Appendix — Swann v. Charlotte-Mecklenburg Board of Education

Supreme Court brief1971

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INDEX

Volume I

Docket Entries ...................

Motion for Further Relief, filed September 6, 1968....

Answer to Motion for Further Relief -.......................

Transcript of March 10, 1969, hearing, pages 18-39,

line 20; page 41, line 15 through page 83, line 23;

page 352, line 10 through page 487, line 17; and

page 544, line 3 through page 678, line 25 ................

Opinion and Order Dated April 23, 1969, Regarding

Desegregation of Schools of Charlotte and Meck-

lenburg County, North Carolina ..............................-.

Appendix paiasiiaiaheliddcaahthabsdaiaiinstabeldbicilontibentiaal

Plaintiffs’ Motion for Temporary Restraining Order

dated May 15, 1969

Defendants’ Plan for Desegregation, filed May 28,

ais ai ch sAaestbe ised cinta

Defendants’ Report in Connection with Plan of De-

segregation filed May 28, 1969 ........2.....2.....eeeececeee--

Defendants’ Response to Mction for Temporary Re-

straining Order, filed May 29, 1969 .......................

Order Dated June 3, 1969

PAGE

la

2a

9a

lla

285a

317a

324a

330a

341la

346a

Order Adding Additional Parties, dated June 5, 1969

Motion to Set Aside Order Joining Additional Par-

ties Defendant, filed June 12, 1969

Plaintiffs’ Response to Defendants’ Motion to Strike

Additional Parties Defendant, filed June 16, 1969

Transcript of June 16, 1969, Proceedings, page 487,

line 22 through page 544, line 8 ....

Tentative Plan for the Integration of the Charlotte-

Mecklenburg Schools (for discussion purposes),

dated May 8, 1969

Opinion and Order dated June 20, 1969 ........................

Supplemental Findings of Fact in Connection with

the Order of June 20, 1969 (dated June 24, 1969)

Plaintiffs’ Motion to File Supplemental Complaint,

filed July 22, 1969

Order Allowing Filing of Supplemental Complaint,

filed July 22, 1969

Volume II

Plaintiffs’ Supplemental Complaint, filed July 22,

1969 :

Exhibit A Attached to Foregoing Supplemental

Complaint ..

Defendants’ Amendment to Plan for Further Deseg-

regation, filed July 29, 1969

PAGE

372a

376a

379a

383a

43la

448a

459a

460a

464a

ili

Defendants’ Report in Connection with Amendment

to Plan for Further Desegregation, filed August 4,

NUT “icesnecteilesediceclobensitedehstitb ange celica acniabtoasiies

Transcript of August 5, 1969, Proceedings: page 4,

line 22 through page 41, line 17; and page 57, line

5 through page 84, line 25

Answer of the Defendants, the North Carolina State

Board of Education and the Superintendent of

Public Instruction for the State of North Caro-

lina, to the Supplemental Complaint, filed August

11, 1969

Order dated August 15, 1969

Order dated August 29, 1969

Plaintiffs’ Motion for Further Relief, filed Septem-

ber 2, 1969 ......

Order dated October 10, 1969

Defendants’ Response to Motion for Further Relief,

filed October 11, 1969

Summation of Integration 1965 (March) and 1968-69

(Oct. 1, 68) and 1969-70 (Oct. 2, 69) (App. 1, pp.

63-70) ..

Defendants’ Report to the Court Pursuant to Order

of October 10, 1969, and filed October 30, 1969 ......

Exhibits annexed to foregoing Report ................

PAGE

491la

498a

525a

575a

579a

593a

596a

601la

606a

608a

616a

626a

iv

Order dated November 7, 1969

Memorandum Opinion dated November 7, 1969 ........

Amendment to Plan for Further Desegregation of

Schools, filed November 17, 1969

Report submitted in Connection with the November

13 (17), 1969, Amendment to Plan for Further

Desegregation

Exhibits annexed to foregoing Report ................

Plaintiffs’ Response to Defendants’ Amendment to

Plan for Further Desegregation of Schools, filed

November 21, 1969

Opinion

Order dated December 1, 1969

Order dated December 2, 1969

Motion for Immediate Desegregation, filed January

20, 1970

Plan for Desegregation of Schools Submitted Feb-

ruary 2, 1970

Exhibits annexed to Foregoing Plan ....................

Transcript of February 2 and February 5, 1970,

Proceedings: page 43, line 5 through page 11, line

15; and page 137, line 1 through page 150, line

1

PAGE

655a

657a

670a

680a

691la

692a

698a

714a

717a

718a

726a

744a

749a

Motion for Hearing on Plans for Desegregation of

Charlotte-Mecklenburg Public Schools, filed Feb-

ruary 6, 1970

Order dated February 5, 1970

Motion to Add Additional Parties Defendant and for

Further Relief, filed February 13, 1970 -...............

Notification and Request for a Three-Judge Court,

filed February 20, 1970

Defendants’ Tender of Evidence Nunc Pro Tunc and

Objections filed February 24, 1970

Affidavit of William C. Self Referred to in Forego-

ing Tender of Evidence

Affidavit of J. D. Morgan Referred to in Foregoing

Tender of Evidence

Board of Education Plan Referred to in Tender of

Evidence

Volume II

Affidavit of Louis W. Alexander Referred to in Ten-

der of Evidence

Affidavit of Herman J. Hoose Referred to in Tender

of Evidence

Affidavit of Robert L. Deaton Referred to in Tender

of Evidence

PAGE

817a

819a

840a

845a

867a

Order Adding Additional Parties Defendant, filed

February 25, 1970

Notice of Appeal, filed February 25, 1970 ..................

Plaintiffs’ Motion to Add Additional Parties Defen-

dant and for Further Relief, filed February 27,

1970

Plaintiffs’ Motion for Temporary Restraining Order

and for Contempt, filed February 27, 1970 ..............

Plaintiffs’ Request for Admission of Facts, filed Feb-

ruary 27, 1970

Amendment, Correction or Clarification of Orders of

February 5, 1970, dated March 3, 1970 ....................

Court of Appeals Order Granting Stay Order of

March 5, 1970

Order Suspending Superior Court Temporary Re-

straining Order, entered by Judge Snepp, filed

March 6, 1970

Order of March 6, Directing Parties to Prepare and

File Additional Evidence by March 13, 1970, dated

March 6, 1970

Order Directing Parties to Submit Information with

Respect to Specific Inquiries of the Court, filed

March 6, 1970

Deposition of John A. Finger, dated March 11, 1970

PAGE

918a

921a

922a

925a

930a

PAGE

Defendants’ Response to Plaintiffs’ Request for Ad-

missions dated March 13, 1970 101lla

Defendants’ Submissions to Court in Response to

March 6, 1970, Order and Motion for Extension of

Time, filed March 13, 1970 1014a

Exhibits Annexed to Foregoing Submissions .... 1015a

Affidavit of Herman J. Hoose Referred to in Forego-

ing Submissions 1038a

Defendants’ Submissions to Court in Response to

March 6, 1970, Order, filed March 17, 1970 ............ 1041la

Affidavit of William C. Self Referred to in Foregoing

Submissions 1042a

Affidavits of J. D. Morgan, Ralph Neill and W. H.

Harrison Referred to in Foregoing Submissions .. 1045a

Exhibits Annexed to Foregoing Affidavits .......... 1047a

Deposition of J. D. Morgan dated March 19, 1970 .... 1069a

Exhibit Annexed to Foregoing Affidavit .............. 1188a

Defendants’ Response to Plaintiffs’ Supplemental

Exhibit of March 20, 1970, submitted March 21,

1970 1192a

Response to Plaintiffs’ Supplemental Exhibit of

March 20, 1970 1193a

Tabulation 1196a

PAGE

Supplementary Findings of Fact dated March 21,

1970 1198a

Supplemental Memorandum dated March 21, 1970.... 1221a

Defendants’ Objections and Exceptions to Supple-

mentary Findings of Fact of March 21, 1970, and

Motion for Modification and Clarification Thereof

dated March 25, 1970 1239a

Order dated March 25, 1970 1255a

Further Findings of Fact on Matters Raised by the

March 26, 1970, Motions of Defendants dated

April 3, 1970 1259a

Opinions of Court of Appeals dated May 26, 1970 .... 1262a

Judgment of Court of Appeals 1304a

Order of Three-Judge District Court dated April 29,

1970 1305a

Order Granting Certiorari dated June 29, 1970 ........ 1320a

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Docket Entries

oa

Papi Ose

Leber ea RAE SNe ER

Rh AAAS,

2a

Motion for Further Relief

(Filed September 6, 1968)

IN THE

UNITED STATES DISTRICT COURT

For THE Western District or NortH CaRoLina

Cuartotte Division

Crvm Action No. 1974

James BE, Swany, et al.,

Plaintiff's,

and

Tue Nort Carotina TEacHERs AssociaTION, a corporation,

Plaintiff-Intervenor,

—Vs8S.—

Tae CHARLOTTE-MECKLENBURG Boarp or Epvucation,

a public corporate, |

Defendant.

The plaintiffs and plaintiff-intervenor, by their under-

signed counsel, respectfully move the Court for further |

relief in the above-styled cause, and, as grounds therefor,

show the Court as follows:

1. This cause was initially filed by plaintiffs on January |

15, 1968, seeking injunctive relief against the racially dis- |

criminatory practices and policies of the defendant in the |

operation of the Charlotte-Mecklenburg Public Schools. |

3a

Motion for Further Relief

Plaintiffs challenged at that time (a) the attendance zones

of the various schools which limited or restricted desegre-

gation; (b) the exception by the School Board of 10 Negro

schools from attendance zoning; (c) the use of freedom of

choice imposed on attendance zoning, permitting students

assigned to integrated schools to transfer out, thus re-

segregating the schools and (d) the failure of the board

to take immediate and effective steps to desogregate teach-

ers and staff personnel.

2. Following the hearing of this cause in July, 1965, the

District Court entered an order dated July 14, 1965 approv-

ing of the plan adopted by the school board providing for

attendance zones for 99 of the 109 schools, exception of

the 10 Negro schools from geographic attendance plan,

transfer of pupils from integrated schools to segregated

after initial assignments, and modification of the plan with

respect to teachers, requiring immediate integration of

teachers. The United States Court of Appeals for the

Fourth Circuit affirmed the District Court order on Decem-

ber 24, 1966, reasoning that the 10 excepted Negro schools

had been closed, that there was no affirmative duty on the

school board to act consciously for the purpose of achieving

the maximum mixture of races in the schools, and holding

further that any party may apply to the District Court

for further relief or for modification of the District Court

order, the United States Supreme Court decided Greene v.

County School Board of New Kent County, —— U.S. —,

20 L.ed.2d. 727; Monroe v. Board of Commissioners of the

City of Jackson, US. , 20 L.ed. 2d 733, and Raney

v. Board of Education of Gould School District, —— U.S.

——, 20 L.ed. 2d 727, and the United States Court of Ap-

peals for the Fourth Circuit decided Brewer v. School

4a

Motion for Further Relief

Board of the City of Norfolk, —— F.2d —— (Fourth Cir.

#11782, May 31, 1968). It is clear from these decisions

that the further modification of the District Court order

of July 14, 1965, is warranted.

3. Since the District Court order of July 14, 1965, the

school board has closed the 10 Negro schools, excepted from

the geographic attendance program of 1965 and has estab-

lished new boundary lines for the schools. In addition, the

school board has constructed and made additions to several

new schools. The new boundary lines established and the

placement of the new schools and additions to existing

schools were designed and have had the effect of perpetu-

ating segregation in the school system. The defendant has

also continued the free transfer provisions allowing stu-

dents to transfer out of integrated schools and has failed to

take appropriate steps to completely desegregate staff and

school personnel.

4. Specifically :

(A) Defendant has perpetuated attendance area school

districting in such manner as to maintain and perpetuate

segregated schools. The all-white, all-Negro and tokenly

integrated schools in this system result from racially gerry-

mandered school districts, the use of attendance areas based

on racially segregated and developed housing, both pub-

licly and privately contrived, the use of a feeder system

which perpetuates the racially segregated system as existed

before Brown v. Board of Education. This practice has

been condemned both by the Supreme Court and by the

United States Court of Appeals for the Fourth Circuit. Al-

ternative methods exist here for complete disestablishment

of the segregated system, and, under the decision cited

5a

Motion for Further Relief

above, the school board is required to pursue these alterna-

tive methods.

(B) Defendants use of the freedom of choice or free

transfer plan is clearly for the purpose of perpetuating

segregated schools. The use of freedom of choice in this

system, imposed on geographic attendance zones where the

results have been to perpetuate segregated schools, has

been condemned by the Supreme Court and the United

States Court of Appeals for the Fourth Circuit. Under the

decisions cited above the school board is constitutionally

required to eliminate this practice.

(C) Defendant’s “feeder system” has also been used to

perpetuate racial segregation of students. This system,

as used by the defendant, tends to filter Negro and white

students, who initially began their education in segregated

elemetary schools, into segregated junior and senior high

schools. Such a system, if properly oriented, may be a

constitutionally permissable step in the integration of the

public schools. See Monroe v. Board of Commissioners of

the City of Jackson, supra. However, where such a system

is used to perpetuate segregation, as here, it violates the

requirements of Brown v. Board of Education.

(D) Defendant has failed to take immediate and effec-

tive steps to desegregate its teachers and school personnel.

