Bush v. Orleans Parish School Board

205 F. Supp. 893, 6 Fed. R. Serv. 2d 1120, 1962 U.S. Dist. LEXIS 3877
District Court, E.D. Louisiana·Decided May 23, 1962·No. Civ. A. 3630·Published·Cited by 9 cases

Opinion

ELLIS, District Judge.

Defendant, Orleans Parish School Board, moves for a new trial of the issues decided by the April 9, 1962, order 1 of this Court, 204 F.Supp. 568 expanding the order of May 16, 1960, to include desegregation of the first six grades of defendant’s schools and enjoining the use of the Louisiana Pupil Placement Law 2 in defendant’s schools so long *895 as defendant maintains a dual school system based on race. Defendant assigns various errors of fact and law in the April 9 order. There is no serious contention in defendant’s motion or in its argument before the Court that proper disposition of this motion necessitates the taking of new testimony. 3 In the main defendant challenges the ultimate determinations of fact and law made by this Court on the prior record. A full and extensive trial with adequate briefing was given on first hearing and this Court can find no reason for reopening the hearing.

However, a Rule 59 4 motion for new trial may result in alteration of the findings and judgment without taking new testimony. 5 Moreover, this Court as presently constituted is competent to consider this motion and direct whatever relief or alteration it deems necessary. 6 The peculiar circumstances of this case, necessitating periodic full trials, the constant supervision of the Court, 7 and the ever-present balancing of individual and public interests 8 demand that this Court be able to examine what it must supervise and adjust according to the law and its allowable discretion.

Defendant’s first assignment of error is that this Court as previously constituted erred in finding that the separate school facilities provided for white and negro children in Orleans Parish were unequal. Therefore, defendant concludes, expanded desegregation based on such finding is erroneous. 9 The proposition presents the serious question of whether the existence of separate but equal facilities is an allowable consideration in granting delay of desegregation under the “all deliberate speed” test of Brown v. Board of Education, 349 U.S. 294, 75 S.Ct. 753, 99 L.Ed. 1083. In the second Brown decision the Supreme Court set down the allowable limits of delay. 10 Among the allowable considera *896 tion were “problems related to administration, arising from the physical condition of the school plant, the school transportation system, (and) personnel.” The implication is clear that where present facilities were incapable of immediate integration because of consequent overcrowding, or where sudden shifting of present pupil allotment would overtax personnel, a school board would be allowed time to work out a plan of physical equalization “on a non-racial basis.” However, there is nothing to suggest that a school board could constitutionally continue separate but equal facilities under the umbrella of the “deliberate speed” rule when it is admitted that negroes are living relatively near white schools which are below capacity. It should be noted that the condition of the Orleans Parish Schools is virtually the same as the condition of the schools in the cases which came before the Supreme Court in Brown v. Board of Education, 347 U.S. 483, 74 S.Ct. 686, 98 L.Ed. 873. The Supreme Court was unequivocal in its expression: “We conclude that in the field of public education the doctrine of ‘separate but equal’ has no place.” Brown v. Board of Education, supra at 495, 74 S.Ct. at 692. The Fifth Circuit in the infancy of desegregation, held that existing separate but equal facilities were not grounds for dismissal of a desegregation suit for prematurity. 11 Defendants do not direct the Court’s attention to any case in which separate but equal facilities were an allowable consideration for delay under the “all deliberate speed” mandate, and we can find none. It is not within the power of this Court to perpetuate a repudiated constitutional doctrine by imposing it as a check rein on a superceding mandate of the Supreme Court.

The Board’s second challenge is that it has been complying with the Brown mandate by making a prompt and reasonable start towards desegregation. The Board alleges good faith compliance with the Brown order and concludes that the Board, not this Court, is the one to make plans to effectuate desegregation. A brief history of the law and the history of the case will illuminate the proposition. In the second Brown decision the Supreme Court stated that “ * * * the (district) courts will require that the (school boards) make a prompt and reasonable start toward full compliance with our May 17, 1954, ruling. Once a start has been made the courts may find that additional time is necessary to carry out the ruling in an effective manner. The burden rests upon the (school boards) to establish that such time is necessary in the public interest and is consistent with good faith compliance at the earliest practicable date.” 12 (Emphasis supplied). And further: “(The District Courts) will also consider the adequacy of any plans the defendants may propose to meet these problems and to effectuate a transition to a racially nondiscriminatory school system.” 13 Subsequently in Cooper v. Aaron, 358 U.S. 1, 7, 78 S.Ct. 1401, 3 L.Ed.2d 5, the Court ordered that “ * * * (A) District Court, after analysis of the relevant factors (which, of course, excludes hostility to racial desegregation), might conclude that justification existed for not requiring the pres *897 ent nonsegregated admission of all qualified Negro children. In such circumstances, however, the courts should scrutinize the program of the school authorities to make sure that they had developed arrangements pointed toward the earliest practicable completion of desegregation, and had taken appropriate steps to put their program into effective operation.” And finally, “State authorities were thus duty bound to devote every effort toward initiating desegregation and bringing about the elimination of racial discrimination in the public school system.” 14 There can be little doubt that the original conception of' the Supreme Court was that desegregation would be implemented by the school boards through plans devised by the boards and supervised by the District Courts. 15 The history of desegregation in New Orleans proves that this was not to be the case here.

The implementing decision in Brown was handed down on May 31, 1955.

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Bush v. Orleans Parish School Board, 205 F. Supp. 893, 6 Fed. R. Serv. 2d 1120, 1962 U.S. Dist. LEXIS 3877 (E.D. La. 1962).

205 F. Supp. 893 (Bush v. Orleans Parish School Board) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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