who impress on Christians th a t they are the “Chosen People," and when anyone tries to interfere with their plans, sta rt the cry "Anti-Semitism,” although they are not Semitic, but of Turko-Mongol blood. We see, however, th a t it is not anti-Semitism but anti-Red (Edom means Red) and anti-Communist. “The Protocols of Zion” *(Britons’ Publishing So ciety, 74 Princedale Rd., London, W. 11) appears to be their text-book, in which they have outlined their plans for world-control, the crowning of their "sovereign lord of all the world," (Protocol 2, para. 9, etc.) and the formation of their “super government of the world.” (Protocol 6, para. 3, etc.). It was Alger Hiss, now doing penal servi•W ritten by Ascher Ginzberg (Vide "Waters Flowing Eastward” : Page 38.) �tude as a Communist agent, who was executive Secretary a t Dumbarton Oaks, where he per suaded President Roosevelt to form the United Nations Organization, in the forming of which Hiss was very active. In his recent book "Far and Wide,” Douglas Reed devotes one chapter to "Zionism Para mount,” in which he demonstrates th a t the U.N.O. is completely controlled by a small clique, headed by w hat he terms “The Money Power," and consisting of Zionists and Communists. Thus we have the framework of the Zionists’ "SuperGovernment of the world” in the U.N.O. In his interesting booklet, "Palestine, ESAU Claims Possession," David Davidson, M.C., M.I. Struct. E., demonstrates th a t Amalek, the pre datory and illegitimate (Gen. 36:12) tribe of the Edomites, is now represented by International Finance, the “Money Power,” (page 10) and th at they are “the synagogue of S atan” (pages 7 and 10). He further demonstrates th a t the so-called Israeli are not Jews by blood, but are descendants of Esau (Edom) who are masquerading as Israel to hoodwink the Goyim (Gentiles) into allowing them to hold Palestine. I t must therefore be clear from the above quotations th a t the great majority of the Zionists are not true Jews, but are Edomites of TurkoMongol blood, who have no right whatsoever to Palestine. We must therefore differentiate between Zionists and Jews, as the true Semitic Sephardim Jews accept the nationalities of the countries in which they settle, and become good citizens: whereas the Edomite Zionist, inventor of Com munism and Socialism (Protocol 2, para. 3) plots and plans the destruction of the Anglo-SaxonCeltic race wherever he goes. Protocol of Zion, No. 2. para. 3 states: “Do not think for a minute th a t these statem ents are empty words; think carefully of the SUCCESSES WE ARRANGED FOR DARWINISM (EVOLUTION) MARXISM (COMMUNISM), and NEITZSCHEISM (SOCIALISM). To us Jews a t any rate it should be plain to see what a DISINTEGRATING IMPORTANCE these DIRECTIVES have had upon the minds of the Goyim,” (Gentiles). It is a very interesting point th a t the Zionist 8 banker, Amschel Mayor, assumed the name "Roth schild" about 150 years ago, as in German th at name means “Red Shield,” (Vide: New Teachers’ Cyclopaedia, Vol. 5, page 2454). I t was Amschel Mayer ROTHSCHILD who or ganized the Zionist International Finance, who since then have gradually usurped control of our governments through their financial policies. To Amschel Mayer Rothschild is attributed the statem ent: “Perm it me to issue the currency and credit of a nation, and I care not who makes its laws.” In view of this remark, it is signifi cant th a t through th e Bank Charter Acts of Britain, the United States, and Canada, it is the banking systems who now issue credits (on which 95 per cent of business is done) and not our gov ernments, who formerly held the prerogative of issuing both currency and credit. I t is a further interesting point th a t about 1805, the Rothschilds usurped the m ain devices of the Royal Arms of Great Britain, viz. the Lion and the Unicorn supporting the Crown of David. Further above the original Crown they have superimposed three crowns, which in heraldry symbolize th at the superimposed crowns have overcome the original Crown of B rit-ain (Hebrew for Covenant Land). Perhaps one of the m ain points of the Rothschild arms is th a t in one of the super imposed crowns they have placed the interlaced Triangles of Zionism INSIDE THE HORNS OF A BULL. Now the horns of a Bull are the ancient crest of the Anglo-Saxon Race (ancient NGLTZKSEN; Hebrew for Bull sons of Isaac, i.e. Joseph’s sons, Ephraim and Manasseh. as in Deuteronomy 33:17, and in Engl-Land, Hebrew for Bull Land, hence our John Bull). Thus these arms denote th a t the Zionists are working IN SIDE THE ANGLO-SAXON Race, i.e. BRIT-ISH (Hebrew, Covenant Man) Commonwealth and the United States of America (Vide: Burke’s Peerage). These facts corroborate the above-quoted speech by Rabbi Rabinovich, who states th a t their plan is to destroy the white race, of which the main p art is the Anglo-Saxon-Celtic Race, the des cendants of Jacob. 0 �In further corroboration. Protocol of Zion No. C, para. 7 states: “We appear on the scene as the ALLEGED saviours of the worker from this op pression, (which they have previously stated th at they have caused) when we propose to him to join OUR FIGHTING FORCES—SOCIALISTS, ANARCHISTS, COMMUNISTS—to whom wo al ways give support in accordance with an ALLEGED brotherly rule (of the solidarity of all mankind) of our Social masonry. The aristocracy, who en joyed by law (note: in Continental Europe, under the Civil Code of laws) the labour of the workers, was interested in seeing th a t the workers were well fed, healthy and strong. We are interested in JUST THE OPPOSITE—IN THE DIMINU TION AND KILLING OUT OF THE GOYIM.’’ (Hence Rabbi Rabinovich’s statements). Again Our Lord Jesus Christ prophesied of this, stating: “When ye therefore shall see the Abomination of Desolation, spoken of by Daniel the prophet (Dan. 11:31 and 12:11) stand in the Holy place, (whoso readeth, let him understand), then let them which be IN JUDEA flee into the mountains,” (Matt. 24:15, 16). In Daniel the literal Hebrew is "The Detestable Thing th at m aketh Desolate.” In his book “Our Money System,” Gardner states (page 24): "Amschel Mayer Rothschild, founder of th a t House, died in 1812, and on his death-bed nominated his five sons to dominate the world. Their problem was to ABOLISH CHRISTIANITY and rob and exploit all world governments.” To corroborate this. Protocol of Zion No. 17, para. 2, states: “Freedom of conscience has been declared everywhere (as a result of their efforts they have previously stated) so th a t now onlyyears divide us from THE COMPLETE WRECK ING OF THAT CHRISTIAN RELIGION.” This they have done in Russia under Communism, and in Socialist Germany under the Nazis, thus con tinuing the war commenced by Herod against Jesus Christ (Matt. 2: 16, etc.) and still further back by Amalek (Exodus 17:8-16). Further, Protocol No. 5, para. 4, states: “The Holy Unction of th e Lord’s Anointed has fallen 10 