Where such integration has taken place, the school per-

sonnel assigned have consisted primarily of librarians,

music, art, reading and Special Education teachers. Schools

with large Negro or white student enrollments have fairly

completely segregated faculties. This practice fails to meet

the constitutional mandate of the Supreme Court, the

United States Court of Appeals for the Fourth Circuit

and the Court order entered in this case.

6a

Motion for Further Relief

(E) Defendant has followed a practice and policy of

discrimination against predominantly or all-Negro schools

by providing them with inferior educational programs and

facilities. Defendant has maintained ability grouping (“ad-

vanced,” “regular,” and “basic”) systems in predominantly

white schools. Negro students in predominantly white

schools, are for the most part, relegated to the lower group-

ings and given little opportunity to reach the “advanced”

levels. In general, the curriculum in the white schools is

broader and more varied than that in the Negro schools.

Defendant has failed to provide adequate funds for build-

ing and school construction and the purchase of needed

school facilities at the all-Negro or predominantly Negro

schools. Funds even though immediately allocated to Negro

schools have been diverted to white schools often to the

detriment of the Negro schools. Moreover, even with the

construction of new schools or the additions to existing

schools, the effect has been to limit the integration of

schools. There is presently no plan for the construction

of new schools which would bring together a highly inte-

grated student body.

Wueneror:, plaintiffs respectfully pray that this matter

be set for hearing at the earliest possible date and that

upon such hearing the Court permanently enjoin defendant:

(1) to present a plan within a period of time that will

permit its implementation at the beginning of the 1969-70

school year, establishing school zone lines, school and grade

consolidation, or both, in order to completely desegregate

all schools in the school system, and to eliminate the racial

identity of the various schools;

;

rf

3

Ta

Motion for Further Relief

(2) to completely desegregate all teachers and school

personnel in the school system so that for the 1969-70 school

year the percentage of Negro and white teachers and school

personnel in all schools in the system will approximate the

number of Negro and white teachers in the school system;

(3) to cease planning and constructing schools, additions

to schools, and school facilities on the basis of race and

color. In this connection, that the defendant be enjoined

to present to the Court, with copies being served upon

_ plaintiffs, a report of any planned construction, addition,

_ alteration or closing;

(4) to eliminate, effective with the beginning of the 1969-

70 school year, any and all disparatives in school facilities,

_ school buildings, curriculum and equipment;

(5) to discontinue and eliminate any and all other prac-

tices in the school system based on race and color.

Plaintiffs further pray that pending a full and complete

3 implementation of the Order of the Court that the Court

retain jurisdiction of this cause; that the plaintiffs be

_ awarded the causes herein and granted such other and fur-

_ ther relief as the Court may deem equitable and just.

8a

Motion for Further Relief

Respectfully submitted,

Conrap O. PEARSON

20314 East Chapel Hill Street

Durham, North Carolina

Jutivs LEVonnE CHAMBERS

James E. Fercuson, II

James E. LANNING

216 West Tenth Street

Charlotte, North Carolina 28202 —

:

3

"

Jack GREENBERG 4

James Nasait, III

Rosert Beuton

10 Columbus Circle

New York, New York

Attorneys for Plaintiff

9a

Answer to Motion for Further Relief

(Filed September 6, 1968)

IN THE

UNITED STATES DISTRICT COURT

For THE WesteRN District or NortH CaRoLINA

CuarLottre Division

Crvm Action No. 1974

James E. Swany, et al.,

Plaintiffs,

AVS

THe CHARLOTTE-MECKLENBURG Boarp or Epvucarion,

Defendant.

The defendant, answering the motion of the plaintiffs

filed herein on the 6th day of September, 1968, says and

alleges

1. The allegations of paragraph 1 deal with matters

and things appearing of record in this case and this de-

fendant is not required to either admit or deny said alle-

gations, except that it is alleged that this cause was initially

filed on January 12, 1965.

2. The allegations of paragraph 2 deal with matters

and things appearing of record in this case and this defen-

dant is not required to either admit or deny the same

except that it is denied that further modification of the

District Court order of July 14, 1965 is justified.

10a

Answer to Motion for Further Relief

3. Answering the allegations of paragraph 3, it is ad-

mitted that since said Court order of July 14, 1965, the

defendant has abolished the dual school system as it relates

to race, has made some necessary changes in boundary lines

of attendance areas, has constructed and made additions to

new schools and old schools and has permitted pupils to

transfer from one attendance area to another when there

was sufficient room in such other attendance area to accom-

modate the pupils. Except as herein admitted the allega-

tions of paragraph 3 are denied.

4(A). The allegations of paragraph 4(A) are-denied.

4(B). Answering the allegations of paragraph 4(B), this

defendant denies that the transfer plan permitting pupils

to transfer from one attendance area to another has been

for the purpose of perpetuating segregated schools and this

defendant alleges that such transfer plan has been used by

pupils without regard to race and has proven of value and

convenience to pupils without regard to race.

4(C). The allegations of paragraph 4(C) are denied.

4(D). The allegations of paragraph 4(D) are denied.

4(E). The allegations of paragraph 4(E) are denied.

Wherefore, the defendant prays the Court that the relief

demanded by the plaintiffs in said motion be denied, that

this action be dismissed and that this plaintiff recover its

cost and have such other and further relief as it may be

entitled to receive.

Brock BarkKLey

Attorney for the Defendant

814 Law Building

Charlotte, North Carolina 28202

Pe PAIR Ee

SP & Gh wey

lla

Transcript of Hearing March 10, 1969

[18] ee ¢

All right, the plaintiffs may proceed with their testimony.

Mr. Chambers: We would like to identify Plaintiff's Ex-

hibit #1, Defendant’s answers to plaintiff's interrogatories

of September 9, 1968, defendant’s answers being dated

October 31, 1968.

Court: This is the defendant’s answers?

Mr. Chambers: Yes, sir, defendant’s answers. As Plain-

tiffs Exhibit 2 the defendant’s answers to plaintiff’s in-

terrogatories of January 31, 1969, defendant’s answers

being dated March 3, 1969. We would like permission of the

Court to substitute the original of these answers now on

file with the Clerk in lieu of our copies.

Court: I was looking at the exhibit and didn’t realize

you were asking a question. You asked if the original might

[19] be substituted, it may be, yes.

Mr. Chambers: Plaintiff’s Exhibit 3, Collective Exhibit

3, consists of the depositions of Mrs. Gertrude Coward,

Mr. James Burch, Mrs. Mary Jane Kistler, Dr. Robert

C. Hanes, Mr. Joseph Frankford, Mr. John B. Phillips;

Mr. William L. Anderson, Mrs. Ann Hausmann, Mr. Car-

roll C. York, Mr. John W. Harrison, Mr. Henry L. Smith,

Mr. Ralph W. Eaton, Mr. Herbert L. Puckett, Mr. James

Clark, Mr. J. B. Davis, Jr., Dr. James Mikaelson, Mrs.

Dorothy Boone, Dr. Leslie Bobbitt, Dr. William C. Self,

and Mr. William E. Poe.

Plaintiff's Exhibit #4 I’d like to identify an overlay

showing the racial housing pattern in the City of Charlotte.

Court: That’s an overlay on itself or on something else?

Mr. Chambers: It’s an overlay of the County map of

the various district lines of the School Board.

Mr. Chambers: Prepared by Mr. Green. We will call

him as the first witness. We just wanted to identify them

12a

Colloquy

now. As Plaintiff’s Exhibit 5, a census tract map of

Mecklenburg County for 1960.

Court: What is a census tract map?

Mr. Chambers: The Bureau of the Census prepares

various districts for the County for census purposes.

Court: What does a tract mean?

[20] Mr. Chambers: That is the district, the tract it-

self.

Mr. Barkley: We are not admitting the competency.

Mr. Chambers: Plaintiff’s Exhibit 6, we have a racial

breakdown on the census tract map showing the percent-

ages of non-whites in the various tracts in the City of

Charlotte as of 1960. As Plaintiff’s Exhibit 7 we have an

overlay of that census tract map showing the racial com-

position as of 1968, October 31, 1968. As Plaintiff’s Ex-

hibit 8 we have a map showing the income for family in

the various tracts of Mecklenburg County as of the 1960

census. As Plaintiff’s Exhibit 9 we have a zoning map

for the City of Charlotte for 1947.

Court: Mr. Chambers, we have some visitors in the back

who may be personally involved in the suit. Is the nice

looking lady in the back row in charge of these folks? Are

you the teacher?

Voice from the Audience: Yes, I am.

Court: If you'll tell us who you are, we'll be glad to

welcome you to the court as long as you want to stay.

Mrs. Kelley: Thank you. I am Betsy Kelley, member

of the Schoo] Board and this is a group of students from

St. Gabriel’s Elementary School, eighth graders.

Court: We are glad to have you with us, Mrs. Kelley.

Mr. Chambers: Plaintiff's Collective Exhibit 10, zoning

ordinance for the City of Charlotte 1968 and the [21]

zoning maps with index for the City of Charlotte 1968.

Plaintiff's Exhibit 11, copy of zoning ordinance for the

County of Mecklenburg.

13a

Colloquy

Court: Is that current?

Mr. Chambers: Current. Plaintiff’s Exhibit 12, a pub-

lication of the Charlotte-Mecklenburg Planning Commis-

sion entitled The Next 20 Years with the map showing the

recommended residential zoning and industrial zoning for

the next twenty years for the City of Charlotte. Plaintiff’s

Exhibit 13, a map showing the major thoroughfares for

the City of Charlotte dated June 1, 1968. Plaintiff’s Ex-

hibit 14 a map showing the urban renewal areas for the

City of Charlotte dated November, 1968. Plaintiff’s Ex-

hibit 15, a publication of the Charlotte-Mecklenburg Plan-

ning Commission entitled Residential Blight in Charlotte

dated September, 1962. Plaintiff’s Exhibit 16, a copy of a

publication of the Charlotte-Mecklenburg Planning Com-

mission entitled Review of Community Facilities, dated

1964. Plaintiff’s Exhibit 17, a copy of publication by the

Charlotte-Mecklenburg Planning Commission entitled A

Statistical Summary of Population and Economic Data dated

March, 1968. Plaintiff’s Exhibit 18, publication of the City

of Charlotte entitled Model Neighborhood Proposal dated

April, 1967. Plaintiff’s Exhibit 19, a copy of the Workable

Program Report submitted by the City of Charlotte to the

United States Department of Housing and [22] Urban

Development, dated January 27, 1969. Plaintiff’s Exhibit

20, a two volume publication of the Charlotte Area Fund

prepared by the North Carolina Fund entitled A Profile

of Community Problems dated 1964. Plaintiff’s Exhibit 21,

a publication of the Charlotte Area Fund prepared by the

North Carolina Fund entitled Characteristics of Individuals

in Areas Served by the Charlotte Community Action Pro-

gram, dated August, 1967. Plaintiff’s Collective Exhibit 22,

a copy of the Code of the City of Charlotte 1946, Chapter

14; Code of the City of Charlotte 1946, Chapter 1; Code

14a

Colloquy

of the City of Charlotte 1931, Chapter 5, Section 320(a),

Chapter 14, Sections 483 through 486, Chapter 15, Section 4

544; Code of the City of Charlotte dated 1902 showing

the City census Part 1 and the unofficial appendix attached —

to the code. Plaintiff’s Collective Exhibit 23, interim re- —

ports and summary prepared by Engelhardt & Engelhardt ©

for the Charlotte-Mecklenburg Board of Education. E

Your Honor, for the purpose of the hearing we would ©

like to identify also exhibits that are attached to defen. |

dant’s answers to interrogatories which show elementary, |

junior high and senior high school distribution for the

City of Charlotte.

We'd like to follow with Exhibit 24, a map of the City |

of Charlotte elementary school districts; as Plaintiff’s Ex-

hibit 25 the map of the City of Charlotte junior high

[23] school districts; and as Plaintiff’s Exhibit 26, the

map of the senior high school districts for the school [

system.

Court: What vintage is that?

Mr. Chambers: 1968-69.

Court: Are tlfey separate, you say the City of Charlotte.

Mr. Chambers: The Charlotte-Mecklenburg School

System.

Court: You’re still talking about the same thing. Those

three are all 1969.

Mr. Chambers: 1968-69 school year. We'd like to call

at this time Mr. Green.

Court: Let’s take a ten minute recess.

Snort Recess

Mr. Chambers: In connection with Plaintiff’s Exhibit 14,

we have a statistical listing by the Charlotte Redevelop-

ment Commission showing where families in the urban

lda

Charles L. Green—for Plaintiffs—Direct

renewal areas were located and we’d like to have this

document attached to our Exhibit 14.

Court: All right.

Mr. Barkley: We haven’t had a chance to read any of

these or check them. We have agreed that we will admit

that the source of the material comes from where it appears

that it comes. This particular document, it doesn’t show

it, but we have one like it and we will admit it comes from

the Redevelopmert Commission.

Court: Let me see if I can put this question in a [24]

light that will leave everybody at ease about it. I intend

to entertain all objections to any evidence before the record

is closed, but I intend to consider all evidence that is

pertinent to the case that is introduced if, in my opinion,

it is pertinent to the case and is not incompetent for some

clear reason. But all of these exhibits are being accepted

subject to your right to make any objection that appears

when you have had time to study them and before the

record is closed with the presumption being that the Court

is going to sift the wheat from the chaff in making any

decision that is made and with your objections in mind

when that is done.

Mr. Barkley: It is understood that we do not admit the

competency of any of this material.

