Case: Liddell v. Board of Education for the City of St. Louis

Background

On February 18, 1972, five African-American parents and their minor children filed this class action lawsuit in the U.S. District Court for the Eastern District of Missouri. They sued the Board of Education of the City of St. Louis and a number of its officials under 42 U.S.C. § 1983. The plaintiffs, represented by private counsel, asked the court for injunctive relief, claiming that the defendants operated city schools in violation of the Fourteenth Amendment. Specifically, the plaintiffs claimed racial discrimination in the operation of the St. Louis Public Schools.

This case developed from school assignment policies. In 1971, some parents of students who attended public school in St. Louis, Missouri received notice that, due to school overcrowding, their children were being assigned to attend school in a distant, old, and worn school building. After informal efforts to get the school district to change its decision failed, five black parents and their minor children filed this class action complaint. They asked the court to promptly require the defendants to operate the schools using "nondiscriminatory allocation of financial and physical resources" and without "racially identifiable" boundaries, building usage, pupil/staff/faculty assignments, and transportation services.

On October 3, 1973, after discovery proceedings by the parties, U.S. District Court Judge James H. Meredith allowed the case to proceed as a class action. He invited other interested parties to intervene on or before December 1, 1973. No one applied for intervention.

On October 30, 1973, Judge Meredith denied the defendants' motion to direct the plaintiffs to add the state of Missouri and various of its agencies and officials, as well as twenty school districts in St. Louis County (a separate entity from the city) and the county's board of education as defendants in the case.

More than twenty-five years of litigation followed, which included the design, approval, and adoption of the nation's first voluntary interdistrict student transfer program used to settle a school desegregation case.

The Litigation

The parties filed a written stipulation of facts on June 7, 1974. On December 24, 1975, they entered into a court-approved intradistrict consent decree. Aiming to create racially diverse schools, the decree included a requirement for the city board to operate magnet schools specializing in topics such as business, science, and the performing arts. The court ordered publication of the judgment, advising that anyone who had objections to it should file them by January 16, 1976. Six black pupils, through their parents and friends, and the St. Louis chapter of the NAACP filed objections and sought to intervene. They were represented by private counsel and by attorneys of the NAACP. The original plaintiffs and defendants resisted both the objections and the intervention motion. Following a hearing, Judge Meredith overruled the objections. He denied the application for intervention on the grounds that it was untimely and that the class was adequately represented. He also found that the decree was adequate for the present time and gave all interested parties the opportunity to make additional suggestions to the court from time to time. The rebuffed putative intervenors appealed to the U.S. Circuit Court of Appeals for the Eighth Circuit. Meanwhile, several magnet schools began operation during the 1976-77 school year.

The Eighth Circuit noted that the appellants' failure to intervene in 1973 ordinarily would preclude their success on appeal, but found that other factors made the attempt at intervention sufficiently timely, in the circumstances, which included that the proposed decree took "only partial steps toward implementing a unitary school system...." Difficulties in working out a meaningful constitutional plan for a school system then comprised of 70% black students and 30% white students, most of whom attended largely single-race schools, prompted the court (i) to suggest that the district court invite intervention by the U.S. Department of Justice and the state, (ii) to recommend that the parties explore the creation of a bi-racial citizens advisory committee, and (iii) to encourage investigation into the voluntary cooperation of the county in accepting transfers of minority students. Ordering the district court to immediately grant the appellants' petition for intervention, the appellate panel remanded the case for hearing the parties' objections to the plan and for submission of alternate plans, adding that "[i]n no event should implementation of plans for a unitary school system be delayed beyond the commencement of the 1977-78 school term. Liddell v. Caldwell, 546 F.2d 768 (8th Cir. 1976) (Circuit Judge Donald P. Lay). Efforts to stay, and for further appellate review of, this decision failed. The case returned to Judge Meredith.