from the heads of kings in the eyes of the people, and WHEN WE ALSO ROBBED THEM OF THEIR FAITH IN GOD, the might of power was flung upon th e streets, into the place of public ownership (State Control) AND WAS SEIZED BY US.” Again, a m atter which has bothered our economics since 1946, is given in Protocol No. S, para. 7, which states: “We shall RAISE THE RATE OF WAGES, which, however, will not bring any advantage to the workers for, a t the same time, WE SHALL PRODUCE A RISE IN THE PRICES OF THE FIRST NECESSITIES OF LIFE—We shall further undermine artfully and deeply sources of production, by accustoming the workers to ANARCHY (Class warfare) and to drunkenness, and side by side therewith taking ALL MEASURES TO EXTIRPATE FROM THE FACE OF THE EARTH ALL THE EDUCATED FORCES OF THE GOYIM” (thus ^corroborating Rabbi Rabinovich’s statem ent re the destruction of the white race). In view of Rabbi Rabinovich’s speech, and the above-quoted statements from the Protocols of Zion, we can see th a t these Edomites (Reds) are those referred to by Our Lord Jesus Christ (Rev. 1:1) when He spoke of “them of the synagogue of Satan, who SAY they are Jews, and are NOT, but do LIE.” (Revelation 3:9, note also John 8:44). St. Paul prophesies, “For when THEY shall say PEACE and safety, THEN sudden destruction cometh upon THEM, as travail upon a woman with child, and THEY shall NOT escape.” (1 Thes. 5:3, Ussher date A.D. 54). But to whom does the “THEY” and “THEM" refer? Protocol of Zion No. 10,p ara 18 states: “T h erec ognition of our despot (king) may also come before the destruction of the Constitution (U.S.A.). The moment for the recognition will come when the peoples, utterly wearied by the irregularities and incompetence—A MATTER WHICH WE SHALL ARRANGE FOR—of their rulers, will clamour: "Away with them and give us one king over all the earth who will unite us and annihilate the 11 �causes of discords—frontiers, nationalities, re ligions, State debts—who will give us PEACE and QUIET, which we cannot find under our rulers and representatives.” We can therefore see th a t the cry of PEACE and Safety (Quiet) which is prophesied through St. PAUL is being arranged by political Zionist propaganda in favour of their so-called "sovereign lord of all the world,” and it is therefore to the Zionists th a t the "THEY" and "THEM” refer. They have already set up the framework cf their “Super-Government of the world,” in the so-called United Nations Organization, through Alger Hiss and other Communist-Zionist agents. This organization is prophesied in both Isa. 28: 15, 18, and Ezekiel 13: 10-16, and is to be des troyed, “Because, even because THEY have se duced MY People (Jacob) saying ‘Peace,’ and there was NO peace,” as the Zionists have no intention of letting us have Peace, but instead, as stated by Rabbi Rabinovich and in the Protocols, (The DIMINUTION and KILLING OUT OP THE GOYIM) are using th a t Organization to promote a Third World War, to destroy the power of the Anglo-Saxon-Celtic Race, and as a means of destroying the white race. They further state in Protocol No. 13, para. 5: "Who will ever suspect then THAT ALL THESE PEOPLES WERE STAGE-MANAGED BY US ACCORDING TO A POLITICAL PLAN WHICH NO ONE HAS SO MUCH AS GUESSED AT IN THE COURSE OP MANY CENTURIES?” (Note th a t Rabinovich states th a t after THREE THOU SAND YEARS their plans are practically ready to obtain world control). In this, as usual, THEY are deceived by their leader, Satan. The LORD, “declaring the end from the be ginning,” (Isa. 46:10) knew what “THEY” would attempt, and through King David about 1042 B.C. (Ussher date) prophesied of their AT TEMPTED setting-up of a “Super-Government of the world,” and of a so-called “sovereign lord of all the world” in ZION, and referring to it, stated: “He th a t sitteth in the Heavens shall LAUGH: the LORD shall have THEM in derision. THEN SHALL He Speak unto THEM in His wrath, and vex THEM in His sore displeasure," adding: “Yet HAVE I set MY KING (JESUS Christ) upon MY Holy Hill of ZION.” (Psalm 2: 4-6, note also verses 1-3, and I I Thes. 1: 7, 8, and 2: 3-10). THUS we see th a t th e joke is on Esau. Again, prophesying through King David of His Crucifixion, Our Lord JESUS Christ stated: “For dogs have compassed Me: the Assembly of the Wicked (i.e. synagogue of Satan) have inclosed Me: THEY PIERCED My hands and My feet.” (Psalm 22:16, “dogs,” i.e. Canaanites, (Matt. 15; 22-26,) also the descendants of those of Genesis 38: 1-10, note Jer. 24:8-10, John 8:44, i.e. “The Tares are the children of the WICKED ONE, the enemy th at sowed them is the devil.” (Matt. 13:38, 39). In “The Protocols of Zion,” it is stated th at the “Head of the Snake” (apparently the “syna gogue of Satan”) consists of 300 “Hidden Heads.” or elders, known only to each other. (Intro ductory Note to the Protocols) whilst the "Body of the Symbolic Snake,” consists of the rank and file of the Zionists (Protocol 3, para. 1) and it is stated th a t the Body has no idea as to the plans of the Head, bu t simply carries out its orders blindly. Therefore the prayer of our Lord Jesus Christ on the Cross would APPEAR to mean: "Father, forgive them (the unthinking masses) for they (the unthinking masses) know NOT what THEY (the Assembly of the Wicked, i.e., synagogue of Satan) do.” (Luke 23:34. Note also M att. 21: 38, John 8:44, and Exodus 34:7, “By no means clearing the GUILTY”) and which, from Protocol 3, para. 1, quoted above, still appears to be the case. “Declaring th e end from the beginning.” (Isa. 46:10) and knowing w hat the Esau-Edomites. now masquerading as Zionist-Jews, would do, we can understand the Lord’s prophecy: “Yet I loved Jacob, and I hated Esau,” (Malachi 1:2, 3) as Jn "ob (Anglo-Saxon-Celtic Race) have been breaking the Nazi-Fascist yokes and feeding and clothing the hungry and naked of the depressed races (Matt. 25:31-40), whilst Esau has been 12 13 �planning for three thousand years to destroy the white (Jacob) race, as stated by Rabbi Rabinovich and in the Protocols of Zion (Note Isa. 58:6-14). Because of Esau’s terrible plans for world con trol with its “DIMINUTION a nd KILLING OUT OP THE GENTILES,” the Lord has already stated His Judgment on Esau, saying: “And there shall not be ANY remaining of the House of Esau, for the Lord ha th spoken it:" (Obadiah 1:18, note also Ezek. 35:14, 15 to Idumeans, Mount Seir was the home of Esau). The Lord has prophesied: “Come, MY People, enter thou into thy chambers (countries) and SHUT THY DOORS ABOUT THEE: hide thyself as it were FOR A LITTLE MOMENT, until the indignation be overpast. For, behold, the Lord cometh cu t of His Place to punish the inhabitants of the ea rth for their iniquity.” (Isa. 26:20, 21). We are told "For a little moment," “Because a short work will the Lord make upon the earth," (Rom. 9:28). Further, in the "Protocols of Zion,” it is stated th a t “THEY” must teach "NO racial discrimina