Court: That’s all right.

Mr. Chambers: As Plaintiff’s Exhibit 27 we’d like to

introduce a copy of the regulations of the Department of

Agriculture dealing with the school lunch program.

Cuarites L, Green, a witness for the plaintiffs, having

first been duly sworn, was examined and testified as follows:

16a

Charles L. Green—for Plaintiffs—Direct

Direct Examination by Mr. Chambers:

Q. Will you state your name, please? A. Charles L.

Green.

Q. What is your address, Mr. Green? [25] A. 711

Baugh Building in Charlotte.

Q. What is your occupation, Mr. Green? A. I am en-

gaged in Marketing Research.

Q. Would you describe for the Court what this consists

of? A. It consists of various studies, statistical, primarily

in the development of information dealing with a number

of things, socio-economic problems, the testing of radio

commercials, interviewing people for consumer products,

sales, any sort of information that is concerned with

marketing or social problems.

Q. Does your work consist at any time of counting

houses or where people live or determining where people

live? A. That is correct. I have done a considerable

amount of this type of work.

Q. How long have you been involved in this particular

kind of practice? A. Since 1954.

Q. In studying where people live, have you concerned

yourself with racial areas where people live, whether they

were black or white? A. I have done a study on this, yes,

sir,

Q. Have you studied residential patterns according to

the income of families? A. This was in connection with the

study on the white and non-white population distribution.

[26] Q. Now, were you requested, Mr. Green, to make a

study of the City of Charlotte for us for this lawsuit? A.

That is correct.

Q. Were you requested to do a map to show the racial

housing patterns in the City of Charlotte? A. That is

correct.

nh Pe Cee oe he ee,

ae ee

17a

Charles L. Green—for Plaintiffs—Direct

Q. Were you requested to do a study for the plaintiffs

to show the income of families according to the census

tract? A. That is correct also.

Q. Did you prepare such maps? A. I did.

Q. I show you a document which has been marked plain-

tiff’s Exhibit 4 and ask if you prepared this document. A. I

did, sir.

Q. Would you state for the record what this exhibit is.

A. This is an overlay of a map of Mecklenburg County. On

the overlay the census tracts are outlined and the overlay

itself is color-coded by census tract as to the percentage of

non-white population within the individual tract. These

percentages are as of September 1, 1968. I think you should

clarify that in view of the other exhibits.

Q. The overlay, Plaintiff's Exhibit 4, is a representation

of the non-whites in the various census tracts as of Sep-

tember 1, 1968? A. Right.

[27] Q. Now I show you a document marked Plaintiff’s

Exhibit 5 and ask if you will tell us what that is. A. This

is a blank census tract map showing the census tracts within

the Charlotte area, commonly called the urbanized area

of Charlotte.

Q. Who prepared that document, Mr. Green? A. The

base map was prepared by the Bureau of Census.

Q. Do you know the basis for the divisions of the tracts?

A. The Bureau of Census, in connection with a local com-

mittee, establishes census tracts and they try as much as

possible to get homogeneous groups of population, income,

size, not necessarily geographic size but the size of the

population should be fairly consistent. The average of 4000

is the national average within a census tract.

Mr. Waggoner: We object to this line of testi-

mony because it’s based on what he assumes other

18a

Charles L. Green—for Plaintiffs—Direct

people have done and at best on hearsay.

Court: Is this identification necessary for any 4

testimony he is going to give? It’s a map of an area, ©

Do I understand you're going to fill in what you

want the Court to know about his testimony?

Mr. Chambers: Yes, sir.

Court: I think the objection is technically well —

taken. I’ll sustain it.

Q. Mr. Green, is there a publication that sets out how the

[28] census tracts are established? <A. Yes, sir.

Mr. Chambers: I’d like to identify as Plaintiff's

Exhibit 28 a document prepared by ServAnalysis of

Charlotte entitled Charlotte, North Carolina, Census

Tracts 1 through 54, estimates of number of house. |

holds and populations by tract as of June 1, 1966.

Mr. Barkley: It’s not contended that was prepared

by him, is it? a

Mr. Chambers: By Mr. Green. I’m just going to |

establish that.

oe ae eee” ee ool mas

on Pe ee ee sane

Q. Would you look at that document, Mr. Green, and F

tell us what it is? A. It is an update of the 1960 census

figures, estimated number of households and population

by census tract in the ’54 urban census tracts of Charlotte

as of the lst of June, 1966.

Court: Updated from—?

A. 1960 census ‘figures.

Q. Did you prepare this document, Mr. Green? A. I did.

Q. I show you another document marked Plaintiff’s Ex-

hibit 6 and ask if you will state what this is? A. This is a

19a

Charles L. Green—for Plaintiffs—Direct

map showing by census tract the percentage of non-white

population in Charlotte as of 1960. These are 1960 census

figures.

[29] Q. Did you prepare that document, Mr. Green?

A. I did, sir.

Q. I show you a document marked Plaintiff’s Exhibit 7

and ask if you will state what that is. A. This is an overlay

for Exhibit 6, which is the previous map, showing the esti-

mated percentages of non-white population in the census

tracts of Charlotte as of 1968, September 1.

Q. I show you a document marked Plaintiff’s Exhibit 8

and ask if you will state what that document is. A. This

is a map showing by census tracts the median family in-

come for the Charlotte census tracts as of 1960. These also

are Census Bureau figures.

Court: Is this exhibit something you prepared?

A. Yes, sir.

Court: You prepared #4, #6, #7 and#8?

A. That is correct, Your Honor.

Q. Mr. Green, would you state to the Vourt the pro-

cedure you followed in preparing Exhibit #4? A. Well,

having the 1960 census figures and the percentages and

the number of people within the various tracts according

to race, I had conferences with the City Planning Com-

mission, with the Redevelopment Board, relocation people,

with real estate agents, with the Chamber of Commerce,

with various and sundry people who would have some

knowledge of any shift in population since 1960. We estab-

lished roughly the areas [30] into which there had been

population shifts, especially of the non-white. That

20a

Charles L. Green—for Plaintiffs—Direct

was really the main thing we were trying to determine,

where the non-white population had migrated since 1960.

Having established these areas, we were then able to work

from small maps that the Planning Commission has and

street by street to come up with percentages of the non-

white population on these streets. This was done only in

the areas of transition. There were some areas that were

quite obvious there had been no change, no significant

change. Having established these percentages, of non- —

Re

x

:

Q

q

¥

‘%

4

white population, we could then equate that to numerical :

population. The overlay was prepared from the percent-

ages. It is color-coded in 20% gradations.

Q. Looking at the overlay, Mr. Green, would you tell the

Court the various percentages represented by the colors!

Court: Are they set out on the face of the exhibit!

Mr. Chambers: Yes, sir.

Q. Would you accompany me over here to this map and |

explain how this overlay is to work on the maps of the

School Board? (The witness does so.) Mr. Green, where

would your greatest concentration of non-whites reside?

A. Your greatest concentration of non-whites would be in

the areas of shaded purple. That percentage runs from

81 to 100% of non-white population, in these purple areas.

Q. That would include this section down here indicated

by 23? £31] A. That would include census tract 23.

Court: Is that near Griertown?

A. Yes, sir.

Q. As you indicated just a moment ago, the overlay is

based on the various census tracts? A. That is correct. The

black lines on the overlay are the outlines of the census tract

RN Te?

21a

Charles L. Green—for Plaintiffs—Direct

boundaries. These are the census tract numbers.

Q. Now, while you’re there, Plaintiff’s Exhibit 8 is also

based on the census tract as of 1960, is that right?

Court: This exhibit on the board, #4 and 24, this

speaks as of what time, 1968?

A. Yes, sir.

Court: Go ahead.

Q. This exhibit shows the income level in the community

as of 1960, is that correct? A. That is correct.

Court: You’re talking now about exhibit what?

Mr. Chambers: Exhibit 8.

Q. The only difference in your Exhibits 6 and 7 and

Exhibit 4 is that you show a change in the population in

Exhibit 6 and 7 from 1960 to 1968, A. Right.

Q. Take the stand. (The witness does so.)

Mr. Chambers: I’d like to mark as Plaintiffs Ex-

hibit [32] 29 copies of the census tracts 39 and 36,

and as Plaintiff’s Exhibit 30 copy of the census

tract 38.

Q. Mr. Green, would you look at Exhibit 29 and explain

to the Court what that is? A. Your Honor, this is a more

detailed map of all portions of these two census tracts.

They are two that are in transition as far as black and

white inhabitants go.

Court: Those tracts are what?

22a

Charles L. Green—for Plaintiffs—Cross

A. Tract 36 and Tract 39.

Court: Where is that in the town?

A. Both of these tracts are bounded on the north by the

Southern Railway tracks. They are in the western part

of town, West Boulevard runs through them. You get into

the Clanton Park area.

Q. Would you look at Exhibit 30 and tell the Court what

that exhibit is? A. This is also a more detailed map of

census tract 38 which is north of Yorkmont Road. It runs

over off the Revolution Park area. All three of these tracts

are together. This is the northern portion and this includes

also portions of the Clanton Park, Rolling Wood area.

Q. Mr. Green, you prepared the Exhibit 4, the Exhibit

6 and 7, the Exhibit 29 and 30 which you have just been

testifying about. In your opinion do they truly and ac-

curately represent the non-white population in the County

of Mecklenburg? [33] A. Yes, sir, I think they do. We

consider they are accurate within plus or minus 5% which,

in the fields of statistics, is quite an acceptable figure.

Q. You also prepared Exhibit 8, which is the income dis-

tribution by census tract for 1960. In your opinion does

that exhibit truly and accurately represent the income by

census tract for 1960? A. I think that as far as Govern-

figures go, that is 100% accurate.” -

Mr. Chambers: I have no further questions.

Cross Examination by Mr. Barkley:

Q. Mr. Green, what is your profession? A. Marketing

research.

Q. Did you graduate from college in Marketing Research!

23a

Charles L. Green—for Plaintiffs—Cross

A. No, sir. My degree is Bachelor of Science on Commerce.

It included courses in marketing, marketing research, statis-

tics. At that time we were required to write a thesis for a

degree and my thesis was in the field of Marketing and

Research, or Polling, really, at the time.

Q. Where did you graduate? A. Washington and Lee

University.

Q. When did you graduate? A. 1949.

Q. And you went into this business in 1954? [34] A.

Yes, sir.

Q. For whom do you prepare charts and make surveys

of this nature? Have you done this before? A. Yes. Some

of my clients have included local banks in connection with

the location of branch banks, the Chamber of Commerce,

the Model Cities people, several insurance companies. There

is a wide range of people who need and use marketing re-

search of one kind or another.

Q. And your specialty is Marketing Research, I would

figure. A. Yes, sir. AP i

Q. Now, this overlay that you have here, Exhibit +4, it’s

not based on school attendance lines under any circum-

stances, is it? A. No. My commission was to work by

census tracts.

Q. And you worked solely by census tracts? A. That is

correct, yes, sir.

Q. And you have no knowledge as to the attendance areas

in those particular sections? A. Not as such, no, sir. I

tried to do no correlation between the two.

Q. Can you tell us the approximate distance between the

southern boundary of this purple, which I believe you say is

colored, and the northern boundary, just your best estimate

as to the number of blocks or miles that it would be. A.

Sir, would you object if I came closer?

24a

Charles L. Green—for Plaintiffs—Cross

£35] Q. Well, the northern boundary of the Negro area 3

with the southern boundary of the Negro area, whick ap. ©

pears to be about Dilworth Road. A. It runs up to I-85, if 7

I am not mistaken.

Q. That is what it may be, yes. A. Well, I would esti. |

mate that that would possibly be five miles.

Q. Now what is the yellow here, the orange, what is this 4

supposed to show? A. You have the color-coding chart on |

the overlay, sir. I do not have it before me.

Q. You don’t remember what your code was? A. No, 4

sir, I code so many things it’s difficult to remember.

Q. Well, on your code of orange you have 61-80%, what 4

does that mean? A. That means that within the census ~

tracts coded in orange your estimated non-white popula- q

tion is between 61 and 80%.

Q. It would be between 61 and 80%? A. Yes, sir.

Q. Now, what area of the community is that, do you A

know? A. That is west of Pineville Road and parts of ©

South Boulevard, your large area there.

Q. Well, would that also take in large residential areas

in there? A. Yes, sir. Parts of those tracts are industrial- —

ized but the southern part of, I think it’s tract 38, the lower

part there, [36] has had a tremendous residential growth

in the past several years.

Q. And you say that is only 61% white? A. Non-white,

sir.

Q. 61% non-white? A. Yes, sir.

Q. Do I understand that a majority of the people living :

in the area shown by the orange color would be Negro!

A. That is correct.

Q. What residential areas does it embrace?

25a

Charles L. Green—for Plaintiffs—Cross

Mr. Chambers: Your Honor, Mr. Green would like

to come down and look at the map.

Court: Go on down and look at the map.

A. I would like to look at it, sir. (The witness goes to the

map.)

Q. This area here 38 and 39, first tell me, if you can,

roughly where does it run? A. This is Camp Green, I be-

lieve it runs south of the Southern Railway tracks over to

the Wallace Neil Road. It runs then on Byrum Drive and

down to Beam Road to the Arrowood Road and then over

to the Pineville Road.