The district court then added additional plaintiffs, including a parents’ group, the city, and the United States, and additional defendants, including the state, its education commissioner, and its board of education. A trial began on November 17, 1977 and continued until May 26, 1978. The district court accepted post-trial briefs through October 31, 1978 and heard oral arguments on February 2, 1979. Judge Meredith, on April 12, 1979, found that the city's housing segregation and neighborhood schools policy led to the public schools' racial imbalance, not any intentional segregation caused by the school board. The judge viewed the NAACP's plan to integrate schools by racial percentage assignments as likely to result in more segregation, as did an expert witness for the United States, Dr. Gary Orfield, who had suggested that the city board ask county districts to find volunteer white students to attend city schools to achieve integration. The judge noted that such interdistrict transfers could result from the city board's continued operation of magnet schools, but he imposed no remedy because he had found no constitutional violation. Liddell v. Board of Education, 469 F. Supp. 1304 (E.D. Mo. 1979). Separate groups of plaintiffs appealed.

The Eighth Circuit heard the case en banc and, on March 3, 1980, unanimously reversed the district court. Again writing the appellate opinion, Judge Lay found that the city board's neighborhood schools policy (with attendance zones drawn to correspond with racially identifiable neighborhoods) and the board's failure, since 1954, to take steps necessary to convert to a unitary system implied an intent to segregate and required a system-wide remedy. The court evaluated the several desegregation plans that had been submitted to the district court and remanded the case to that court with instructions that the city board develop a comprehensive integration plan within 60 days under either of two approaches. The first approach consolidated the city and county schools, and the second involved voluntary interdistrict transfers. The Court held that the defendants would be required to pay for the costs of integration. Judge Lay noted that the county districts had, prior to 1954, collaborated with the city to ensure segregated schools through these districts' assignment and transport of suburban black students to the city's black schools. Adams v. United States, 620 F.2d 1277 (8th Cir. 1980). The opinion added that plaintiffs' attorneys' fees should be awarded upon proper application to the district court.

On remand, Judge Meredith appointed Dr. Orfield as the court's expert. The city board approved a desegregation plan in April and submitted it to the court, which held hearings on the plan. On May 21, 1980, the judge found that both the city and the state were responsible for the segregated St. Louis schools. He approved a comprehensive intradistrict desegregation plan to take effect that fall. Along with the plan's student reassignments, magnet schools, faculty integration, biennial progress reports, and monitoring committee, the judge directed the state, the United States, and the city to work with county school districts and develop, for 1980-81 implementation, a voluntary cooperative plan of interdistrict pupil exchanges to eradicate the remaining vestiges of government-imposed school segregation in the city and the county. Liddell v. Board of Education, 491 F. Supp. 351 (E.D. Mo. 1980). These interdistrict planning requirements, part of paragraph 12 of the decree, referenced what came to be known as the 12(a) voluntary plan and the 12(c) mandatory plan. The state and two groups of plaintiffs appealed, but Judge Meredith's monitoring committee remained active, headed by Edward T. Foote, then-Dean of Washington University School of Law.

Meeting with state and city education officials throughout the summer, Dean Foote presented to the court in October 1980, a framework for a voluntary interdistrict transfer plan including state-financed incentives for cooperating districts. The state had, by December 1980, submitted a plan for voluntary city-county student exchanges, but Judge Meredith found it insufficient to even determine its feasibility and directed the state to submit another voluntary plan by February 2, 1981. Liddell v. Board of Education, 508 F. Supp. 101 (E.D. Mo. 1980). Two days after Judge Meredith's ruling, responsibility for judging the case passed to District Judge William L. Hungate. He ordered Dean Foote to draft a 12(a) plan. Most of this plan's proposals, submitted to the court in March 1981 as "An Educational Plan for Voluntary, Cooperative Desegregation" (reprinted at 2 Pub. L. F. 35-68(1982)), were adopted in the 12(a) plan approved by the court in July 1981. The plan featured voluntary transfers of black city students to county schools, city magnet schools to attract white county students, state fiscal incentives to participating districts, and state payment of transportation costs. The court added that county districts' participation would not be evidence of liability in the on-going interdistrict component of the school desegregation case and could be a factor in any compulsory plan later ordered. By August 1981, however, only five county districts accepted the plan, which was then implemented as a pilot project.