tion," so th a t when they crown their so-called “sovereign lord of all the world,” in Zion, the youth of the Goyim (Gentiles) will have lost their patriotism, and will refuse to fight for their own countries against him. Sir W alter Scott wrote: “Breathes there a man with soul so dead, Who never to himself ha th said: ‘This is mine own, my Native Land’?” I t is this spirit of patriotism in the AngloSaxon-Celtic Race which the Zionist propaganda is endeavouring to kill, so th a t through their controlled U.N.O., they will cause us to .sign over our national sovereignties to th a t organization, and will thus destroy the power of the Anglo-Saxon Race, and then through it, des troy the white race. The Lord purposely put "enmity” between the "seed of the serpent” and the “Seed of the Wo m an,” (Genesis 3:15, For Serpent, see Revelation 12:9. “For their rock (Satan) is not as our Rock.” (Christ) Deut. 32:31, Note I Cor. 10:4.)' "Seed of the Serpent,” “Not as Cain, who was of th a t Wicked One,” I John 3:12, “The Tares are the children of the Wicked One; the enemy th a t sowed them is the devil.” Matt. 13:38, 39, “Ye are of your father the devil, and the lusts of your father ye will do. He was a murderer from the beginning, and abode not in the Truth, be cause there is no tru th in him .” John 8:44, “One of you is a devil,” i.e. Judas Iscariot, (John 6:70), so th a t the "Seed of the Woman,” (“And she (Eve) bare a son, and called his name SETH: (Hebrew for APPOINTED) "For God,” said she, “h a th APPOINTED me another SEED instead of Abel, whom Cain slew,” (Genesis 4:25) would have nothing to do with the “Seed of the Serpent,” (“and w hat concord h a th Christ with Bel-ial?” (Children of Baal, i.e., Satan. I I Cor. 6:15, or the Christian Anglo-Saxon-Celtic Race with the atheistic Communists or with the “Syna gogue of Satan’’?) nor would they allow the "Seed of the Serpent” to infiltrate into their governments to destroy them from within. I t is this “emnity” against th e “Seed of the Serpent” which the "Synagogue of S atan ” are try ing to kill through their propaganda for “NO racial discrimination,” with th e intention, as stated by Rabbi Rabinovich, of destroying the white race through it. Thus we see th at “THEY” still retain their enmity against the white race, whilst removing through propaganda our Di vinely-given protection against such a result. Let us therefore, accept Our Lord’s Command: “Come, MY People, (Jacob) enter thou into thy chambers, (countries) and shut thy doors about thee.” (Isa. 26:20, 21, note, “Come out of her, MY People, th a t ye be not partakers of her sine, and th a t ye receive not of her plagues.” Rev. 18:4), retiring from the Zionist-controlled U.N.O.. until the Lord destroys the "Seed of th e Serpent," as outlined in M atthew 13:40-43. “For Esau is the end of the world (system); and Jacob is the be ginning of it th a t followeth." (II Esdras 6:9 Apocrypha.) Our Lord Jesus Christ promised: “AT THAT DAY (of Christ) ye SHALL ask in My Name: and I say unto you, th a t I WILL pray the F ath er for you.” (John 16:26, note II Chron. 20: 14 15 �15, 20-25, Jerem iah 31:7). Should we not there fore accept this Promise, and pray th a t the Lord will deliver us from the Zionist-Communist peril, as they have so worked themselves into our gov ernments, State Departments, and into every act ivity of our countries th a t we can of ourselves do nothing against the synagogue of Satan. (Note John 15:5). Let us therefore pray Our Father in the Name of His Son, Jesus Christ (note Acts 4: 12) th a t He will deliver us from Satan and his synagogue. We are promised: “Repent, and be baptized EVERY ONE of you in the NAME of JESUS (Greek for Saviour) C hrist for the remission of sins, and ye SHALL receive the Gift of the Holy Spirit" (Acts 2:38). Thus those'w ho accept this Great Free Gift will be safe when “sudden destruc tion cometh upon 'THEM’ ” of I Thossalonians 5:3. “The Good News of the Kingdom, however, shall be proclaimed throughout the whole Empire, as a witness to all nations: and THEN the END will come.” (of Satan’s world system) (Matt. 24:14. Fenton Translation.) 16 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Booklet, Plans of the "Synagogue of Satan", no date. 9 pages. Description An account of the resource Anti-Semitic tract from the British Israel Association of Greater Vancouver. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Eustace Mullins Date A point or period of time associated with an event in the lifecycle of the resource No date Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant unknown Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_25 https://projectdaps.org/files/original/5e0e555f0c3b2fc7674a51eda79ac0c0.pdf 3b06ab21fc84fb8a74f8932722373b89 PDF Text Text N E W S R E L E A S E For Further Information Marianne Karydes, Chairman Committee for Equal Education 536-9448 FOR RELEASE May 18, 1971 ARLINGTON, VIRGINIA, May 18--The Committee for Equal Education has called this meeting to express its feeling that the recent Supreme Court decision has resolved some of the unknowns in the pending suit of the Drew parents against the Arlington School Board. The Supreme Court has indi cated that it is and always has been its purpose and intent that the last vestiges of legally or officially imposed segregation be done awaywithfnschool systems. Drew School certainly is such a vestige. In addition, the Supreme Court realizes that each community is different and no one plan for integration could possibly apply to all. It is our Committee's view that these decisions answer and invalidate much of the basis-for the School Board's defense of this suit. We understand that an offer of settlement is being made - to withdraw the law suit provided the School Board move ahead with a feasible plan by; September 1971. t Consequently, we have sent the following message to the Chairman and the members of the Arlington School Board: * * * * Dear. Dr. Saulmon: As you know, the date for the trial of Hart vs. the Arlington .. Sctvood- -.. ... Board has been set fro July 26. Now that the Supreme Court has handed down its decision, only the date of this trial stands in the way of Arlington's completing the integration of our school system. Even an immediate decision in late July would not allow time for adequate preparation for an integrated session beginning in September 1971. Shoald the trial take a long time, or the decision not be quickly forthcoming, we run the risk of having the court order sudden implementation in the middle of a school session. This circumstance would be highly disruptive to the whole community, and would preclude essential careful planning. We urge that the School Board take the steps necessary to settle this case out of court as soon as possible. We further urge that the Board ar range to hold public hearings on the matter, as it is o»r feeling that the public