# Amicus Curiae Brief — Alexander v. Holmes County Board of Education > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385001_1336%3A6 ## Record - **Collection:** Supreme Court brief - **Document type:** Amicus Curiae Brief - **Published:** January 1, 1969 - **Citation:** 396 U.S. 976 ## Text "MOTION FILFD | | OCT 17 1969 LES ro4n ® Meee: ik ; | Supreme Court of the United States O-roper Teem. 1960 No. 6B BeATMICE ALPNANDEI, fr At. Petitioners: . | . . \ HoumMes Country Bown on pes VHION, BY AL, * 7 Li Nsaergiale jit. On Writ of Ceriiorari to the United States Court of Appeals: ee _ for the Fitth Circuit . MOTION FOR LEAVF TO FILF BRIEF AMICUS CURIAE AND-FOR IMMEDIATE CONSIDERATION THEREOF pe AND BRIEF AMICUS CURIAF “OR THE NATIONAL EDUCATION AS. >7IATION Rie tei DR Nomen. Peet dette a Plate’. NV Wstsditnieton, a ~IMK it Pave Pain | " Ol loth Stfheet, VOW Washington, DL. rm . Adflorice ys fan Lmicus . : Curiae.’ Nettopne hkduaca air ( diine | ficty Lascentlion Mic uate Vo Sey orn Ison, detlerson LP hens ee Pas || Woashitwton, bh ¢ OE TABLE OF- CONTENTS pies es: Page Moros ror Leave To Eine Brier Amicus CURIE AND row IM MEDIATE CONSIDERATION “TaekKor ae BeCn CUMIAR .. 3S... ace ee Sewage as Ae Pees l I. Interest of the National Education Association 1 MH. Summary ofthe Arguments..0.000.00...0.... 2 HEL. Argument 0000 5 as EO St 3 A. Segregated Education Results ir Knormous and Irreparable’ Injury to Black Children B. The Considerations Relied Upon by the Gov ernment and the Court Below Do Not Justit'y Delay in Deseeration eter eae iF 4 * IV. Conclusion are | ie 12 TABLE OF AU TILORUPLES (‘ASES:. : , > | Brown ov. Board of ‘Mdueation, S47, US. 488. 494 — (1954) . | ie | ae United States vo Hinds County School Board, r. 2d- » Doeket Nos. 28080 and 28042" August’ 28) 1969, * oshp opinion at .o° ee oo ay | United States vo Jefferson County Board of Kdueation |’ S80 2d SSO (oth Cir.) (en bane), cert. denied 389 -U.8..840 (1967) ©. 2... ....:. F STATUTES! ’. «- - Tithe 42 U.S.C. Seetion 200061 0... a f Mlementary and Secondary Education Net of les ¢ it 4 | " Contents Continued s (Pe tinn AL PHOMETIRG | National -Bdueation Association, (‘omtiission On Pre fessional | Rights, and Responsibilitios, Wado. (County. Alabama: A Ntudy of Noowdl. & rer tte un! Bdwcational Bankruptey *. * » of £ fl — Lniteal States Conumission on ¢ Wel Wiwhis, Rue tsolation om the Public Schools —- ; 4 Lramscriupt of Hearing ww Mismt gone iy. tlhadcarie United Stat » Dopaartunenet of thealth, Budueas ch, otted \\ olfare : (ithe af Mialucution, Byucdlety ae! | ¢ 6 - portunity wes I, ‘oe vs) Report mai C'swal Ry pares IN THE Supreme Court of the United States OcTOBER TERM, 1969 * Brarnick ALEXANDER, ET AL., Petitioners, L Hommes Counry Boarp or Epucarion, ET AL, | Respondents. On Writ of Certiorari to the United States Court of meen for the Fifth Circuit — MOTION F OR LEAVE TO FILE BRIEF AMICUS CURIAE AND FOR IMMEDIATE CONSIDERATION THEREOF ‘Lhe National Edue; ation Association hereby moves, pursuant to Rule 4203) of the Rules of this Court, for Joave to file the attached brief amieus euriae in » ~ the above-entitled cause. Petitioners and respondent United States of America have consented to the filing’ Consent has been denied by the respondent schooi hoards. Beeause of. the expedited schedule that has been established by the Court in this case, movant requests immediate consideration of this motion, with- out awaiting the receipt of written opposition by the - respondent school boards, so that*the attached: brief may be considered along with the other br iefs that will he filed before argument. | The Nations! Education Association ('the Associa- tion’’) is an independent, voluntary organization, of educators open to all professional teachers, supervisors and administrators. It presently has over one anillion regular members, and is the largest professional organi- zation wr the world. The Association was first or- ganized in 1857%nd was chartered by a special act of Coes in 1906.. Its statutory purpose is Pe clevate the character and advatice the in- terests of the profession ofteaching and to promote the cause of education in the United States. Overall, poligies of the Association are determined hy its: Representative Assembly, a body composed of approximately 7,000 delegates representing affiliated local and state education associations... The Associa- tion has long been committed to the .principle that racial segregation in education adversely affects the quality of the education received by both black and white students. It has eonducted detailed studies of the edueational implications of the maintenance of 'The written consent of these parties has been filed with! the Clerk.’ . *. ~~ dual segregated school systems. At its June, 1969 Convention, the Representative Assembly adopted a formal resolution urging adherence by the Federal gov- ernment to the established timetable for complete de- ’ segregation of Southern scliool districts. The resolu- tion instructed the officers and staff of the Association “to exert every effort*to reestablish the Deemer, 1969 deadline for full compliance.” It has lone heen settled that the complete disestab- lishment of formerly de jure segregated school sys- “tems is required under coustitutional mandates. The issue before the Court in this case does not so much concern legal requirements, but rather educational rea- sons purportedly justifying a further delay in the im- plementation of those requirements. - While movant fully supports the position of the petitioners that there are no acceptable reasons justifying further delay in school desegregation, it, as the principal association of educators in this country, is particularly well equipped to inform the Court as to the substance, or lack thereof, of the non-legal justific ations for delay on which the court below, the Government and the respondent school boards have ‘relied ¢ Accordingly: the National Kdueation Association re- spectfully requests that this Court grant leave to file the attached brief amicus curiae, without waiting for the receipt of papers in opposition, and that the Court Cd “The National Education Association and its state associations — have participated as amicus curiae in other major proceedings involving issues of education and race ASee Smuck vy. Hobson, 408 KP 175 (D.C. Cir. 1969): Lee vy. Yeon County Board of Educa- tion, 283 F.Supp. B94 (M.D. Alaf 1968). | ~ + consider said brief together with the briefs of the parties, and with the other papers in the case. ~_Rspectfully submitted, | Ricuarp ‘B. Sozor. : 1823 Jefferson Plage, N. W.: Washington, D. C.- 20036 _ Davip Rusin | | 1201 16th Street, N. W. Washington, D. C. 20036 Attorneys for Amicus Curiae, National Educa- tion Association Of Counsel: Ricuarp T. SEyMour 1823 Jefferson Place; N. W. _ Washington, D. C. 20086 ° * October 17, 1969 IN THE : Supreme Court of the United States OcTOBER ‘TERM, 1969 —_ No. 632 ___— SEATRICE ALEXANDER, ET AL., Petitioners, v. HloLMES County Boarp or Epucation, Er AL., ia Respondents. On Writ of Certiorari to the United States Court of Appeals for the Fifth Circuit BRIEF AMICUS CURIAE FOR THE NATIONAL EDUCATION ASSOCIATION 7 INTEREST OF THE NATIONAL EDUCATION ASSOCIATION © The National Education Association is an-independ- ent, voluntary organization of professional educators. It has over one million members, including teachers, supervisors, and administrators. As‘stated in the As- » ae _ soclation-Charter, its purpose is ‘to elevate the charae- ter and advance the interests of the profession of teach- ing and to promote the cause of education in the United States."’ Both the Association and its members have a deep interest in the quality of education received hy the children of all races. For this reason, it has conducted investigations of the problems of race and education in the school systems of Wileox County, Alabama, Balti- more, Maryland, Hyde County, North Carolina, and Detroit, Michigan. For this reason also, it has actively supported litigation in.numereus schoo! desegregation ‘ ‘ases, Me SUMMARY OF THE ARGUMENT Segregated education imposes enormous and -irrep- arable injury on black children, Hirst, there is the psyv- chological damage to the black-student, recognized liv this Court in 1954, flowing from. official maintenance of separate black schools. Seeond, it is established that black children, particularly in the South, are substan tially less