Singleton v. Jackson Municipal Separate School District

Facts of the Case

The dispute in Singleton began in 1963, when 10 school-aged children filed suit against their school board, asserting they had been irreparably injured by its failure to maintain unitary or desegregated schools. The plaintiffs alleged that the board ignored precedent from the U.S. Supreme Court directing school boards to create unitary school systems immediately (Alexander v. Holmes County Board of Education, 1969). The plaintiffs claimed that the board also ignored the six criteria that the Supreme Court declared should be used to determine whether school systems had achieved unitary status in Green v. County School Board of New Kent County (1968). These factors address the composition of a student body, faculty, staff, transportation, extracurricular activities, and facilities.

The trial court later found that the school board achieved unitary status with respect to five of the six established Green factors: faculty, staff, transportation, extracurricular activities, and facilities. Insofar as the remaining area of concern dealt with the desegregation of the student body, the board sent the court a new plan. The court accepted the plan for desegregating the secondary schools but not the elementary schools. In June of 1971, the court accepted a plan for desegregation of the elementary schools, and since that time, all parties agreed that the system had been desegregated. In 1981, when the board petitioned to have its desegregation order terminated, several persons opposed its request in order to assure continued protection for minority students.

The Court's Ruling

In resolving the dispute, the trial court noted the school board achieved unitary status in 1971 under the six Green factors. In the most significant aspect on one of the earlier rounds of litigation, and the proposition for which the Fifth Circuit's 1969 judgment in Singleton is remembered, the court was satisfied that the board demonstrated that it had desegregated its teaching [Page 766]faculty. At that time, the Fifth Circuit acknowledged that the board succeeded, to the fullest extent possible, in ensuring that students were taught by both Black and White teachers and that the ratio of Black to White teachers was appropriate. Additionally, the trial court reiterated the Fifth Circuit's holding that board officials proved that there was a racial balance in the distribution of administrative authority and that no one had mounted a successful challenge to the board's racial hiring practices in over a decade.

Turning to transportation and extracurricular requirements, the court pointed out that the Office of Civil Rights (OCR) had issued an order stating that the school board's policy of providing free transportation to all students who lived more than nine-tenths of a mile from their assigned schools was nondiscriminatory. The court also commented on the OCR's investigation of allegations of discrimination in the board's extracurricular programs, maintaining that there were no racial barriers for students who wished to participate.

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