4:65-cv-00041
N.D. Miss.Feb 27, 2019Background
- United States sued Carroll County Board of Education in 1965 claiming de jure racial segregation; court issued multiple desegregation orders and injunctions beginning in 1966–1971.
- District implemented various assignment plans and court-ordered measures (alphabetical class assignments, unitary transportation, reporting requirements); magnet schools approved in 2007.
- By 2018–19 the District operated two schools in a single-grade configuration: Marshall Elementary (K–5) and J.Z. George High (6–12), enrolling 934 students (533 Black, 355 White, 46 other).
- Faculty and staff totals (2018) were 155 employees: 84 Black and 71 White; transportation provided nondiscriminatorily; no evidence of racially discriminatory extracurricular access or new construction resegregating schools.
- The United States reviewed the District in 2018, concluded the District had complied with desegregation orders and eliminated vestiges of de jure discrimination to the extent practicable, and joined the District in a motion for declaration of unitary status and dismissal.
- The court found the District satisfied the Green factors and related standards, dissolved prior injunctions, terminated jurisdiction, and dismissed the case with prejudice (Feb. 27, 2019).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether District has complied with court desegregation orders long enough to warrant unitary status | United States: District has complied for a reasonable period and requests unitary status and dismissal | Carroll County: joined the motion, asserting compliance and entitlement to dismissal | Granted — Court finds compliance and declares unitary status |
| Whether District eliminated vestiges of past de jure discrimination to the extent practicable | United States: evidence shows elimination across Green factors (student assignment, faculty/staff, transportation, activities, facilities) | Carroll County: concurs; no contrary evidence presented | Granted — Court finds vestiges eliminated to extent practicable |
| Whether District demonstrated good-faith commitment to desegregation and constitutional obligations | United States: single-grade configuration, nondiscriminatory policies, diverse faculty/staff indicate good faith | Carroll County: asserts ongoing compliance and commitment | Granted — Court finds good-faith commitment satisfied |
| Whether remaining judicial supervision and injunctions should be dissolved | United States: seeks termination of supervision and dismissal with prejudice | Carroll County: seeks same relief | Granted — All prior injunctions dissolved; case dismissed with prejudice |
Key Cases Cited
- Green v. Cnty. Sch. Bd. of New Kent Cnty., 391 U.S. 430 (1968) (establishes "Green factors" for dismantling dual school systems)
- Bd. of Educ. of Okla. City Pub. Sch. v. Dowell, 498 U.S. 237 (1991) (standards for terminating desegregation decrees)
- Freeman v. Pitts, 503 U.S. 467 (1992) (addresses scope of judicial supervision and unitary status considerations)
- Missouri v. Jenkins, 515 U.S. 70 (1995) (unitary status requires compliance, elimination of vestiges, and good-faith commitment)