able to learn-in an environment of racial isolation than in an integrated educational septing, Third, some school districts across the South still pro- vide facilities for black students that are marked inferior to those provided for whites, thus further reducing the quality of the ede ay afforded black children. The disastrous consequences of racial segregation in education have been established and accepted for many years, but the judicial attitude toward the question of speed of desegregation has often failed to cousider that these consequences are acertiing daily angl cannot. be reversed. A vear’s delay means that tens of thousands of bhick school children Will endure another irremootount wl a segment of their edacation in racial isolation: nan of these children will complete -their, education during ; that period. It is time that the question of delay be put nh these human terms. The National Education Asso- elation believes that ucither administrative Ineouven- lenee, hora general warning of ‘tchaos, contusion, wd a catastrophic educational setback’? justified the delay granted in these eases, The administrative ineon venience in the immediate implenientation of desegre gation plans-is, in the opinion of the Association, resid: iy surmountable, Considerations of the qaality. of . edueation call for speed, het tor delay. se ee) 2 ARGUMENT A. Dearianied Education Results in Enormous and Irreparable Injury to Black Children In 154, this Court recognized that the fact of offi ehully-sponsored segregation, without more, enuses seri- ous pisychologieal damage te children in elementary and secondary schools: ; . ‘To separate them from others of similar age and quialitiesttions solely beeause of ther reaee wenerates a teeling.of inferiority as to their status in the -commmiunity thet may atfect their hearts and minds Ina way unlikely ever to be undone, > ; : The isolation of black students from: other children with varving backgrounds and aspirations is injurious In another respect. ‘Phe ‘United States Office of Edu eation, in an official report based on a nationwide Sir. vey, found that ‘the aehievement of minority: group Diracaum f Inereases” Mh proportion te the level of tthe I} y: mwe\ “fh ’ ; pf ; af + re ~ ty *? Leg Pee | e t a ‘quality’ between black-attended and wi , 200 TNE), Comeress directed that’this studs de made - \p educational aspirations and backgrounds of fellow stu- dents Sy oe . - , It is those Negroes who are in the South ‘whose achievetuent appears to vary midst greathy: with variations in the characteristics of their fellow students. Here, where the most oduct “aitionally ais _ indvantaged barkgrounds are found, and where achievement is lowest, is Where student body char weteristies ‘make most’ differences’ for Ne “rie Achievement. [is in these more/stabile, less urban areas Where exposure to children of different edu cational backgrounds has in the past been least possible for Negro children. : ly hene tinnlingrs are corroborated by ithe United St: ‘tLt's Conmuission on Civil Rights, Whieh coneluded that ‘the effects of racial composition of se hools are ciimuledive, The longer Negra students are in desegregated schools, the better is their académic achievement... Corr versely, there it a growing de tieit for Negroes Whi re natin in racially isolated! se hools.? A third major catise of edie ational hary fo ehilitre Mn attending all-black-schools ix Re continued isparity in Me attended —— inthe South, Por example, the Conmityission on Civil Rights found that, in a sixteen-county\ area of Alabania, whit™attended school Hartlelinnges andl their 7 (Mice of Educition, United States Department of Henlt catwonanmd Welfare, Equality of Bdiagtional Opportunity « at 302 In ate: 402 of the Civil Rights Vet or 1968, 1 1 S0\ so ‘hi at woos . -_ .. “Racial lsolation in the Public Schools VOGT) at 204 Finda Nou " inte Ractal Poorhats vt ond thu thet, stiae sel et | cathe * : 4 . ‘! * . ’ ° . . ‘ on . Py - > ‘ ‘ . . . ‘ “. 