would rather be involved in the formulation of the plans than have the court impose on Arlington a plan which the citizens had had no part in shaping. Our committee is hereby submitting for the information of the Board �2 the various plans we have been considering. If we can begin now with a Board commitment to integration in September 1971, we will have the entire summer for necessary planning. The teachers are hoping for this time to prepare. Parents are anxious to know what the next year holds. The children will handle it well; as Governor Holton remarked, the children always do. Please put this matter on your agenda at the earliest opportunity. Our committee is ready to help. Sincerely, Marianne Karydes, Chairman Committee for Equal Educa tion PLAN 1 - Drew as a kindergarten center This plan favored by those who wish to retain Drew's successfully integrated kindergarten. The kindergarten program at Drew is excellent, and retaining the two teachers responsible, could be expanded. Careful selection of tea chers, concentration on early childhood development and enrichment programs, parent participation, possible use of Project PLAN if it proves to be of value are all aspects to consider for improvement. PLAN 1-A Kindergarten center and first grade Given the same attention as above, a program for kindergarten and first grade would make better use of Drew's pupil capacity (980). Proximity and capacity of Drew would determine the schools to be involved. PLAN 2 - Boundary Changes (see current school district map) 1. Line between Drew and Randolph (now S. Walter Reed Dr.) move to S. 18th at S. Monroe; follow S. 18th St. to S. Stafford, bear south following path of Stafford to Four Mile Run Dr. ________ Randolph children to Drew district 2. Line between Drew and Abingdon (now near Arl. Mill Dr.) move to Kemper Road. From S. Walter Reed Dr. to Shirley Hwy’____Drew'children to'Abingdon. . 3. Line between Drew and Fairlington (Shirley Hwy) cross Shirley, continue down county line to S. Meade, over to S. 28th St., back up Shirley.____Oakridge children to Drew. 4. Entire Hoffman-Boston School (129) to Oakridge. (Overpass now under construction will make this easily accessible in a year or so. Meanwhile, a bus would take a roundabout but safe route via Columbia Pike, S. Glebe Rd. PLAN 3-A (Pairing) Projected enrollment 1971-72 Drew Oakridge 710 559 Capacity 980 775 �3 Whether exchange of students were determined by lottery, or by splitting of grade levels, so that one school took K-3 and the other took 4-6, it is plain that these two schools are the largest, most modern and have more than adequate capacity. The districts are contiguous. If greater propor tion of white students were desirable, Custis could be included in this plan. Projected enrollment at Custis - 293; capacity - 325. Custis is not the up-to-date facility that Drew and Oakridge are, however. PLAN 3-B (Abingdon-Randolph-Drew) K-2 at Drew - 849 total, ratio of white to black 565/284 260/222 3-4 at Randolph - 482 total, ratio of wh to bl 235/226 5-6 at Abingdon - 461 total, ratio of wh to bl PLAN 4-A Middle School K-3 at: Fairlington 50 from Drew 235 " Fair. 285 capacity :400 wh/bl 235/50 Oakridge 130 from Randolph 120 " Drew 365 " Oakridge 615 capacity: 775 495/120 Abingdon 137 from Drew Rand. 100 ? Abing. 425 " 662 capacity : 725 525/137 Claremont 100 from Randolph 80 " Drew 305 " Claremont 485 Capacity : 500 405/80 4-6 at: Drew 96 from Claremont 255 " Abingdon 140 " Fairlington 245 " Oakridge 198 " Drew 934 capacity: 980 736/198 PLAN 4-B Randolph 100 from Claremont 60 " Drew 200 " Randolph 360 capacity: 425 300/60 K and 4-6 at Draw of Drew, Fairlington, Abingdon and Oakridge On the theory of teachers that the most beneficial age for black children to experience having white children freely come to a black school is the 4-6 grade, when children are developing self-concept, community spirit, pride of identity, etc., this plan is suggested to achieve the dual purpose of retaining the excellent Drew kindergarten, and also bringing the white 4-6 graders into the black school. Capacity is adequate at all schools in this plan. Drew 1-3 grades would go to the other three schools, where the racial balance would be heavily white in all cases, and contiguous districts would not involve long bus distances. PLAN 5 Model School Establish at Drew a voluntary-attendance elementary program emphasizing �4 unstructured and ungraded approach; experimental programs, emphasis on indi vidualized attention low pupil/teacher ratio, enrichment programs, early childhood development, parent participation (which in coop nurseries is both mandatory and highly beneficial). If Project PLAN (computer-assisted instruc tion) proves beneficial it could be utilized. As an attendance-area, the Drew district would be discontinued. Drew chil dren could attend either the model school or be assigned to a nearby white school. A certain number of openings could be reserved fro the black stu dents. There are 839 black children in South Arlington, including Hoffman Boston, fro 1971-72. There will be S7S available spaces in the surrounding white schools as now assigned. If 264 black children remained at Drew, the rest could attend the white school nearest their home. This plan would allow the entire county to participate in integration, and voluntarily, which many parents wish the opportunity to do. Moreover, positive educational benefits would result for all who participated in the model school. * * * The Committee for Equal Education is opposed to any plan which would dis continue the use of the Drew building for elementary eduaation. We further urge the County to provide in-service training this summer for all teachers who will be teaching in integrated classrooms. Federal assistance is available throught Title 4 of E.S.E.A. for this purpose. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Press release from Committee for Equal Education, May 18, 1971. 4 pages. Description An account of the resource Press release expressing the opinion of the Committee for Equal Education that the offer of settlement in the lawsuit should be accepted. Includes open letter to Dr. Saulmon consisting of the 5 plans for integration of the Committee for Equal Education. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Committee for Equal Education Date A point or period of time associated with an event in the lifecycle of the resource 1971-05-18 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1970s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_21 https://projectdaps.org/files/original/eda6b94babc7c02e8b060beba85f7f7f.pdf e9d45439427b927ff1f59f3ed793ce82 PDF Text Text i JKa y y 0 Arlington Parents Sue ver All-Negro School irents and guardians of 1 G In their suit, the parents claim ents at Arlington’ Drew El- that Drew illustrates that s entary School have filed a cial discrimination in the (Ar­ By CHRISTOPHER DODD [At present there is onJy one white “ leral civil rights suit seeking lington) school system yet pre­ SUN Stall Writer student at Drew. ; desegregation of the coun- vails. ARLINGTON — The results of Polls results were released on 5largest all-Negro school, They blam e Chisholm and the a poll taken in Green Valley that thesam e day the Virginia House school board for having "failed was presented to county author- ot Delegates was giving final ap­ n their five-page suit filed , ities yesterday indicates most proval to an anti-busing bill intro­ iterday in U.S. District Court and refused to . . . adopt and Alexandria, the parents execute a plan that promises - Drew Elemental^ School parents duced by Del. Geo. P. Shafran, want the school to be integrated. R-Arlington. That bill, which now arged the county school board realistically and promptly and The survey, conducted during goes to the Senate for considera­ d School Supt. Robert I. completely to convert said pub­ tion, would prohibit appointed January and February shows that h i s h o 1m with maintaining lic school system to a unitary January and Februaiy, shows that school boards from busing stu­ non-racial system." . attending the almost totally black dents to achieve or avoid racial rew as “ . . a school specially The parents ask the court to t apart for Negro children.’ Drew School, 1S1 of them would balance in school attendance. restrain the school authorities like to see the school integrated. In a related question to busing, Arlington Negro leaders for from “ failing to adopt and im­ The poll also revealed that Drew Drew parents said in the survey Veral years have fought unsuc- plement a plan which will parents are in favor of busing that they do not "favor keeping isfully for the desegregation promptly and efficiently com­ school children. Of those inter­ Drew strictly a neighborhood he 793-pupil school, located at plete the elimination of racial 4 viewed, 127 stated they would sup­ school,”Some 1 3 families stated 3 S. 24th St. in the predomi- s e g r e g a t i o n in the public port busing white children to Drew that just because Drew School is /tly Negro Green Valley sec- schools.” No date has been set and black pupils from Green Val- located in the heart of Green Val­ <n of the county. for a hearing on the case. ley, a black community, it should ey to predominantly white schools not have to drar.v its pupils solely : 'Neighborhood' School Study Results Due from that neighborhood. School officials, who acknowlThe school board last year di­ John Robinson, field director of s the Arlington Community Action ige Drew’ all-Negro emoll­ rected school administrators to ient, have said that it results prepare a study of possible Program (ACAP) pointed out re­ • a countywide policy of a methods of desegregating Drew om sults of the poll taken in Green jiGhborhood school system in and the advisibility of taking Valley were somewhat different hich students attend schools such action. The staff report is from those of similar polls taken expected early this summer. their homes. in other parts of the country. ■ i.- iT rti.- u i.iig io ivoDinson. many, According to Robinson, many iThe parents, who contend that . Drew, which is currently all Negro, has occasionally hfid one black cm S ro n ilta r a i d “ 5 r“ neighborhood schools to r a t o i ? ™ hri A r,6htS' or two white kindergarten pu­ seere-rated. wve brouSht tb<?ir case to court pils. The Drew parents are repre­ ’ nake the judicial'decision on sented by attorneys S. W. Tuck­ of the survey indicate an aware-: Drew applicable to other schools er, of Richmond, and Robert M. of the "Drew parents ot the the county. Alexander, of Arlington. problems that exist in integrated junior and senior high schools - both socially and educationally - and for this reason they say n want Drew Elementary School in­ tegrated. a lopsided margin of 131 to • 5 the parents of Drew School 3, •children expressed approval of * * re-drawing the entire elementary ' school district in order to bring r about school integration. Dr. Robert L. Chisholm, coun­ ty school superintendent said that ■"die whole matter of school inte­ gration is under study," and one of the plans under consideration |is re-drawing of the grade school districts. The survey was sponsored by the Black Youth for Progress, The Arlington Parents for Better Welfare, and students from Ho­ ward University with some as) sistance from ACAP. A spokesman at ACAP said rci suits of the poll would be examin- cd by a county school study group •and recommendations would be • made to the school board. "Those who are not outright 1* opposed to busing generally 1 say it’ all righ t to bus others s s in, bu t not to bus their chil- I dren out," Caruthers said. H e said a court order to dc- 1 < segregate the school within the next year — particularly if c busing w ere involved cou ld i : cause "serious financial p rob­ lems." 1 Arliogt:on Parents File'Suit Desegregation Of Drew, Other Schools Asked By Nancy Scannell Waihinsion Post Staff Writer A group of A rlington County parents file d suit yesterday in A le xandria fed­ eral court to desegregate Drew Elementary School, . which has one white student among its 793 pupils. T h e suit w ould direct the sch ool board and superintend­ ent to "realistically and prom ptly" convert the A rling­ ton school system to a "uni­ tary nonracial system." No other Arlington p ublic school has so lop-sided a ratio of blacks to whites. Drafted by Arlington, Rich­ m ond and N ew York lawyers, the suit charges that "racial discrim ination . . . yet pre­ vails" in the county that started desegregating its other schools in 1959. A rlington and N orfolk were the first V irginia localities to begin sch ool desegregation ns ordered by the U.S. Suprem e C ou rt in 1954. Th e class action suit, filed by 10 parents on behalf o f 16 children attending Drew, asks that the school board be or­ dered to im plem ent im m edi­ ately a d esegregation plan. Th e suit cam e five months after the school board, under m ounting criticism and p res­ sure to desegregate, o rdered a staff study to explore the advi1 sibility and feasibility o f inte1 grating Drew. Som e plaintiffs in the suit said two weeks ago that they •did not fee l the board was N m oving ahead on the study with reasonable promptness. Sam uel W. Tucker, a Rich­ mond attorney representing jt . the parents, said the school board is expected to. file an answer within a month. A h earing date w ould then be set in federal court, he said, j For several years, commuI nity groups and residents of I the predom inantly black 1 G reen Valley area that sur­ rounds Drew have been pres­ suring the board to'd ese gre ­ gate the school. In March, a door-to-door poll of the G reen Valley area resi­ dents showed them to be over­ whelm ingly in favor ot d eseg­ regating the school at 3500 S. 24th St. The