Q. The southern part of that tract is Pineville Road,

then? A. The boundary, yes, sir. ,

Court: Mr. Green, you’re going to get me con-

fused right at the beginning. I think Pineville Road

runs [37] north and south and the Southern Rail-

road runs east and west. I’m wrong, of course, geo

graphically, but that’s the way it always seems fo

me. You're talking about an area west of the Pive-

ville Road and south of the Southern paige gen-

erally speaking?

A. Yes.

Court: And it runs generally along the west side

of South Boulevard and Pineville Road for three or

four miles and extends along the Airport Road and

south of that?

la

A. Yes, sir.

Court: What is the northern boundary, the upper

boundary the way the map is hanging now?

26a

Charles L. Green—for Plaintiffs—Cross

A. The upper boundary would be the Southern Railway, —

Q. And what is this neighborhood in here? A. Arrowood

Road down here. |

Q. And you say that is 60% black? A. Between 60 and

80%, yes, sir. You see, you have a large concentration up

in these areas.

Q. What does this green mean? Is that industrial or busi-

ness? A. No, sir. That means between 41 and 60% of the

population is non-white. The witness returns to the stand.)

Q. Did you make the samples yourself from which you

determined your estimate of the population within the

area? A. I don’t understand your question, sir.

[38] Q. Did you examine the residents to determine the

number of Negro residents in a given area? A. Yes, we

sampled. We did a great deal of visual.inspection.

Q. How many people would you see during the course of

your sampling? A. In certain areas there was no need to

sample. In a transition area in some cases we checked each

household. ree

Q. What are the transition streets or areas, can you tell |

me that? A. I can tell you by tract numbers. Would that

help any?

Court: It won’t mean a thing.

A. Well, your main areas are in the Clanton Park, Rolling

Wood and Barringer Wood areas. You have some transi-

tion up off Tuckasegee Road. You have had a great deal

over in the northeastern part of town, headed up towards

North Charlotte, starting at the Seaboard Railroad tracks

and working up north towards the North Charlotte area,

up through Belmont and Villa Heights. That is in a tremen-

dous state of transition. You’re having some transition off

27a

Charles L. Green—for Plaintiffs—Cross

North Tryon Street. Those are the major areas of transi-

tion.

Q. Your study wasn’t concerned with the white race as

far as its location and transition. A. Only in respect to if

you get percentages for one, you have the percentage for

the other.

Q. That would be by deducting the black percentage from

the [39] total, would it not? A. Yes, sir, that’s correct.

Court: Did your studies take into account thaf

we’ve got a lot of pastureland where there used to be

a lot of people living?

A. We allowed for that, yes, sir. It also takes into con-

sideration the fact that there has been a considerable

amount of demolition of housing through the Urban Re-

newal Programs and express right-of-ways, and such.

Q. You were really looking for transition areas, weren’t

yout A. I was looking for the total picture. The transi-

tion areas were the ones that we had to devote the most time

to. There was no point, really, in taking a sample of the

Greenville area, for instance, because that is, I would say,

100% non-white population.

Mr. Barkley: That is all I care to ask him, if it

please the Court.

Mr. Chambers: Does the Court have any ques-

tions?

Court: No, sir.

Mr. Chambers: Thank you very much, Mr. Green.

[41] *¢¢@

28a

Daniel O. Hennigan—for Plaintiffs—Direct

Dantet O. Hennican, a witness for the plaintiffs, having

first been duly sworn, was examined and testified as fol- |

lows: ,

Direct Examination by Mr. Chambers:

Q. Will you state your na:ne, please? A. I am Daniel ©

O. Hennigan. The O is Othello.

Q. What is your address, Mr. Hennigan? A. 2500 New.

land Road.

Q. That’s here in Charlotte. A. Here in Charlotte.

Q. What is your occupation? A. I am an ordained Pres.

byterian Minister and a real estate broker.

Q. Would you tell the Court your educational back-

ground? [42] A. Yes. I completed the elementary and

high school education, Salisbury, North Carolina; I am a>

graduate of Johnson C. Smith University, both college and

seminary with majors in mathematics and Bachelor of

Divinity.

Q. Have you had any further study since then? A. Not

formally. I have attended a number of institutes in rela-

tionship to appraising and in relationship to the pursuit of

brokerage work, etc. I have not pursued anything in terms

of a Masters or Doctorate.

Q. Were you born in Charlotte? A. I was not. I was

born in Salisbury and at the age of 2 I came to Charlotte.

My father and grandparents, this is their home, and from

age 2 on I have lived principally in Charlotte and Salisbury,

North Carolina. Because of family reasons I did my ele-

mentary and high sehen! education in Salisbury. However,

until that time i ived''n Charlotte and after which I re-

turned to Charlotte.

Q. Where did you live when you first moved to Charlotte!

29a

Daniel O. Hennigan—for Plaintiffs—Direct

A. My home place is on Douglas Street, 2224-26, and my

grandparents on my father’s side have lived here as long as

I can remember.

Q. Is Douglas Street in the northwestern part of Char-

lotte? A. It is.

Q. Is it out near Johnson C. Smith University? A. Be-

yond Johnson C. Smith University. Douglas Street inter-

sects £43] Beatties Ford Road, or enters Beatties Ford

Road. It does not go all the way across, just in front of the

City Water Works.

Q. When you first moved to Charlotte had Beatties Ford

Road developed to the extent that it is today? A. It had

not. Beatties Ford Road was, of course, one of the main

and respected streets and so was Douglas Street at that

time and perhaps was the section where most of the echelon

Negroes lived when I was a boy.

Court: What is your age, Mr. Hennigan?

A. Sorry you asked that, sir, but I am 43.

Q. Now, when you first moved to Charlotte had the Grier-

town area been developed to the extent that it is today?

A. Grier Heights had not been developed. When I first

moved to Charlotte there was some scattered families in

that section. Arthur Grier developed the Griertown sec-

tion I think somewhere around age 12 or 13. I was some-

where in that age range when the Grier Heights section de-

veloped as a community as such under the leadership of the

late Mr. Arthur Grier.

Q. Had the Cherry section of Charlotte developed to the

extent that it is today? A. The section in Cherry was a

budding community and had developed to some extent but

not to the extent to which it is today. Cherry, as most of

30a

Daniel O. Hennigan—for_Plaintiffs—Direct

us who are settlers in Charlotte know it, is the section that ©

was principally developed for [44] the convenience of those ©

who were servants to the Myers Park and I believe the Dil-

worth area, and this characteristically is what Cherry has

meant to the City of Charlotte and to us who have lived

here.

Q. Would these servants be black or white?

Mr. Barkley: I don’t want to be interrupting the ~

court but we object to all of this testimony. I take ©

it to be testimony relative to racial patterns. I ©

don’t want to keep interrupting the Court but it is ©

understood we can object to these questions after

they are all in?

Court: Yes, sir. It’s all right with me if you ob- |

ject at any time.

Mr. Barkley: I just don’t think it’s competent.

Court: I have a little trouble knowing what is

relevant and what isn’t. This would be competent,

if relevant, and I think we just have to go ahead and

find out what the relevance is. There may not be

any. You may object any time or later on, if you

want to. The real problem is one of relevance to any

question the Court has to decide.

Mr. Barkley: Yes, sir, I think relevance is more

correct than my idea of incompetency. The point

that I am undertaking to make is that the testimony

with reference to racial patterns, residential pat-

terns, is [45] not relevant to this case.

Court: I’d have to turn my strainer down a little

finer than I have it now to say it’s not relevant. So

let’s go on and see what he says. If it’s not relevant,

it will be disregarded.

a La la

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3la

Daniel O. Hennigan—for Plaintiffs—Direct

Q. Mr. Hennigan, what were basically the Negro or

black sections of Charlotte when you moved to Charlotte?

Court: When is this you’re talking about now,

what year?

Q. What year did you move here, Mr. Hennigan? A.

1927, or ’28.

Q. What basically were the Negro or black areas of

Charlotte at that time? A. Greenville was a Negro com-

munity at that time. The Brooklyn area and, of course, the

First Ward area, and we have mentioned already the Cherry

community and of course, the Grier Heights area. These

were the principal Negro communities at the time I came to

Charlotte.

Court: How do you locate the Greenville area

today?

A. How do I locate it?

Court: How would you describe it?

A. Generally the northwest section. Statesville Avenue

back over to Beatties Ford Road and Beatties Ford Road

on now to the new I-85 which, I guess, would be a natural

divider. We normally consider it to be in the northwest

section.

[46] Court: How far into town do you come in

locating what you refer to as Greenville?

A. We come to the Seaboard Railroad. That comes across,

let’s see—there’s a school there on Burton Street, Fairview

32a

Daniel O. Hennigan—for Plaintiffs—Direct

I believe it is, and the Seaboard Railroad track comes across

there on the other side of that property and on—

Court: Generally north between Beatties Ford

and Statesville Road?

A. That’s right. Oaklawn Avenue, perhaps, would be the

other boarder for Greenville going north? |

Court: Oaklawn?

A. Oaklawn.

Court: Oaklawn is a Quartermaster Depot, isn’t

it?

A. No, that’s on Statesville Avenue, between Graham and

Statesville, and Oaklawn is, I guess, the last natural thor-

oughfare this side of Newland Road and the next thorough-

fare going across to Beatties Ford would be 1-85.

Mr. Chambers: I’d like to identify as Plaintiff's

Exhibit 31 a map of the City of Charlotte as of 1950

with various census tracts and wards.

Mr. Barkley: Let the map speak for itself. We

admit the source of the map is as stated on the bot-

tom but we don’t admit anything else.

Court: All right, sir.

Mr. Chambers: And as Plaintiff’s Exhibit 32,

census [47] population figures by wards for the City

of Charlotte 1940.

Q. Mr. Hennigan, you were talking about the general

Negro areas of the City as of the time that you moved

—«#~

Dar

lennigan—for Plaintiffs—Direct

33a

here. Coul

areas Y°".int out by words on the Exhibit 31 the

normally “ferring to? A. Yes, I can, What we

this maP ‘ be the Brooklyn area is designated on

First War 1 and 2. What we consider to be the

cormally—

“0 say that First Ward was thought of

A. No, I Brooklyn?

ea is

= eaodr that what we consider to be the Brook-

north of 24 as Wards 2 and 1 on this map. What

as Wardser to be First Ward is that section

le Street and I believe it’s shown here

(

We

isn’t the line between First and Second

A. Just #rade or Elizabeth Avenue?

This is n

correct. think we have the map turned around.

north of In that particular case, that would be

that withTrade would be Wards 1 and 2 and

then thahld be Wards 3 and 4. May I correct

area is dien being in its proper direction we find

we DOT™normally consider to be the Brooklyn

designaty, this map as Wards 3 and 2 and what

Q. Novr to be £48] the First Ward area is

Smith bGap as Wards 1 and 4.

4 would nid the residents around Johnson C.

map. “"n that map, in which ward? A. In Ward

ignation of Johnson C. Smith on this

g3 beyond Ward 4.

1 First Ward extend west of Tryon

1 not, did it?

34a

Daniel O. Hennigan—for Plaintiffs—Direct

A. It did not extend west of Tryon. It extended east of

North Tryon. 4

Court: I had the notion that the wards were num. 7

bered starting at Tryon you just go around th ©

clock, 1, 2, 3 and 4, clockwise. 3

A. That’s generally correct. I believe those four ward —

are around Tryon Street and I believe Ward 4 is fron |

Tryon to Graham or Statesville, basically, and then of ©

course the Greenville area adjoining Ward 4 going ina ~

northerly direction which is not shown on that map.

Court: Does this make a difference in reading th —

exhibits? :

Mr. Chambers: No, Your Honor, we just wantedto *

indicate where the areas were. 4

Court: Let’s go on to something else, then.

Q. Mr. Hennigan, you have had an opportunity to ob

serve the growth and development of Charlotte since yn —

moved to Charlotte? [49] A. Yes, I have. e

Q. Now, how long have you been in real estate as:

broker? A. Since the spring of 1962,

Q. Has all of that time been here in Charlot.:? A. It

has been.

Q. Have you in your work had an opportunity to pur-

chase property for clients? A. I have. ,

Q. Have you had an opportunity to sell property for |

clients? A. I have. 4

Q. Have you had an opportunity to rent apartments or f 7

houses for clients? A. I have. 7”

Q. Have you had an opportunity to know the City of

Charlotte residentially? A. I have. 3

35a

Daniel O. Hennigan—for Plaintiffs—Direct

Q. Have you in your work, Mr. Hennigan, encountered

any discrimination in the sale or rental of houses?

Mr. Barkley: I’ll object to that. I don’t believe—

how can you answer a question like that.

Court: What is the pertinence of this, Mr. Cham-

bers?

Mr. Chambers: Your Honor, our contention here

is that the residential housing pattern has developed

through public and private discrimination and we

propose to show through Mr. Hennigan and his ex-

perience in real [50] estate that we have had private

discrimination in Charlotte in the sale and rental

of housing. The Fourth Circuit Court of Appeals

in the Norfolk school case indicated this would be a

relevant and pertinent inquiry by the Court and we

were trying to establish here that we have the hous-

ing pattern because of practices that the Court said

should be considered by the District Court. I might

say further that in the Fourth Circuit opinion that

we are referring to, Brewer versus Norfolk City

School Board, the Court specifically indicated to

the District Court that the inquiry there should be

whether the racial housing pattern in the City of

Norfolk developed from public or private discrimina-

tion or both and that, if so, that the School Board

would not be able to utilize the basic boundary lines

they were then employing for the assignment of high

school students to the school. This is our conten-

tion here relevant to the elementary, junior high

and senior high schools.