7 e ‘ ’ . P . ‘ . ‘ ° ,@ . . ’ id . eo? F ‘ . ‘ id ’ ‘ . : J Py . . * »s 9 . Py * * P 7 ’ ; e ‘ : iM ‘ ee e yas , . coments were Worth ct awe rage | of SUNT, WW per pengoal. Those attended diy blocks in the same area were worth only S2ZS83.00 per pupik ‘The National Eduegrion As _ eechition.Tomnd: simihor alisparitios HN DES Levers tigger t ion of the Wileox County, Aladin short systonn * Transeriptiof Tearing ebb betire the BS) Conmissice iat Cast Kighits. Votity penn een Abighitiius ..1hos . ahibi No we at sas \l the baer ar iteee the Stote Suter tenden) af Bdecation oe : it athe ! ack ol beetaresd tt col ioetitiy these ‘disp Piles , My tiles ksteas [dort ‘ “het * Phy Stes Pera . brerarey thieeN tbe sabes aul toe Tee ge s! Th this « jit bial ont ! wt f 4 y » Py ’ * red wvetinaelidl atest ome! often totharl ppsticleattite: wt " ' oth Stone | Alabama State, Sepertutenibient Sat | futation We Nuon Dovrertn, cody ‘ Sage Creer an tay! 1 otis * . of rn Ps -¢ * * Mr Aili! ole t bss: ot Wwe inipele’s th Mea itua fs t fi fortis staat Py . " : : . , r divates that Use Newte schaols opel, Oath fia wardte Tent of bes ‘i ti lint ‘ crud atin’ at, blots 4 evighs ue af 7 | ts oteate dry v te op ss ert it Vara )¢ winnie Oger font geetitat isa? ade islet that Ti ies Oe oe eT mtv ozn'y one white’ sel ty i 4heyinu i ' +] “4 jie itiset af hk as’ ; prh ted ated | t ‘ I, wal | rt ie | | i ficeee cel Oy inn y ariel « :/ wil i} Ns Wise, we Bains odie aots this otheet lated beaver ate iesiheatiet Gil isathios of I . rh Ta 4 . ° ’ iN al Chow h Ve a vabdolue oof I: » that stn gel two detu - , * ” ally. have ajvaluationof $70 o ¢ . se ; , ‘ ay ; . . * “ ‘ F ‘ 1, Stine dow mt bil foe, Tlie thie Loscateds ii jb wel ean er Sivan WES eytertestee Pitaldaneee Cheer 14 mrer EF .04 ‘ ‘ jie st «al { +t s, th. weet! ta At || iF i ipet ' ’ . . ° bs . ee ’ 1 : 4 Now i! ts lipwte the mer ats J feetl ue "ue lis “ ' tite , ’ tal * aet ‘wither setae’ ath Oty tvs fares ATL Ode yeh es Wer ; Gare hy the ‘Pirtal natlipteed A why ans te sat letth: «=< ‘ thy . host Wer ¢ | * . : ‘ ie | ; : t : ) » dentoenies pied we Case Hat a perked pratt, well - . : : ; Piatisoript at Sbts) So Si Bt aan * o* 7 S x ‘ - Cention om Protestuoial dete miter i ‘ : : a ' * a ' ; ‘ ; oo ft ’ at : , . ‘ ? tonal si the Ayewtation” Wy (cisial Hee 4 Ntuid s, : F j " ’ ’ P ; “ ety 3 ; ym ‘ anal | ‘a ee ’ i ii tr rus fi ; 1 ; 7 4 ' ’ . y ; te abtitl « t) j AD ! ; i’ “ fe wal a ‘ll ‘ | ti ite feet whats att tiebal it | tf uh if lan # : ' hicewa epee t : rote't os per Ne “lin pious ti Cae or* Te silaass PY Ras il %, 00 it fi anit | ee ies ; 2 . ae ae » ' z ; ’ . . = o * * . ° . . F . ° J oe ‘ . ' “ ? . . ’ The Oni “° ‘of. Kalu ation curve y established that the , «palit of the education: al fie ility hits oo stronger effect * on the aehievement of disadvantaced stindents thon st “lies on the ae hie Verment of stteleruts from Hione duly, tysel bckaeronneds, Ir jilsersVoutsl that the ay Lita eet fli’ Paeibite was Wiest nipert int for Neutoes tr th Souths, | ‘ Sinee carly 1967, almost every school deteiet ime the 2 Rift Crrenit: desesregatinig’ tik court order ba Drcrerny werdered te eqtalize the Caeulities oat a Ti vee! Couitegd Slates Vv. Je therson County Roard of hiluen fron, 1 bo pad | “pals Oth Cin (iu hitne ) cert. dented GS TUS SHO PGT), but without clscernible effees Pir thee sytem af the As oGiation, the Only praetieat procedure Por the ebliitiation ot the qinilitatiye tithes wnees in black ati) White sehoots 4 complete iitiegra feet "i : ys hese three ‘se Perate phetetiena combine te pivots Trreriediable © dhucationak havi, ‘Uhis ace valine for this Mie vl Pidivecation Survesa, be thee riural South bokinerks ~thiudent- midhe th rik Are an Vette of Go rrineles ” boebitomd white steelent. ter. eeocdiee Compre bie tye teen B. The Considerations Helied Upon by the Governimont-and the * Court Below Do Not Justity Delay in Desegregation Phe et Peete cel thie ‘eoourt tne Leow, sat pre bel itiy ihe combi thi ulite that townie il li “aera ctl pl ittg: be bape tietitesdt thi. Fe alt, wa prem vl chbingts gene cane Nuiiruist - VO, PO better rut hi by the re retary of the dh punt ¢ . COitiow asf Tagernt gente | ib wd s ‘a ely riaiei t tf thea “Hal . athe viel Wella cm tT 4 kad thine! sri mae Seba a tie 4 :* : : a y » © ys . x = . ° , “hd, tl. bo tn ure it ! | hu sath te . abe ant be thy 1. al } eg ual ‘ % , ale Maoliisndo whi } Natline « tere hiertisteets “ a ‘ . " - ’ . * . ; . P e ° . mentoat