poll o f 181 fami­ lies further showed that they were alm ost 2 to 1 in favor of busing if necessary to achieve desegregation. Inform ed o f the suityesterday, Preston C. Caruthers. school board chairman, said the board "is attem pting to be responsive to the wishes o f the community," and is awaiting the results o f the staff study. Caruthers said h e now ex­ p ects the staff study to be com pleted in the summer. The county is under a 1963 c ourt order to achieve racial balance in the school system. In a March m eeting, the school board set attendance boundaries for next year that reflected no substantial changes from the current year. However, the school adm in­ istration has not released the , results o f a poll o f Falrllngton Elem entary S ch ool parents to determ ine their attitudes on busing children from nearby Drew and vice versa. Caruthers said various board m em bers have reported m ixed reactions on the busing question from parents in the G reen Volley area and the seven con tigu ous school dis­ trict areas surrounding Drew. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Three newspaper articles concerning Drew School integration. Description An account of the resource "Drew School Poll Favors Integration", Northern Virginia Sun, May 4, 1970; "Arlington Parents Sue Over All-Negro School", Washington Star, May 7, 1970; "Arlington Parents File Suit", May 7, 1970. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Northern Virginia Sun, Washington Star, Washington Post Date A point or period of time associated with an event in the lifecycle of the resource 1970-05-07 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1970s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_20 https://projectdaps.org/files/original/56f4cc3700804d550cce19f7b67677da.pdf f8e909cd3071ae55218a26d320c47dbc PDF Text Text C (jc f o a s l j u t jj f o n f J o s C I j - j r p - y J , ...E Obituaries T g M A Y SATURDAY, iw lfis s fe s i W§5 23 ii§ USf-.| r 9 2 3 a|s ifjg Photos by Ken Foil—The Washington Post J. E lm e r T u r n e r , p r in c ip a l o f D re w E le m e n ta ry S c hoo l, sta n ds b e fo re th e r e c e n tly b u ilt sectio n. School Integration Asked B y H e rb e r t H. D e n to n Washington Post Staff W riter lin g t o n h a d f o u r a ll- b la c k scho ols th e S u p re m e • o u r t f ir s t outC s c h o o l s e g re g a tio n in 1954. T h e les R. D re w E le m e n ta ry S c h o o l, in county’s la r g e s t N e g ro ne ig h b o r, was one o f them , w, 16 ye ars la t e r , D re w is s t i l l a ll b u t it m ay n o t stay th a t way lo n g e r. n y r e s id e n ts in G re e n V a lle y , th e D m in a n tly b la c k e n c la v e th a t serves, f e e l t h a t t h e ir segregated sta n ds u p , b r ic k b y b r ic k , w it h is t in th e county, c h ie f ly fro m th e b e lie f t h a t th e n u in g r a c ia l is o la t io n is to u g h on k id s , p a re n ts a nd c iv ic le a d e rs b e g u n to press f o r d eseg re ga tio n school. •nths of lo b b y in g b e fo re the ly s cho o l b o a rd have b ro u g h t o n ly n d response: e s ta b lis h m e n t o f a n itte e to “ s tu d y ” d eseg re ga tio n, r a l C o u rt Case s a tis fie d , p a re n ts ha v e ta ken case to fe d e ra l c o u rt to fo rce th e Ly to in te g ra te th e scho ol, e n s tu d en ts, a fte r s ix years at lea v e G re e n V a lle y fo r th e inte-. d j u n io r , a n d s e n io r h ig h scho ols •lingtoh, th e a d ju s tm e n t is o ften m ch fo r the m , p a re n ts say. th e tim e th e y a d ju s t, th e y ’x-e ei- ' k ic k e d b u t o f sch o o l o r gradusays Jo hn R o b in s o n , a n a tiv e of V a lle y a nd d ir e c to r of t h e Ar>n C o m m u n ity A c tio n P ro g ra m , t f a ll r a c ia l tu rb u le n c e at A r lin g W a k e fie ld H ig h S c h o o l aroused th e c o nc e rn o f G re e n V a lle y , a n d the re s t of A r lin g t o n . A N e g ro s tu d e n t fro m G re e n V a lle y was c r it ic a lly stabbed in a f ig h t w it h a w h ite s tu d e n t a t th e h ig h school. F is t f ig h t s b etw een b la c k a nd w h ite stu ­ d e n ts fo llo w e d . T h e w h ite s tu d e n t ac­ cused of th e s ta b b in g c o m m itte d s u i­ cid e. C a ll f o r D is c ip lin e Som e p a re n ts in th e c o u n ty d e ­ m a n de d s t if f e r d is c ip lin e in the schools. I n G re e n V a lle y , m a n y began to f e e l th a t th e p ro b le m s th a t h a d s u r­ faced a t th e h ig h scho o l c o u ld be best a p p ro a ch e d b y g e t t in g a n e a r lie r s ta rt in in te g ra tio n . _. G re e n V a lle y is one o f s e v e ra l’ s m a ll b la c k c o m m u n itie s in th e W a s h in g to n s u b u rb s t h a t a re , ex c e p tio n s to th e , com m on p a tte rn o f a b la c k in n e r- c ity s u rro u n d e d b y w h ite s u burbs. •' . T h o u g h th e re are th e c e n tr a l c ity p ro b le m s o f su b s ta n da rd h o u s in g , ille -? | g itim a c y a nd n a rc o tic s, th e r e is a q u a l­ it y a b o u t th e p la c e th a t, is r u r a l and suggestive^ of a bygone era. M ost o f th e houses a re o n h ills a nd some streets d o ' no t ha v e sid ew a lks. T h e re a re s m a ll stores; b u t n o t superm arkets; . a few g arden-type apart- J m ents, b u t m o stly s in g le f a m ily homes; In one s m a ll cafe in th e h e a rt o f G re e n V a lle y , it is p o s s ib le to g et a s u p p e r of c h it t e r lin g s and e o lla rd greens. A cross th e stre e t at a d ru g sto re , one ca n have desse rt o f sweet pota to p ie a nd a t a ll g lass o f m ilk ; &' ' i See D R E W , B8, C ol. 5 30, 1 9 70 ____ � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Partial newspaper article, School Integration Asked, Washington Post, May 30, 1970. Description An account of the resource Article on Arlington integration specifically Drew School. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Washington Post Date A point or period of time associated with an event in the lifecycle of the resource 1970-05-30 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1970s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_19 https://projectdaps.org/files/original/720037905bebb408f35535bbe3c4426a.pdf a6deb0cf7488ea3fdf25163c9615b3c1 PDF Text Text Thursday Maryann 25 June (sp?)— S e v e r a l i d e a s h a v e o c c u r r e d to me as I've p o n d e r e d over "being h e l p f u l i n the D r e w d e s e g r e g a t i o n . 