Judge Hungate resumed efforts toward a 12(c) plan for the non-participating county districts, ordering a hearing on mandatory interdistrict relief for March 1, 1992, and interim development of such plans and a 90-day discovery period. The state and various parties had appealed aspects of the district court's rulings, resulting in an Eighth Circuit opinion on February 25, 1982, written by Circuit Judge Gerald W. Heaney. The decision, which came to be known as "Liddell V," first ruled that a broad 12(c) plan could not be implemented on the then-present record, as the suburban districts had not been afforded an opportunity to be heard and no findings had been made that those districts contributed to the city schools' segregation or that the state, through its control over the suburban districts, had done so. The ruling suggested the district court enter a 12(c) order and quickly try the issue of the state's and the suburban districts' interdistrict liability. It also upheld imposing the 12(a) plan's transportation costs on the state and a stay of interdistrict litigation granted to the 12(a) plan's participating districts. Liddell v. Board of Education, 677 F.2d 626 (8th Cir.), cert. denied, 459 U.S. 877 (1982).

The Settlement

Nine additional suburban districts joined the 12(a) plan, perhaps worried about the financial burden that would result from losing the interdistrict litigation. On October 15, 1982, Judge Hungate appointed Professor Bruce LaPierre of Washington University School of Law as Special Master for the purpose of exploring settlement possibilities among the original plaintiffs, the NAACP, the city board of education, 23 suburban school districts, the state, the Department of Justice, the city, and the county. By February 14, 1983 (the trial date for the interdistrict component of the case), Prof. LaPierre reported that settlement was a strong possibility, leading to trial postponements so negotiations could conclude. A voluntary interdistrict school desegregation plan resulted, part of a settlement agreement submitted to the court on March 30, 1983, and approved by Judge Hungate on July 5, 1983. Liddell v. Board of Education, 567 F. Supp. 1037 (E.D. Mo. 1983). With few modifications, the Eighth Circuit upheld the settlement on February 4, 1984, and the Supreme Court declined review. Liddell v. Board of Education, 731 F.2d 1294 (8th Cir.) (en banc) (Liddell VII), cert. denied, 469 U.S. 816 (1984).

Liddell VII set out the procedural history of the case to that point, set a 15,000 student cap on transfers from city to suburban schools, disapproved requiring state funding for county-to-county district transfers or for county-based magnet schools, required magnet school planning that presented reasonable probability of attracting suburban white students, made distinctions between remedial and general education programs which were part of the quality education component of the settlement (distinctions affecting state financial liability), approved allocating equal financial responsibility to the state and city board for city school capital improvements, and outlined a process (if needed) to achieve prohibition of a property tax rollback, disapproving the prohibition earlier ordered by the district court.

Implementation of the settlement agreement began in 1983. An excellent secondary source, La Pierre, "Voluntary Interdistrict School Desegregation in St. Louis: The Special Master's Tale," 1987 Wis. L. Rev. 971 (1987), describes the problems in implementing a comprehensive voluntary solution in this case and concludes that the courts kept the St. Louis plan from unraveling in the summer of 1987. Beginning on February 1, 1985, U.S. District Court Judge Stephen N. Limbaugh replaced Judge Hungate. On September 4, 1991, Judge Limbaugh transferred the case to District Judge George F. Gunn, Jr. (1991 WL 177702), but resumed presiding over the case in 1998, after Judge Gunn died. Overall, many thousands of docket entries were made reflecting actions in the case. A more comprehensive account of these actions, and their historical context, exists in a book by Judge Gerald W. Heaney & Dr. Susan Uchitelle, Unending Struggle: The Long Road to an Equal Education in St. Louis (Reedy Press 2004).

Enforcement

Among the case's developments over the years were 1985 and 1986 appellate decisions concerning aspects of planning, funding, and operating the magnet schools; Judge Limbaugh's March 1987 order revamping the magnet school program and May 1987 order reconstituting the magnet review panel with three nationally-known educators, Charles V. Willie, Eugene Reville, and John A. Murphy; that panel's September 1, 1987, report which led to negotiations and Judge Limbaugh's August 4, 1988, comprehensive plan to achieve student desegregation and financially sound school improvement; and the judge's dissatisfaction with city board efforts toward expanding the magnet school program.

