Bush v. Orleans Parish School Board

194 F. Supp. 182, 1961 U.S. Dist. LEXIS 3240
District Court, E.D. Louisiana·Decided May 4, 1961·No. Civ. A. 3630·Published·Cited by 24 cases

Opinion

RIVES, Circuit Judge, and CHRISTENBERRY and WRIGHT, District Judges.

At its last session, officially labeled the Second Extraordinary Session of 1961, and actually the fifth consecutive sitting since November, the Legislature of Louisiana passed, and her Governor approved, two additional measures designed to subvert the effective desegregation of the New Orleans schools and thwart the implementation of the orders of this court looking to that end. 1 The statutes in question are Acts 3 and 5, the enforcement of which the United States now asks to enjoin. 2

The legislation takes the form of amendments to the Louisiana Criminal Code. Act 3 purports to create a new crime entitled “Bribery of parents of school children.” It punishes giving to, or acceptance by, any parent of “anything of apparent present or prospective value” as an “inducement” to sending his child to a school operated “in violation of any law of this State.” 3 The companion crime announced by Act 5 is *184 labeled “Intimidation and interference in the operation of schools.” Here, in rather strange language, the conduct condemned is the offering to do or doing of any act * * * to a child or parent, teacher or other school employee, which may influence that person “to do or perform any act in violation of any law of this state.” 4 Both statutes grant immunity from prosecution and promise a monetary reward to informers,

With commendable frankness, Louisiana’s Attorney General admits that these enactments are probably invalid, being too vague and indefinite to define a crime. 5 But he insists that this is nei *185 ther the time nor the place to challenge them. He would prefer the test to come in a state court after an accused has been arrested, held and charged under authority of the statutes here assailed. Such a ■person, he argues, would have a better .standing to contest the constitutionality >of these measures, and, since a ruling •striking them down can confidently be predicted from the Louisiana courts, we are urged to spare ourselves this unnecessary chore.

True, “it is a familiar rule that -courts of equity do not ordinarily restrain criminal prosecutions.” 6 Douglas v. City of Jeannette, 319 U.S. 157, 163, 63 S.Ct. 877, 881, 87 L.Ed. 1324. And this principle has special force when application is made to a federal court to enjoin the enforcement of state criminal statutes, for then considerations of comity add their weight to suggest abstention. Beal v. Missouri Pacific R. Co., 312 U.S. 45, 49-50, 61 S.Ct. 418, 85 L.Ed. 577. See also, Harrison v. N. A. A. C. P., 360 U.S. 167, 79 S.Ct. 1025, 3 L.Ed.2d 1152. But the rule cannot be applied mechanically. N. A. A. C. P. v. Bennett, 360 U. S. 471, 79 S.Ct. 1192, 3 L.Ed.2d 1375; cf. Doud v. Hodge, 350 U.S. 485, 76 S.Ct. 491, 100 L.Ed. 577. Special circumstances will sometimes compel a federal court to act. Truax v. Raich, 239 U.S. 33, 36 S.Ct. 7, 60 L.Ed. 131; Pierce v. Society of Sisters, 268 U.S. 510, 45 S.Ct. 571, 69 L.Ed. 1070; Hague v. Committee Industrial Organization, 307 U.S. 496, 59 S.Ct. 954, 83 L.Ed. 1423; see Terrace v. Thompson, 263 U.S. 197, 214, 44 S.Ct. 15, 68 L.Ed. 255; Packard v. Banton, 264 U.S. 140, 143, 44 S.Ct. 257, 68 L.Ed. 596; Spielman Motor Co. v. Dodge, 295 U.S. 89, 95, 55 S.Ct. 678, 79 L.Ed. 1322; Beal v. Missouri Pacific R. Co., supra, at page 50, 61 S.Ct. 418; Douglas v. City of Jeannette, supra, at page 163, 63 S.Ct. 882; Denton v. City of Carrollton, Georgia, 5 Cir., 235 F.2d 481, 484-485. This is such a case.

The challenged statutes are not ordinary criminal provisions. They constitute special legislation, passed as “emergency” 7 measures to accomplish a specific purpose. Placed in context, their mission is all too clear. These are the invidious weapons of a state administration dedicated to scuttling the modest program of desegregation which has been initiated in Orleans Parish. The plain intent of the measures is to publish a threat of imprisonment against all who would have any dealings with an integrated school. Whether or not prosecution is ever attempted under these provisions, the obvious hope of the sponsors is that the mere promulgation of the statutes will accomplish the desired end. Thus, the effect is immediate. The harm has already begun. In these circumstances, there can be no question of postponing decision

Nor can there be any doubt as to the unconstitutionality of these acts. They are revealed as but another effort to circumvent the orders of the court issued pursuant to the mandate of Brown v. Board of Education, 347 U.S. 483, 74 S.Ct. 686, 98 L.Ed. 873. 8 Constitutionally unable to require racial segregation in the public schools, arrested in its plan to close the integrated schools, and unsuc *186 cessful in its boycott of these schools by other means, the State has now marshalled the full force of its criminal law to enforce its social philosophy through the policeman’s club.

It is argued, however, that we read too much in the statutes. We are told that these laws have no connection with segregation ; that the reference to schools operated “in violation of any law of this State” does not mean desegregated schools. It cannot be, so the argument goes, because this court has voided all laws requiring or permitting segregation of the races in public education.

Of course, the circumstances under which these measures were adopted belie any such claim of innocence. The Legislature clearly wants parents and teachers, and other interested persons, to understand that they will be punished if they have any contact with an integrated school. Yet, it would play tricks with the court and pretend it had meant nothing of the kind. “But courts cannot permit themselves to be deceived.

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Bush v. Orleans Parish School Board, 194 F. Supp. 182, 1961 U.S. Dist. LEXIS 3240 (E.D. La. 1961).

194 F. Supp. 182 (Bush v. Orleans Parish School Board) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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