Mr. Waggoner: We have a copy of the Brewer

ease and I can read the language Mr. Chambers was

36a

Colloquy

referring to in its entirety, if you like. It’s about ©

one paragraph.

Court: I’m a little puzzled. You know, it’s rough

enough on a green judge when you allege what ©

you’re complaining about, but when you don’t al-

lege what you’re [51] complaining about the theory

is just a little strange, you make it even harder. You

don’t say anything in your pleadings about this

subject you’re now going into.

Mr. Chambers: In the motion for further relief

we do, Your Honor.

Court: This is what I’ve just gotten through read-

ing and I don’t find anything in here on that point.

That’s not the end to inquiry on it, of course, but

I just say you're launching off on a mission of your

own on uncharted country as far as this case is |

concerned. Does it make any difference on your

theory whether you do or don’t prove the motive

by which a pattern of living is developed?

Mr. Chamber: Your Honor—

Court: I don’t think we can sit here and try the

whole community and go into all the forty thousand

reasons people build houses where they did as op-

posed to another over a forty-year period.

Mr. Chambers: We would contend that it should >

not make any difference. However, the Fourth fF

Circuit said that this should be an inquiry by the

District Court.

Court: Let me see the Brewer opinion.

Mr. Waggoner: Yes, sir. This is not very clear.

Court: Here it is. I don’t see that an historical

[52] study of why people bought, built, sold and

rented houses is going to help us any, but if you

want to pursue it, 1'll hear what he knows about it.

37a

Daniel O. Hennigan—for Plaintiffs—Direct

Q. Mr. Hennigan, have you encountered in your practice

any discrimination in the sale, racial discrimination in the

sale or rental of houses in Charlotte?

Mr. Barkley: I object to that as to the form of

the question. Discrimination, I take it, is a conclu-

sion from facts and not a fact itself.

Mr. Chambers: I’ll rephrase the question.

Court: I think the objection is well taken. I don’t

know the history of Charlotte thoroughly but I would

figure from what the place looked like twenty-five

years ago that there had been mighty little built

here from 1930 to about 1947, or ’46, ’45, and that

whatever pattern was established, whatever building

was done in these zones you’re talking about had

already been done in 1927 when he moved to town.

This is a theory you’re developing by an incompetent

witness, I think. What he could testify about what

happened after 1962 in the way of discrimination

probably wouldn’t be of any pertinence because you

had a situation existing at that time in which the

present school system operated. Am I wrong about

that?

Mr. Chambers: Your Honor, I think we can

establish [53] some practices of discrimination that

further perpetuated the housing pattern subsequent

to 62. In addition, I think that from 1929 when he

moved to Charlotte until the time that he actually

became involved in real estate, he can testify of his

own knowledge of practices that existed that con-

tributed to the racial housing pattern. That testi-

mony as well as that subsequent to 1962 would

clearly be competent. We have some other matters

38a

Daniel O. Hennigan—for Plaintiffs—Direct

that are now in evidence relative to discriminatory ©

practices even prior to 1929. We didn’t propose ©

through live witnesses to go back and show exactly |

how every house was set up or the housing pattern ~

developed prior to the time he came in. 4

Court: To make this sort of question competent, ©

I think you just probably have to ask him for oc- 7

casions he knew of that people had refused to buy, ~

sell or rent to people of the Negro race. This is

what you’re talking about, isn’t it?

Mr. Chambers: That’s correct, Your Honor. 4

Court: If he knows of instances of that sort, why —

he can testify to that. a

Q. Mr. Hennigan, do you know of any instances where

Negroes have been denied the right to purchase houses in |

white or predominantly white areas in the City of Char-

lotte? A. I know of, yes, some instances where this has

been true [54] I was not the collaborating broker, how-

ever, in instances where Negroes have actually gone to see

houses and have offered to buy and did not have the

opportunity to do so. I have had personal experience where

Negroes—and I have been a part of three groups where

we have sought to buy land that we could develop housing

for our people or for all people and for various reasons

even though signs have been on these properties, either

the selling broker would come back and say either we have

a contract or I’m sorry, the price has suddenly gone up,

and in other instances the property was suddenly taken off

the market and reappeared three and four months later.

Mr. Barkley: Your Honor, I move that answer

be stricken out on the ground that it states no fact

39a

Daniel O. Hennigan—for Plaintiffs—Direct

whatsoever that would tend to show any discrimina-

tion.

Court: Motion denied.

Q. Mr. Hennigan, let me ask this; have you followed

the Charlotte News & Observer in its advertisement of

housing in the City of Charlotte? A. I have.

Mr. Barkley: I object to that.

Court: Objection overruled.

Q. Have you followed the Charlotte News in its adver-

tising of housing in the City of Charlotte? A. I have.

[55] Q. Prior to 1968, Mr. Hennigan, would you state

whether they advertised housing for colored and housing

for white? A. This has been the pattern of advertising

as long as I can remember.

Mr. Barkley: Move that +e stricken, the testimony

what some third party has done.

Court: Motion denied.

Q. Now, Mr. Hennigan, would you tell us further some of

the specific instances you know of where Negroes have been

unable to purchase houses in white or predominantly white

areas? A. I was involved, I was the broker in one instance

where I had a house for sale in a white community and, of

course, I had a purchaser. In this instance it was not a

case of a non-cooperative owner, the owner was perfectly

willing to sell the house to any qualified buyer. However,

upon the submission of an application for a mortgage loan,

the lending institution refused to get involved on the

grounds that it might cause some reprisals on the part of

40a

Daniel O. Hennigan—for Plaintiffs—Direct

their patronizing clientele if they should make a loan in this |

particular area.

Mr. Waggoner: Objection, motion to strike as to |

what the lending institution did, or reason it did the |

same.

Court: Motion denied.

Q. Go ahead, Mr. Hennigan. A. I think that completes ”

that story and that was the end of that case. We, of course, |

could not find a lender that would make [56] a loan to this ©

particular family in this particular instance. I had, of ©

course, another experience where I had a house that was |

listed. Again, the owner had no compunctions about who |

bought the house. The house was for sale and the house i

was, of course, put on the market and was the next day |

bought off the market. The presumption was...

Mr. Waggoner: Objection.

Court: Don’t tell us about presumptions, Tell us i,

what you know.

A. All right. The house was bought off the market by a

mortgage company who bought it in for a community or- Ff)

ganization that was formed in this particular community.

There was an agreement when these homes were initially

sold by this same mortgage company that developed the

area with regard to the swimming pool. It was a covenant

relationship whereby the initial owner had right to share

and use the swimming pool but in the event that the prop

erty should be sold and should be sold to a client that was

not desirable to this particular association, then the as

sociation had the right to buy the property back in, and

the house was bought by this particular firm for this as-

4la

Daniel O. Hennigan—for Plaintiffs—Direct

sociation, and subsequently sold to a white family.

Q. Are you familiar with the development of Double

Oaks? A. I am.

Q. Now what section of Charlotte i is that in, Mr. Henni-

gan? A. Double Oaks is just beyond the Greenville area to

the north [57] of Oaklawn Avenue in the northwest section

of the City of Charlotte.

Q. Is that presently occupied by Negroes or whites? A.

Negroes.

Q. Was there built at the same time that Double Oaks

was built an apartment project that is now occupied pre-

dominantly by whites? A. In what community, sir?

Q. In the section of Charlotte near Wilkinson Blvd. A.

These two projects were built, according to my recollection,

about the same time and the one on Wilkinson was for

whites and the one called Double Oaks was for Negroes.

Q. Are you familiar with the development of Dalebrook?

A. I am.

Q. Will you tell the Court approximately where that sec-

tion is located in the City of Charlotte? A. Dalebrook is

in the northwest section fronting on Newland Road, bound

by I-85. Incidentally, I happen to live in that community.

Q. Would you tell the Court whether a similar white

section was built in the City of Charlotte at the same time

by the same developer? A. Yes, sir. There were several

sub-divisions at the same time being built by the same de-

veloper and these were for white and the Dalebrook com-

munity was for Negroes.

[58] Q. Are you familiar with the development of Uni-

versity Park? A. I am.

Q. Would you tell the Court what section of town that is

inf A. Northwest section of town. It’s to the west of

Beatties Ford Road. LaSalle Street and I-85 and Beatties

42a

Daniel O. Hennigan—for Plaintiffs—Direct

Ford Road are the boundaries of this subdivision.

Q. Is that section or subdivision occupied by Negroes or

whites? A. Negroes.

Q. Are you familiar with the development of Northwood

Estates? A. I am.

Q. Would you tell the Court whether that section is oc-

cupied by Negroes or whites? A. It is occupied by Ne-

groes. It’s also in the northwest section beyond I-85. Prior

to its development it was in the county, the Long Creek com-

munity. The developer was able to have it included as a

part of the City of Charlotte and I’m sure it’s the way it’s

classified currently. It is the only community outside of the

city limits of Charlotte, so far as I know of, for Negroes

that is incorporated as a part of the City of Charlotte.

Q. Let’s indicate something on the map. Is this the area

here, Northwood Estates?

Court: Is that north of I-85?

Mr. Chambers: North of I-85.

Court: And straddling Beatties Ford Road?

[59] Mr. Chambers: Yes.

A. Northwood Estates fronts on Beatties Ford Road and

runs west from Beatties Ford Road about a quarter of a

mile or maybe half a mile from I-85 going north.

Q. Would this be the section commonly referred to as

University Park? A. That’s right.

Q. That’s tract 46. A. I can’t see the tract but from what

you say and from what I can see from here, I didn’t bring

my glasses—I do have an impairment—that is it.

Q. Would this be the section commonly referred to as the

Dalebrook section, tract 487 A. To the east of Newland

Road, bounded by Newland and I-85.

43a

Daniel O. Hennigan—for Plaintiffs—Direct

Q. That’s correct? A. Yes.

Q. Mr. Hennigan, had Myers Park been developed at the

time you came into the city? A. Yes. It was a developed

community. However, it has developed some since that

time. Dilworth was budding and the new community at the

time I came.

Court: What did you say was the new community?

A. Dilworth.

Court: Dilworth is a much older community than

Myers Park, isn’t it, Mr. Henmgan?

[60] A. Both of them are old communities. When I say

budding community, perhaps it was an expanding com-

munity at the time. I am not saying that Dilworth was

beginning or a new community at that particular time,

but Myers Park basically was developed and has not really

developed substantially beyond the point that it was, I

think, twenty-five or thirty years ago. However, the Dil-

worth community has had some substantial numbers of new

homes built in that length of time.

Court: I think you’ve got it confused with busi-

ness building but I don’t think it matters here.

A. Well, of course, you know, we didn’t really have much

occasion to go into these communities unless we had a

specific purpose there and that primarily would have been

to perform some service. Most of what we knew is what

we heard or read. So I could be in error on a lot of that.

Q. Mr. Hennigan, are you a member of the Charlotte

Board of Realtors? A. I am.

t4a

Daniel O. Hennigan—for Plaintiff s—Direct

Q. How long have you been a member of that organiza.

tiont A. About a year-and a half. October a year ago

I was admitted to the Board of Realtors.

Q. Will you tell the Court what the Charlotte Board of

Realtors ist A. The Charlotte Board of Realtors is a

trade organization composed of persons who are interested

in the real estate industry £61] or those who are practicing

real estate brokerage and who subscribe to a specific code |

of ethics. :

Q. How many Negroes are members of that Board! §

A. One, and that’s me. ;

Q. Would you tell the Court your experience in becom- [

ing a member of the Board of Realtors? A. I'll be glad |

to. I went into real estate in 1962. Of course, there isa §

required state examination. i

Mr. Waggoner: If the Court please, it seems this |

is straying quite far from the inquiry we are about |

today.

Court: I agree with you. Can you give us any :

reason for pursuing this, Mr. Chambers?

Mr. Chambers: Yes, sir. We are trying to estab-

lish, Your Honor that there was not only private

discrimination but institutional discrimination in the

sale and rental housing and we think in this testi-

mony we can point out some evidence to substantiate

the institutional discrimination.

Court: Now let me see where we're going. How

much of your evidence is addressed to this general

area, that the present Charlotte school plan is de-

fective because once upon & time and now people

practice racial discrimination in the sale and renting

of houses? How big a part of your case is this?

45a

Colloquy

Mr. Chambers: We have three witnesses we pro-

pose to [62] call to testify about the discrimination

in the sale and rental of houses.

Court: Let’s try the lawsuit first and then get

around to that. I don’t think it matters at all for the

purpose of the present community problem we're

dealing with why people are living now where they

are now living. I'll be glad to hear you put all that

evidence in but it does not help me in coming to any

conclusion nor the School Board as to what we ought

to do here.

Mr. Chambers: May I request of the Court

whether the Court will take judicial knowledge of

that fact.

Court: I'll be glad to hear your testimony on

whatever you want to offer. I might take judicial

knowledge of more than you can competently prove.

I’d like to get to the lawsuit first.

Mr. Chambers: Your Honor, we considered it an

important part of the lawsuit. We think that a

showing of this further compounds the illegality of

the Board’s utilizing boundary lines on the pattern.

If the Court feels, however, that this evidence would

not be necessary, we can, of course, forego that. We

would request, however, permission to depose the

witnesses that we have.

Court: Well, if you’ve got them here it’s cheaper

for everybody, especially your client and including

the [63] rest of us, to take the testimony while

they’re here. But I’m just telling you I don’t see

where it helps or hurts. I might be more impressed

- by it if you said more about it in the complaint or

motion.

46a

| Daniel O. Hennigan—for Plaintiff s—Direct

Mr. Chambers: We did refer in the motion, we io

thought, to the matter but perhaps not as clearly = |

we should have. We have, in fact, taken a lot for 2.

granted in the motion in terms of what the courts =

were now saying relative to utilization of boundary q

lines. We had assumed that this evidence would be | =

some evidence that the Court would want to consider, ~

Be that as it may, may we have a five minute recess

and regroup our troops and move on to something

else?

want to make out a prima facie case on this theory,

Court: Well, I’m not going to cut you off. If you 4

go head, but maybe under the circumstances that’s 4

the proper thing for you to do, but I think we're

all far more interested in other phases of the case.

Mr. Chambers: Would the Court permit me to go |

ahead and finish with Mr. Hennigan and then go :

into something else?

Court: Sure.

Q. Now, Mr. Hennigan, would you go ahead and describe le

the problems you had in becoming a member of that Board!

A. Yes. After completing the state examination and, of |

course, £64] opening up MY business I did apply for mem —

bership in the Board and I was told that I would have |

to have at least three years of experience and that I would

have to have an office and it would have to meet certain |

PRTEAY ae

prescribed conditions, and etc. At the end of the third |

year I applied again and, of course, Was told that I was

not eligible for membership in that the bylaws had been |

changed and I would have to attend the Realtors Institute

and complete Course 1. I then, of course, applied for ad-

mission to the Realtors Institute and found there was al:

other 47a

ia mnigan—for Plaintiff s—Direct

guess hich was that I had to have three

thirty, was not a member of the Board I

aay enroll in the Institute. After, I

fei four months and conversing with some

the erent real estate brokers in this town

was OF their consideration of this request,

by tons to sign this application form and

had ill and, of course, took Course 1. At

had | then was advised that‘iny enrollment

withupon evidence that was to be received

advi I learned that a state investigation

wound that persons from the state office

for irlotte and had conducted an inquiry

themsiness. And then on Saturday I was

antamination would be given and that I

I g‘ as a full-fledged student and I asked

ga then take Course 2 [65] while I was

Paleing offered the following week, in

if Je some changes in bylaws by the time

I tte and I thought I’d get ahead of the

Itland take Course 2. My examination

mq I did pass Course 1 and was advised

M€ame three endorsers then, of course, .

ane Monday and enroll in Course 2.

ovNharlotte that Saturday afternoon and

Hine three persons who had endorsed

“ne was out of the City and after a

vi I did make an appointment with the

signed it and I went back to Chapel

ind was admitted tentatively on the

ird person who was out of the city

pplication. On Wednesday I was ad-

person had sent them a telegram ex-

-

48a

Daniel O. Hennigan—for Plaintiffs—Direct

pressing his desire to sign and that he would do so and

so I did complete Course 2. I came back to Charlotte and

then went back to apply for membership in the Board and,

having completed Course 1 and 2 successfully, I was ad. |

vised that I could not then enroll or make application un-

less I got a member of the Charlotte Board of Realtors to

get the application form. I could not go to this office to the =

Board office and myself pick up a form and fill it out and |

submit it for consideration. I then talked to some, I guess,

sixty persons, members of the Board, and all of these de ©

clined the invitation to go get an [66] application for me |

and I had an attorney who worked with me and used his =

influence to get some of them to do so. After this I wrote |

the Board a letter and asked the Board of Directors if

they would give me an application as a whole, hence elim. |

inating the necessity of some one person either putting ©

himself. out in this particular way, just to pick up a form —

and give it to me. The Board, of course, declined, indicat- |

ing that this had not been done in the past and saw no ©

reason to break with the tradition to do this for me. I =

believe some four or five months later some Negroes had &

raised a concern that no Negro had been admitted to the |

Board and I believe one such person is present in this |

room, and this was a meeting with the Board of Realtors |}

and some other interested persons and this group was told |

that there was no Negro in the City of Charlotte that |

would qualify for membership in the Board and they then

advised the Board that they understood that I was quali-

fied. The following day I was asked to pursue the matter |

again to see if I couldn’t get an application. It so hap |

pened that I happened to have been in a governmental office ‘

the following day and one of the persons who was a part of Ff

this group wanted to know why I had not been admitted.

49a

Daniel O. Hennigan—for Plaintiffs—Direct

I recited the story I have just recited here and this govern-

mental agency then turned to one of their real estate prac-

titioners and asked if he was aware of this and in the mean-

while the conversation then ended, that this [67] Real Es-

tate Board member agreed to use his influence to get an ap-

plication for me. He picked the phone up in our presence

and called the Board office and after an hour and a half of

conversation by telephone he was advised that if he wanted

to do this he would, of course, have to do it and suffer

any consequences that may come. He assured the person

at the other end of the line that he was willing to assume

any responsibility for any of the consequences and if he

= would leave the application where he could pick it up,

he would be down to get it. I got the application in that

way and this same person said that he would sign it and

he would use his influence to try to get another Board

member to do so, and I went to the other Board member

and indicated all that I had done in the pursuit of this and

this person agreed to sign and then I finally got a third

person. I had to have three. In addition to this I got some

supplementary references from two banks and from two

attorneys that I knew and had worked with down through

the years who could attest to my character and this sort

of thing. I believe about two months later, after a series

of conferences, these conferences centered around the con-

cern that the Board had because my application had regis-

tered interest in becoming a full member of the Board to

include a member of multiple listing. I was advised that

if I pursued this matter of multiple listing that I could

do so but that it would go against me and that perhaps I

could [68] be hurt seriously if I insisted on this.

Q. Would you tell the Court what multiple listing is?

50a

Daniel O. Hennigan—for Plaintiffs—Direct 3

Mr. Waggoner: If Your Honor please, I’d like ) »@

move to strike the last answer. It’s based on state |”

ments attributed to other people, suppositions, it; 4

hypothetical. It has nothing to do with this lawsuit,

it’s irrelevant.

Court: I think so, too. Motion denied.

A. Multiple listing is a separate organization of the Board 4

and— :

Court: You'll have to admit it’s a good story, 4

though. iS

A. And so is the Charlotte Board of Rental Agencie, ~

These are sub-corporations of the overall corporation. Yun 4

do have to be a member of the Board before you can becom ~

a member of multiple listings. Multiple listing is where al =

of the brokers who are members of multiple listing pod ~

listings and any member has the right to show any hom ~

that has been listed and registered with the multiple listing

agency. There is a key, for example, if I were a member 3

of the multiple listing I would have a key and in the event ©

that the house was empty I would not have to say to any:

body when I wanted to go see the house or who I wa’ ©

bringing to see it. However, there is a code of ethics and |”

matter of courtesy. If the home is occupied, naturally the | :

brokers work together and in the interest of the owner the ba '

appointments are normally made through the listing broker.

But all have the right to show [69] it and all have the right | |

to sell it. The agreement is that the commission—and this | 7

is how we make our money in this field—the commissior |

is split between the listing broker and the se.‘ing broker.

Q. Mr. Hennigan, if you were a member of multiple list- |

ing with the Board, you would have the opportunity, would | 7

5la

Daniel O. Hennigan—for Plaintiffs—Direct

you not, to show Negroes homes in white areas that might

be listed in multiple listing? A. I’d have the opportunity

to show anybody a home anywhere in the City of Charlotte

if it’s listed in multiple listing and I would have the op-

portunity to take a Negro and to show a home in a white

community if I were a member of multiple listing.

Court: You are not now a member of the multiple

listing?

A. I am not. We entered into an agreement, sir. I con-

sented that perhaps what they were saying might be real

true and, being young in the field and being in an area all

alone, I did not see I had much opportunity to wage a battle

with this strong body, but I did insist that, well, there is a

fee that we have to pay. Currently it’s $1,200.00 to become a

member and, of course, you have to be approved by the

multiple listing committee and I did ask for the privilege

of knowing and the privilege of joining prior to any subse-

quent changes in the rules or in the governing documents

governing this [70] particular agency. Primarily if any

increase in multiple listing enrollment should occur, I

wanted the right to do this and then I also asked for the

right to work and I asked the Board of Directors to use

their influence among any brokers in the City of Charlotte

who happened to be broadminded enough and willing to

work with a Negro and I insisted that I did not particularly

care for a working relationship or to force a working rela-

tionship on any who did not care to work with me. The

Board agreed to use their influence to do this and also

agreed to give me the privilege to join prior to any subse-

quent changes in the multiple listing bylaws,

52a

Daniel O. Hennigan—for Plaintiffs—Direct

Mr. Chambers: Your Honor, I’d like to mark as |

Plaintiffs Exhibit 32—

Mr. Barkley: I don’t believe we’ve gotten him on

the Board yet, Mr, Chambers.

A. I'm sorry, yes, you're right. After these conferences and

these agreements then, of course, I was admitted to the

Board membership, October a year ago. Of course, from

the time I first pursued this until the time I got in was three

and a half to four years.

Court: Are you selling any more houses?

A. I have not had the cooperation I anticipated. I do have ||

some real friends, I think, at least I hope I have, but we | —

have not been able to get down to a working relationship.

I am not sure I can say just what the character of the rela-

tionship [71] is except we are good friends. We eat to

gether, have dinner occasionally and I am on one committee

that meets about twice a year and this has been the extent

of my participation thus far.

Q. I show you a document marked Plaintiff’s Exhibit 33

and ask you if you will state what this is. A. This is the

Code of Ethics and this is published by the National As.

sociation of Real Estate Board.

Mr. Barkley: We object to that.

Mr. Waggoner: Could we take a look at this before

he reads from it?

Court: Certainly.

EP AERC RoR Ti Stata (oat aed RAZR PRR! CRRA IA

Q. Would you state whether or not as a member of the i

Charlotte Board of Realtors you are governed by that Code

of Ethics? }

53a

Daniel O. Hennigan—for Plaintiffs—Direct

Mr. Barkley: Objection.

A. I am, yes.

Mr. Barkley: That’s another third party’s interest.

I don’t see how it’s got any business in this court...

without someone competent to identify it.

Court: He said it’s a copy of the regulations under

which his trade organization operates and to which

he subscribes. Isn’t that what he said?

Mr. Barkley: Approximately, but I wonder if I

would be competent to sit on the witness stand to

testify to the Code of Ethics of the American Bar

Association.

{72} Court: I think you would, Mr. Barkley, as

well as anybody I know.

Mr. Barkley: Well, I'll try that on Your Honor

some day.

Q. I will show you another document marked Plaintiff’s

Exhibit 34 and ask you to state what that is. A. This is

a circular that, of course, came to all members of the

Board of Realtors. The date is March 8, 1968, and I did

receive a copy of this and it has to do with the concern

for the legislature to abolish the practice of allowing real

estate brokers to list properties honoring the prerogative

of the owner to say to whom this house may be sold and

to whom it may not be sold.

Q. Was that sent out by—

Court: Now, what you said probably made good

English but I got lost in it. That circular is in

favor of—

54a

Daniel O. Hennigan—for Plaintiffs—Direct

A. To have the option to say this. As perhaps most you

know, the Real Estate Board nationally objected to the

recent legislature which made it unlawful for an owner

to restrict in his listing agreement to whom the house may |

be sold and this has been one of the practices, I think :

nationally and certainly here in Charlotte, if an owner

listed property with a real estate agent, the owner had the _

right to say it may be sold to whites and not to Negroes

and many of these listings were accepted under this ar.

rangement. Of course, when this [73] open housing legis.

lation came up, then of course the real. estate industry

nationally was a lobbying agency agaiy@) the enactment

of open housing legislation. This circular, of course, came

from our Board. I received a copy of it and have one in

my file, asking that we use our support to write our legis.

lators and ask them to vote against this particular bill

and that the inherent right of the owner should be sup-

ported and that this should be a continuing practice.

Q. I show. you a document marked Plaintiff’s Exhibit 35

and if that is a circular also from the Charlotte Board

of Realtors. A. This is.

Q. Did you receive such a document in the mail? A. I

did.

a

ie

+S

.

rf

Q. As a member of the Board of Realtors? A. That's _

right. Might I say this, I don’t know what the record would

indicate but I did respond to this circular and I wrote

to our Congressmen and I did ask them to use their in-

fluence to support the bill and I think at one of our meet-

ings it was indicated that perhaps I was the only Board .

member that did this.

Court: What is the date of that circular?

A. March 25, 1968.

i

i

|

55a

Daniel O. Hennigan—for Plaintiffs—Direct

Court: What did they ask you to do?

A. This comes from the Board of Realtors and Home

Builders Association of Charlotte. The subject is: Forced

Housing. £74] It indicates that the Directors of the Board

of Realtors and the Directors of the Home Builders

Association hereby reassert their support of the principle

of equal opportunity in the acquisition or employment of

real property . . . enjoyment, rather, of real property,

and the right of individuals to determine the disposition

of that property, and of course it goes on to say how they

feel about it and they also indicate on this letter that the

forced housing measure is supposed to remove discrimina-

tion in housing and, of course, the contention at that time

was that they were taking the right away from the owner

and giving it to a minority group and to take one right

and to give it to another was discriminatory. This is

the essence of this letter.