In the early and mid-1990s, Judge Gunn oversaw disputes and delays involving school construction as part of the magnet school program; the Eighth Circuit sympathized with him and expressed its frustrations at the parties' delays. On multiple occasions during this period, the state unsuccessfully moved to terminate the case, asking for findings that the city's schools had achieved unitary status. On March 3, 1996, Judge Gunn began a unitary status hearing. Without ruling on the unitary status issue and continuing in effect the 1983 settlement, the judge appointed Dr. William H. Danforth, the former chancellor of Washington University, as settlement coordinator on April 23, 1996. Unsuccessful appeals followed, as did two years of negotiations.

In 1998, the state enacted legislation to help fund components of a settlement and, in 1999, the parties achieved a new settlement agreement. Unlike the 1983 agreement, "the Danforth agreement" contained time limits for ending the desegregation programs. Submitted to the court in February 1999, it provided that the magnet school programs would continue for ten years, state-funded interdistrict transfers would be reduced, and that the state would fund a capital improvements transition fund for the city schools (in conjunction with funding from a voter-approved city sales tax increase). A fairness hearing resulted in Judge Limbaugh's March 12, 1999 unpublished order approving the agreement and thanking various court-appointed committees, consultants, experts, and law clerks. The agreement provided that disputes over its contractual obligations were to be resolved in state, not federal, courts. It allowed that plaintiffs could seek specific performance of its terms, however, through resort to federal court. One effort to do so failed in July 2003, when the plaintiffs could not convince Judge Limbaugh that irreparable injury would result from the city board's plan to borrow from its capital improvements fund to meet operating expenses. The dispute led to an August 21, 2003 settlement agreement clarifying purposes and limits on funds usage, which was later modified by the parties and approved by the court on February 25, 2005.

On November 3, 2011, the parties filed a Joint Motion to Approve Agreement. Though the 1999 Settlement Agreement had been approved by the Court on March 12, 1999, the parties asked the Court for approval for an agreement they reached to allocate a portion of the funds set aside under the provisions of Section 10 of the 1999 Agreement. The parties agreed to use the remaining Section 10 money to provide for a wide-ranging array of benefits to students of the district, including increased childhood education programs, additional mentoring programs for teachers and principals, technology acquisition and support, additional services to reduce drop-out rates among young parents, and the complete elimination of the district's debt. Many of these programs were to continue for a period of at least three years, or until 2014. This agreement was accepted by the Court on November 16, 2011.

By September 3, 2013, the parties had again made changes to the agreement and hoped to get the Court's approval. This agreement focused on the St. Louis Monitoring and Support Task Force, which was responsible for monitoring the parties' compliance with the 1999 Agreement, reporting its findings to the public and gathering community support for St. Louis Public Schools. To fulfill its responsibilities, the Task Force used an independent consultant, which had been paid for by the Danforth Foundation up until July of 2013. Because that source of funding was no longer available, the parties agreed to allow $62,500 of the Section 10 money to be used to support the work of the Task Force for a year, which is set out in this agreement. The Court approved this agreement on September 4, 2013.

A year or so later, the parties were unable to come to an agreement about how to spend the Section 10 money during the 2014-15 school year before the school year began. The district funded all of the programs as agreed upon in the 2013 agreement until the parties could figure things out. The parties finally reached an agreement on September 16, 2015, allowing the use of the funds to continue all of the 2011 programs, as well as to provide additional support for students in lower performing "superintendent zone schools." Those supports included funding for a full-time counselor, nurse and social worker at each school in the superintendent zone for a period of three years. The funding would also provide for additional professional development for teachers in those schools, additional reading and math facilitators and eight additional family community specialists to support connections between school, parents and community, all for three years.

This agreement also required the district to meet certain goals each year in order to continue receiving funding. In the event that these goals were not met, the parties agreed to meet again and confer. As for the Task Force, this agreement allowed for the district to provide funding for it through 2018. On September 18, 2015, the parties filed yet another motion to modify the consent agreement to include the just-described terms; this modification was entered by the Court on September 21, 2015.