1 t h i n k t h e re's a n e e d f or f a v o r a b l e p u b l i c s u p p o r t v i a n e w s m e d i a a n d w h a t e v e r e l s e — so that the ( m a n i n the street' gets the i d e a that t h e r e are groups and i n d i v i d u a l s in the co m m u n i t y that are in f avor of this step. I w o n d e r e d w h e t h e r some k i n d of p u b l i c m e e t i n g , s ay a t D r e w itself, to d i s c u s s the g e n e r a l i d e a of W h y W e S h o u l d D e s e g r e g a t e Drew, w o u l d b e useful. For example, if the o r g a n i z a t i o n s w h i c h ap p r o v e of t h i s — L e a g u e , A A U W (I a s s u m e ) , C o u n c i l o n H u m a n R e l a t i o n s , etc etc w o u l d l e n d t heir n a m e s to s p o n s o r i n g s u c h a m e e ting, plus any p r o m i n e n t i n d i v i d u a l s (or e v e n n o t so p r o m i n e n t — so as to get a g o o d l o n g l i s t of r e s p e c t a b l e p e r s o n s a n d o r g a n i z a t i o n s ) , it w o u l d s h o w t h e r i r is c o n c r e t e s u p p o r t for this. B u t I b e l i e v e it is very i m p o r t a n t that the b l a c k c o m m u n i t y (or the D r e w p a r t of the c o m ­ munity) i n v i t e these g r o u p s to w o r k o n s u c h a puTblic meeting. All these o r g a n i z a t i o n s then w o u l d h o p e f u l l y s e n d t heir m e m b e r s to s u c h a m e e t i n g , that w o u l d b e c o v e r e d b y the press, to s h o w the g e n e r a l p u b l i c that there is a g o o d r s i z e d g r o u p of l a w - a b i d i n g cit i z e n s in f a v o r of this. A l l this to d e v e l o p the 'public i m a g e 1 of t his d a s e g r a t i o n i n a c o n s t r u c t i v e , f a v o r a b l e light. F o r the s p e c i f i c t a s k of p r e p a r i n g the s u r r o u n d i n g c o m m u n i t i e s for this e v e n t u a l i t y , I w o n d e r if some s o r t o f a 'task force' or team of p e r s o n s m i g h t b e o r g a n i z e d to s p e a k w i t h the b oards (I w o u l d see t his s t e p b e i n g t a k e n i n a d i s c r e e t m a n n e r a n d w i t h j u s t the b o a r d s of P T A ' s as a f i r s t s t e p — b e c a u s e of the n e e d f o r s mall enco u n t e r s w i t h l e a d e r s h i p p e r s o n s ) o f the F T A ' s w h o s e s c h o o l s are in the D r e w area. P e r h a p s 4 or 5 c a r e f u l l y c h o s e n p e r s o n s could serve on s u c h a t e a m - - a n e d u c a t i o n e x p e r t ( like a Mr. A d l e r of Lee school) w ho k n o w s m a n y a n s w e r s to the q u e s t i o n s o f 'will the quality of the school b e l o w e r e d ' , 'will my c h i l d b e s l o w e d d o w n b y these D r e w children" etc. o ne or two g e n e r a l c o m m u n i t y p e r s o n s w h o h a v e some k n o w l e d g e of the w h o l e a r e a of- s c h o o l d e s e g r e g a t i o n s either s p e c i f i c a l l y A r l i n g t o n or the N a t i o n as a w h o l e ( L e ague p e r s o n s or othe r s ), a k n o w l e d g e a b l e p e r s o n f r o m the D r e w c o m m u n i t y , s o m e o n e w h o can answer the q uestions a b o u t w a y s that b u s i n g can b e w o r k e d o u t w i t h o u t too m u c h d i s c o m b o b u l a t i o n (how to s p e l l that?? ?) (does H E W h a v e s u c h a n a u t h o r i t y I w o nder?) $-a p e r s o n f r o m thfes a r e a w h o s e o w n c h i l d r e n w o u l d b e "aff ected" b u t w h o sees the i m p o r t a n c e of goinp- a h e a d w i t h d e s e g r e g a t i o n quickly, ( w h i t e , o f course) M a y b e f r o m a n info r m a l , n o n - p u b l i c i z e d m e e t i n g of this kind, A P T A b o a r d m i g h t Jshen g e t a f e e l i n g of r e s p o n s i b i l i t y for h e l p i n g p r e p a r e their l o c a l p a r e n t s (and t e a c h e r s a n d p u p i l s eventually) for this i m p o r t a n t s t e p — I w o I d like to t h i n k they m i g h t t h i n k in terms of r e a c h i n g their p a r e n t s w i t h some sort of a n i n f o r m a t i v e meeting. Hoepfully s o m e t h i n g c o n s t r u c t i v e w o u l d g r o w o u t of this k i n d of m e e t i n g . So m u c h of the 'anti' f e e l i n g c omes f r o m t h e " g r e a t u n k n o w n " p a r t of the d e s e g r e g a t i o n p lanning. I a l s o t h i n k t h a t p eople m u s t at f i r s t h a v e their m i n d s "'inspired" for l a c k of a b e t t e r w o r d c o n c e r n i n g the n e e d for a h a r m o n i o u s s o c i i e t y — the n e e d f o r us all to b r i n g t o gether o ur 'polarizing' s o c iety of b l a c k s and w h i tes. I n o t h e r words, the b e s t in p e o p l e s n a t u r e s m u s t b e s p o k e n to f i r s t so that they will c o n ­ sider this c o n t r a v e r s i a l issue w i t h a k i n d of o p e n e s s b e f o r e t h e y get d o w n to the n i t t y g r i t t y details. Well--for what it's worth. I f a n y t h i n g d e v e l o p s , my m ail c a n be forw a r d e d , cf August. B o n n e s v a c a n c s s to you.' 1 � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Letter to Marianne from Joanne Booth, June 25, ?. Description An account of the resource Suggestions on how to garner favorable public support for the desegregation of Drew School. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Joanne Booth Date A point or period of time associated with an event in the lifecycle of the resource No date Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant unknown Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_12 https://projectdaps.org/files/original/23f4bdb8720f7a8350a1aed157cc532f.pdf 305a110c26cbdd5015caf972bcca508b PDF Text Text To: M. K a r y d e s F rom: J . B o o t h Re: 19 M a y various plans for d e s e g r e t a t i n g D r e w A l o n g w i t h h a v i n g i n s e r v i c e t r a i n i n g p r o g r a m s for t e a c h e r s ( w h i c h s h o u l d b e f o r e c e f u l l y p r o m o t e d so that the h i g h e s t p e r c e n t a g e p o s s i b l e of t e a c h e r s a t t e n d ) , there s h o u l d b e i n - d e p t h w o r k w i t h P T A c o u n c l l a ^ a b o u t t h e i r role i n m a k i n g t h e s e c hanges h a r m o n i o u s a n d succ e s s f u l . Mr. G r a v i t s has e x p e r i e n c e in this work, as d o e s Mr. A d l e r , w h o s t r o n g l y u r g e d that P T A ' s c o n s c i o u s l y w p r k to see t h a t b l a c k p a r e n t s share i n w o r k a n d d e c i s i o n - m a k i n g i n their s c h o o l s (via P T A a n d w h a t e v e r als6 is p o s s i b l e). A l s o , this is a ' g o l d e n m o m ent' to c a p t u r e for the f u r t h e r i n g of the g r o w t h of b e t t e r 'human r e l a t i o n s ' , a n d if ever p e o p l e see a n o p p o r t u n i t y to be h e l p f u l , this is it. * ( s e r i o u s e d u c a t i o n i n the i m p o r t a n c e of e qual e d u c . , the b a c k g r o u n d o f ' b l a c k rage), b l a c k p o wer, hist, of A f r o - A m e r i c a n s , n a t u r e of p r e j u d i c e , s e l f - e x a m i n a t i o n , g r o u p t h e r a p y / s e n s t i i v i t y or w h a t e v e r — ti m a k e p e o p l e think, a n d f a c e t h eir o w n h a n g - u p s a n d r e s p o n s i b i l i t i e s ) Re p l a n 3 — d o n ' t b e l i e v e there is too m u c h c hanee of p e o p l e f l e e i n g 'cause of t i g h t h o u s i n g , e x p e n s i v e h o u s i n g p r oblems. 