Q. Mr. Hennigan, the section of the Code of Ethics that

dealt with the right of the owner to direct how his property

should be sold or rented is what section? A. This is Part 2,

Article 2, and the heading is Relationship to Client, and

of course this is the article that, according to the Code

of Ethics, gave to the real estate broker the real tie with

an owner and indicated that his first responsibility, of

course, was to the owner or the person who lists property

with him and his rights should be protected above all else

and that this was the moral responsibility of the realtor,

to uphold and protect the private interests of the owner

of the property, and of course this is the article that

primarily £75] gave to the realtor the strength in his claim

that the right of the owner was, of course, inherent and

that he then as an agent for the owner should have his first

56a

Daniel O. Hennigan—for Plaintiffs—Direct

loyalty to the owner and the request of the owner. So ther

the owner had the right when the property was listed with

a broker to spell out how this property would be disposed

of and realtor, then, of course, was bound contractually |

to an agreement with this owner in terms of a listing’

agreement. :

Q. Would one be in violation of the Code of Ethics ass

real estate agent if one sought to sell a house to a person

of a race other than the one indicated by the owner? A”

Today that is true. This, of course, in our national associa. |

tion and in our state association last September all of this, ©

of course, has been legally clarified. The real estate indus

try has been advised that it is no longer constitutional for ~

this to be done and any broker now listing property is in ”

violation to list it indicating that it must be sold tos

white or to a Negro or to some other ethnic group. So the |”

listing agreements today do not carry along with it thes |

built-in prerequisites that the owner has spelled out.

Q. You have had an opportunity to look at Plaintiff: e

Exhibit 4, which is this overlay here, indicating the racial 4%

composition of the census tracts of the City of Charlotte é

and the County of Mecklenburg, have you not? A. I have. E d

[76] Q. You’ve also had an opportunity to observe the | 7

various neighborhoods in the City of Charlotte— 4

Mr. Barkley: I object to his leading now. 4

Court: That’s the poorest objection you made yet, | 3

Mr. Barkley. That’s the only one you made that |”

hasn’t bothered me. é

Q. Have you, Mr. Hennigan, hsd an opportunity to ob 4

serve the various racial housing situations in Charlotte! |

A. Yes, I have. E

57a

Paul R. Leonard—for Plaintiffs—Direct

Q. In other words, you know where the blacks stay and

where the whites stay generally? A. Yes, I do.

Q. In your opinion does this map, overlay Exhibit 4,

fairly and accurately depict where the blacks and whites

stay in the City of Charlotte and County of Mecklenburg?

A. It is a fair and relatively accurate picture of the hous-

ing situation today in the City of Charlotte.

Mr. Chambers: Your witness.

Mr. Waggoner: We have no questions.

Mr. Barkley: We move all the testimony be

stricken out.

Court: The motion is denied but, although tre-

mendovsly interesting, I’m still not sure it helps me

to decide the case. Motion is denied.

Mr. Chambers: Thank you very much, Mr. Henni-

gan. May I approach the bench with opposing coun-

sel?

£77] Court: Yes, sir.

(Conference is had out of the hearing of the Court

Reporter.)

Ssorr Recess

Paut R. Leonarp, a witness for the plaintiffs, having

first been duly sworn, was examined and testified as follows:

Direct Examination by Mr. Chambers:

Q. State your name, please. A. Paul R. Leonard.

Q. What is your occupation? A. I am a Minister, or-

dained Presbyterian Minister.

Q. How long have you been a resident of Charlotte? A.

Since June of 1964.

58a

Paul R. Leonard—for Plaintiffs—Direct

Q. Have you had occasion, Rev. Leonard, to study the

housing patterns and practices in the City of Charlotte?

A. Yes, I have.

Q. What has been your occasion to make that study? A.

I made it in relation to a class in Urban Sociology that I

was taking at the University of North Carolina at Char-

lotte and I chose the topic of Housing Patterns in Charlotte

because of my relationship to the Charlotte Fair Housing

Association as its President.

Q. What is the Charlotte Fair Housing Association!

A. This is a voluntary association of a membership of about

[78] sixty-five citizens that was formed in February of

1968 to work for an end to discrimination in the sale and

rental of housing in Charlotte and Mecklenburg County.

Q. Under whom were you studying at the time that you

did this paper? A. Dr. Barbara Goodnight.

Q. And would you tell the Court how you proceeded with

your studies?

Court: Was that here or in Chapel Hill?

A. It was here. From work with the Fair Housing Associa-

tion we had compiled by the help of the Redevelopment

Commission, primarily depending upon them, we had com-

piled a map, drawn up a map which showed the racial

patterns in housing as they existed in Charlotte in the

summer of 1968. My main attempt in the paper was to see

what changes had taken place and how fast over the last

eight years. I had really wanted to go back further than

1960 but the census material prior to 1960 was not broken

down by tracts as it is now and as it was in 1960. So the

paper was primarily an attempt to compare what had hap-

pened in Charlotte in the last eight years and to ask the

59a

Paul R. Leonard—for Plaintiffs—Direct

question of why, what were the factors involved in the

changing neighborhoods and in the racial patterns as they

existed.

Q. In your work did you use census figures? A. I used

census material; I used a good bit of material furnished by

the Charlotte-Mecklenburg Planning Commission, one [79]

report in particular. I can’t quite remember the title but

I think it was entitled Blight September 1962, and this re-

port the Planning Commission had, by census tract, broken

the census tracts into blocks, indicated which areas of the

city were occupied by blacks and which areas were occupied

by whites. So it became a relatively simple matter to use

this as a basis of comparison with the present racial pat-

terns.

Q. Did you consider any data supplied you by the Re-

development Commission of the City of Charlotte? A.

Yes, I did. I considered this in relation to the question of

what had happened in those eight years.

Q. Did you consider any data supplied you by the Char-

lotte Public Housing Authority? A. Yes, primarily data

concerning the existing housing projects and those that

were planned and the racial makeup.

Q. Did you reach any conclusions? A. Yes. The major

conclusion was that Charlotte is rapidly dividing ...

Mr. Waggoner: Your Honor, we object to his giv-

ing a conclusion which is in effect an opinion. He is

not qualified as an expert.

Court: Well, without couching it in terms of con-

clusions or estimates, tell us what you observed about

the housing patterns or situations of last summer

compared [80] with whatever the other time was

you started with.

60a

Paul R. Leonard—for Plaintiffs—Direct

A. Yes, sir. I observed that the city was divided and

rapidly the division was increasing between blacks and

whites living . . . with whites living in the east and blacks

predominantly in the west and kind of taking a line from

North Tryon to the Plaza to Independence Blvd., coming

south on the map following those streets [ found that, ac.

cording to my figures, 96% of the Negro population in

Charlotte lived west of that line. There appeared to be to

me, if you consider the areas that were in transition, only

one area in the west that still remained predominantly white

and where transition had not taken plece. So I found the

city divided and the division increasing.

Q. Did you have an opportunity to see any data from

the Redevelopment Commission of the City of Charlotte

relative to relocation of families from the urban renewal

areas? A. Yes, I did.

Q. I show you an exhibit marked Plaintiff's Exhibit 14

and ask if you had a chance to see that document. A. Yes.

Q. Does that document show that families in the redevel-

opment areas involved have been relocated in primarily

Negro areas?

Mr. Barkley: He’s telling us what some other doc-

ument says. Wouldn’t that document be the best evi-

dence of that?

£81] Court: It would, but if it shows that and en-

ables me to put a label on that document while he’s

going at it—

A. I found that more than 50% of the families had been

moved into areas which, according to the 1960 census, were

high density black.

Court: What percentage?

6la

Paul R. Leonard—for Plaintiffs—Direct

A. 50%, and the others had been moved into areas that

since 1960 had changed from predominantly white areas

of residence to high density black today.

Q. You referred to a document that you used in your

study a moment ago called Residential Blight. Is this a

copy of the document you referred to? A. Yes, it is.

Q. And that’s Plaintiff’s Exhibit 15. A. Yes.

Q. Did you observe anything else relative to the public

housing in the City of Charlotte? A. As I began to try to

answer the question of why the racial patterns existed as

they did, in looking at the makeup of the public housing

racially and in a conversation with Mr. Cock, who is the

assistant to Mr. Dillehay, he indicated that approximately

95% of the occupants of public housing were Negroes.

Mr. Barkley: Move to strike Mr. Cock’s testimony.

Court: That testimony is technically incompetent.

The [82] motion is sustained. Have you got some

other way of proving those figures, whatever they

are.

Q. Were you given any figures, statistics, Rev. Leonard,

about the occupation of public housing racially?

Court: Consistent with my ruling, he can’t tes-

tify what those figures are? Have you got them in

some official publication?

Mr. Chambers: We’ll have them in the morning,

Your Honor. The Public Housing Authority is giv-

ing them to us this afternoon.

Court: This is a valid objection he’s making and

I guess I ought to sustain it as to competency of the

witness to testify about what he’s saying.

Mr. Chambers: That’s correct.

62a

Paul R. Leonard—for Plaintiffs—Cross

Q. Rev. Leonard, I show you a document which has been

marked as Plaintiff's Exhibit 36 and ask if you will state

what that document is. A. This document is a mimeo-

graphed copy of the paper I did on the housing pattern in

Charlotte.

Mr. Chambers: We have no further questions.

Court: You can review that if you wish and make

objection to it later. The use I would make of sucha

study is simply as a convenient way of having col-

lected whatever the figures are on which he’s making

his conclusions. You can make your objection now

and I'll rule [83] on it after I read it and find out

what parts of it are really incompetent and what

parts are not.

Mr. Waggoner: We noted a difference in the ex-

hibit we have and the one introduced and by agree-

ment of counsel we are going to substitute our Page

3 in the official exhibit. —

Court: All right. 36 is the one you’re talking

about?

Mr. Chambers: 14, Your Honor, the list showing

the relocation of families in urban renewal. We have

to duplicate his copy of Page 3 and insert that in the

morning.

Court: Take it away now so we can be sure we've

got it right in the morning.

Mr. Chambers: All right.

Cross Examination:

Q. With reference to your study on housing patterns,

did you pay any particular attention to school districts as

such? A. No, I didn’t. In one particular instance involved

SO ee

63a

Paul R. Leonard—for Plaintiffs—Cross

in the paper which I reported about, this was concerning

the Barringer Woods elementary school where there had

been a rapid turnover of population from white to black

in the year 1967-68 and, as President of the Fair Housing

Association, I was involved in two community meetings in

the Burringer Woods community prior to the opening of

school in September of 1968 in which one black family had

moved into the neighborhood and the [84] residents were

coming together to ask what shall we do. In the meetings

prior to the opening of the school they were pretty much in

agreement to stay and not flee. They had been approached

by realtors indicating that blacks would be moving in and

their property values would be going down, but the day

school opened the racial balance in Barringer Woods school

had shifted because of the change in the other community

from a predominantly white school to where there were

now, according to the people, 75% black. And the—

Q. With reference to the Barringer—

Mr. Chambers: Your Honor, we request that the

witness be permitted to finish his answer.

Court: Finish the rest of that statement.

A. And the day the school opened seven more houses went

up for sale.

Q. Barringer Woods is a subdivision in itself, is it not?

A. Yes, fifty-six homes, right.

Q. Are there any other subdivisions in that school dis-

trict? A. I don’t know the makeup of that district. I

think that the children from Clanton Park, which is the

area that had gone from all white to black, I feel the chil-

dren from this must be filtering into the Barringer Woods

school. I don’t know.

64a

Paul R. Leonard—for Plaintiffs—Cross

Q. Are you familiar with Rolling Wood? A. Are you

talking about the school?

Q. No, Rolling Wood subdivision. [85] A. Yes, next to

Clanton Park.

Q. All of these areas were all white within the past sev-

eral years, were they not? A. That’s correct.

Q. And now they are practically all black, is that correct!

A. Right.

Q. The white people sold their homes to the colored

people, is that right? A. Yes.

Q. Your study was based primarily on the census tracts

as we see them on the overlay, is that correct? A. That’s

right.

Court: Have you talked to any members of the

School Board about these problems that you were

studying?

A. I have on occasion talked to one, yes, sir.

Q. Who was the one School Board member you talked to!

A. Mrs. Kelley.

Mr. Waggoner: I have no further questions.

Mr. Chambers: I have nothing further. Rev.

Leonard has indicated he would like to be excused

unless the defendant needs him.

Mr. Waggoner: We have no objection.

Court: Thank you, Mr. Leonard.

65a

Dr. Wiliam C. Self—for Defendant—Direct

[352] ** @

Dr. Wimuiam C. Setr, a witness for the defendant,

having first been duly sworn, was examined and testified

as follows:

Direct Examination by Mr. Waggoner:

Q. Would you state your name and residence address,

please? A. William C. Self, 6137 Devern Drive.

Q. What is your official position with the Board of

Education? A. I am Superintendent.

Q. Dr. Self, what is your training in the field of educa-

tion? A.I had my undergraduate degree at Catawba

College; Masters Degree and Doctorate at the University

of North Carolina at Chapel Hill.

Q. What is your educational experience from a work

standpoint? A. I was a teacher and assistant principal,

& principal in the elementary field at Winstom-Salem; I

moved from the principalship to Directorship in Instruc-

tion in the central office capacity; I was Assistant Super-

intendent in Instruction in Winston-Salem City Schools;

moved to Charlotte as the [353] Associate Superintendent

prior to becoming Superintendent. This is the second year.

Q. Dr. Self, what is the size of the staff at the Board

offices at the present time? A. In terms of the professional

staff I think the number is 3558 teachers,

Court: Are there any exhibits that have these

figures in them?

A. I can furnish a fact sheet which has these figures in

it, Ihave only one copy right at the moment. I mentioned

the teaching staff, 3553 is the exact figure. To this you

add 404 other members of the staff. You begin to get into

the non-professional people, the clerical, cafeterial, custo-

dial, maintenance, transportation, television station, and

66a

Dr. William C. Self—for Defendant—Direct

the grand total would be slightly in excess of 5800 em.

ployees total.

Q. Dr. Self, how does this compare with other employers

in the school district? A. I understand that the Charlotte.

Mecklenburg School System is the largest employer in the

County.

Q. With reference to the dimensions of the school dis.

trict, have they always been the entire County of Meck.

lenburg? A. No. They have this size since 1960, the year

of the consolidation of the two existing school systems.

That was the Mecklenburg County System and the Char.

lotte City System.

[354] Q. Were these two systems autonomous of each

other? A. Yes, they were.

Q. As I understand it, you came here in 1962, is that

correct? A. That’s correct.

Q. Were there any problems that flowed from the merger

of the two systems? A. Yes, very definitely.

Q. Has this been a time consuming problem that your

staff has had to meet through the years? A. Yes.

Q. With reference to the composition of the City system

of schools as against the County system of schools—

Court: Are you going to leave it right there? You

say the merger created a lot of problems and I jusi

wondered what they were.

Mr. Waggoner: Judge, I don’t want to stir up

some things that have been buried. I wanted to show

the Board has been occupied.

Court: Go ahead.

Q. With reference to the racial composition of the City

at the time of the merger as against racial composition

of the County, do you have an opinion as to whether there

were more whites percentagewise in the County than in

67a

Dr, William C. Self—for Defendant—Direct

the City? A. I have no facts to go on. I do understand

that the changing ratio of Negro to white was one of the

factors that entered [355] into the deliberations about

consolidation.

Q. Has this merger of the two systems facilitated inte-

gration of the student population?

Mr. Chambers: Isn’t that a conclusion of law?

Court: Is that an objection?

Mr. Chambers: Objection.

Court: Overruled.

A. Would you repeat the question?

Q. Has the fact of merger of the two school systems

facilitated the integration of the student population in the

schools? A. I think I would answer that in the affirma-

tive because it relieved the problem I referred to pre-

viously, at least it made it a problem of the entire county,

and it also solved the problem of the tax base, the dimin-

ished tax base behind the pupils that resided in the

Mecklenburg County School System.

Court: Now you’re beginning to make me think

it was a pretty good idea after all.

Q. With reference to the size of the present school sys-

tem, do you know the approximate number of square miles

in the system? A. Yes. The county is right at 550 square

miles, I believe.

Q. How far is it from north to south, do you know? A.

The length is approximately 35 miles and width about 23

miles,

Q. Do you have some general facts about the educational

system that we have in this county that you can give to

the Court? £356] A. Do I have—again, please.

68a

Dr. William C. Self—for Defendant—Direct

Q. As I understand it, your office has distributive in.

formation sheets about the public school system and this

is what I have reference to. Could you tell the Court some

of the major points that may be of interest with reference

to this system?

Court: Have you got that information sheet with

you?

A. Yes. Are you referring to this paper, Facts about the

Charlotte-Mecklenburg Schools?

Q. Yes.

Court: Let me look at that. Can I just get Mrs.

Wentz to duplicate this and let you render any ob-

jection to it that you want to?

Mr. Chambers: That would be fine.

Court: It will save me taking notes. Go ahead,

Dr. Self.

A. I really think what Mr. Waggoner was getting at was

some indication of the size of the school system once again.

If that’s not what he wished, he can ask subsequent ques-

tions to get at it. The consolidation of the Mecklenburg

County System and the Charlotte City System was the con-

solidation of the #1 and #2 systems in the State and, of

course, when you combine two large school systems, as they

were, you get a mammoth school system which is what we

have today. At the time of the consolidation I understand

that the student enrollment was right at 58,000. That was

in 1960. Our size today is [357] 83,000, which indicates a

prodigious growth over a relatively short period of time.

There have been years when the pupil population increased

by 3600 pupils. The low point in the terms of our increase

69a

Dr. William C. Self-—for Defendant—Direct

was 2000. At the present time we feel that the pace of in-

crease in terms of our pupil enrollment has slackened off

slightly and we will probably be a school system increasing

by about 2500 pupils per year from this point on.

Court: Is that about 100 classrooms a year or 90?

A. If we take 2500 pupils and if we figured arbitrarily on

25 per classroom for ease of division, you’d get your 100

classrooms. We are not fortunate enough to have that 25

pupils per classroom so you would assume that’s 85 or 90

classrooms that would be required. This growth has pro-

' duced some terrific problems for us in terms of being able

to house youngsters. At the same time that we have tried

to gear construction programs to meet the increased en-

rollment, we have been faced with the problems of trying

to update facilities that went through the war years with

very little money spent on them and with very little mainte-

nance. So it has presented something of a problem for the

Board of Education to deal with.

Q. With reference to the School Board which administers

this district, how are the Board members selected? A.

They are selected by an election process, bi-partisan [358]

election. It occurs every two years and three of the nine

members of the Board of Education are elected every two

years.

Q. Have you had any vacancies created by moving from

the County or any other reasons on the Board of Education

in the past two years? A. Yes, sir. We had a resignation

by reason of a move out of the City on the part of Mr. Tom

Braden.

Q. Did the Board of Education appoint someone in his

place? <A. Yes.

Q. What is his name? A. Rev. Coleman Carey.

70a

Dr. William C. Self—for Defendant—Direct

Q. Will you state whether or not he isa Negro? A. Yes,

he is.

Q. Has he been a candidate for the School Board in prior

years? A. Yes.

Q. With reference to an elementary school, what proce-

dure does the Board follow in deciding, or what does it do

to reach the point of construction of a new school? What

facts give rise to the location and selection of this particv-

lar location? A. Well, I’m sure that our studies would have

revealed that this elementary schoo] that you’re talking

about would have encountered housing problems for a num-

ber of years, its enrollment would have exceeded its rated

capacity, and the excess of youngsters would be accommo-

dated in existing facilities through the use of what we have

called sub-standard spaces. [359] These may be basement

classrooms, a classroom on a stage in an auditorium, parti-

tioning of a larger classroom into two sections, things of

this nature. In other words, there would be crowding within

the elementary school. In all likelihood the neighboring

schools would also be crowded. This would reflect a general

tendency within the neighborhood of inability to house the

youngsters in the neighborhood in the existing facilities. In

all probability we would reach the point where mobile units

would need to be brought into play to house the yougsters of

these schools. I would have hoped that in the earliest stages

we would have recognized the problem and might have

acquired a site, at least, before homes were built on it, so

that we would have a site available for that school. We have

in the past employed architects to draw up plans and de-

velop them to the stage of working drawings so that the

moment the money becomes available we can build a schoo!

in that area. We eventually will reach the point where we

must have a new facility and then we put that school down

7la

Dr. William C. Self—for Defendant—Direct

on that particular site. We are not able to afford the luxury

of overbuilding which will mean that it is quite likely that

everyone of the classes would be filled the first year. As a

matter of fact, it is not an infrequent occurrence that a

new school may have a mobile unit. As the elementary

school nears completion, Mr. John Phillips, who is the

Assistant Superintendent for Elementary Education, will

have called in [360] to conference the principals of these

surrounding schools and enlisted their aid and the aid of

the principal of the new school, too, if we are fortunate

enough to have appointed him, and ask these people to join

him in designating the attendance area that will be served

by this school. The starting point in their deliberations will

be the capacity, the number of pupils that that school will

house, and in essence their problem is carve out of the

surrounding school areas enough territory to give us the

required number of pupils so that that school may open at

capacity when it’s ready.

Q. Now, these principals make recommendations to the

Assistant Superintendent in charge of that? A. Yes, they

do. They are encouraged also to discuss this matter with

the School Committees—there is a School Committee at

every school—so that there will be communication with the

lay public regarding the location of these attendance lines.

Q. Now, the final act of establishing the school lines is

performed by whom? A. By the Board of Education.

Q. Is this on your recommendation? A. Yes, it is.

Q. With reference to Independence High School how did

it become located at its particular location? Could you give

us the history of that? [361] A. Of course, the problems of

overcrowding that I spoke of appeared in the neighboring

high schools, Garringer and East Mecklenburg. A site was

selected. We used principles of triangulation in terms of

72a

Dr. William C. Self—for Defendant—Direct

selecting sites with a school located at each of the angles

in the triangle. A piece of property was located by a real

estate consultant employed by the Board of Education and

negotiations were entered into to acquire the property,

That deal was consummated, the property was available,

the Board elected an architect and the school was built.

Court: Where is Independence High?

A. Independence High School is in the eastern section.

It is off Wilson Grove Road.

Court: Wilgrove?

A. Wilgrove, I beg your pardon.

Q. Dr. Self, would you come to the large map and point

that out, please. (The witness does so.)

Court: I believe that’s off your map, Mr. Wag-

goner.

Mr. Waggoner: My map is a little dated.

Court: Is that between Central Avenue and In-

dependence or is it above Central Avenue? It’s south

of Albemarle Road, isn’t it?

(Conference is had out of the hearing of the Court

Reporter.)

Q. Dr. Self, did the School Board own property adjacent

to York Read Junior High for the purpose of constructing

a high school nearby? [362] A. Yes, sir.

Q. Has a high school been constructed over in that site!

A. No, it has not.

Q. What action was taken with reference to that project!

A. The Board of Education had employed an architect and

73a

Dr. William C. Self—for Defendant—Direct

the architect had developed plans up to a particular point.

The Board decided that to locate the school there would be

to assure that it would be totally black from then on. They

abandoned the plans, instructed the architect to alter his

work, acquired a site, which we now know as the Olympic

site, and built the school in that area.

Q. For the purpose of the record, what area is Olympic

located in? A. Southwest section, off Sandy Porter Road.

Q. Now, with reference to Randolph Junior High School,

could you tell us the considerations that went into the loca-

tion of that school? A. The same pattern was repeated

here. There was a site available and we referred to it com-

monly as the Mason Wallace Junior property. It was

located off Billingsly Road. Again the same factor entered

into the decision of the Board of Education. That site was

abandoned and another site was acquired. This was the

Wagner property off of McAlway Road and Randolph

Junior High School was constructed there.

Court: Is that to the south of McAlway?

[363] A. It’s actually to the east, where McAlway meets—

Im sorry, the name of the other road escapes me.

Q. Dr. Self, what kind of school population does Randolph

Junior High serve? A. An integrated student population.

Also one that I would judge varies in socio-economic level.

Q. What action, if any, did your office take with reference

to freedom of choice at that school? A. Probably you are

referring to the section of the Pupil Assignment Plan which

prohibits transfers out of a newly established school. The

reason for that, of course, is that the Board of Education

has felt that there ought not to be freedom of transfer that

first year, that the school ought to have an opportunity to

74a

Dr. William C. Self—for Defendant—Direct

establish itself. In this particular circumstance pressure

was brought to bear to try to get the Board of Education

to relax this particular policy. They did stand firm on it

and the policy helped.

Q. With reference to Olympic, was the same rule enforeed

there? A. Yes.

Q. Is this also an integrated school? A. Yes, it is.

Q. With reference to the pupil assignment policy of the

Board, have there been any changes in the operation of this

policy since 1965? A. Yes.

[364] Q. In what way? A. It’s quite difficult. Could

I use an exhibit to explain it?

Q. Certainly.

NIGER MER eae

Mr. Waggoner: We have a document entitled

Charlotte-Mecklenburg Elementary Schools 1968-69

and we’d like it marked Defendant’s Exhibit #1.

A. Mr. Waggoner, do you have the junior high and senior

high document to go along with that?

Q. This is just the elementary. A. There is another

group that was with it.

Q. I don’t seem to have the senior high. A. It’s stapled

to the junior high.

Mr. Waggoner: Your Honor, we would offer the

junior high and senior high as a composite part of

Exhibit 1 for identification.

Q. Dr. Self, would you first tell the Court what Defend-

ant’s Exhibit for identification #iis? A. In the first place,

the title is quite misleading. It just says Charlotte-Meck-

lenburg Elementary Schools. What it is is an administra-

tive work sheet which was used in making the recommenda-

75a

Dr. Wiliam C. Self—for Defendant—Direct

tion to the Board of Education regarding the capacity of

schools.

Court: Do you have a copy of high and junior

high.

Mr. Waggoner: Yes, sir, I’m sorry.

Q. Dr. Self, if you will, identify Defendant’s Exhibit for

[365] identification #1. A. It’s headed Charlotte-Meck-

lenburg Elementary Schools. As I said, the title tells you

nothing and I had sought to elaborate upon it by saying

that this is a work sheet that was used by the administra-

tion in making a recommendation to the Board of Educa-

tion preliminarily to their setting the capacities of all of

our schools. Capacity, of course, is directly related to

pupil assignment and to freedom of choice because the only

thing that determines whether or not a request for change

of transfer is granted is whether the receiving school has

space to accommodate these youngsters. It stands to rea-

son that if you have a school capacity that is set on rather

generous terms that you have a more liberal freedom of

choice. With that in mind, I think we can get the gist of

the paper by looking across the column headings. The

name of the school is in the first column, of course; the

total teaching spaces is next. That’s an actual cou

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Appendix — Swann v. Charlotte-Mecklenburg Board of Education · 402 U.S. 1 | Frix