On April 11, 2016, the plaintiffs filed a motion to enforce the settlement agreement after the passage of Senate Bill 287, which reallocated the money set aside by the 1999 agreement to non-parties who have no desegregation remediation obligations. On May 31, 2016, the plaintiffs filed a motion to intervene on behalf of Charter Public School Parents and Children. On July 20, 2016, the movant's motion to intervene was denied, and the interveners appealed the decision. On September 28, 2016, the plaintiffs filed a motion to amend/correct the April 11th motion to enforce.

The Eighth Circuit denied the appeal on the May 31 motion to intervene on July 5, 2018 and remanded to the district court to determine the issue of the movants’ standing. On September 26, 2018, Judge Henry Edward Autrey held a status conference on the motion to amend/correct the April 11 motion to enforce, and granted the plaintiffs’ motion. Judge Autrey also granted the motion to intervene on October 9, 2018.

On October 15, 2019, the plaintiffs filed a Motion to Enforce the Settlement Agreement. The plaintiffs argued that Senate Bill 287, which was passed in 2006, violated the terms of the Desegregation Agreement by mandating that charter students receive a per pupil percentage of the local sales tax. The Settlement Agreement, the plaintiffs argued, was intended for the sole purpose of remediating segregation; since the State is not required to use these funds for that remediation purpose, the tax violates the Settlement Agreement.

Judge Henry Autrey for the E.D. Missouri granted the plaintiffs' motion in part and denied it in part. 2020 WL 6939608. On November 4, 2020, Judge Autrey found that basing the tax on a "per pupil" basis for charter schools did not violate the Agreement because charter schools fell within the Agreement's coverage of schools. However, Judge Autrey found that the funding was not being put toward desegregation efforts and ordered the school district to allocate the funds toward that effort henceforth. The defendants appealed the decision and moved to stay the district court's order pending appeal; the stay was granted on January 26, 2021. 2021 WL 254015.

As of June 2022, the case is ongoing and the appeal is pending in the Eighth Circuit (where oral argument was first set and then pulled from the calendar).

Available Opinions

After this case's first reported decision, Liddell v. Caldwell, 546 F.2d 768 (8th Cir. 1976), came many others, as listed below (along with a summary of the action taken by the court):

1. Stay denied by:

Liddell v. Caldwell, 553 F.2d 557, 1977 U.S. App. LEXIS 10304 (8th Cir. 1977)

2. Application to recall and stay appellate court mandate denied:

St. Louis Board of Education v. Caldwell, 429 U.S. 1086, 97 S. Ct. 1092, 51 L. Ed. 2d 531 (1977)

3. Writ of certiorari denied:

St. Louis Bd. of Education v. Caldwell, 433 U.S. 914, 97 S. Ct. 2987, 53 L. Ed. 2d 1100, 1977 U.S. LEXIS 2657 (1977)

4. On remand at, and findings of fact/conclusions of law at:

Liddell v. Board of Education, 469 F. Supp. 1304, 1979 U.S. Dist. LEXIS 13088 (E.D. Mo. 1979)

5. Reversed by, remanded by:

Adams v. United States, 620 F.2d 1277, 1980 U.S. App. LEXIS 20007 (8th Cir. 1980)

6. Writ of certiorari denied:

Adams v. United States, 449 U.S. 826, 101 S. Ct. 88, 66 L. Ed.2d 29 (1980)

7. On remand at:

Liddell v. Board of Education, 491 F. Supp. 351, 1980 U.S. Dist. LEXIS 11684 (E.D. Mo. 1980)

8. Motion to disqualify law firm denied:

Liddell v. Board of Education, 505 F. Supp. 654 (E.D. Mo. 1980)

9. Claim dismissed by:

Liddell v. Board of Education, 508 F. Supp. 101, 1980 U.S. Dist. LEXIS 16213, 1980 U.S. Dist. LEXIS 16214 (E.D. Mo. 1980)

10. Appeal dismissed by:

Liddell v. Board of Education, 693 F.2d 721, 1981 U.S. App. LEXIS 15562 (8th Cir. 1981)

11. Affirmed by, remanded by:

Liddell v. Board of Education, 667 F.2d 643, 1981 U.S. App. LEXIS 19100, 1981 U.S. App. LEXIS 20218 (8th Cir. 1981)

12. Writ of certiorari denied:

Caldwell v. Missouri, 454 U.S. 1081, 102 S. Ct. 634, 70 L. Ed. 2d 614, 1981 U.S. LEXIS 4648, 50 U.S.L.W. 3447 (1981)

13. Rehearing denied by:

Caldwell v. Missouri, 455 U.S. 929, 102 S. Ct. 1294, 71 L. Ed. 2d 473 (1982)

14. Writ of certiorari denied:

Missouri v. Liddell, 454 U.S. 1091, 102 S. Ct. 656, 70 L. Ed. 2d 629, 1981 U.S. LEXIS 4768, 50 U.S.L.W. 3447 (1981)

15. Subsequent appeal at:

Liddell v. Board of Education, 677 F.2d 626, 1982 U.S. App. LEXIS 21490 (8th Cir. 1982)

16. Writ of certiorari denied:

Missouri v. Liddell, 459 U.S. 877, 103 S. Ct. 172, 74 L. Ed. 2d 142, 1982 U.S. LEXIS 3726, 51 U.S.L.W. 3258 (1982)

17. Motion denied by:

Liddell v. Board of Education, 98 F.R.D. 548 (E.D. Mo. 1983)

18. Judgment entered by:

Liddell v. Board of Education, 567 F. Supp. 1037, 1983 U.S. Dist. LEXIS 15682 (E.D. Mo. 1983)

19. Stay denied by:

Liddell v. Missouri, 717 F.2d 1180, 1983 U.S. App. LEXIS 16965 (8th Cir. 1983)

20. Affirmed in part and reversed in part by, remanded by:

Liddell v. Missouri, 731 F.2d 1294, 1984 U.S. App. LEXIS 25668, 76 A.L.R. Fed. 435 (8th Cir. 1984)

21. Writ of certiorari denied:

Leggett v. Liddell, 469 U.S. 816, 105 S. Ct. 82, 83 L. Ed. 2d 30, 1984 U.S. LEXIS 3051, 53 U.S.L.W. 3236 (1984)

22. Clarified by:

Liddell v. Board of Education, 758 F.2d 290, 1985 U.S. App. LEXIS 28733, 1985 U.S. App. LEXIS 30596 (8th Cir. 1985)

23. Appeal after remand at:

Liddell v. Board of Education, 801 F.2d 278, 1986 U.S. App. LEXIS 29462 (8th Cir. 1986)

24. Rehearing, en banc, denied by:

Liddell v. Board of Education, 804 F.2d 500, 1986 U.S. App. LEXIS 33214 (8th Cir. 1986)

25. Later proceeding at:

Liddell v. Board of Education, 654 F. Supp. 334, 1987 U.S. Dist. LEXIS 1025 (E.D. Mo. 1987)

26. Motions ruled upon by:

Liddell v. Board of Education, 654 F. Supp. 345, 1987 U.S. Dist. LEXIS 1653 (E.D. Mo. 1987)

27. Affirmed in part and reversed in part by, remanded by:

Liddell v. Board of Education, 822 F.2d 1446, 1987 U.S. App. LEXIS 7344 (8th Cir. 1987)

28. Later proceeding at:

Liddell v. Board of Education, 823 F.2d 1252, 1987 U.S. App. LEXIS 8953 (8th Cir. 1987)

29. Motions ruled upon by:

Liddell v. Board of Education, 674 F. Supp. 687, 1987 U.S. Dist. LEXIS 8532 (E.D. Mo. 1987)

30. Subsequent appeal at:

Liddell v. Board of Education, 830 F.2d 823, 1987 U.S. App. LEXIS 12362 (8th Cir. 1987)

31. Subsequent appeal at:

Liddell v. Board of Education, 839 F.2d 400, 1988 U.S. App. LEXIS 1447 (8th Cir. 1988)

32. Writ of certiorari denied:

Missouri v. Rockwood School Dist., 488 U.S. 825, 109 S. Ct. 74, 102 L. Ed. 2d 50, 1988 U.S. LEXIS 3817, 57 U.S.L.W. 3231 (1988)

33. Later proceeding at:

Liddell v. Board of Education, 686 F. Supp. 235, 1988 U.S. Dist. LEXIS 5721 (E.D. