# Appendix — United States v. Scotland Neck City Bd. of Ed. > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386414_0052%3A02 ## Record - **Collection:** Supreme Court brief - **Document type:** Appendix - **Published:** January 1, 1972 - **Citation:** 407 U.S. 484 ## Text - No.70187 2 PAT BLACK COPTON, BF Ala tee ticy aoe cog : oe Petitioner _Soomanp NECK: Crry Boar OF Epucation, ET. AL, : R \ Ol WRIT OF CERTIORARI TO THE UNITED STATES COURT OM APERALS FOS THE VOURTH Cigcyr A * ‘Mmows ron wars OF cHRTIORARI FILED APRI. 2 it te ee _ AND MAY 20, 1971 | (CERTIORARI GRANTED OCTOBER 12, 1971 pO an S ' ME ee “UNITED STATES oF Anca, es a ae Ete, ad ies poman Neck crry BOARD .OF EDUCATION, ET AL, : | "Respondent, ete No. 70.187 re "PATTIE Brack Corton, ‘er Me : Pe : _ Petitioners. Z : —V— ae ‘ % ON WRIT. OF CERTIORARI TO THE UNITED ‘STATES COURT . : 7 Page | “Certified copy of doeket entries: denies entnndtapeed Seabee tab oom ee ine 7 | fre Ge at St esisosme: TERM, 1971. _‘Scomaxo Neck Crry BoanD OF Bpvcamton, ET AL., . on APPEALS FOR THE FOURTH specu : are INDEX TO APPENDIX _. Plaintiff's ‘notice of motion ‘ink motion for a preliminary er Ee OEE Scere Dace ea te es 39 - -, Phintiff’s notice. of Rito and sieotScinn for a to-join an _ party er semgie and . to file an amended mee Plaint __ 6 sie « Reponse to plaintift’s. motion for a silainaits injunetion, : - Motion for leave to join an. additional’ party defendant, and motion to file‘an ‘amended complaint - i | i haewes of all defendants with the exception of Halifax eed 7 County Board of Education : ie AT ' aK s er NRC ea INDEX TO APPENDIX. aes | eee ee ee Response to plaintiff's ‘motion foe’ a preliminary injunction, : * motign’ for .teave ‘to join: an .additional party. defendant, » and motion .té fife an amended complaint... ES Answer of. Halifax CountysBoard of Edptation wo ictinigs 56— : oe Notice of, hearing by Judge Butler, pene Ts ee : ON Order that. ‘Clerk ‘file’ amended complaint ce Fe "U.. S. Marshal - ce . 7 “serve copies upon defendants _ anc eye $. * amended com ME a eda fp: : * 69 | Answer ‘t@ amended complaint. by all defendantstexcépt Hali, is oy. fax County: Board of Education . Ss eats 69 / Answer’ of defendant Scotland Neck Board of. Education eens Transcript of hearing on August 21-22, 1969 Liss . 4G Deposition of Ferd Harrison OES SC Ae ) 96 . Deposition of €. M. Moore, Jr. 2 ie o/.. nt : ™ . Deposition, of Craig Phillips —_— | : - . : "153. * Deposition of. W. Henry Overman « es oe | “918 _ Deposition, of Henry Harrison ener ne) aa Deposition of. Frank P: " Shields ... : -_ ar eee a) | Deposition of Aubrey Powell — er enar a 460. Beposition. of F. “Boyd Bailey _ ee INDEX TO APPENDIX -Jadgment that Chapter 31. of ‘the 1969 Session -Laws of North Carolina —— Scotland Neck Administrative — . Unit is declared to,be unconstitutional and null and void. Defendants, their respective officers, agents, ete., are permanently enjoined from all ‘further Proceedings pur. suant to said. statute_ Sic ccs siohanipcgen ncabsucaginsandaceiaisaat Amended order, amending order: of district court dated 5/18/70 se ge Poa - Notice of appeal ‘by Scotland Neck City ‘Board of Edueation- "Notice of appeal to the United States Court of Appeals for the Fourth Circuit by Robert Morgan, Attorney .General of North Carolina,. North Carolina State Board of Educa-. tion,-and Dr. A. Graig Phillips, State Superintendent of Public Instruction - cacaed ~ Motion of defendant Halifax County Beara. ‘Edtication for - further amendment to “Proposed Interim WUE cnnibebccue Plaintiff’s response to defendant’s motion to amend interim desegregation plan approved May 19, pened recur ae sa Defendant Scotland Neck City Board of Education’s Answer to motion-of Halifax County Board of Education . he _ Plaintiffs’ in intervention opposition to defendant’s Yiotion to.-amend interim hE ES ak ——— = 19, | We Order dang 1 motion of. didindebite to ‘aiinaa ee ies of May 19, 1970, with respect to the operation of aaa “* Neck School ahd Brawley School (Judge Larkins) _. Affidavit.of W. Henry Overman dated ae 15, 1970 (Enrollment Statistics) - sicslpssstaesntedinendadicaacs Affidavit of W. Henry. RENNES “dated December’ 2, 1970 (Enrollment. Statistics) — PS SEs Sat eaten soe Opinion and judgment of the ‘United States Court of dae for the Fourth Circuit dated March 23, 1971 Opinion of the United States Court of Appeals for the Fourth Circuit in Wright v. Council sid the: os of asian: — Gy TIA ee ea, Order staying the iuniahe a dated re 21, 1971. Order of Supreme Court of Octeber 12, 1971 allowing certi- : eg | enone Order of Supreme Court of October 12, 1971 slowing certi- orari in No. 70-187... soaks . None . Affidavit of W. Henry (aaa dated October 14, 1971 (En- RI TION occas eee Halifax County map indicating the pained: districts and dif- ‘ferent — 2 [Caption Omitted). io ae LARKINS, District J are - This cause coming on to be heard: before ‘a Court on. a motion for a preliminary injunction filed by the plain- . : tiff pursuant to the provisions of Sections 407(a) and — (b). of the Civil Rights Act of. 1964, as codified, 42 US:C.A. §§2000c-6(a) and (b) seeking to restrain -the - defendants: from giving any force or effect to the provi- sions of Chapter 31 of the North Carolina Session Laws. of 1969, an Act to establish a separate administrative unit for the operation of the public schools of the Town of Scotland Neck, North Carolina; and due notice hav- _ ing been given to the defendants; ‘and cn oer having ~ considered the evidence and the argument counsel and being fully advised ‘in the premises; and it appearing to the Court that effectuation of’ the terms of the Act will result-in the operation of the schools of Scotland. Neck, North. Carolina, and ‘Halifax County, North Carolina, on a-racially: discriminatory basis to the irreparable dam- age of the United States and the Negro pupils of Halifax. County; and it. further appearing to the Court that no injunctive relief as ‘to. effectuation of the provisions of Chapter 31 is being sought against the defendant Hali-. - fax County Board of Education; and that the defendants ° - ‘Ferd. L. Harrison, as Mayor of the ‘Town of Scotland © - Neck, J. A. Andrews, F. G. Shearin, J. I. Walston, D. E. . Josey, Jr.,‘as: members of the Board of Commissioners of the Town of Scotland Neck, and the Town.of Scotland . a body corporate, are ‘hot ‘proper ‘parties to this | on; * It is, therefore, ORDERED, ADJUDGED. and DE- CREED: ‘THAT the motion to dismiss filed on behalf of the de- - _fendants Ferd L, Harrison, as Mayor of the Town of * Seqtland Neck, J. A. Andrews, F. G. Shearin, J. I. Wal-' . ston, ». E. Josey, Jr, as members of the Board of Com-— _ 789 . * Raleigh, North Carolina. ~ ‘missioners of the Town of Scotland Ned, and: the Town. of Seotland Neck, a body corporate, be, and “the same . hereby is allowed; and THAT. the defendant Scotland. Neck City Bone of Education and its officers, agents,, employees and suc- cessors are hereby enjoined from giving any force or . effect to the provisions of Chapter 31 and from. taking. any action pursuant to the provisions of Chapter 31 pend. ing a-.final determination on the merits. of the issues. | raised in the present action; and THAT pursuant to the provisions of Rule 65(¢) af _. the’ Federal Rules of Civil Procedure, no security shall’ '. be required of the a United States of Ameren, and . -THAT this ORDER shall betome effective as of 12 0. Noon on Monday,. August 25, 1969; and THAT a Memorandum _— os will be filed in this action; and THAT the Clerk shall serve copies of this ORDER.” upon all counsel of record, and the defendants. ‘Let this ORDER be entered forthwith. /s/ John D. Larkins, Jr... _JOHN D. LARKINS, JR. - United States .District Judge — _ /8/ Algernon L.-Butler | ' ALGERNON L; BUTLER — . United States District Judge August 25, 1969 (4 in He a p 790 [Caption Omitted] - =f "| MEMORANDUM OPINION: - GARKINS, District. Judge: ti Sy ‘This Court entered its ORDER on August 25, 1969, — * ‘effective at /12:00 noon. ‘The Clerk served copies of said ORDER upon all defendants ad counsel of record. . _ Pursuant to said ORDER this MEMORANDUM OPINION is filed in support of said ORDER and is in- cluded therein by: reference: , ee ;; This =: coming on to-be.heard before the United | States District Judges for the Eastern District. of North ‘Carolina, and being heard upon the motions of plaintiffs _ and additional plaintiffs for a preliminary injunetion and for a declaratory judgment; and due notice having — _ been given to: all defendants; and the Court having con- | sidered the evidence, the stipulations, the briefs and argu-, ‘ ments af counsel, and being fully advised in the premises,” makes the following: a _ FINDINGS OF FACT: 1. On March 3, 1969, the General Assembly of North ~ . - Carolina ratified a measure designated Chapter 31, Ses-—-—=~ ~ sion Laws of North Carolina 1969, creating the Scotland Neck City Administrative Unit in Halifax County to operate the. public schools in said unit; providing that all public school: property located within the unit should become the property of the unit; providing for a ‘sup- ‘Plemental tax. levy, and directing -a special election to authorize the establishment of said unit and the levying. of said tax. The voters approved said proposals, ~ 2: The Board of Education of the Scotland Neck City _ unit permits transfers of students in and out of .said units. Scotland Neck City has established a_ tuition charge of $100.00 a year for the first child in a family, _ $25.00 for the second child, $25.00 for the third child, — and each subsequent child per family free, for all “stu- dents transferring into said unit. _ - 2, ; - 38. During the school. year 1968-69, .all- the public _ Schools of Halifax County were operated by the Halifax - ad . . POR OS ERC So een pearance Re ep corppy-e.y ae J: County Board of education: There was a total of 10,655 students. The racial composition ‘of the county school - ' system was approximately as follows: White, . 2,357 (22%); Negro, 8,196 (78%), and Indian, 102.-°- tt i The: Scotland Neck City unit has approximately - 695 resident students: _ White, 399 (57.4%); Negro, 296 (42.6%). The school facilities within the unit will ac | commodate approximately 1,000 students. Since the cre: ation of the City unit under the 1969 Act, 350 “@ and 10 Negroes’ have transferred from the county schools into the City unit; 44 Negroes %m the eleventh and twelfth - grades have transferred from the city to the Brawley ' High School iri ‘the county system. The net effect on the _ City. unit for the school year 1969-70 is as follows: . White, 759 (74%); Negro, 262 (26%). . 5.. The racial composition of the county school syste as a result of the creation of the administrative unit, and king into consideration the net effect of the transfers. - In and out of the systems, ‘is as follows: White, 1,598 ‘AT%): grees 2) | (83%); Indian, 102. - 192 CONCLUSIONS OF LAW 1. This Court has jurisdiction of the ‘sails and. of 5 the subject matter of this proceeding. R eS 2. Without determining the constitutionality of Chap-. : ter 31 of the 1969 Session Laws of North Cerolina, the’ , Act in-its application creates a refuge for white stu- dents, and promotes segregated schools in Halifax County. _ -8, The Act impedes ‘and defeats the Halifax County ‘ Board of Education from implementing its plan to.com- .-. pletely desegregate all of the public schools: in Halifax County by the opening of the school year 1969-70. a ~4. Unless the defendants are“ enjoined, the’ plaint ntiffs will suffer immediate and. irreparabi injury By the de- 3 ——— of their constitutional righfs. ac of e ' /s/ Johy D. Sicritiie ‘Tr. Ao D. LARKINS, ,) ited. States District J udge ‘Raleigh, North. Carolina _ August 25, 1969 — PR Ro et ss Ee | [Caption rerun ae ‘AMENDED ANSWER The adeaslilink The Scotland Neck City Board of Edv- ’ eation; a body corporate, snewrering the Amended Com ‘ plaint, alleges and says: © : 1. That as to the allegations contained in pee 1, Claim One, the answering defendant is not Sufficient- ly. informed concerning the. averments contained therein . from which to form a belief and /hence_ denies Same, - 2. That the allegations contained in ‘Paragraph 2 of Claim One are admitted. : 3. That as to the allegations contained in Paragraph 3, Claim One, it is admitted that the defendant Halifax County Board of Education (hereinafter the Halifax . “County Board) is a body corporate, organized and exist- . ing. under the laws ‘of the State ‘of. North Carolina, and it has a duty under North Carolina law to operate a ' public school system in Halifax County, North Carolina -' .other' than in the Town of. Scotland Neck. 4, That the allegations contained in | paragraph 4 of Claim One are admitted. - 5. That the allegations eomtningn’ in Paragraph 5 of Claim One are admitted. — 6. That the allegations eontained in ‘Paragraph 6 of . Claim One are admitted. — ‘ 7. That as to the allegations contained in Paragraph | 7, Claim One, the answering defendant ‘is not sufficiently - LP seek concerning the averments contained therein from which to.form a belief and hence denies same. ' 8. That the. allegations ‘contained in saris 8 of Claim One are admitted. ' 9. That the allegations contairied in Paragraph 9of Claim One are admitted. -10. That the allegations, contained in Paragraph 10 - of Claim One are admitted. ts | - 11. That the allegations contained ‘in Paragraph 11 © of Claim One are admitted. | _ °12.. That as to the allegations contained in Paragraph 12 of Claim One it is admitted that the Scotland Neck | to open its schools: for students on August 28, 9, and itis further admitted that the vast majority - ‘ ae students: who will attend the schools of ,the Scot- Jand Neck City Administrative Unit during the 1969-70 school year attended schools operated by the Halifax County Board during the previous year; all other alle- _ gations contained in Paragraph 12 are denied. 18. The allegations and averments contained. in- Para- graph 18, Clairn One are denied.. "14. The allegations and: avexments contained in ‘Para- graph 14; Claim One are denied. . — 15. The allegations and averments contained in. Para- graph 15, Claim One are denied. | 16. It is.admitted that unless restrained by order of _.the Court this answering defendant will continue to give full force and effect-to the provisions of Chapter 31; all . other allegations contained in Paragraph 16 are denied. 17. That.as to the allegations contained in Paragraph 1? of Claim Two, which realleges Paragraphs 1, 2, 3, 7 “and 8 of the Claim’ One, this defendant :answers said paragraph in the. same manner as above. . _ 18. That as to the allegations contained in Paragraph . 18, Claim Two, the answering defendant; is not suffi- ciently informed concerning. the averments contained therein from which to form a belief and henee denies same. 19. That as to the allegations. contained in Parairaph 19, Claim Two, .the answering defendant is .not suffi- : ciently informed concerning the averments ‘contained therein. from which to form a belief and ‘hence denies. ' game. 20. That as to the allegations contained in Paravrech 20, Claim Two,’ the answering defendant is not suffi- | ciently informed concerning the averments contained _ therein. from which to form a’ belief and hence . denies - game, - 21: The allegations and averments contained in Para- ' graph 21, Claim Two are denied. - ; Pn ey The allegations and averments contained in Para- graph. 22, Claim Two are tated. | : \ \ \ Fh : “04 : ; Board has hired a. Daneaiedidaid of Schools and is pre- . ; é PV eae eee + 96" FIRST FURTHER ANSWER ~ ~ For a First Further Answer. to. the Plaintiff's amend- . _ ed complaint this Defendant alleges and says: : 1. The Statute (North Carolina Session Laws i969, Chapter 31) -hereafter called’ the “Statute,”: the consti. e _ tutionality of which is here challenged. by the Plaintiff, followed a long established North . Carolina legislative precedent and pattern of the formation’ of a special ad- ministrative school unit within a county consisting usual ly of a municipality. There are in North Carolina, ex- clusive of Scotland Neck, fifty-two special municipal ad ministrative school units. i , rae _. 2. The Statute created a special school administrative unit; the boundaries of which were designated as the - municipal boundaries of the Town. of Scotland. Neck ~ Within the geographic boundaries of the Town of Sct- ‘land Neck there now reside approximately 751 students : _. .0f school age; 56.86. percent of which are white and 438.14. percent of ‘which are negro. Classroom facilities - within the town: limits can accommodate approximately - 812, students; 784 of which are accommodated by per- "manent facilities and 28 of which are accommodated by - . @ mobile ‘classroom, na Li ae _ _ 8.. The Statute provides, -as conditions. precedent to - the formation of the unit,;'a vote of the people in Scot- ’ land ‘Neck approving both.the formation of the unit and - - the imposition.of a school fax.of 50 cents on the dollar” of taxable property. valuation in the town. | 4. By election held pursuant to the Statute, the peo. ple of Scotland. Neck approved both ‘the formation and the. imposition of the special school tax. ~~ AG - 5. The resident school population is sufficient. to con- stitute an efficient separate school administrative unit, - and the special tax funds will, enable the Defendant to ' Offer. to its resident students an educational system Which is greatly superior to that heretofore enjoyed by _ them and: superior to that which would be available to them if there were no such tax. Defendant made ar- -. . ’ i : . , A giao gg ‘ 2 ? F . o Z g : . J , ae ; eee ES 5 » . : . : _rangements to operate such an ‘improved’ school system - "in Scotland Neck for the school -year 1969-1970. 7 6. On August 25, 1969’ there was issued a tempo a " jnjunction in this-cause, preventing Defendant from tak- ing any further steps in connection. with the operation : of a school unit until the final. determination of. the merits of this cause. = = i ti eS 1. The single issue in this case is the’ constitutionality :. of the Statute. The issue is not the propriety ‘or the i legality of whatever might, from time to time, be the - plan or plans of operation under the Statute. . ee _ 8 It is the present intention of: this, Defendant, and this Defendant makes this. continuing representation, _ . that, if and when there is. removed the’ temporary in- junction. barrier preventing operation under the Statute, . Defendant will confine its student’ body to those students _ residing within the geographical limits-of the town of . Scotland Neck, plus or minus such student transfers as: _may be.in conformity to the law and/or Court ordér or ‘orders applicable to Defendant, and in conformity toa =Ss- _ plan’ of limitation of. transfers to be prepared by De- . - fendant and submitted to this Court. we ey _ WHEREFORE, this Defendant : respectfully prays that: 1. The Court declare to be constitutional Chapter 31 - of the 1969 Session Laws of North Carolina;- -. 2.° The Court dissolve the temporary injunction bins —tofore issued in this cause on the 25th. day of August 1969; | . 3.. The Court retain ‘jurisdiction of this” cause for the receipt of a plan of transfer to be submitted by the _—-Befendant to the Court and for the — of any ‘ob « 1* 2 ection that may’ be filed thereto. es oe "6. _ Krrcin Josey bs) William ‘T. Joyner cre! WILLIAM T. , JOYNER —/8/ Walton K. ‘Seyne. -s | as WALTON K. JOYNER . oo, oa Attorneys: for the defendant, “ : Scotland: Neck City Board : _ _ of, Education,: a body cor- - — . t — gs ~ i : [Caption Omitted] ‘MOTION: S&S Now -comes the defendant, the Scotland ' Neck City Board. of Education, a body corporate; by and through _ its attorney, €. Kitchin Josey, and respectfully shows unto the Court: . - ae _— 7 That at 12 o’clock noon on the 25th day of August,. : 1969, an order was entered in this ¢ause enjoining this defendant “from taking any action pursuant to the pro- ‘visions of Chapter 31 (of the 1969 Session Laws of» North Carolina): pending a final determination on‘ the | merits of the issues gaised in’ the present action.” That prior to the entering*of the above mentioned - order ‘this defendant in its official capacity and in ac- ° cordance with the laws of the State of. North Carolina. under its then“ policy: accepted students that lived out- — administrative unit boundaries on a tui- -- ‘side the schoo tion basis receiving approximately ‘$11,656.53 from the parents of. such tuition: students. Of this amount, $2,- 970.66 was expended by this defendant for obligations incurred prior to the entering of the above ‘mentioned . order. | - 3. That the defendant, the Scotland Neck City Board of.. Education, desires to repay in full- the parents of the , Students who have previously paid in these tuition funds. - | ee? 4 4 ahs a That the Scotland Neck City Board ‘of Education has heretofore incurred certain legal expenses in connection -with the defense of this cause and the said defendant _ > expects: to incur certain additional expenses until this matter is finally determined. a , 798 799 ; _ That this defendant has been” offered certain’ private donations from citizens in this, area’ and particularly the - citizens of the Town of Scotland Neck for the purpose - of repaying the parents of the tuition students and for the purpose of defraying expense of defending this law suit. wo a WHEREFORE, this defendant prays the Court that : an order be entered modifying the temporary injunction | order of August 25, 1969, to the effect that the defent. ant, the Scotland Neck ‘City Board of. Education, -be al. lowed to receive donations from’ private: sources and to use such funds, together with the tuition funds now in its hands, for the repayment of the amounts heretofore paid by parents of ‘tuition students, and further that said Board: be permitted to use -said privately donated _ funds for the purpose of ‘legal expenses and. fees in- eurred and to be in¢urred ‘until this matter is finally determined. . : This the 12th day, of September, 1969. /s/ C. Kitchin Josey | ©. KITCHIN JosEY, William T. Joyner and Walton K. Joy- _ ner, Attorneys for the Scot- ‘land Neck City Board of Education 800 - : [Caption Omitted] | «ORDER © This cause coming on: to ‘be héard’on a Motion by the’ defendant, the Scotland Neck City Board of Education, a body corporate, for a modification of the order of pre- liminary injunction heretofore entered by this Court at - 12 o'clock noon on August 25; 1969, to the effect. that ertain funds now. in said defendant’s hands and certain private donations be authorized for use by said defend- * ant to repay certain parents of ‘tuition Students and for | authority to use said privately donated funds for’ the |’ purpose of defraying legal expenses in connection with the defense of this cause; _ _ Sh Te os _ And it appearing to the Court that the ‘requested modi- fication of said temporary injunction is proper and said Motion should be’allowed; «°° ' : IT IS NOW, THEREFORE, ORDERED, ADJ UDGED AND DECREED that the defendant, the Scotland Neck City Board of Education, be allowed to receive dona- ‘tims from private: sources and to use such funds, to- gether with the tuition funds now in its hands, for the repayment of the amounts heretofore paid by parents of. tuition students, @ad further that said Board be per- - mitted to use said privately donated funds for the pur- pose of legal expenses ‘and fees incurred and to be in- curred until this matter is finally. determined. IT IS FURTHER ORDERED that the Clerk: shall _ Serve copies of this Order upon all counsel of. record. - Let. this Order be entered. forthwith. - ° _ {s/ Algernon L. Butler . CHIEF UNITED STATES DISTRICT JUDGE. ~ /s/ John D. Larkins, Jr. | * "UNITED: STATES y DISTRICT JUDGE 801 . [Caption Omitted] . MOTION. OF ROBERT MORGAN, ATTORNEY Gey. _ _ ERAL OF NORTH CAROLINA, TO INTERVENE - IN THIS .ACTION IN BEHALF OF THE STATE. - OF NORTH CAROLINA, AS PARTY. DEFENDANT. Robert. Morgan, Attorney General of North Carolina, in behalf of the State of North Carolina, hereby moves _ the Court for leave to intérvene in this action in order -to assert the defenses of the State of North Carolina, as set: forth in the proposed Answer of which a copy is. hereto attached, on the grounds and for the reasons, as follows: | | "1. That Applicant, Robert Morgan, is the duly .elected and qualified Attorney General of the State of North Carolina, and makes this application to intervene in this --action in behalf of said State of North Carolina; that. North Carolina is one of the States that compose the United States of America and exercises such powers and duties as set. forth in its Constitution and Laws enacted by its General Assembly and in. accordance with the Constitution of the United States. — - 4 at 2. That this motion. to intervene in this’ action by the Attorney General of North Carolina is made in behalf of said State of North Carolina (hereinafter referred . to as:.Applicant) pursuant to the Federal Rules of Civil ‘Procedure, the same being Rule 24; that this application is made as a matter of right in that the constitutionality eof one of the acts or statutes of said State is involved in said action; that applicant may be bound by any judg- ment -entered by the Court in this action, and_ applicant is entitled to adequate representation on the question of the constitutionality of said State act or statute; that applicant is also entitled to intervene in this action in the discretion of the Court and as a permissive interven- -tion in that the plaintiff-relies upon the allegation of the unconstitutionality of an act’ or ‘statute of this State as a part of its claim; that there is a: common question of law and fact as the constitutionality of said State law or ~ 802. ; act is drawn into question and if-said intervention is. al- Jowed, as herein requested, the same will not unduly de-. lay or prejudice the adjudication of the rights of the es, ; . = 8. That ‘the att of the General Assembly drawn in question. as to its constitutionality in this action is. Chap- ter 31.of the Session Laws of. 1969, which became effec- _ tiveon the 8rd-day of March, 1969; that-a copy of. said - "act is attached to the amended complaint of the United States of America and is hereby referred to as‘a part ~ of this motion; that the plaintiff alleges that said act — _and its implementation is in violation of the Fourteenth Amendment to the Constitution of the United States and this is denied by the applicant; that applicant, if allowed - ' to intervene in this’ action,. will allege and assert that. said act is valid and that its result ‘is to establish a city ' board of education similar to many other city boards of education throughout the State of North ‘Carolina and - which have been established for many years; that if said act is held by the Court to be invalid and unconstitutional the status and establishment of all other boards of edu- cation, both city and county, will be put in jeopardy. 4. That applicant accepts the status of this action as " heretofore developed but reserves the right to except to any evidence orders, rulings or proceedings that may he made oy~entered, or heretofore made and entered, con-— trary to the constitutional validity of said act. or statute, and the right to argue in support of the validity of said ‘act or statute; that applicant agrees-to be bound by the ~ temporary injunction heretofore entered in this cause but ccs tke right to move that same be vacated by the 5. That annexed hereto, in accordance with ‘Rule 24 (e) of the Federal Rules.of Civil Procedure is ‘a proposed Pleading entitled: “Answer of Robert Morgan, Attorney General of North Carolina, in behalf of the State of North Carolina, in Intervention.” The applicant moves the Court that said pleading be deemed .the appearance. of applicant in’ support. of the constitutionality of the act of the General Assembly of North Carélina, and in _pposition to all pleadings and motions of the parties 803 hereto that have been or may be made herein insofar as said pleadings and motions are based on the contention’ that said act of the-General Assembly of North Caroling --is -in-any respect, or in any application, unconstitutional, WHEREFORE: Applicant prays. the Court that an order be entered herein allowing. applicant to -intervene in this. action as a party defendant and that his Proposed - answer be filed as a pleading. in this action; that this . motion be brought on before the Court for hearing on _October 24, °1969, at the Federal Courtroom in ‘Raleigh, North Carolina, or at such other time- as may be con. . venient and as ordered by the Court. = ~ This the 81 day of Oetober, 1969. = /s/ Algernon L. Butler Chief Judge of the District ’ -Court of the United States _. for the Eastern .District of : ™” | North Carolina ak : | . /s/ John ‘D. Larkins, Jr. mam . + Judge of the. District. Court - _ . . of the United States for the Eastern District of North Carolina A True Copy, Teste: SAMUEL A. Howasp ~ Clerk By /s/ [Illegible] Deputy Clerk © B06 [Caption Omitted] "ANSWER OF ROBERT MORGAN, ATTORNEY GEN- _/ BRAL OF NORTH CAROLINA, IN BEHALF OF - THE STATE OF NORTH CAROLINA—INTERVEN- | . .ORDEFENDANT.- The Intervenor-Defendant, Robert Morgan, Attorney General of North Carolina, in behalf of the State of ‘ North Carolina, answering the. original and amefided ‘complaints, filed herein, alleges: ORIGINAL COMPLAINT an 1, The Intervenor-Defendant has not knowledge or- in- formation. sufficient to forma a beliéf ‘as to the truth of \ Paragraph 1 of the original cqmplaint, and, therefore, denies the same. 2. The alleg»tions of Paragraph 2 of the original com- plaint are denied. - 3 4 3: The allegations of P aragraph 3 of the original com-.. . plaint are admitted. —_ 6. That the Intervenor-Defendant is not concerned ~ Paragraph 6 of the qriginal | e Intervenor-Defendant is not concerned with the rs alleged in Paragraph 7 and is not required to 807 > ‘11. ‘The allegations of Perseeueh 11 are sihiati 12.” The Intervenor-Defendant for lack of knowledge or information to.form a belief -as to the truth of Para. . graph 12 of the original complaint denies the same. ' 13. The allegations of Paragraph 13 are denied. _ 14. The allegations of .Paragraph 14 are. denied, 15.- The allegations. of Paragraph 15 are sha ~~ CLAIM.TWO are re-alleged as Answers to this Claim /and. ineorpo-/ rated herein by reference as if fully set forth and all herein. — 16. That Paragraphs 1, 2, 3, 6 and 8 of; this Answer / 17. For lack of - ‘Mnow latino. or information. suftciente - to forfn a. belief as to the truth of allegations 11, are denied. they 18. The intervenor-Defendant alleges: that he is not required to answer, Paragraph 18 ‘of the original com- . plaint since they are concerned with matters ; f adminis- tration. 19° Answerihg the aiacations of Parherath 19 of: the original complaint: the Intervenor-Defendant alleges that neither the State, the State Board of Education, or the State Superintendent of. Public Instruction has any legal authority: to fix attendance areas, assign pupils ‘to the various facilities of the pyblic school system, dr to adopt. or implement plans of: de¢e segregation ; and except as alleged said paragraph is denied. | here ~ 20. On information and belief, ‘said Paragraph is de. “ _ nied. 21. The allegations of Paragraph 21 are denied. ‘AMENDED COMPLAINT |B Answering Paragraph 1 of the amended complaint, it is’ admitted that the Attorney General of the United States attached to the original complaint his certification as therein shown; that itis a condition precedent ‘to the bringing of this action that there shall be secret com- plaints made te the. Attorney General of the United ‘States; that any action -based: upon secret — is ° . . void, invalid and. unconstitutional and a Violation of the due process clause and the equal protection ‘of’ the law. cause. of the’ Fourteenth Amendment of the Constitution of the United States; that the provisions of 42 USC . 2000c-6¢a) and (b) are unconstitutional and void in that. said ‘provisions purport to confer jurisdiction, upon Fed- a - eral Courts .to- entertain actions based upon secret com- F plaints, discriminate in favor of one -ethnie group as y " against another ethnic group by furnishing government _£ attorneys to one group as against. another group, fur- . i nish costs and expenses in favor of one group as against - _, another group, and thus create an ‘invidious discrimina- i/ tion in favor of one group of citizens as against another — . f | group of citizens in violation ‘of the Fourteenth Amend- te. a ment of the Constitution of the United States; and ex-. . cept as herein alleged said paragraph 1 of amended fom- plaint is untrue and'is denied... =, . -° é 2. The allegations of Paragraph 2 of the amended ‘- complaint are untrue and are denied. pi a te a 7 _ 3. The allegations: of Paragraph 3 are admitted. _ ae 4. The allegations. of Paragraph 4 .are.admitted eX- “| cept it is denied that such action should lawfully be main- og 5. The allegations of Paragraph 5. are admitted. oa f 6. The allegations of Paragraph 6 are admitted. 7. That ‘the Intervenor-Defendant has not knowledge or information sufficient to form a belief. as to the truth . Of the allegations of Paragraph. 7, and,, therefore, denies — Ft, ng, ae ee oes : 3 _ _8.. The allegations of Paragraph 8 are denied for lack eo of knowledge or. information sufficient. to. form a belief as to the-truth of same. > — | Bie 9. The allegations: of Paragraph 9 are admitted. = 10. The allegations of Paragraph 10 are aren ee a" 11. The allegations of Paragraph 11 are admitted,. -- 12. Answering the allegations of Paragraph 12 on in- TREN Roget ST . perintendent of Schools and: prepared to open its Schools for the school year beginning in the Fall of 1969; ‘that > ‘ - ss ” ep | re : i a. - £809 oo i ae) . except as herein admitted the-‘allegations of Paragraph 12 are denied. - : & tg Oe _ 18. The allegations of Paragraph 13. are denied, _ 14., The allegations of Paragraph 14 are untrue and -are denied; further answering said paragraph; Inter. venor-Defendant alleges. that it is untrue that’ the ‘size | and pupil enrollment shauld control: the size of the -edy- ‘cational administrative unit; that- large‘ educational units. / with marching bands, football teams, gymnasiums and many social and ‘athletic events and numerous extracur- rieular activities are desired by those who stil] worship - - + the outworn creed 4nd bankrupt philosophy: of ‘so-called. .. progressive educatior\in which system actual imparting q of knowledge and insthuction of the pupil “is lost in. the shuffle; that.in many cases the smaller unit furnishes . better financing, better instructors: and graduates a stv. \, . dent of high caliber ‘who completes is. college education; _ it is further alleged that _the\peoplé_ have the constitu. tional right to. determine the type, of administrative unit .” they desire and ‘not theoretical. scaled educators who desire a bureaucratic, dictatorial. pwdlic school system _ under their ‘complete control; that. the ‘Rederal’ Govern- ~ ment has no constitutional’ right, under theguise of con- _ , Stitutional interpretation, to determine the typecand size of the school administrative unit that the people of, the State shall have and use. _ Pre, - TN, _‘ 15. The allegations of Paragraph 15 are untrue and _ years; that the Scotland Neck City Board of- Education e has never had the chance to administer its school system - _ oe ~ and aos -coamplirg its proposed or future ad- ‘ministration is nothing but speculation and conjecture; ‘that no constitutional attack of this nature can ‘be made until. the practical: results of such administration are available; that if Chapter 31 of the Session Laws of 1969, is unconstitutional and irfvalid then the stability of every * school administrative unit in the State- of North Caro- lina is endangered and subject to attack if the members of the black race are dissatisfied and displeased with its. boundaries ‘and enrollment limitations and it will take a Federal decree to settle every boundary and ¢ttendance area; it is again denied that Chapter 31 of the Session Laws of 1969, is unconstitutional and invalid or that it - Violates any provision of the Fourteenth Amendment to ‘the Constitution of the United States and it is alleged. ‘that those who pay the largest part of the taxes that - support the public school system of the State should have — : some voice in public school administration. . § = AG. The allegations of Paragraph 16 are. untrue and — aredenied- - re ee CLAIM TWO. 4 _ 1t. That the answers to Paragraphs 1, 2, 3,7 and.8 — of Claim-One of this Amended Complaint are here re- ~ alleged in’ this Claim and are made a part hereof by ref- | erence, 2° oe, , _ | That the Intervenor-Defendant has_not knowledge or Jif ation’ sufficient to form a belief as to the truth | of the allegations of Paragraph 18; _and,. therefore, de- © . Mies the same. _ . 19. That:the allegations of Paragraph 19 relate to the Halifax County Board of Education and this Intervenor- Defendant does not know what alternative ‘methods ‘of pupil ‘assignment are available for this.county unit, and, » therefore, denies ‘said’. Paragraph 19. Soe 20. That Intervenor-Defendant does “not know what’ the Halifax County School Administrative Unit has failed and refused to do nor what plan of desegregation it has - failed to adopt, and, therefore, denies said paragraph 20. roy * . “ , . . . . ; « . . ° "° ak : . OOF Eppa re wm. ty " _ _ a ‘ -_ am Y . a ; 7 4 \ id ° ’ 811 | . 21: The allegations of Paragraph 21 are untrue ai are, therefore, denied. . -. ae 22. -The-allegations of Paragraph -22 are untrue ‘and are denied. | WHEREFORE: having fully answered, the Interveno. Defendant prays the Court:: © pot (a) That Chapter 31 of the Session Laws of 1969, enacted by the General Assembly of North Carolina, be declared ‘to be constitutional and valid. - _ (b) That this action be dismissed and the Temporary Restraining Order. heretofore entered in this cause be dismissed: Fo, ae | (ce) That, such other and further relief be granted by. the Court as -may be proper and just. 3 _ ’ be /s/ Robert Morgan _ Attorney General of: _ -North Carolina /8/ Ralph Moody . . Deputy. Attorney General of North Carolina * P. O. Box 629 . Justice Building © | Raleigh, North Carolina 27602 [Caption Omitted] -* ORDER This cause coming on to be heard. befbre the Court on a motion for a preliminary injuriction filed by the plain- tiff seeking to restrain the defendants from: giving any - force or effect to the provision of Chapter 31 of the . North Carolina Session Laws of 1969, an Act to “estab- lish a separate unit for the operation of the public schools: of the town of Scotland Neck, North Carolina and _there -. being also before the Court a. motion by the defendant, _ Halifax County Board of Education, that it be dismissed from that portion of this action dealing with the consti- tutionality of the Scotland Neck Act as said defendant was not.a party to the creation, of said Scotland Neck _ Unit; and it: appearing to the Court that said .defend- ant, since it was not a party to the creation of said Act, should not be put to the expense of defending this action in this Court or ‘in any subsequent appeals, if any there be, as said defendant is already before the ‘Court charged with violation of the Civil Rights Act and will be bound by the orders of this Court to comply: with all the laws, state and federal, affecting the public schools - in Halifax County. ; It is therefore, ORDERED, ADJUDGED and DE- CREED; ee! THAT - the ‘motion ‘of the | defendant that ‘it: be dis-.. missed from this action is allowed insofar as the ques- — tion of the constitutionality of the Act creating the Scot- _ land Neck’ Unit is concerned. Said defendant will no ’ longer be réquired’ to defend or. appear in subsequent. ° _ actions, involving enly - the constitutionality of: the Act creating ‘said unit, but ‘said defendant is not® relieved. from the other parts of this action involving its violation of the Civil Rights Act, but shall comply with the orders of this Court, and orders of any Appellate Court or the Supreme Court of the United States of America, as they ‘may effect the operations of the publie schools of Halifax - County, LF us a 2 nn —— ee | 813 THAT this. ORDER shall become ‘effective: ‘S$ soon as it is executed by the Court. : Let this ORDER be entered forthwith. This the 3rd day of. Moremi, 1969. 2: ‘October .. - Raleigh, N orth Carolina pee | /*/ John D. Larkins, ie ‘JOHN D. LARKINS, JR. United States District Judge ALGERNON L. BUTLER } United States District Judge 814 PLAINTIFF'S EXHIBIT #38 Civil Acton No. 1128 ANSWER TO PLAINTIFF'S INTERROGATORIES | TO DEFENDANT HALIFAX COUNTY BOARD OF - _ EDUCATION | October 28, 1969 IN THE UNITED STATES DISTRICT COURT. FOR THE EASTERN DISTRICT OF NORTH CAROLINA - WILSON DIVISION Civil Action No, 1128 | - UNITED STATES OF AMERICA, PLAINTIFF, Vv. HALIFAX County BOARD OF EDUCATION, a body - corpo: rate, and the SCOTLAND NECK CITY BOARD OF EDvu- CATION, a body corporate, DEFENDANTS, ‘ANSWER. TO PLAINTIFF’S ere nkoestonns 4 TO DEFENDANT HALIFAX COUNTY BOARD OF -. EDUCATION _—— oe hiatal, | . : 815. APPENDIX w Q exeveseroe.. | a ie : 816 1 Please state the name, location, brates served, “date - of construction and any substantial additions; and at- tendance zone lines for each" school in defendant’s school mit for the 1969-70 school year. If there are no present. attendance, zones, describe the lines for the zones for the last year before: they were eliminated, and state what t year that- was. If possible, please show as much of this information as‘practicable on a map, such asa general highway map prepared by the North Carolina Highway Department. 1. The names of schools, ‘grades served, -date of con-: _.struction and substantial. additions for - the ‘schools . in _ Halifax County Unit in the 1969-70 school unit are shown on the attached form. ( See attached sheet No. 1). ~ The location of these schools are shown .on the attached map (See attached map No. 1). There were no attendarice zones during’ the 1968-69 ‘school year except for pupils in grades 7 and 8 who were © transferred to predominantly white schools as follows: . Grades 7 and 8 from John A. Chaloner School to. William R. Davie School. . Grades 7 and 8 from McIver School to Aurelian Springs School. | . Grades 7 from Inborden Elementary School to En- | field School. - . Grades 7 aid 8 from —— School to Scotland Neck School. There are no attendance ‘zones for the 1969- 70 school year. _ 3 Ee PRT LPC a af in oe : . ; >t ve snags 5 pe a ltt " “ . 7 . . ‘ ~ , . aera Nai MAN ED SAMI aN lb iANRIMLSSLIZ IGA Ls) wagon IW oy esdelaaid a guacdatauiats Bsa, Ph aaa 255 a ll okt ssitauatdintes es z : é . SL aE INAS RRR UR TI eR AEN FM DL CESS RIES SENOS Tt TM NNT BOE SRN AN ANON Rie in NT é - * . e . . : . a .* 2 School. Grades Served - Date of Construction - Date of substantial. additions 00 ‘ ‘ : \ 7 , . . a 7 i . # 7 , ~— Aurelian Springs : 1-12 _ 1922—4 classrooms . 1925—4 classrooms, 1 library’ Route 2; ° . Auditorium ‘ 1929—5. classroon\s, library - Littleton, N: C. ; ‘ 1984—6 classrooms ; ; 1935—1. classroom; 1 -shop 1948—Gym-Cafeteria . 1959—3 classrooms al e 7 t ° Bakers Elem. , . . 1-8 1959—10 classrooms — 1961—3 classrooms, 1 Cafe- Route 1, Box 103 a a . 1 Library. torium . Scotland Neck, N.C. , — : :; a Brawley School | “,° 4-12 + 1926—8 classrooms 1937—8 classrooms : ; . Scotland Neck 74 . 1 Library ‘1942-2 classrooms, 1 shop- : ; -. North Carolina + ae are a ; 1951—5 classrooms, 1 library . . 1955—5 classrooms , 1960—Gymntorium, 4 class- rooms _ , 1968—Cafeteria Dawson Elem. 18 —. ' 1938—4 classroom -.. ° *1957—6 classrooms a Scotland Neck — ' yO 1 Music Room 1960—10 classrooms, 1 li- North Carovlina : _ brary, Cafetorium * Eastman “sy 1-12. 1947—1 cl. srucm _ 1949—Gymtorium Route 2, 1 sh . 1953—5 classrooms, 1. library * Enfield, N:C:-. _ , oe ; ' “ » 1956—7’ classrooms | : ; 1959—13 classrooms, 1 li- _ : brary *- = a : 1968—Cafetorium . Enfield Graded : 1-12 = 1948—20 classrooms 1952—1 classroom, 1 shop Enfield, N.C. : ; Library , are ‘ : : . , Auditorium si ; 7 : . Cafeteria Par : Gym _ School Everetts Elem. sgh ‘ Route 1, we Roanoke Rapids, N.:C. : : . Holhster Elem, 3 Holli El we Hollister, N.C. - Inborden Elem, .. Enfteld, N.C. Inborderr Hi h-: Enfield, N.C. ~ J. A. Chaloner | Roanoke’ Rapids North Carolina ’ Melver High _ Littleton, N.C. yo : * ee Seay PRRs Ce er i Vries ey perme tansy PRN . i 5 aad on Grades Serve 1-8 1-8 9-12 1-12 ... 1-12 Date of Construction . Date'of substantial additions 1958—14 classrooms Library 1960—13 classrooms 1948—12 classrooms cafeteria 1951-—5 classrooms” library 1924—-5 classrooms library: auditorium 1925—6 classrooms TURN RR MR ert Sonate RH Ce Ret cot 1960—6' classrooms, Cafe- — torium’* rr 1966—Cafetorium, Library 1954—2 classrooms 1956—2 classrooms, library 1960—12 classrooms 1969—Cafetorium 1955—3 classrooms, Gym- ~ torium .. _ 1961—1 classroom, 1 slop 1988—4 classrooms on 1940—-1 classroom, 1 shop -1941—7 classrooms, caf@eria 1942—1 classroom | 1944—-1 music room 1945—Gymnasium 1950—2 classrooms 1955—6 classrooms . 1958—9. classrooms, library 19380—4 classrooms _. '1941—band room, 1 class- ‘room, 1 shop’ | 1948—Gymnasium 1954—-2 classrooms, library -1959—8 classrooms . 1964—6° classrooms 1968—cafetorium . School ae . | Grades Served Pittman Elem. | ot : 1-8 - Route 8, : >*s 7 Enfield, N.C, s. | ; Scotland Neck School _ . 1-12 ‘ Scotland Neck, N.C. _ - _ Thomas Shields . SO ; 1-8 a Hobgood, N.C. Tillery. Chapel Elem. _ rae N.C, a. z ’ Route 2, Enfield, N.C. ~ Wm. R. Davie Pa . . ‘ 1-12 Route 1,: “ Roanoke Rapids, N, Cc. Date of Construction 1959—15 classrooms ‘library 1908—12 Sinstionede. i oO library ay s -1957—6 classrooms 1932—4 . classrooms e 1959—10-elassrooms 1940—11 classrooms 1 library auditorium > . ‘e - . » bd ‘ is 4 4 Pe Pas ra Date o 2 of stantial additions _ a - 1960—eafetorium, 1 ‘class- room 1923—cafeteria, 3 class- rooms, library 1939—1 Home Ec. Lab, 2 classrooms, 1 shop, Gymnasium 1949—1 classroom . aa en auditor- = 1960—4. Georedeia” cafe- teria, library _1958—4 classrooms 1961—library, cafetorium 1957-6 classrooms : 1962—1 classrooms, library, cafetorium, 1966—1 classroom, library, cafetorium. 1952—4 classrooms, library 1953—1 shop, cafeteria, gym- ; “ ‘nasium, 1955—5 classrooms 1958-—4 classrooms 1961—2 classrooms — J - * wv _ stale Ake seins diy Caiomata commited 618 miy~ POMP HE VR MEO \ : — .. . » ‘ . 7 . - . . . . - a. - « 7 ; : . ; . ERRNO ERP etaE scieccones ' he pees 6 me eam aX: Sy AR ag ee ? « \ - a? — i ‘ , \ ‘ ' . ne ie » oy ae a t : ‘awe ieOetarion ° atv eke or sf 7 7 . ~! . * . PY ‘ e\ . \ . ‘ ie ” HALIFAX COUNTY toy aA rear cae. we aa “———__g04 2. Please describe any changes in. the number, names, locations, grades served or attendance zone lines of the _ schools in defendant’s. school unit since the beginning of the 1964-65 school year. | _S 7 2. Changes in school organization since the beginning © of the 1964-65 school term are as follows: ~ a. John Armstrong Chaloner School formerly in - noke Rapids City School Unit and the Halifax County” | School Unit, and by action of the State Board of . - Education began operating as a part of the Halifax - County School Unit at the beginning of the 1966-67 — . school year. This school had been operating to serve approximately 80% who were living within the Hali- County at the beginning of the 196’ -68 school year. € elementary department of the Haliwa Schoo}. . Was closed at the end of the 1968-69 school year and approximately 140 students grades-1-8 who live in Halifax County: transferred to schools in Halifax . County. : red, Die Same ? : 2, (4) Upon closing grades 1-5 of the Littleton School : In Warren County at the close of the 1968-69 schoo! term - ‘s 822 - approximately 60 students who live in Halifax County - Were transferred to Halifax County Schools. (See at. — map No. 1). (a) Please state the enrollment in each school by tai and race for the 1964- 65, 1965-66, 1966-67, 1967. 68, 1968-69 and 1969-70 school years, and for. any other’ - school year in which there - ~was any Clesegregation of pupils in the system. ° . HALIFAX COUNTY SCHOOLS : Halifax, N. C. Enrollment. by Race and Grade. for the . Following Years SCHOOL: | Aurelian. ‘Springs . 3 | . 1964-65 - 1965-66 _. 1968-67 1967-68 1968-69 _ 1969-70 GRADE W NW W NW.W Nw W NW W NW Ww NW - eg) —ettton = 1. 80 20 25 26 20 4863 «16. ~~ (20 . 2 21 28 17 28 25 25° (17)1 8 23 23 25 1 16 1 28 19 (21) ‘ 4 26 28 20 1 28° 1° 20 23 (19 5 31 ' 27 23 21 1 29 1 48 . (28)1 Py 6 29 33 © 23 1 25 19 27 =(15)1 7 36 28 80 1 24 1 25 5318 (12) ¢ : 8 7 39 26 29 2 -22 64 25 (15 Spec. Ed. ’ : (12 9. 38 46 38 17 31 22 «31 23 «(14 (22)3 10 27 33 42 14 29 17 26 18 29 (14)4 . 11 33 25 85 11 38 13 81 138 25 (16)3 *. 12 24 30 23 12 26 14 36 10 24 (12)1 TOTAL 865 860 8260 «BB O21 72 817 186 263 232 W-=White - . . ss NW=Negro or Indian ° | -% . . ee )=Indians in Predominantly Negro. Schools . ; Enrallment figures were determined at different times during the school year. COMMENTS: ° 7 | . : . 90 . : a) - | bs Yeas De een * mere w at : -_ . ‘s s —n * Lin? egos: ; Be BE epee nae rege sans = Weates . ws = ; . Sepang P ‘ ; MRM erpe OHTA . . . of : ? -. - . . ? , ™ e HALIFAX COUNTY SCHOOLS : Halifax, N: C. _. .Enrollment by Race and Grade for the Following Years SCHOOL: Bakers | : 1964-65 1965-66 1966-67 1967-68 1968-69 - 1969-70 GRADE. W NW W NW W NW W NW W. NW .W. NW (.)==Indians in Predominantly Negro Schools \ ; Enrollment figures were determined at different times during the school year, COMMENTS /?. ; —— 1 49 42 39 36 27 36 2 44 49 87 42 34 29. 3 62 39 41 31 36 39 4 ¥ 47 41 36 37 29 39. 5 45 41 33 39 43 27 6 . 48 49 41 34 38 45 q 43 47 56 86 33 34 8 42. 87 44 49 34 85° Spec. Ed. 18 18 20 15 9 9 10 11 : . 12 = . . . ye ss \ TOTAL 383 | 863 . 847: - $19. 283 —(«, 284 W=White NW==Negro.or Indian ° “\ a e HALIFAX COUNTY SCHOOLS , ; - Halifax, N. C, _ @ or, oe . Enrollment by Race and Grade for the Following Years - SCHOOL: , Brawley Pa - ; . . | on a _ 1964-65 — 1965-66 1966-67 1967-68 __-1968-69 | __ 1969-70 | . GRADE W NW W NW W NW W NW W. NW W NW 1 65. . “61 63. 48 Ct 60 » 50 ’ -" 2 67 61 52 50. 59 ba 3 70 62 ° 54. 49 - 54 ‘53 4 71 66 55 56 49 55 ° 5 72 70. . BR -° 6B. 66°: 42 6 66 | 74 1 58 a) ry) oe rn: 68 73 2 = 48 - ie ft 7 61 -6F = 9M 80°C: 56. Spec 18 18 ‘ -18 8B - s¥¥% , . : 221 234 218 282s ~ 247 1 =--* 161. 170 192° * 157 182 184 > i ae 112. °* WWd-) 148 4. 154 12 , ; 12 *. 104 9% |. 106 108°. 118 124 | ae i on eS TOTAL | 11575977 1151. . 1106 © 1117 *'; “W=White BAP | | Co : NW=Negro or Indian . 2% . - 99 . 9 , Pe . . ° ~— a - at 11 ; “ae ce , a i ° - 6 5. 45 3) a 3) 29 4 37 (6-84-10 19 7 6 °..42 ee 5 30 5 82 -7 2g 8 : ee ee ae | 47 4 42 7° 81 .128 . 23 20 ee a 37 1-40 2° 47:. ..7 47°. 6 16 17 Spec. Ed: 11 © aes ~ Seen x : ee eee ite a a so a ee | 5 26 9 1. Gwe 8 Me ge. 5. 81. 2 82 7 11 40 i @ 4.9 32 85 T™ & 1 «17 3 ie ae aos. 8 10° 96 -10 .-g 5 TOTAL 606" 6 456 69 419 .. 67. 404 (77-408 177 256 @ 89 W==White i : : : NW==Negro or Indian * Halifax, N. Cc, “Minvoliendas by Race” and . Grade for the ‘Following Years SCHOQL: Everetts 1964- 65 1965-66 - 1966-67 1967-68 1968-69 1969-70 se GRADE Ww wid W-.-NW. W NW; W. NW ww. Nw W soNW. ees "89° 96 76 i tree ame 57 ee 66 a . ee 66 - 46 3 .,. oes. eo) 62 66. i Se ‘91 58° ae 67 “+ ae : em 69 es 57 a> ae ee 70 " 73: eo a 50. or ay ee. ee 7 64 es 60 -~ 50 ec 70 . 56. : 62: i? 55 Spec. Ed. : 18 ee alee: 5 . * 9 . ae = : 10. ae fl , W=White - NW=Negro or Indian ~ 2 waee: : > | ot . ; 7 TOTAL ‘598 614 -. * 647 ; 20 478 _ 460 C joe =Indians in Predominantly Negro Schools . Enrollment figures were determined at di COMMENTS: ° erent times Surte:# the school year, wy ° : leigh Neins & Observer 9 ie 08), 3 ae , | ANNOUNCES. SCHOOL PLAN |. HALIFAX—The. Halifax a ty. Board of Education , announced. a ‘desegregation. plan Tuesday affecting its 18 . . ‘public schools, four of which are. predominantly white and 14 all-Negro. . © ~C. M. Moore Jr., chairman, said’ the. plan resulfed. from demands by the U. S. Department of Justice in July, 1963 - that ‘a dual system be eliminated and .that the: Halifar ff schools be in full compliance with: the? Civil Rights Act of 1964 at the beginning of the 1969-70 School year, Halifax was ordered to submit its plan to the ay ‘ment of Justice not later than March-15, 1969.- _-*, The plan ‘specifies that any student assigned to a school - ' where there is less than 15 per cent of his race or les . than 15 per cent of a race different from his own, may be assigned to. a School where such a situation ‘does. not - exist. / .. A student: desiring such a: transfer must make a _’ “timely-request”. and furnish his own transportation to the school to which he transfers. ; . Staff. and faculty, according to the plan, shall be as * signed as far as possible to constitute the. same ratio be: tween white and Negro races as exists in student body. - The plan further states; however, that. no’ school fac- ~ ulty shall be comprised .of less than: 12 per ee: of either ” - Negro or. white. ‘The dual bus system now- “used. to transport students and from school will be eliminated. ‘The buses = be - operated without regard to racé,. . . There are approximately 10,655 students in. the Hal fax school system, including 8, 196 Negro students, 2,357 whites and 102 Indian students. ere are’447 teaehers, . = 322 t Negro, 123 white and two Indian. r : a oe ae aon & Observer, 2/14/63) s : - RUSH TO THE REAR . One of the ‘most. astute comments so far on the Scot- land Neck school separation moyement came from a local © foe who called it “a- ad backward when we:should be “ping forward. roe ON vo Instead- of.-Striving . to strengthen all Halifax County - ghools' through consolidation, Scotland Neck people -sup- porting an independent school unit for their town limit a Shere for better education to municipal. boundaries. _ ‘They: want town money confined to town schools. Pre sumably, the rest of Halifax could just go begging. | _ Shrewd strategists are at work arguing through. the General Assembly ‘the bill permitting a local referenduni m the separate unit idea. They claim that there’s no a hope.for passage of a countywide school tax, while Scot- : land Neck people probably would support a..town levy. _And as Rep. .Thorne. Gregory said on behalf of the refer- - ndum ‘bill he introduced, “the — of. Scotland Neck ‘ know what’s best for us. ae ‘What Scotland Neck seliesetiote paeee believe best Ae for them is' an educational island dominated by whites. - Statistics make this clear. The Halifax County school system now has about 8,100° Negroes and. 2,300 whites; i Scotland Neck’ unit would have some. 736, Writes and : mt Ne oes. The. county. school system must fully: inte- | September. Undouhtedly, Scotland Neck would © ie td. do its own integrating. By creating a sharper . racial imbalance in_municipal schools, the town would: ° promote a sharper imbalance—in reverse—out in the county, , ~ ‘The forgotten. ones in this matter ¢ are the children who: — would‘remain in the Halifax County school.‘system. If Stand Neck pulls out, county schools. will be left with just 37 per cent of Halifax’s taxable property from which to draw support for educating roughly 67 per cent of — Halifax children. The State, furthermore, would have’. . lo subsidize this inequity by footing a $22,000 bill for Scotland Neck’s school’ administrative offices. ax ee 3 a a 3 ae . j : . a. - , P . . : , = 3 : - . . ® ™ % . 786 sae santas wee . : : : ‘ 2 Ss = a ‘ 3 , | The separation bill got sedis the House on Wednes. ’ day, aided by .an incredible argument that Sitice it was *, Jocal -legislation, balking gt it would be a personal. in- * sult to the sponsor. Surely: the Senate will. display 3. more responsible concern over this . measure, which is local in name only and far removed from the usual pay hike or dog tax ‘proposal. It suggests a- precedent whic truly would be a rush.to. the rear, and. North Carolina ‘~~ could pay for it with inferior county. — _ ica ; orating r race relations. . es ae 7 [Raleigh News & ; Observer, February ‘22, 1969] ee NEW STATE POLICY? oe If the State Senate approves the. Séotland Neck seo . _.... bill, it will. do more than separate the present Halifar pga. County School System into two units—with most of the _county’s white pupils in a new Scotland Neck unit. . Ir * disputably the Senate+also will set a new State policy contrary‘ to thé’ desirable trend toward consolidation and , contrary to the spirit if not the letter of federal law.— This i8 no simple matter of acceding to a local goven- ment request, of letting the people involved have the kind - Of school structire they want. The State legislature wil .be giving official endorsement and $22,000 in State funds . for the fragmentation of a-school system now so small it is lacking in some aspects of educational soundness and: efficiency. 7 . The example will not be lost on. ‘other school items - confronted with similay racial problems. They will sek —and how. can the legislature deny them?— -. gourse of least resistance,‘ the-same creation of new schod - + . units with less. racial accommodation. . And in each it stance the State will be footing the bill for new admit: istrative costs and putting its stamp of acceptance on the _.educational inefficiency and racial jl will created ~ This would be new State policy of. using the legis -+, ture to evadé national policy. If it failed—if the court - struck it" down—it ‘would create new and unnecessaly eb ry it wind encourage more racial apartness and dis- ; trust. Negro North Carolinians would be given an — lesson in White Power, and a oo example ff Law and Order with Justice. ~The Halifax County school system may have ‘special The legislature could provide. the education . tools and money to help meet them. It still could/post--— action until it researched such: possible alternatives. ‘The Scotland Neck ‘school bill is.a. change in State’policy, — with far reaching consequences. It ought not: to be en- acted without further search for a. wiser, less harmful! -answer to the concerns’ of Scotland ‘Neck people. . ,° eithip our gvitrniientat Selatie: If” it. a ee oe |N WRIT OF CERTIORARI TO THE UNITED STATES COURT patience! ce. cake Naianceedl . _Pmons rou. wairs oF césnonant YUED APRIL, Wt eae AND ‘MAY 29, 1971 | _ GRIMIORARI GEAWTED OcTomEE 18, 197 ie 803 “hereto. that have been or may be made herein insofar as ‘said pleadings and motions are based on the contention ‘that said act of the General Assembly of North Cardlina is in any respect, or in any application, unconstitutional, ° ; WHEREFORE:”’ Applicant prays the Court that an -. order be entered herein allowing applicant to intervene in this action as a party defendant and that his proposed answer be filed as a pleading in this action; that this _ motion be brought on before the Court for hearing on *October; 24, 1969, at the Federal Courtroom in Raleigh, North Carolina, ‘or at such other time as may be con- venient and as ordered by the Court. /s/ Robert Morgan Attorney General of North Carolina ‘/s/ Ralph Moody - ; Deputy Attorney. General of North Carolina *P. O. Box 629 Justice Building . Raleigh, North Caro ae 7602 804 [Caption Omitted] “ORDER ALLOWING INTERVENTION OF ROBERT MORGAN, ATTORNEY GENERAL OF NORTH CAROLINA, IN BEHALF OF THE STATE OF NORTH CAROLINA. ° a | This cause coming on to. be.heard upon the Motion of — | : the Attorney General of North Carolina that he be al- =— \ “lowed to intervene in this action as an Intervenor-De- _ fendant in behalf of the State of North Carolina; and It appearing to the Court: that there is involved in’ this action a question’ as to the validity and constitutionality . . of an ‘Act of the General Assembly of North Carolina; a a that this is a- question of public interest throughout the ‘State and involves the right of the State to create a pub-, lie school administrative unit; that it is a legal possibil-— ity that the State of North Carolina may be bound by ' the judgment entered by the Court between the parties plaintiff and defendants as this action now stands; that there is a common question as to the validity of a similar statute involved in the Warren County. case which is con - slidated with this: case; that the defendants in this ac- © " tion rely upon the validity of Chapter 31 of the Session Laws of 1969, enacted by the General Assembly of-North | Carolina: — | | IT IS, THEREFORE, ORDERED AND ADJUDGED . BY THE COURT: That as.a. matter of right, or in the - © alternative, in the discretion of the Court, as a permis- sive right, thé Attorney Genéral of- North Carolina, in _ behalf of the State-of North‘Carolina, be, and he is here- by allowed, to intervene in this action as a. party inter-, ° _ Venor-Defendant, and-that he be allowed to file -his An- ‘Swer which is attached to the ‘Motion herein filed. TT I§ FURTHER ORDERED BY THE COURT: .=©- + That said Intervenor-Defendant shall accept the status Pp of this action as it now stands and: shall be bound by the Temporary Restraining Order heretofore entered in this. Cause with the right to adopt’ the objections, exceptions - and motions in this cause that have-heretofore been en-- » SSRI ETO Re Rah oe é . -- & 805 ee “2 tered by the other defendants and ‘to support the validity, of Chapter $1 of the Session Laws of 1969, 48 enacted _ ~~ by the General Assembly of North Carolina. IT IS FURTHER ORDERED BY THE: COURT: - That the Plaintiff be allowed to file such responsive plead- ing to the Answer of the Intervenor -Defendant as it shal} deem to be- advisable. This thie 31 day of cde ten ‘/s/ Algernon L. Butler _.. _ Chief Judge of the District — ' ..Court of the United States _ for the Eastern District’ of orn Carolina /8/ John D. avian: Jr. Judge of the. District Court of the United States for the . Eastern District of North Carolina A True: Copy, Teste: SAMUEL A. HowaRp Clerk 7 os me By /s/ [Illegible] | | Deputy Clerk - [Caption Omitted] XSWER-OF-ROBERT. MORGAN, ATTORNEY GEN- ERAL OF NORTH CAROLINA, IN BEHALF OF “THE STATE OF NORTH CAROLINA—INTERVEN- * . OR- DEFENDANT. | The ‘intewwente: Defendant, ‘Robert _Morgan, ioe ‘General of North Carolina, in behalf of the State of North Carolina, answering the original and amended _ complaints, filed herein, alleges: ‘ORIGINAL COMPLAINT 1. The Intervenor-Defendant has not knowledge or in- formation sufficient to form a belief as to the truth .of Paragraph 1 of the original complaint, and, therefore, ‘denies the same.. 2. The allegations of Paragraph 2. of the. eriginal-com- plagat are denied. : 3. The allegations of Paragraph 3 ot the original’ com- plaint are admitted. | 4. The allegations of Paragraph 4 of the original com- “plaint are admitted. _ 7 5. The allegations of Paragraph 5 of the original com- . plaint are admitted. ° 6. That the. Intervenor-Defendant is not concerned __ with the matters alleged in Paragraph 6 ‘of the original _ answer and neither admits or denies the same. _. 1. The Intervenor-Defendant is not concerned with the matters alleged. in Paragraph 7 and is net _Tequired to answer same. 8. .The Intervenor-Defendant i is not soneened with the matters alleged in Paragraph 8 and is not required to . _ answer same. 9. The allegations: of paraerape 9 of the original com- plaint are admitted. ; ‘10. The Intervencr- Defendant has ‘not knowledge or | information sufficient to ‘form a belief as ta the truth of © Paragraph 10 of the a complaint, and, therefore, denies the same. : . eth UU, tip ge), enilaia 4 4 . _ aH. The allegations of Para a, alae. ' RAR at shueiclesine bs ted 807 11. The allegations of Paragraph 11 are admitted. 12. The Intervenor-Defendant for lack -of knowledge — or information to form a belief as to the truth of Para- graph 12 of the original complaint denies the same. 13. The allegations of Paragraph 13 are denied. ibe 14 are denied. \ 15. -The allegations of bi sail 15 are. Gented. \ CALM TWO 16. That. Paragraphs 1, 2, 3, 6 and 8 of this Answer are re-alleged as Answers to this Claim and ineo rated herein by reference as if fully set forth and alleged : herein. 17. For lack of: knowledge or information sufficient to form a beliéf as to the truth of. allegations 17, they. are denied. : 18. ::The Intervenor-Defendant alleges that he is not required to answer Paragraph 18 of. the original com- plaint since they are concerned with matters of adminis- tration. 19. Answering the allegations of Paragraph 19 of the - original complaint the Intervenor-Defendant alleges that - neither the State, the State Board of Education, or the . State Superintendent of Public Instruction has any legal.’ authority to fix attendance areas, assign pupils to the various facilities of the public school system, or to adopt . or implement plans of desegregation ; and except as. here | ’ alleged said paragraph is denied. nied. ZA; The allegations of Faragraph. 21 are pened “20. On information and. belief, said paragraph is de “AMENDED COMPLAINT... 1. Answering Paragraph 1 of the amended coniplaiil \ it is admitted that the Attorney General of the United © States attached to the original complaint his certification __ as therein shown; that it is.a corfdition precedent to the _ bringing of this action that there shall be secret com- . plaints made to the Attorney General of the United . States; that any ‘action based ” upon secret complaints is 808 void, invalid and unconstitutional anda violation of the. due process clause and the equal protection of the law © - cause of. the Fourteenth Amendment of the Constitution of the United Statés; that the provisidns of 42 USC " 9000e-6(a) and {b) are unconstitutional and.void in that = | ‘said provisions purport to confer jurisdiction upon Fed- = -_—|, eral Courts to entertain actions based upon secret com- - plaints, discriminate in ‘av Otago one ethnic group as against dnother ethnic group by furnishing government attorneys to one group as against another group, \fur- —E ‘nish costs and expenses in favor of one group as against . &§ another group, and thus create an\ invidious discrimina- - ~- : tion in favor of. one. group of citizens as against another | ‘ - group of citizens in violation of the, Fourteenth Amend- 7 ment of the Constitution of the United States; and ex- | cept as her€in alleged said paragraph 1 of amended com- = plaint is untrue and is denied. —— | 2, The allegations of Paragraph 2 of the amended complaint are untrue and-are denied. . | 3.. The allegations of Paragraph 3 are admitted. _ 4, The allegations of Paragraph 4 are admitted ex- - “eept it is.denied fhat, such action should lawfully be main- tained. _ eee Gu? at * = 5. The allegations of Paragraph 5 are admitted. .6: The allegations of Paragraph 6 are admitted. . 7. That the Intervenor-Defendant ‘has: not knowledge - or information sufficient to form a belief as to the truth of the allegations of Paragraph 7, and, therefore, denies the same, . | -8. The allegations of Paragraph 8 are denied for lack - - of knowledge or informatien sufficient to form a belief as to the truth of. same: a . . *4 9. The allegations of Paragraph 9-are admitted. | ive _ 10. The allegations of Paragraph 10 are admitted. — ms ‘ ll. The allegations of Paragraph 11 are admitted. — 12. Answering the allegations of Paragraph 12 on in- formation and belief, Intervenor-Defendant admits that. the Scotland .Neck City Board of Education hired ‘a Su- j —. Perintendent ‘of Schools and prepared to open its: schools” i FP © for, the school year beginning in the Fall of 1969; that ~ se PRO NT AEE IT Ley INS True oN . tional right to determine the type of administrative unit : _ "under their complete control; that the Federal Govern- 809° except as herein admitted the allegations of Parag 12 are denied. 13. The allegations of Paragraph 13 are denied, 14. The allegations of/ Paragraph 14 are untrue and are. denied; ‘further - ‘answering said paragraph, Inter- venor-Deferidant alleges’ that it is untrue that the-size - and pupil enrollment should control the size of the edu. cational ring en unit; that large educational units - with marching band football teams, gymnasiums and — many social and athletic events and nurherous extracur.: -ricular activities are desired by those who still worship ' the outworn creed and bankrupt philosophy of so-called progressive education in,which system actual imparting . .of knowledge and instruction of. the pupil is lost in the shuffle; that ifi.many cases the smaller unit furnishes better. financing, better instructors and graduates a stu- dent of ‘high taliber who campletes his college education; it-is further. alleged that the people have the constitu: _ they desire and not theoretical so-called educators. who .. desire a bureaucratic, dictatorial public school system ment has no constitutional right, under the guise of con stitutional interpretation, to determine the type and size of the school administrative unit that the. people of the _ State shall have and use. ; 15. The allegations of: Paragraph 15 are untrue a are denied; ‘further answering said paragraph, the In- - . tervenor-Defendant alleges that Chapter. 31 of the Ses sion Laws of 1969, is a constitutional and valid act of the .General Assembly of North Carolina and is: within . the scope and: authority of said. General Assembly; that county and city boards ‘of educdtion as the proper ager- - eies of administering the public schools of the State have -been.in force and effect since the School Machinery Acs of 1933 and 1935 and there is some 160 to 180. such ab _ ministrative units established in the State; that there are administrative school ‘units in the State that are as ‘small, and some Slightly larger, as. the Scotland Neck: City Administrative Unit and they have operated for some ee that the eee Neck _ Board of Education 810 “has never had the chance to’ admimister its school system ministration is nothing but speculation and conjecture; until the practical. results of such ‘administration are ‘available; that if Chapter ’31-of the Session Laws of 1969, is unconstitutional. and invalid then the stability of every school administrative unit. in the State of North Caro- - Jina is endangered and subject to ‘attack if the members ’ of the black ‘race are dissatisfied and displeased with ‘its area; it is again.denied that Chapter ‘31 of the Session Laws of ‘1969, is. unconstitutional and invalid or that it violates .any provision of the Fourteenth Amendment to that those who pay the largest’ part of the taxes that support the public school system of ‘the State should have “some voice in public school administration. . aredenied).- : CLAIM TWO... erence, . - or information sufficient to form a belief. as to the truth ° of the allegations of Paragraph 18, and, : therefore, de- _ Mies the same. . ; ee Le , 19. That the allegations of Paragraph 19 relate to the Halifax County. Board of Education and this Intervenor- Defendant does not know: what alternative methods of _ stherefore, denies said Paragraph 19. | ee 20, That Intervenor-Defendant .does ‘not know what and refused to-do nor what plan of, desegregation it has | i, a and constitutional attack on its proposed or future ad-— that no constitutional attack of ‘this. nature.can be made — - boundaries and’ enrollment limitations and it will take a :- Federal deeree to settlé every boundary and gttendanée- the Constitution of the United States and it is alleged. ~ 16. The allegations of Paragraph 16 are untrue ‘and 17. That the answers to Paragraphs 2, s 3, 7 and 8 | of Claim: One of this Amended. Complaint are here re- — alleged in‘ this Claim and are made a part hereof by ref-" : 18. That the Intervenor-Defendant has not knowledge- ‘pupil assignment are available for: this county unit, and,. " the Halifax County School Administrative Unit has failed © - failed to adopt, and, therefore, denies said paragraph 20. ~ | a a 4 The si aco of Paragraph 21 are ‘untrue and _are, theréfore, denied. | ' 92. The as of Paragraph 22 are untrue and " are denied. WH EREFORE: has ing fully ayer the teen Defendant prays the Court: ”. (a) That Chapter 31 ‘of the Session ‘Laws of 1969, enacted by the General Assembly of North Carolina, be. \ declared to be constitutional and valid. ; \, (b) That this action be dismissed and the Temporary estraining Order heretofore . entered in this eause be diNnissed. : (@ That such other and further relief be granted by the Court as may be proper and (uae eS — /s/ Robert Morgan \: Attorney Generél of | Noxth“ Carolina “ast sc Balt Moody - | Rebuty Attorney General of ~ | ote Carolina. 629 is Taste Biiding =. ‘Raleigh, Nor “Caroling 27602 -) Pa _ . . - : . ° é é ; . : . bes [Caption Omitted] ‘ORDER > force or effect to the provision of Chapter 31 of the lish a separate unit for the operation of the public schools of the town of Scotland N@ck, North Carolina and there was not a party to the creation of said Scotland Neck ant, since it was not a party to the creation of said ‘Act, should not be put to the expense of defending: this there be, as said defendant is already,before the Court _ the laws, state and federal, sein the public schools - in Halifax County; | | CREED: @ THAT the motion. of the defendait that it be dis- #. . missed from this action. is. allowed insofar as the quies- . tion of the constitutionality, of the Act creating the Scot- land Neck Unit is concerned. Said defendant -will no actions involving only the constitutionality® of the Act creating said unit, but said defendant is not relieved of the Civil Rights Act,: but shall comply: with the orders of this Court, and orders of any Appellate Court or the Supreme Court of the United States of America, as they rad effect the operations of the public schools of Halifax County. ‘This. cause coming on to be heard before the Court on | -g motion for a preliminary injunction filed by the plain- tiff seeking to restrain the defendants from giving any’ North Carolina Session Laws of 1969, an Act to estab- - being also before the Court a motion by the defendant, Halifax County Board of Education, that it be dismissed. from that portion of this action dealing with the consti-~ tutionality of the Scotland Neck Act as -said defendant. . Unit; and it appearing to the Court that .said defend- . '.action,in this Court or in any subseqtient appeals, if any 7 charged ‘with violation of the Civil Rights. Act and will |. be bound by the orders of this Court.to comply with all It is therefore, ORDERED, ADJUDGED and DE- longer be. required to defend or’ appear in subsequent from the other parts of this action involving its violation’ — eae th 2 LEONE MI SI TON ET Rs Pi 813 " THAT. this ORDER shall become effective as soon as it is executed by the Court. Let this —— be entered forthwith. This the 3rd day of November, 1969. -/s/ John D. Larkins, Jr. ‘JoHN D. Larkins, Jr United States District Judge | —_ _. ALGERNON L. BUTLER are | : United States District Judge Raleigh, North Carolina : October _, 1969 —_. ‘ PLAINTIFF'S EXHIBIT #38 sas Action’ No. 1128 ANSWER TO PLAINTIFF'S INTERROGATORIES TO EDUCATION | October 28, 1969 7 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF . os “NORTH CAROLINA WILSON DIVISION Civil Actiori No, 1128 UNITED STATES OF AMERICA, PLAINTIFF, _rate, and the SCOTLAND NECK CITY BOARD OF EDU- CATION, a body corpor ate, DEFENDANTS. ANSWER TO PLAINTIFF’S INTERROGATORIES TO DEFENDANT HALIFAX COUNTY BOARD OF EDUCATION , B14 DEFENDANT HALIFAX COUNTY BOARD OF HALIFAX COUNTY BOARD OF EDUCATION, -a body corpo- AHR ee | 815 . » Questions i mo © vu BSse¢eeen... |& ! ! RS BB of construction and any substantial additions, and. at- . tendance zone lines for each school ‘in defendant’s schéol | ynit for the 1969-70 school year. If there are no present attendance zones, describe the lines for the zones for the t year before they ‘were eliminated, and state what highway map prepared by the North Carolina Highway * Department. . stryction and substantial additions for the schools in -lalifax \County Unit in the 1969-70 school unit. are shown on\the attached form. (See attached sheet No. 1). map (See attached map No. 1). There weke no attendance zones during the 1968-69 transferred to\predominantly white schools as follows: Grades 7 William R. . Grades 7 an Springs Schoo . Grades 7 from \Inborden Elementary: School to En- field School. avie School. 8 from McIver School to Aurelian - Neck School. There are no attendance zones for the 1969- 70 school year. ; ; 816 L Please state the name, locatton, ‘grades served, date that was. If possible, please show as much of this . information as practicable on a map, such as a general 1..The names of: schools, grades served, date of con- The location of these schools aré shown on the attached | shool year eXcept for pupils in grades 7 and 8 who were d 8 from John A. Chaloner School to . Grades 7 ‘na 8 from Brawley School to Scotland ° URC EEO ERR - . AOR Rare ett age uae cays . F Lie oleh duck ae Voda aaa ee co es NONE MD iy e ny O "a School Aurelian Springs Route 2, ° - Littleton, N. C. Bakers Elem. | Route 1, Box 103 Scotland Neck, N.C.~ Brawley School © -Scotland Neck North Carolina Dawson Elem. Scotland Neck . North Carolina ' . Eastman. _ Route 2, - Enfield, «N.C. Enfield Graded Enfield, Nic... . Grades Served 1-12 1-12- 1922—4 classrooms Auditorium 1959—10 classrooms 1 Library 1926—8 classrooms 1 Library 1988—4 classroom 1 Music Room 1947—1 classroom ' 1 shop 1948—20 classrooms Library , Auditorium Cafeteria Gym ‘Date of Construction. " Date of substantial additions a ~ so ne 1925—4 classrooms, 1 library 1929—5 classrooms, ‘library 1934—6 classrooms : 1935—1 classroom, 1 shop — 1948—Gym-Cafeteria 1959—3 classrooms . 1961—3 classrooms, ‘1 Cafe- torium ; 1937—8 classrooms 1942—2 classrooms, 1. shop 1951—5 classrooms, 1 library * 1955—5 . classrooms . 1960—Gymntorium, 4 class- rooms , ‘ 1968—Cafeteria . 1953-6 classrooms 1960—10 classrooms, 1. li- brary, Caf etorium '1949—Gymtorium 1953—5 classrooms, >? library 1956—7 classrooms 1959—13 classrooms, 1 li- brary. 1968—Cafetorium - *, 1952—1 classroom, 1 shop “LIS” : School Everetts Elem. _ Route 1, - . Roanoke Rapids, N. c. Hollister Elem. Hollister, N.C. Inborden Elem. _ Enfield, N.C. Inbordeff High Enfield, N.C. ‘J. A, Chaloner Roanoke Rapids North Carolina McIver High Littleton,’ N.C. Grades ‘Served 1-8, 1-12 Date of Construction 1958—14 stanatGouna Library 1960—18 classrooms - 1948—12 classrooms cafeteria. ° 1951—5 classrooms library ~ 1924—5 classrooms library auditorium 1925—6 classrooms Date, of substantial additions —_— 1960—6 classrooms, Cafe-? torium 1966—Cafetorium, Library. v 1954—2 classrooms 1956—2 classrooms, library 1960—12 classrooms 1969—Cafetorium 1955—3 classrooms, Gym- . torium.: , _1961—1 classroom, 1 shop 19388—4 classrooms 1940—-1 classroom, 1 shop . 1941—7 classrooms, cafeteria 1942—1 classroom 1944—-1 music room 1945—Gymnasium 1950—2 classrooms 1955—6 classrogms 1958—9 classrooms, library '1930—4 classrooms 1941—band room, 1 class- room, 1 shop 1948—-Gymnasium 1954—2 classrooms, librarye 1959—8 classrooms 1964—6 ° classrooms 1968—cafetorium : School " Pittman Elem. _ Route 3, infield, N.C, . Scotland Neck School Scotland Neck, N.C. Thomas Shields — Hobgood, N.C. “Tillery Chapel Elem, ’ Tillery, N.C, oo White Oak Route 2, . Enfield, N.C. Wm. R. Davie Route ‘1, Roanoke Rapids, N.C: Grades Served 1-8 1-12 1-8 i / | : Date of Construction - 1959—15 classrooms library 1903—12 classrooms library as 1957—6 classrooms 1932—4 classrooms 1959—10 classrooms 1 940—1 1 ‘classrooms~ _ 1 library - auditorium eee 2 ~ ee eng Date of substantial additions 1960—ecafetorium, 1 class- ° room — 1923—cafeteria,. 8 class- rooms, library 1939-1 Home Ec. Lab.) 2... ‘classrooms, 1 “shop, Gymnasium ; .1949—1 classroom 1954—4 classrooms, auditor- on ium . 1960—4 classrooms, _ cafe- teria, libraty 1958—4 classrooms 1961—library,: cafetorium 1957—6 classrooms | 1962—1 classrooms, library, cafetorium, . . ‘ . . | . , , . e be 7 . . : : . ‘+ bd : : 2 . , , . . . | | . . . . : . . ; . 7 . q . . ® e .* = . ° . . . . , | ; ; . . . . . 7 . . : . | ®: _ | | | . . . * . : ‘ . | > Y ° , . ) Od 7 . : . e . . 7 ; . : . . 4 ° . : . rd = e . . . ; . . . . , , - e 7 « . . ; | . . . . . . aM Me LAAN ¥¢ ‘} fea ? = > / 39s rORTANIONM Any armTeneanecs Cert ‘nap sarnetesere net ’ yw \ ¥ HALIFAX COUNTY * Orrums . Onees bs - - . Se CARA ie MRP Aa . he 8 ' ‘ ® . ‘ . . 7. e . tek = ae » . ‘ 7 in. sg . . : + ° : . e ~ ad o - s , ; . e . . _ _ ’ =e? » \ Cy 1 8 ' . ' . ae ° ( . oe . ee . . - 7 e . ‘ ° . ° . o% - . . ‘. , yj , . . oy - i @ . a \ ‘a ben's e ° ” \ ae . . - . . . a ‘ ‘ - s . ; ® . . e - . . R . . . . . . . . . . . as - . ° . . “ . . a ° . : « wey t ‘ Ps . e =m % 7 ; . Q ° . ‘ e- . * . . ° + » . . e *. e . . « ‘ . . ‘ . ° 8 ; e . . e ‘ . » ’ . . : ° ° : -* . ’ . evs : , ~ " ~ ° . “See . 7 * \ ‘ bad an te. ‘ | ‘ ' A e a . ¥ » *% ¥ os : bd iz * « rs / . . “ ° vole . . . . * bd ® - . ‘ . . S ° ? ~~ — / . ‘ . bad . 3 . . ' . : "8 - ° . x . se A . ' ° : . iS . . ° . = . ” , e? , - . - . . ad e . i o-% : = ° ~-. -'% . . a . 7 . - t . * —s ‘ ‘. e . ‘ . \ . . ‘ . « P . . . 7 7 . » > . ° ‘ ‘ « i = ° * ‘ . ‘ . ¢ > . . ® . : - . a . “ss 2. Please dente any. changes in the eumber: names, | \, - jgcations, grades served or attendance zone lines of the schools in defendant’s school unit since the beginning of the 1964-65 school year. - 9 Changes in school organization since the beginning of the 1964-65 ‘school term are as follows: a. John Armstrong Chaloner School formerly in ~\ : Roanoke Rapids City School Unjt, by: order of offi- © _ - ¢ials of the Civil Rights Division of the U.S. De-: -. > partment: of Health, Education. and Welfare, by agreement between the Boards of Education of Roa- * noke Rapids City School Unit and the Halifax County - Schoo! Unit and by action of the State Board of. Education began-operating as a part of the Halifax . County School Unit at the beginning of the 1966-67 . ‘school year, This school had been operating to ‘serve © approximately 80% who were living within the-Hali- ‘fax County: Unit. Approximately, 190 students or-. 20% living, within the boundaries of Roanoke Rap- . ids. City Administrative Unit transferred to: other schools ‘in the. Roanoke: Rapids Unit. - b. Hobgood School, grades 1-8, was closed at the. — } end of the 1966-67 school year. By. choice, elemen- > .tary students have been attending Scotland Neck | School from the beginning of the 1967-68 school ‘year. The Scotland Neck School attendance area for grades . .1-12° became the same as the attendance: area for the grades 9-12. (See map attached, No. :1). "> e. Upon closing the high school department of the . Haliwa School in Warren County, approximately 70 ‘students in grades 9-12 who live near Hollister in - Halifax .County transferred to schools in Halifax _. County at the beginning of the 1967-68 school year. —_- _ The elementary department of the Haliwa School. * was closed at the end of. the 1968-69 school year and 3 approximately 140 students grades 1-8 who live in - Halifaxe County transferred to schools in “Halifax f ,County. 2. (d) Upon closing grades 1- 5 of the Littleton School - ih Warren County at, the close af the 1968-69 school Cer Te 822 . approximately .60 students who live in Halifax County ; were transferred to Halifax County Schools. (See at. - tached map No. 1). 8. (a) Please state the enrollment in each school b -grade and race for the 1964-65, 1965-66, 1966-67, 1967. 68, 1968-69 and 1969-70 school years, and for‘ any other _ school year in which there was any desegregation of . pupils in ‘the system. HALIFAX COUNTY SCHOOLS 7 4 Halifax, N. C. Enrollment by Race and :Grade for the Following Years’ - SCHOOL: Aurelian Springs . 1964-65 1965-66 ; 1966-67 .1967-68 1968-69 1969-70 GRADE W NW W NW WNW. .W NW W NW W_ NW 1 30 20 25 26 25 38 16 (20) 4 21 28 17 .28 43) 25 (17)1 13 23 23 25 1 16 1 28 19 (21) 4 26 _ 28 20 1 28 1 20 23 «+ (19) 5 81 27 23 21. ‘1 =. 29° 1 18. (28)1 6 29 33 23 1 25 19 27 (15)1 7 36 28 30 1 24 1, 25 53 «18 (12) . 37 39 26 29 2 22 64 25 (15) Spec. Ed : : (12) 38 46 38 17~—s 3 22 31 23 14 = (22)3 - 10 27 33 42 14 29 17. 26 18 29+ (14)4. 11 33 25 35 11 38 13 = 31 138 25° §«(16)3 12 24 30° 23 12 26 14. 36 10 24 (12)1 TOTAL — 365. _ 860 . 826 °58 321 72 317 186 263 . 2382 _W=White NW=Negro or Indian . ( )= Indians in Predominantly Negro Schools Enrollment figures were determined at different times during the schoal year. COMMENTS: | e. % P) €28. panes oe saz Aides SER SP SRN ‘HALIFAX COUNTY SCHOOLS fsa * 8 Halifax, N.C. es le 4 Enrollment by Race and Grade for the Following Years. SCHOOL: Bakers an | 1964-65 °1965-66 1966-67 _ 1967-68 1968-69 . 1969-70 EPS TEP UTI. RR eT qr De uss , GRADE wo NW W NW W NW W NW W NW W_) NW 1 49 42 39 36. TS 36 2:. 44 49 37 42 “. 34 29 3 52 39 41 31 2 86 39 | 4 AT . 41 - 86 |. 87 - ° 29 39 F 5 a5 41 33 39 48 oe 1: QF. 6 43 49 41 34 38 45 J 7 43. oT 56 36 33° 34. y ; 8 42 37 Ad 49 #4 35 : | _ Spec. Ed. 18 18 20 15 9 _ ~ | 9 | 10 11 12 . Lo ; TOTAL, "38g 863- 347 = 319 28388 — = er os = W=-White NW==Negro or. Indian ( )=-Indiangs in Pre ‘dominantly Negro. Schools : . Enrollment figures, were dete rmined ae diffe rent times during the scheol year. COMME N’ rs: e HAL IFAX COUN TY SCHOOLS F Halifax, N. C. Surana by Race and Grade for the Following: Years - SCHOOL: . Brawley NW=Negro or Indian ( )==Indians in. Predominantly Negro Schools’ Enrollment figures were dete - COMMENTS: ” 1964-65 1965-66 1966-67 1967-68 _ 1968: 69 1969-70 > GRADE WwW NW \ we NW W NW w NW _W NW Ww NW 1 65 61 63 48. 60 50 2 67 61 ‘52 50 - 59 54 3 70 62 54 49 54 53. 4. 771 66 65 56 49 55 5 72 “70 58 55 66 42 6 66 14 - 76 +58 61 52 7. 69 68. 73. 82 48 8 : 61 - 68 70 80 56 Spec. Ed. 18: 18 18 35 £15 , 9 221 234 218 232 288 247 10 161 170 192 157 182 184 11 112 111 143 141 154 152 12 104 96 106 108 118 124 TOTAL 1157 1159 1177 1151 1106 1117 W=White ‘ rinined at different times during the school year, 628 HALIFAX COUNTY SCHOOLS Halifax, ‘N.C. Enrollment by Race and Grade for the Following Years -* SCHOOL: Dawson . on | 1964-65 1965-66 1966- 67 1967-68 - 1968-69 ' 1969-70 . GRADE W NW W.NW W NW W NW W NW W NW aa © 80 67 66 + (56: 49°. 39 2 70 74, 62 56 51 ee 3 7. . 68 . 67 54 bl 41. 4 88 61. 60 59 48 — | 48 5 UT 7° 95 62 ; 55 59 39 6. 62 a a 73 60 -- 50 °* 62 a 54 + 65 66 63 62° 0 48 8 64 49 - . 62 56 © 638. 54 Spec. Ed. eee | Sree ¢ cae 16. 4 26 . 27° 10 11 TOTAL . 662, ° 536 | 522 ATS 459 390. W==White’ : NW=Negro or Indian ( )==Indians in Predominantly Negro Schools Enrollmént figures ware de termined at different times during the “achool year. COMMENT gs: °* os . 928 we WREST Ry HALIFAX COUNTY.SCHOOLS ‘ Halifax, N. C. . Pnroliment by Race. and Grade for ‘the _ Following Years ‘SCHOOL: Eastman 1964-65 1s 65-66 1966-67 - 1967-68 1968-69. 1969-70 __ GRADE WNW W NW WNW. W. NW W NW W Nwe :* me: 61 ‘6400 BT 50 46 2 63 62 63 50 58 56(1) 3 76 62 53 68 41 _ 48 4 59 63 65 42 65 49(1) ? 5 74 50 59 55 46 51 6 75 63 54° 63 b4 46 7 67. 69 65 55 59 54 8 54 56 63(7) 64 59 59° Spec, Ed. ' ‘~ . Tita 42 Oe AE 8B. > 8802) 158 (3) /167(2). 137 10. «1138 + 4 118 - 139(3) 146.» 158(1) - 11 93 92 104 107 108 122 12. 76 | 88 88 101 97 105 ‘TOTAL... 008 -. * OM 952. «965, 952 976 =White _NW=Negro or Indian ( )=Indians- in Predominantly Negro Schools Enrollment figures were determined at*different times during the schoot year. COMMEN TS: L28. . . Halifax, N. C, Enrollment_by Race and Grade for the Following Years SCHOOL: Enfield Graded "HALIFAX COUNTY SCHOOLS 1967-68 . 1968- 69 1969-70 828 | 1964-65 1965-66 1966-67 GRADE W NW. W NW W Nw W NW:W NW W_ NW es ee ya eee ee A ee ee 1 : ° ' 33 12 «29 5 24 7. 27 5 20 4 3 42 37 1.33 9 '80 7 27 5 18 7 4 44 36 31 4 33 :9 381 6. 18 6 5 45 42 29-4. 87. +6 384 10 19 7 6. 42 44 37 = «5s 80 5 32. 7 28 8 7 35 ai: .)0 47) 4D BL 1238 20 8: 41 37 1.40 2 47 7 AT 6 16 17. Spec. Ed. 11 10. eo : . a me _. $89 .. 8 +85 3 40 1 (45 5 ..26 9 10 52 - 2 2 11.3838: 6 30 5 ..81 2. 32 1 11°. 40 °1 48° -14 28 12 85 --°7 .84. 751 1 3 18 4) 87 - 85 8 40 10 26 10 28 5 24 : TOTAL 505 6 456. 59 419 67 404° 77 402 177 256 89 W=White | NW=Negro or Indian © . ¢ )==Indians in Predominantly Negro Gabvecili erent wreiad during the sohbet year. Enrollment figures were determined at di COMMENTS:. eae ee ee ee a HAL IFAX COUNTY SCHOOLS ‘ Halifax, N. Cc, Enrollment by Race and Grade for ‘the Following Years SCHOOL: Everetts * , 1964-65 1965466 1966-67 _ 1967-68 1968-69. - 1969-70 - eo GRADE W .NW.W NW W NW W NW W NW WwW NW - 1 89 ~~ 96 76 — 838 + 56 57 - - 2 66 ~ 7% “gg °. 68 66. 46 3 86 70 65 47 62°..." «66 4. 67 | 91 ° © 58 62 ‘67 «~~ - 66 ; 5°. 82 69. 67. 55 57 sy 6 70° 8 58 61. 50 47 7 67° | 67 : 64 “61 60.- ° 50 8 71 70 °° 66 62 3860 55 Spec: Ed. . er (ie 16. 24 ul . 9 . - : . : : . ‘ ~ 10 | , a1. | 12 . 4 a . | TOTAL .-. 698 614 | 547. 520. 478 460 W=White - 7 = Woo os NW=Negro or Indian . _¢ -( )=Indians in Predominantly Negro Schools eo ; ; Enrollment figures: were determined at different times daites the school year. - 7 - 4 6o COMMENTS: _ Me OP ee a ng km Bl - a HALIFAX COUNTY SCROLLS 4 Halifax, N. C. Oo "se *arglisaent by Race ‘and Grade for the Following Years — . SCHOOL: Hobgood. sg , Pca a ‘ : 1964-65. 1965-66 1966-67 *1967-68. 1968-69 1969-70 GRADE Ww. Nw” Ww: NW W NW_ w NW. W NW Ww NW ee. ee | “ * Mm. > 3/3 9 as A, se e 3 10 . 11 : ° \ : « = j2 ) as .. * Se “W=White : ogee ; » - NW=Negro or Indian — oy; J f 3 \ : ( )=Indians in Predominantly Negro Schoola, : RS . + AF arta figures | were determined at different times during the sient yeag. : wa Ne . : *COMMENTS: School closed and pupils attended Seotland .;Neck School. e ° BRturax COUNTY SCHOOLS . ‘Halifax, N. Cc. . Enrollment by. Race and | Grade ‘for the Following Years SCHOOL: Hollister’ : sn Me “1964-65 1965-66 1966-67 1967-68 1968-69. 1969-70 : GRADE TB kde AON OO Ie. OR BE EE EE ee oe 53 46. 38(8) 51 81(5)* ° 45(5)° 2 55 42 41(5) 80(3) ~ vax 42(8) ¢ 743) 3 44 57 32(5) 44 BG @ ) 40(4 4°: 57 46 59(4) 45 (4) 40(4) 44 5 58 . 56° — 48(6) --42(5) 37 (2) 30(3) 6. 44 48 38(6) -° 58(2) .. 36/6 25(7) Ag 45 43° '41(4) 87(3) 45 (2 35 (6) 8: 35 39 38 (2) 40(2) ° 36,4) 82(10) Spec. _ 13 (2) 10 11 . 12. oF : TOTAL” 386 877. - *:~ 876 361. * 381 831 W=White, / ay. NW=Negro or Indian g ge ( '}=Indiang in Predominantly" Negro Schools ’ Enrollment figures were detormirted at different ime COMMENTS: e° 8 during the school year. ° Tes : " HALIFAX. COUNTY SCHOOLS i? Pa, Sg ae Halifax, N. Gr mh Enrollment “e Race and Grade ~ the Following Years - SCHOOL: Inborden. ea ee Me ae 1965-66 1966-67 Y 1967-68 ef 1968-69. 1969-70 o: : GRADE WNW Ww NW:W NW W NW W.NW W_ NW. SOPAL °° 3000: 008 UE 1418 “W=White - ee eae 2 ee .NWs=Negro or Indian” es ()==Indians in nantly Negro Schools oot s _ Enrollment figures were determined at inane times” during the school ‘year. : _ COMMENTS: : a e . ~ ' *e : We oe ‘ e 7 rg teat . oe = foes © oe e .. ® . HALIFAX. COUNTY SCHOOLS : ' ‘Halifax, N. C.. ’ Enrollment by, Race and Grade for the Following Years : SCHOOL: John Armstrong. Chalo: 1964-65 1965-66 ek GRADE i. NW _W NW’ WNW W NW’ W NW WNW 1 Es: ton lS : he 61 ee. Oe, 52 * g-f 76. 54 70 57 H 51 - 75 | 62 5 $7 “ 67 6 Pes g 59 61 62 59 7 84 73 ‘oe 55 64 71: » 42 it > 74 a 11 Pash ‘- 62 72 6 «69. he 7. 57 ke b+ TOTAL gee Ae 852 °° 887 680 712 .W=White = 9 .7' . a ke sees NW=Negro or Indial ei Rae es ges . ( )s= Indians. in Predotananty Nears nia: on i . Enrollment figures were determined at diferent times during the schoo! year, . hota axel " 4% : i . 2 id : ‘ Py “| ‘ ts 2 me 2 ase Me ae ‘ . ‘ Bi: ad . es _ ; } ‘ “ Bots ee oe sie ee HALIFAX. cour ‘SCHOOLS: Py Bi eh ee vat ree , - + Halifax, N.C. Soe. pe eee Peregrine gee ttal Enrollment by Race and Grade tor the Following Years, eS ; SCHOOL: ‘Melver - Bt ete ee aoe oe a 1964-65 1965-66 “delet . 1967-68 .1968-69 1969-70 ae ee GRADE Ww_NW -W NW W NW W NW W NW W. NW 2S a ge a OR a ae ae oo Bree Ree) ee , ee a so * MRS. lo) aa ae ha 682 sé 72 a ee Te gg BR a ae NW=Negro or Indian a : per. ( oo in Pretembiently Negro “achools % ' Enrollment figures were becca at different times during the school year, COMMENTS: : picyar: scare eee! 3 ile ion : OAD cts Wests anni pseiion unas Nena nas ey inate a ieee | "HALIFAX COUNTY scnoorg™ : yah . Halifax, N. C. ae. Z ~ - Enroliment, by Race and Grade for the Following ‘Years SCHOOL: Pittman” 2 ee a ee gee | 1964-65 * 1965-66. _ 1966-67 __ 1967-68 - 1968-69 1969-70 Noe ge GRADE- W_NW W Nw W_ NW_W NW WNW WwW NW es 80 a 6 | RL 14 58 39 . 81 Re Cas 68 56. > 47. ‘ 3 67 73 70 68 58 61 : ; ee! 74 Oct ee 50. 56 43 5 er x s eee Y 45 52 \ 6 3 78 75 61 62 - 67. 85 > oe * 68 15 - 68 69 83 89 8. ra 60 69 61 46. 85 Spec. Ed. | , 18 ee. eine me Be ° 11 \ a ast cls oe eee DORAL. eas 6 a ae, 420 866 : . : W=White| oe | rvs - | _ NW=Negro or Indian. He Re ° eae ¢ )=Indians in ‘Predominantly Neerd Schools" eae ee ' ‘ e ra Enrollment by Ri a Scotland Neck * HAL AX COUNTY SCHOOLS Meta: Halifax, N.C." and Grade for the ¢ Following. Years: 1906-67. — $$$ aa 1968-69 1969-70 W=White NW=Negro or Indian ¢ )sindians in Predominantly Ne Schools COMMENTS: se ae & . ee ——_———s, 1964-65, ‘ 1965-66 | | RADE WwW Ww Nw| W NW W NW.W NW W NW 60 a ee ie ae, ee Ce eae ce “e . 50 ee i ae ee ee ee Ss: 67 58 54 3 59 hie Woes Se ee ee ae 4 61 71 61 2 -65 4. ox @% 2: 5 OT 71. , 89 8 °.64 ‘ 8°. 8 Se o> oe 71 - fe” Betas Gee ee Bee 3° 77 ” 1° 71 ae ee ae 1 8.8 :-a@: 8 8| 72 69. | 64 ‘8. ££ OQ ew CS Spec. E ; % a | ‘ es ‘ . - Sa : » a re ae : 85 Phe ee eee lay 5 78 4 67 13. 10|. 65 - ea | 8 14 $ ee a SS 11|. 71 61 @ 1% .-2..80.. 19..° 0 .66: ae 18) 6 C4 1 Be 8 Re TOTAL | 797 g "80 829. 46 786 198 741 18 & _. TOTAL 7 0 Sees ee ee ee GRADE W -NW ‘COMMENTS: fas) ee ee ‘Halifax, N.C. es thesia’ ‘by Race and Grade for the” Following Years : SCHOOL: _\ Thomas Shields 1964-65 1965-66 viler 1967-68 eee “1999.00 \ . ‘ a ae HALIFAX COUNTY. - SCHOOLS ee. Z Ww NW WNW WNW WW OID lm coe a |). ' gen a2 eas NW=Negroor Indian). | a ne ( )=Indians in Predo Enrollment figures w ainantly Negro Schools : a ' o determined at difecent. times Pee the school 0 e fs ae ae : 4 "oe : - | 3 . ne ; : ) ; na a : : HALIFAX COUNTY: SCHOOLS ‘Halifax, N..C, “~ : Enrollment by face and Grade -for the Following Years” SCHOOL: Tillery Chapel - | ee wo, 1966.65 1965-66 1986-87 1967-68 | sn 1969-70 * GRADE W NW. wv. NW. Wy om. WwW NW W. NW -W NW Cee oe 9, 49 \; Poke ee a : Ps to ir oo + ae ~ 9s : — Oe ©.0 Baoamem coor [BE \ We eee ae 386 —S~«CSRS EE Oe ee Prat ate Pe NW=Negro or Indian - EP net te A ue ‘6 - : ( )=Indians in “Predomiriantly ioe | Schools’ : [Ne Oe _ Bnroliment fowreswere dterminad ot aiforeit tinan during th, ) : St COMMENTS: i Sp hog Se Ne a St i SCHOOLS . , a : ae Nets He . . Halifax, N.. C. ‘ on « "Enrollment by Race and Grade dee: t: Following Years. SCHOOL: White Oak : Sn aa \ ee . 1964-65 1965-66 ‘ 1966-87 1967-68 __ 1968-60 en GRADE. .W NW WNW we NW _ me NW Ww .NW W NW .. : ede 68 \ 49 48 2. 89 46 * @. . 8 47 58 36 $8(2) me 85 89 5 81 5 . 59 41 84 88: 8. 47 ‘55s _46 - 89 o ee 45 34 58 24 d 8 28 89 82 . BQ Spec. 7 ‘ 16 .10 : * “1 Sr ok ea hes 12 ° Mee SCORN Taegen AN een oe ao CS eae 884. 804 ‘Wawa items ‘ 7 ‘NW= Negro or Indian ( )=Indians in Predominantly Negro Sehooie: _ Enrollment owe were determined at different time ding the sohool yeor COMMENTS: Wee HALIFAX COUNTY SCHOOLS Halifax, N. Cc. tareibuans by Race and Grade: for the Following, Years. ‘William R. Davie “1965-66 ° - SCHOOL: 1964-66 1966-67‘ 1907-68 | * 1968-69 “1968570 NW W.~NW W NW WwW GRADE W NW: W a a a > ° @-sam =380 worrw a ) a 92 12(1) 17 86 6(1) Ww NW 62 73 84 712 719 70 & _W==White . 3 NW=Negro or Indian COMMENTS: ( -)=Indians in Predominantly ‘Negro Schools Enrollment figures were datorminel. at at times uring. the school year. a8 . «€ \, cae “b) ‘Please ‘le Ge. average ‘ile Gites g. each school by grade for the year _ 1968-69 ana the wan Ze reporting period of 1969-70. (c) Please state “the total expenditure: per \pupil- in each school in the system for-each of the years 1964-65. ~~ through 1969-70, and’state whether said figure is based : on Bae cg or. average daily attendance. (b) Average daily attendance in each school by: oul for the year 1968-69 and the first Keposting period. oe of 1969-70. (See attached Sheets), ae ey ‘HALIFAX COUNTY SCHOOLS ok, he lie, He Bo: : Average Daily Attendarice by Grade for the Following Years SCHOOL ‘Aurelian Springs . . a eee oe | Kirst Month a He posen sews : 8 = ‘tec ‘Education ig ie © RSS HELEEESSS 12 - 3 te \842. As teas _ eek oN : en fe ae _fattrax county scuoots. _ Average Dall Attendance by Grade forthe Following Years oe 3 SCHOOL” takers Eine ee > te Se ee “GRADE oo. a - »Segeeses| | SEBRSSBe = “HALIFAX COUNTY SCHOOLS | . Halifax, .N. C. - aS : ‘Reeas Daily ‘Attendance by. Grade for the Following 3 Years Sac unncted _ oe : _— 3 A * .. & First Month “GRADE + 1968-69 . 1969-70 - eee te BRRRER ° _ Special Edueation ° |EESS../ | eaebas gaebets Tot BR cd % .* AG "HALIFAX COUNTY. scHooLs’ Halifax, N. _ eee Average Daily ‘Attendance by Grade for the Following Years. _ SCHOOL, Dawson ‘mod. "First Month _ 1969-70 3 ¥ i eeeaeaess ° HALIFAX COUNTY SCHOOLS = "Halifax, N. C. Average Daily Attendance by Grade sin the Following Years. ~ SCHOOL Eastman — y First Month GRADE 1968-69 . 1969-70 a os i oe ‘ 58 62 8 88 | 47 4 8. 46 sg 40 45 6 _ 49 : 41 i ‘ 68 - 62 Special Education — ae 9. soa 140 | =) 182 ee me 122 129 "es ae 93 106 ys . 89 95 ‘Total 832 857 | '§ HALIFAX COUNTY ee % = Halifax, N. C. aoe e Average Daily Attendance by Grade for the Following onate "SCHOOL Enfield Graded co - First'Month GRADE. 1968-69 - 1969-70 a | ae . a eo i. gg 24 8 - 80 24 + 85 23 2. 87 20 ae 138 42. 8 ware? 48 33 " figectal Béwation oe _— 0 wae 46 - 80 10. 82. 3s. 11 83 20. . - 12 > 29 . 8g. Total 536 © 317° BMGs HALIFAX COUNTY SCHOOLS Ee ‘Halifax, N. C. : Average Daily Attendance by Grate for the Following Years SCHOOL, -Everetts Elementary GRADE _ oa ae onan © hd Bereseses |\eaagseae Special Education > ous 10 11 12 First Month | Se - ‘HALIFAX “COUNTY ‘SCHOOLS ~ “Halifax, N.C.. ° _-Average,Dally Attendance by Grade for, the Following. Yeas = SCHOOL Hollister Elem. . First Month 1968-69 - 1969-70 1. 34 45. *®. 42 29 3° 85 42° 4 41 40 5 84 80 6 86 80 7 41 i 36 2 ay | 84 37 Special Education © — 12 gg. ¥ - 10 ' G = ee ee . 12 . wae | HALIFAX COUNTY SCHOOLS : ‘Halifax, N. C. es 4 "Average Daily Attendance by. Grade for the Following Years bs, ‘SCHOOL Inborden Elem: an | a in _ 3 3 2 Om OD _ & rer = ‘Special Education : eee re tts : 14 _ & 10 | | 12 ~ Total me ae 1968-69 —«-. ._: 1969-70 SR ne eS 63 849 HALIFAX ‘COUNTY SCHOOLS : : Halifax, N. oe 4 Average Daly Attendance by Grade forthe Following Youre SCHOOL Inborden High =. OVA Tm we ‘Special aoa : : 9 160. oc 177 11. o 3 5s 57 Be Total” | " - $55 ” Eons ee HALIFAX COUNTY SCHOOLS. Nae /Halifax, N. C. Average Dally Attendance by Grade for the Following Years SCHOOL John A. Chaloner ’ E re) & 2 S fon) DT im oO Ss = | "Special Education oN ee: NG, “Si poe {mam Total Rgaeseraragas | Ejssgsel | sseeee ae ) . 6 HALIFAX COUNTY SCHOOLS ~ | Halifax, N.C. oe ~ Average Daily Attendance by Grade for the Following Years = SCHOOL Mclver Q 13 Ss i] O2NA TAPE wOND Special Education . “-9 10 ae then, |Z|sgaal)iseeeas 4 Bleaeaesgsessss Total ee HALIFAX COUNTY. SCHOOLS. Stee _ Halifax, N.C. Pe "Average Dali Attendance by Grade fr the Following Yeas ‘SCHOOL Pittman Elem. ¢ a gl ie 1969-70 onraanrk ON SSSERBASE Reeeseeeg: : g 8 rg Ge Pe | ‘Halifax; N. C. a A EE "Average Daily Attendance by Grade for thi Following Years - SCHOOL ‘Scotland Neck ' eae ay) ie ees sg eee ee 7 a Om & J o -_ be Se ar : : Pal , . . . ‘ $e ; é ' A ¢ ye A w , . ) Ne ‘ ‘ 2 ae e a : \ : é eee .4 §. \ pk ; an e a 2 HALIFAX COUNTY SCHOOLS ‘ax, - C.: Pa ‘Average Daily. Attendance he. Grade for the Followinig Years SCHOOL Thomas Shields Elem. ol wo et Month = Ne _ . a 2 , (40m=m oy. + 7 a ‘ x Sere aC . 6 7 8. SSRRBREER |G ~ Total . | — B26 174 on ee awh nN allege CI eT eee ee Rete ————————————————— errr errr eee First GRADE — 1968-69 1 ‘25 : 39 8 ae 85 4 . 88 § { * 3 | / 7 he ao J: READERS LRRD ts DE RiP Wn bc Aenea ata . ei NUMBER OF FULL TIME TEACHERS : ; SCHOOL : ay “1964-1965 "1965-1966 ~~ 1966-1967 "1967-1968 * 1968-1969 1969-1970 ine N W NWI... °N Ww N v.28 EK Be Se ‘Aurelian Springs. . --.- 16... 17. =; ae 17 2 eee Lee 20 Bakers. ; a y See 12 12 SRS ine Brawley 89 40 42 (43°. 40 : Chaloner . * 84 83 29 29 .. Dawson | 15 18 17 16 su. 2 ce 2 Eastman 81 82 85 3 86... .2(f) 88 2 Enfield - 25 25 Ses eee ee 20 Everetts * 16 21 19 18. 19 A eons tee Hollister - 11 11 11 2 mee) Gee tee: Ge We . * Inborden Elem. 80 ae 8 86 oe > : Sao amr . -Inborden High - -— Se ofr 14 Ss eS . Melver és ee 23 26 \ 29 —-—— Pittman: 16 17 18 17 vw. = 15 “oe : Scotland Neck ** 80 1 $2 1 82 4 S&-- 10 84 ee. Thomas. Shields 11 10 11 Q Pe Ses 1 “Tillery Chapel . oe SE 10 10 Re ees + te,Oak 10 cee 11” 11 Sees sek Wm: R. Davie - _-— eet ee cere 42 ee Q | Rae eee Hobgood = oo eS eg Siena CLOSED... TOTAL - —- Si - 100° 984. 117 299 .. 121. , 209. «138. 812——s«8. 288, 119 2." © (Chaloner) was in the Roanoke Rapids City Unit during the 1964-85, 1965-66 School Year : I Indian, e . - i ey eo . : eee. fk : : @ 5 (b) Please state the number of other professional personnel, teachers’ aides, par-time teachers, secretaries, - eafeteria employees and janitorial personnel by race at ; each school for each of the school years 1968-69 and - = Se oe 3 . | _ SEE ATTACHMENTS / / ? . & Oo » ' y — > : a cA | Question 4 Pa ee | .Part (B) i. ; /@ f 2 att ae aie y ate 1968-69 | ars Os } |" “School; : PL Ates —.P.T, Teachers Jasiitorial. Secretaries Cafetarla ‘Tol: B . Ww ‘| N WwW isthe AR oi N Ww N° en ae ~~ ; - A. Springs 1 . - none 3 2 Ae ; 7 7 2 : 4 - Bakers , '8° none Wee 2 ry | 18 : Brawley \8 ° none- 8. , 1 oe. - 22 _| . Dawson 5° ‘none 8 1 1 5 1 14 7. Eastman ’ ss 7... Mone - 8 1 12 . 28 ° Enfield Graded eee | none 8 . 1 1 5. 8 9 * _ Everetts $e he ae none 8 | . 6 18 | ~ Hollister . . 8 noné + 1 5 11 . :. ‘Inborden High 2 none 1 1 - i ’ ‘Inborden Elem, 7 none 8 1 11 22 J. A. Chaloner - 5 none 8 1 7 16 McIver ‘- -. | 5 none 8 1 8 ° 17 . Pittman . 4 none a ho “s 5 12 # - Scotland Nek #4... 2. na 1 et KE SEE 1 8 8 .. ae \. Thomas Shields 8 none Re a 1. 5: ey | _- Tillery Chapel "8+. none ron. 1 5 1m . - ‘White Oak ‘ ees | none | “2. te 6 See William R. Davie . : 1 Pa none os | . <> a Se a S Teta ci ce, eee 2 * 46 4 14 25 104. ‘87 + 229. ra ° . = r . r ° «J ; : z ; ————————— = oo . i aa 998° Question 4 a ' ‘Part (B) Se Sate 196870 Soin RE | School "tM Aides —-&P.T. Teachers §—_—Janitorial_ Secretaries Cafeteria ‘Total : . WwW N:. W [N+ OW N w nN Ww. =N -G ® A. Springs ~ 2 vee none. : ¢ te 1. 7 1 5. De | Bakers : 8 none ae a? oe 5 _ . Brawley — i none 8 1: 11: 1" Dawson . - 4 © none 2 | 1 ' 6 1,. 18 >. Eastman 6 none — 4 | 1 9. 19 Enfield Graded =. si 1 none an ome | ) 1 5 8 8. P. Everetts. . A none 8 ee | 5 13 Hollister 8 none | 2 7 1 11 . Inborden High 1: none st ee 1 7 5> Inborden Elem. 7 ° none 8 1 12 23 J. A. Chaloner . 8 none ‘ ~ 8. 1 7 14 ; «+ Melver 8 none = 7 So 6 -18 ‘ . Pittman _ . 8° none 2 1 ae ' 11 a - Scotland Neck none - 4 1 i 6 4 10 Thomas’ Shields 8. ~ none | 2 1 | ' 6 12 Tillery Chapel . 8 none’ 2 1 | 5. 11 White. Oak _ 8° none 2 - 6 12 William R. Davie 8 1 -.none | 8° 1 11 16 4 “Total « . * -6 54 none ssiy 1. 45 4 14 = 28 99 84 212 6. Please state the teaching schedule for each member. of the faculty at each school for the 1969-70 school year, “his race, his certification, and his score on the National Teachers’ Examination. This schedule should include the - ‘Subject’ and grade taught and ‘the hour of the class. - Please state the number of-students enrolled and, if pos- sible, the average daily. attendance for each class. ae (See Portfolio) 7. Please state the number of Sedchies’ by race and | by school, who have been newly hired . and -who have started. teaching in the defendanit’s school unit eath of the school years from 1964-65 to 1969-70, the certifica- - - tion of each teacher, and the grade and subject to which © _. Ofe’ each teacher has been assigned. State also the number of teachers, by race and by school, who have left employ- . ment, or who -have been transferred ‘from one school to - another, in the defendant’s school unit for each-of the above school years. Please deseribe the manner.in which | new teachers are employed including full details of the — recruiting program and the nature.of any authority - given to or used by principals, school a or others in the hiring process. | (See Portfolio) 8. (a) Please state the name of each tincher and staff . member’ (even though no longer employed by the defend- ant’s school unit) who indicated a willingness to teach or _ work across racial lines and. the steps taken to assign each such teacher across racial lines. Please state what steps, if any, have been taken to encourage teachers and staff members to teach and work across racial lines (in-_ cluding polls), the name of each teacher so encouraged, by whom encouragement was given and the results there- ANSWER: Beginning in the fall of: 1964, _teachers : _and other staff members were approached by the Halifax County Central. Office’ Staff and encouraged to teach ': across racial lines.- In 1965 and in at least one succed- ing year a survey was conducted to determine the will-. ingness of the teachers to teach across racial linés. Few teachers indicated a willingness to change schools. (Ap- - 870. proximately 6 senile year stated. en would anenk such _ assignment, but would not volunteer). Both direct and .. indirect approaches were: made to encourage teachers to - * choose to teach children of a race different from their. Own. It: is ‘impossible “ give the names of the. teachers ap-. _ proached.or the person whom they were approached by - during the past .6 years, since no records were kept of the conversations. Every new: teacher employed ‘was ask- ed whether he or she would be willing to accept a teach- ing assignment in ‘a school of a different race. The results of the concentrated effort are shown by the steady increase in the number of teachers teaching across : racial . lines: S a* 4. .°% | Teachers Employed in a School. * Yer Where Their Race in in Minority. 1964-65 1965-66 1966-67 1967-68 _ - 1968-69 _ 1969-70 - Halifax County 8. (b) QUESTION:: _. Please state the number of workebeiie, meetings, 7 training institutes or similar programs, attended by the school unit’s teachers and other .professional staff mem- bers of both races, and for each such program, its loca- “BRE awe tion, the inclusive dates, number of staff members by © - race in attendance, the topic matter or purpose of such ‘program, and the abonact (5) 8. (b) ‘ANSWER: 2 ae The Halifax ‘County School System } has aaliekad . well planned: in-service education. programs for its pro- ‘fessional and non-professional staff. Each program has - been developed. to increase their understanding of issues — and problems of education, to. improve their methods of. teaching v various — and in — to keep their i * en PERLE GES AEE ALIEN EE EIEN STEEL SEN SE PEC IIE BE RON FR APM » a SO . thinking and their teaching effective. These programs in- _ ‘ volved the Negro.and Caucasion races. (Please ‘see at- tached ‘sheets for ariuahetione and descriptions of, In- -_ Service Programs). 8. (c) QUESTION: _. . Please state the aumber of : ead thectings, ’ training institutes or like programs for staff personnel, which dealt wholly or in part with desegregation of pu- pils or faculties, or koth, to which the staff members of the school unit. were invited or could have attended, and © _ which are not listed elsewhere in your answers to those interrogatories. State for each such meeting the inclusive dates, purpose or topic matter, the number of staff per- . sonnel by race who attended and if no staff personnel at- _ tended, the reasons wy said staff members were not in . attendance. | 8. (c) ANSWER: - A series of conferences and meetings were con- ducted during the 1967-68 and 1968-69 school term that. dealt in part with the desegregation of pupils in the — schools. Representatives from each. of the high schools participated in these conferences and the sessions were held on rotation basis, including all of the high schools bed ‘the County. | ‘Topics included for discussion were: 1. Better Communication Between Stodeats, Fac- . ulty, Parents, and Community ° ‘2. Meaningful Relationship with Members of the Opposite Race and - | 3. Involvement of All Students i in School Activities The number of participants in these conferences varied from one session to another and according to the - - size df the schools involved. Approximately thirty persons participated in each session with a racial composition of: . about.eighteen (18). Negroes and twelve (12): Caucasions. . Each participant from. the schools involved dis- — cussed with their local faculty arid student body the is- sues considered in their county-wide meetings. — = anes ot we _ ee DET Pe PLP Yh ATF PORES PIPE TOE ae Std) . * “ rf - HALIFAX COUNTY SCHOOLS | - - WORKSHOPS, MEETINGS, INSTITUTES ATTENDED: BY. TEACHERS & OTHER PROFESSIONAL STAFF no aes ee oe oy: FROM eS -e 2 eee . x P No. Attended | ee Dates «== Location *N **C ~ Sponsor | | . County ae : June 13, Inborden School -ESEA - Techniques of Teaching a Ne July 1, 19 966 Enfield ei at 57 10 Title I oe . Ae th . ani Ree tat. - County - 1 “ d ; June 2 Inborden School . ESEA ‘ Improvement in Reading : July 1, 1966 - Enfield | 16 10. Title I ; ets es June 18, . Inborden School ESEA § , Modern Mathematics - toe 4 July 1, ‘1966 ~—- Enfield 22 4. Title I . Pee ep . . _ ~ County . Tee aes ys ‘June:18, Inborden School . . ESEA o, ° Arte, Crafts and Music. + duly 1 1966- -- Enfield ee 5 Title I i segs ue, as June ‘18, . Inborden School : ESEA Audio Visual Aids : ' July 1, 1966 _ Enfield 16 -9 Title I 4 eee ie ede , County 4 Roper Ah 8 . June 13, Inborden School - ' ESEA i Pupil Evaluation = «+ July 1, 1966 Enfield | 10. 4 «Title T } ee : r - % . é pipiens cnet teenie et ee a ae eee BT a Ai Ma abhi cna Seis STN ARR PIT Inborden School '~ Problems in Educational Administration 1967 18 Maas June 18, _ ESEA Modern Methods. of Teaching July 1, 1966 ' Enfield 66 8 Title I : : ieee" es Aug, 21-25 ‘Aurelian Springs Sch, " ; : Unit —— in The Elementary School . 1967 Littleton , 20 10 County _. October Inborden School ESEA School Administration of Testing Sree 1967 Enfield - 16 4 Title I Augu Inborden School ' ESEA Teacher Aide Workshop 1967 Enfie _.. 65 15 Title I. + wie a County October ibaa School: : -ESEA Music Workshop . 1967 Enfield | . 22 6. Title I ee & oe ee " October Inborden: School e. ‘ESEA Study of the Disadvantaged Child - 1967 Enfield 40 2 Title I i Scien ‘ : “October . Inborden School _ESEA Reading in The Junior High ‘School 1967 Enfield | - 18 7 : Title I : ges a3 County October Inborden School. ESEA Enfield : \ HALIFAX COUNTY SCHOOLS. a, ae ae Sige 4 WORKSHOPS, ‘MEETINGS, INSTITUTES ATTENDED BY TEACHERS & OTHER PROFESSIONAL STAFF FROM 1964-65 — 1969-70 3 oat byt hs 5 his is/ true because certain sections of the county are: - each. school, and what courses are propo so heavily negro populated that any system of education | that we have devised would. not: bring about integration . fn these areas. »This statement may sound contridictory to previous statements about racial dispersement in the rural, areas, however this can be explained by the high - percentage of negro residents living in Halifax County. 9. {d) Please state the scheols of any other adminis- trative unit served by buses or drivers of the defendant, . the number of each such bus, the number of. pupils by race transported to-or from each such school, and a brief . Summary of any agreements, resolutions or minutes un- * ’ der which said service is provided. ‘Please state the name, address and any official positions of persons known to. - you ‘who have information about this arrangement... : The fourteen schoo] buses that serve the Weldon Ad- ; ministrative Unit are titled to the Halifax County Board | -of Education. ‘This was done on the recommendation of the North Carolina State Board of Education. The Hali- fax County Maintenance Department. provides mainte-: nance and fuel to these. buses" ae exercises no control oe be taught over. their operation. — | 10. .Please state what courses are rt taught at for the 1970-71 school year. If any of the courses are not. ‘ given evey year or are. given only one semester . each _ year, Sas indicate that fact. ; (See Portfolio) 11. ‘Please state what organized athletic prograins, bands, or other extracurricular activities under school - auspices are operated at each school, dnd the number of students, by race, participating in each — or. aside - -at aad ‘school. | he @ «or. =F the numb . this quéstion, I er you ‘to the: following ch Tietnde all the . lol's Athletic schedules, of. players envolved and their racial compo- sition; ‘bands: and their comy ition by race; and, all the . | A, SS, WENT K: Saag e “ WILLIAM RN DAVIE SCHOOL . t 1 sRoute. 2, Be 191. - or . "Roanoke Rapids, 8h ero - 1968-1970 Football Schedule, Ries oa . ~e ganda ae Home ~ Away ce ' « sLonteborg os . ® . , baat * . is ,es ’ , po . * Bat sat” y em é ——preg es ee! oy . . Ns SN srt i Mien at yo his 7 s { ‘, . o-* wnt eres oe . we Do tonantet ‘ cafes Fee ee “ Ops. 4 4 ' 196 * ie , = Friday, January 2 Tuesday, January ‘6° ‘Friday, January 9° Tuesday, January .18 - Friday, January 16 Tuesday, January 20 , ‘Friday, January, 28 Friday, January 80 - Tuesday, ‘February 3 ‘Friday, February 6 © ‘Tuesday, February 10 "Friday, February is * \OWILLIAM R. DAVIE 0 Basketball Schedule - ‘Friday, December 5. o - . Puesday, December 9. i, Friday; December 12, " Tuesday, December 16 . Friday, December 19 pas (Open) Gaston Aurelian Springs Warrenton Norlina Enfield _. Murfreesboro. Littleton Weldon _ (Open) - Gaston . _ Aurelian Springs : Warrenton . Norlina - Enfield ‘Murfreesboro Littleton -- Weldon 879 _ HALIFAX COUNTY SCHOOLS - W. Henry Overmah, Superintendent a 3 > Halifax, N. C. 27839 . Board of Education fo ae a Board of Education C. M. Moore, Jr, Chm. sw * C. H. Leggett Mrs. J. C. Shearin aa - Mrs. A. L. Williams > W. Carlos Burt : ie A. G. Wilcox, Jr. i ‘ . . « = ht a WILLIAM R. DAVIE SCHOOL ‘Activity ‘White Negro. Total Football - cies, Bape | ae 29 Basketball (boys) | Set Yes: +5 14° ‘Basketball (girls), e : -*§ 12 a Monogram Club © | ah 20 5 25 Future Homemakers of” America 18 13 31 ience Club ill 3 - 14 - Future Farmers of America . 2 66 - 4 Library Club °° a. ae 3 |. 25° \ Student Council - | 20 8 28 .Ruture Teachers of America me... -- 3& Beta Club - ar ae | 1. ,. 2 \ . 7 _ °. 7 7 — we a et ee Re Le nent Rin . om JOHN A. CHALONER SCHOOL Roanoke Rapids, North Carolina 27870 ‘Date November 7,-’69 November 11 November 18 - November 21 November -25 .December 2 December 5 ° December 9 -December 12 December 16 December 19 January 2, ’70 ° January 6 - January 9 he January 13 January 16 January 20 January 23 January 27 January 30 February 3 _ February 6 February 10 *February 18 * Subject to change All home games will begin at 7:30 p.m. | Henderson Institute _ C. S.. Brown McIver Henderson Institute Eastman Swift Creek Swift. Creek Perquimans R. L. Vann Brawley ‘R. L. Vann Gumberry Brawley W.S. Creecy . Rich Square, N. C.. BASKETBALL- SCHEDULE — for : 1969-1970 Opponent Location Phillips ' Battlesboro,. N.C. . McIver _ Roanoke Rapids, N.C. Inborden Roanoke Rapids, N. C. Phillips Roanoke Rapids, N. C. Eastman Enfield, N.C. -... Inborden ~- Enfield, N.C. W. S..Creecy .. Roanoke Rapids, ‘N. C. _ C. S. Brown Winton, N. C. Perquimans - Winfall, N.'C. | Gumberry Roanoke Rapids, N. C. Henderson, N. C. . Roanoke Rapids, N: C. ° “Littletort, N. C. | Roanoke Rapids, N.C. Roanoke Rapids, N. C. Red Oak, N. C.- Roarioke Rapids, N. C. . Roanoke Rapids, N.C. © Ahoskie, N. C. Scotland Neck, N. C. - Roanoke Rapids, N. C. ’ Gumberry, N. C. - Roanoke Rapids, N. C. HALIFAX COUNTY SCHOOLS _. © W. Henry Overman, Superintendent Halifax, N..C. 27839 Boardof Education . =. ~~ ~*—~—sBoard of Education - C, M. Moore, Jr., Chm. pow ag _ C. H. Leggett - Mrs. J.C. Shearin . os . Mrs. A. L. Williams W. Carlos Burt poe , A. G. Wilcox, Jr. . Rede: * * | J. 1, Walston, Jr. _ JOHN A. CHALONER. Activity | | a Negro Students — = Future Farmers of America aw 40 Future Homemakers = = . 40 ‘Glee Club er 22 Science Club "4, e 15 School Patrol _ ’ : 20 Basketball = © a’ Studént Government ss - , - 80 Introduction of Vocation’ = —™S 65 * Please note all participants and negro. McIVER HIGH SCHOOL’ ey Farmer, Principal . Littleton, North Carolina 27850 McIVER SCHOOL Clubs ’ _ Athleties Journalism Club’ © - 28 - _ Boys Basketball FFA | 100,“ Girls Basketball FHA 72 "Cheerleader StudentGovt = = > «18 : ‘ ete” wy * fe. % f* _* Please note that ail of these participants are negro. pec ’ vy. ~~ h& sf x : : N * A 4 a “y v4 oo Oy Bee he OO -McIVER BASKETBALL SCHEDULE 1969 November 4 . Oak City Tuesday ** | Boys-and Girls Boys and Jayvee 7 Home November 7. . Oak City s Boys and Jayyvee Away Friday | November 11 _ Chaloner Boys and Girls Away ° Tuesday ? November 14 Eastman . Boys and Girls Home Friday November 25 . Swift Creek | ‘Boys and Jayvee Away * Tuesday: ! December 5 . Inborden Fas Boys and Girls | Home Friday _ December 9. Swift Creek ~ Boys and Jayvee Home Tuesday. — December 12 Speight , | Boys and Jayvee Away . Friday: : ' 1970 January 6 w Chaloner Boys and Girls | Home | ‘Tuesday . " ne January 16 Inborden eae Boys.and Girls Away Friday , January .23 Speight Boys and Jayvee .- Home — Friday . rar | ’ February 6 Eastman Boys and ‘Girls Away Friday . February 17 Tournament ‘Boys and Girls Away Tournament ¢ a, i. February 18 Tournament | “Away . Tournament /, 4 _ BRAWLEY HIGH SCHOOL . Werking Organizations October 23, 1969: : Organizations No, Enrolled | Student Council Officers and Representatives ee Ss ‘Library Club Brae 3 ae _ Honor Society be si = ee ns Se ae ets aaa an RR ee eee, ie a Football Team (Travel Team) == | wm. Basketball (Boys) aise ae _ Not Selected Yet 38 - B [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40386414_0052%3A02. Public record. Not legal advice.