8 u t the 'balance' f a c t o r m u s t b e c o n s i d e r e d i n l £ght of w h a t w i l l p r o d u c e the o p t i m u m c o n d i t i o n s for b e s t educ. o p p o r t u n i t i e s for all. I n S y r a c u s e Integra.tion a n d b u s i n g e x p e r i e n c e , they h a d p a r e n t s take d r y r u n s w i t h k i d s , a n d a l s o h a d one p a r e n t on bus for quite some time to see that t r a n s i t i o n w e n t smoothly. � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Memorandum to M. Karydes from J. Booth, Various Plans for Desegregating Drew, May 19, ?. Description An account of the resource Comments on the four plans for desegregation of the Committee for Equal Education. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Joanne Booth Date A point or period of time associated with an event in the lifecycle of the resource No date Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant unknown Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_11 https://projectdaps.org/files/original/9de4f0714b1dec3e62e7412f5c46b616.pdf 86be2bc24fa5947a6fa517d125b3c42d PDF Text Text April 2$, 1969 2101 South Fillmore St Arlington, Va. 22204 Mrs. Ruth Co*, Chairman Arlington County School Board 4751 north 25th Street Arlington, Virginia 22207 Dear Mi» C&x: , The prupose of this letter 1* to advise you that the iBsssb-rs of the Dr«». Parent-Teachers Association, feel that steps should he taken forthwith t® remove the racial identiflability of the 9r«., Elementary School. As you are aware, this school, for 1968-69, has a student enrollment of 896 pupils, of which all ore Hegro except 18 white kindergarten pupils. The faculty is composed o f 35 full-time teachers, of which ail are B«gro except seven. fhus, it is clear that on the basis of enrollment and faculty, this is a ‘Kagro" school. ’ As you too., w h « * school* h«v«. bu«o established for pupils of a particular race and continue to bo attended solely by pupils of that lacs, sexual boards have an affirmative duty, unbar th« Fourteenth Amendment, to take steps to remove thm racial Sdentiflability of such schools• School boards may not rscapa this affirmative duty to dese­ gregate by merely establishing geographical attendance rones. Recently, th« Federal courts have- stated that "geographic cones,” lilt* any ofchar attendance plan adopted by a school board, is se­ ct-ptable only if it disestablishes rath** than reinforces the dual system if segregation. It appears to us that reasonable means exist by »hich the 0**-« School could bs dasagre-getad. For example, the %oa« lines might be redrawn or Dr*., might be paired or grouped with formerly .hits schoolc located nearby -.hick surv* the same grades. f w stand ready to cooperate with you in making this a reality e and impreaa upon you the need for providing equal educational opportunities for pupils of all races. Very truly yours, Thomsa r . Konrott, President, Drew P.T.A. TRK/bj � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Letter to Ruth Cox, Chairman, Arlington County School Board from Thomas R. Monroe, President, Drew PTA, April 25, 1969. Description An account of the resource Letter requesting the immediate desegregation of Drew School to remove its racial identity. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Drew PTA, Thomas R. Monroe Date A point or period of time associated with an event in the lifecycle of the resource 1969-04-25 Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1960s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_10 https://projectdaps.org/files/original/031f9862a66d212213d73c190bb4986d.pdf 633ebaefa273cec89695006965f976e0 PDF Text Text � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Plan 4, To Achieve Racial Balance, no date. Description An account of the resource Plan 4, To Achieve Racial Balance, K-3 at Fairlington, Oakridge, Abingdon and Claremont. 4-6 at Drew and Randolph, handwritten. Includes pros and cons. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Committee for Equal Education Date A point or period of time associated with an event in the lifecycle of the resource No date Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1970s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_9 https://projectdaps.org/files/original/d7b8848b9e37a03830436c978e8d8610.pdf 675246dfcf130492295319896ff31a40 PDF Text Text � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Plan 3, Pairing, no date. Description An account of the resource Plan 3, Pairing of Abingdon, Randolph and Drew to achieve integration, handwritten. Includes pros and cons. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Committee for Equal Education Date A point or period of time associated with an event in the lifecycle of the resource No date Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1970s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_8 https://projectdaps.org/files/original/b2527fd93639517e369205f83789f04b.pdf 2fc1c1a85be8981238157fbe51a7fbec PDF Text Text � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Plan 2, Boundary Changes, no date. Description An account of the resource Plan 2, Boundary Changes to achieve integration, handwritten. Includes pros and cons. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Committee for Equal Education Date A point or period of time associated with an event in the lifecycle of the resource No date Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1970s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_7 https://projectdaps.org/files/original/d72a3cdb9b3629c83ce9d2e48f557db9.pdf b3f30ad91d1ea963588ded595b805788 PDF Text Text � Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource RG 18: Personal Papers of Barbara Marx Dublin Core The Dublin Core metadata element set is common to all Omeka records, including items, files, and collections. For more information see, http://dublincore.org/documents/dces/. Title A name given to the resource Plan 1, Drew as Kindergarten Center, no date. Description An account of the resource Plan 1, Drew as Kindergarten Center, handwritten. Includes pros and cons. Format The file format, physical medium, or dimensions of the resource PDF Source A related resource from which the described resource is derived RG 18 Creator An entity primarily responsible for making the resource Committee for Equal Education Date A point or period of time associated with an event in the lifecycle of the resource No date Coverage The spatial or temporal topic of the resource, the spatial applicability of the resource, or the jurisdiction under which the resource is relevant 1970s Rights Information about rights held in and over the resource This image is subject to copyright. Unauthorized use of the images in the Local History Collections of the Arlington Community Archives is prohibited. Identifier An unambiguous reference to the resource within a given context 18_2_1_16_6