Health) Mdtcation cmd Welfare, scek ung say i a heli. hii his letter, Seovebars Minch deserted that the plans submitted by the Offiee of bdo dtions pursaint to, the daly Ged diandate of the Court of Appeats, wer | dhevedapedl Without delegate tithe ted thats tha iripile tetitation an the terribly Short space of Gimme remiuan| inne’ preseniod *aduiieetrative and liistieal bifticns! ties whieh eGutd not be ret wathoat prodietag ehac combustor ctl esate Lrarpehis ‘ Vero phig ron el thineec condi hatha. Wire afforded sn the Sex PeLany, Moteover, thes rut aliveethy cottitien t all previo eNpresstafie of the besceutive Pranebe on the issaie:. Breas eviline tothe requested delay, theS@souet of Appeals noted that the Ciovertamont tial prepased a ahlore rigid Jimetable than Chace vstabl breed hay Lhe Compt in its aby) 1960 deeision oe oo (estrous Were spre heady Ghineetedk te thee Neevet ait Mtornes General ippearig on behalf of Me Cioverntiedt Worthen QUT hotk 1th resp” Oe ee et Pk heCattiemiedd the Giev cnn bit view Tet the timetable props bay thie Qhoveen Hint Wie Pecdecnahle - Vii he atlivareedk tdi ifflekene Peseiteae al ‘the | eeeutive 1) \) Whitmer Wartthd Aa bisctalys ov inthatel tee aetneatels thi ilies ‘of bibitetton Gof the | TiitedaS tah Phopecetient of m fh ail Pdluvation aid. Welt ine toe Tattle pedi: > jv yu ied-in thi vpelod Ted by it he eourt Parther aeted thats untihse tt baat Vb rteh Niastiet 1 fetter, Mere trad da Chote sugaeetign that th * = * , . I Tis 4a ifea sect ft mA ' i. j ! j the . ' aap * ; . ° a . . - oi ” E pide “ It ( ive } | L 1% ‘ sift ' i . ° ; . Pr} 2? ce 7 * 4 ; * . ro _ vas ° . ° % s . \\ (ed the REEEEAIEY to consider changes in eurrien- Jumna;: Cd) the necessity to effeet plysieal changes im class- roots, lavatories and other facilities: (eo) the necessity te reassign seme teachers Of) the necessity to reconsider the expenditure of. federal funds available under the Elementary and Secondary Education Aet of 1965.'" The only ad litt onl points In justifieation for delay were references to the dedygability of conditioning tecehers, students and the eoriununity tthe strains of chool desegregation.” : Vhe National Ednueation. Association does uot believe thiat any of these reasons; or the combination of them, noe sueh educational or administrative prob Nenis as to pistify: further delay in des segregation. birst. wheat ever TaAV he the faet in large, complicated school s\'s tems, the asserted considerations have litte relevance her smal] distriets operating only a few schools. Yet vers stall system”! were limped together with larger distiqets on the comnom assertions of ditfienlty. Second, for even the largest ss stems invelved here, he we serted diffientties are nat sufficitnth significant te justify delay, lil at a: feo, ps hd it Out : hd : re a fal jt bia. I oat Hoa, 67a ; Amony the eases at bar, the Aneuilla Line ¢ onsalidated Sehool }) tried hits cada three schools. the Canton \ thieipal Separate bevel DDistriet bras ail four sehools, amd the Wialkinmsons vuartt: ind the North Pike Counts Consolidated Sehool- District. have ! ic footy chools ‘piece (2) (b) 4a) = aE Publicity for new, school zone boundaries en be accomplished by a notice in ai local news- paper and, to the extent necessary, by redirecting persons who report ade wrong school on open- ing day. . Drawing up school bus routes in an intewrated school system is far‘less complicated than the planning of school bus routes under a freeddin of-choice plan, and can normally be accom plished ina matter of divs. The references to supposed changes of curric- lumi is unelear, but since neither the number of students at each grade level nor the number of teachers would necessarily change, the problem seenis only that of allocating given numbers of students to given classes--a problonr managed. at the beginning of semesters by school systems “aeross the country. The minor changes necessary to accommodate different ages of children than were formerly ‘in a school building—installing desks, restroom facilities and water fountains of a different size—can be, and norm: lly are, accompltshed in- a short period. . The assignment of teachers to classes they are qualified to teach is a normal educational task, requiring but a few davs to accomplish. any change in the use of federal funds required y desegregation need het be re solved before school opening, and with the assistanee of TLE W officials, there is flo reason why altering plans for the expendituly of Tithe T ftimads should pre sent a burden of any size. | Cis the suggestion that the ommumnity, the teae he Vs the students need more time to become acclimated. yregation is simply imape Bae fifteen vers Brown. lo Nae after * The tasks referved to by the TEW witnesses should together require a week or, at most, two weeks to com plete. Where a S®sool district could not complete the heeessary work inthe available times? the district court could have ordered a short delay in scheduled schoo! opening. But there are no educational reasons —pre- sented or Nisting Whichavould support a ves’s delay In etfee ting desegregation. Educators in the Office of Madtication coneluded, after intensive investigations, that none of the districts here invelved have somm __ reasons for delaying implementation of the plans sub titted. "Phere is nothing’ in this reeord to suggest that thas conclusion Wis Incorrect, ro. 4 A further compellitig reastu for this Court te pre hibit further delay in desceregation concerns the re- _tationship of eases suchas these, where compliance with coustitutional requirements has not been achbteved, to the min school distriets in the South Where school officials have climinated the dual svstent f tn THEA of the hatter cases, compliance was possible in the face of substantial resistanee. in the eotmiumity beesuse ofthe asstimption that the judicial and exec tive state nents concerning the timetable for desegrewation would be enforced. An abandonment of that timetable at tis time seriously weakens the position of those whe vilveeated the peaceful transition te a unitary svstem, As Secretary Binch’s letter polnted out, serie ort chaol di Pricts involved did thiol bowin thie schoo] S Goan 8" aD itil Stole nie 1] Petition for certiorart at 38a 7 . 12 and threatens to precipitate resegregation in many of these districts.” — haplementation of the plaus proposed in these cases Dy TW during the course of this school year presents problems of disruption that would uot have been pre sented had the Government not sought delay in August, On balance, however, the National Mducation Associa tion believes that the adverse effects of the- continued maintenance of segregated schools for auy additions! period outweighs the adverse effects of a change dur ing the school vear, and neges this Court to order the mimediate iniplementation of the HEW plans. "TV. CCNCLUSION Any further delay in desegregation would result in enormous and irreparable harm to black children. Phe educational and administrative reagons that have been advanced to justify a delay in desegration Ih the case at barare without meri. Sound edyeational policy calls net for delay, but for terminal désegregation, even a the cost of reassigning students during the course of a school Vear, 3 Accordingly, amicus Nations ledueation Association urges that the August-28, 1969 order of the Court o: Appeals be reversed, that this Court hold that odin istrative difficulties will no longer be permitted te post pone desegregatian Lr guns Case, ane that this Hiatter be “A report of the ‘Department of Health, Education. and Wel fare states that there were 29 hast-minute reneves on pfans’’ thy school districts descufemating under EEE Weapproved) voluntars plans, at the beytnning of the PTO school veut Progress Be portion Creed Rights (W684) at 2 randed With instructions that the Distriet Court enter orders requiriig: the immediate implementation of the plans drawn up by the Qffiee. of: Education of * Hie W for these school districts. | Respectfully: submitted, Ricwarp BL Sopot. I8v3 detferson Place, No W. | Washington, D.C. 20036 vA ; ; | Davip Rui | | W201 16th Street, No W. ‘Washington, D.C. 20036. - Attorneys for Amicus Curtae, National Kduca- ¢ ; . tion Association Of Counsel: ' a . Richarp T. Seymour. . 1823 detferson Place, NW, ~. Washington, DLL 20086 --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385001_1336%3A6. Public record. Not legal advice.