Lee v. Eufaula City Board of Education

573 F.2d 229
CourtCourt of Appeals for the Fifth Circuit
DecidedMay 18, 1978
DocketNo. 77-3416
StatusPublished
Cited by5 cases

This text of 573 F.2d 229 (Lee v. Eufaula City Board of Education) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lee v. Eufaula City Board of Education, 573 F.2d 229 (5th Cir. 1978).

Opinion

FAY, Circuit Judge:

This appeal arises from the implementation of a desegregation order entered on March 24, 1970, governing desegregation of the city school system of Eufaula, Alabama. The city of Eufaula operates its own school system within Barbour County, Alabama, which also has a separate school system. Pursuant to this Court’s opinion in Singleton v. Jackson Municipal Separate School District, 419 F.2d 1211 (5th Cir. 1969), cert. denied, 396 U.S. 1032, 90 S.Ct. 612, 24 L.Ed.2d 530 (1970), the order contained the following provision regarding any transfer policy adopted by the Eufaula system:

If the school district grants transfers to students living in the district for their attendance at public schools outside the district, or if it permits transfers into the district of students who live outside the district, it shall do so on a non-diseriminatory basis, except that it shall not consent to transfers where the cumulative effect will reduce desegregation in either district or reinforce the dual school system.

On May 16, 1977, the United States filed a motion for further relief alleging that the Eufaula City Board of Education had violated the Singleton transfer provision by permitting the attendance in the Eufaula schools of non-residents whose attendance had the cumulative effect of reducing desegregation in the school districts involved.1 The United States requested, inter alia, that the Eufaula City Board of Education be enjoined from accepting any transfers having such a cumulative effect and that the Board be ordered to adopt and implement procedures to assure that no further violations of the transfer provision occur.

After an evidentiary hearing, the district court concluded that the transfer policy did not have the cumulative effect of reducing desegregation in the districts involved except with respect to transfers from Quitman County, Georgia.2 R. Vol. I, 125. Nevertheless, the district court enjoined the Eufaula City Board of Education from accepting “student transfer applications from students residing outside Barbour County.” R. Vol. I, 125. The court refused to order the Board to adopt procedures to police transfers to assure compliance with the transfer provision. Because we have concluded that the order of the district court enjoining the transfer of students from counties other than Barbour County is erroneous in light of its finding that the transfer policy has the cumulative effect of reducing desegregation only with respect to transfers from Quitman County, Georgia, and because further findings are necessary in order to assess the validity of the transfer policy proposed by the Board, we vacate the order dated November 4, 1977, and remand this case for further proceedings consistent with this opinion.

The facts underlying this appeal are not in serious dispute. The Eufaula City School District3 is coextensive with the city limits. The Eufaula system has admitted into attendance all nonresidents, whether black or white, who have applied for admission since the 1970 desegregation order. Prior to the filing of the motion for further relief by the United States, the Eufaula City Board of Education had made no concerted effort to analyze the cumulative effect of the transfer program on the Eufaula system nor on the districts in which the students would have attended school if not for the transfers. Nor did the Board have a policy of verifying that students listed as residents were in fact residents of the city of Eufaula. In response to the motion, the Eufaula [232]*232Board undertook an analysis of the effect of the transfers on all school districts involved and verified that each student listed as a resident of Eufaula was a resident in fact. No effort was made, however, to determine which particular schools in the home districts the transferees would have attended if not for the transfers.

At the commencement of the 1977 — 78 school year, 386 out-of-district students were enrolled in the Eufaula system.4 It is uncontroverted that, if all of the out-of-district students were returned to their home districts, with the exception of Quitman County, Georgia, the maximum change in racial composition of any district involved would be 4.24%.5 Nevertheless, at the evidentiary hearing of August 18, 1977, Dr. William Moorer, a member of the Eufaula Board of Education, testified that in an effort to resolve the situation the Board “would make the offer that we would accept transfers only from Barbour County.” R. Vol. II, 78.

The United States first contends that the district court erred in failing to enjoin the Eufaula City Board of Education from accepting transfer applications of white students residing in Barbour County because these transfers reduce desegregation and contribute to the evolution of dual school systems consisting of “black” county schools and “white” city schools. The position of the United States is that in the event white students wish to transfer into the Eufaula system, Singleton only permits a strict one-for-one exchange.6 The Board counters with the argument that the 4% (74 to 78%) increase in the percentage of black students in the Barbour County school district occasioned by the transfer policy is de minimus, and hence permissible, and is justified in any event by the enhanced educational opportunities afforded by the Eufaula system.7

We reject the contention of the government that the transfer of white students can only be permitted on a strict one-for-one exchange basis. We do so because we refuse to draw the line so hard and fast. In measuring the cumulative effect of a student transfer program on desegregation, the Court must do so from a qualitative viewpoint, without blind deference to an objective mathematical formula.

Although not directly in point factually, in Davis v. Board of School Commissioners [233]*233of Mobile;8 this Court recognized the general principle that:

[Sjchool desegregation can first be measured quantitatively, using percentages as a rough rule of thumb, but ultimately must be measured qualitatively, judging whether schools are still identifiable as white or Negro.

393 F.2d at 693.

Similarly, in dealing with the validity of an optional transfer policy, the Sixth Circuit in NAACP v. Lansing Board of Education, 559 F.2d 1042 (6th Cir. 1977), recently held as follows:

Where the foreseeable and actual result of a transfer policy is to increase the racial identifiability of schools with large minority enrollment, continuation of the policy gives rise to a presumption of segregative intent.

559 F.2d at 1051.

The focal issue to be considered on remand with respect to the transfer of students from the Barbour County to the Eufaula system is whether these transfers have a qualitative effect on desegregation in either of the districts.9 We conclude that there is not sufficient evidence in the record from which such a determination can be made.

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Related

United States v. Mississippi
719 F. Supp. 1364 (S.D. Mississippi, 1989)
Lee v. Lee County Board of Education
639 F.2d 1243 (Fifth Circuit, 1981)
United States v. City of Monroe
513 F. Supp. 375 (W.D. Louisiana, 1980)
Lee v. Eufaula City Board of Education
573 F.2d 229 (Fifth Circuit, 1978)

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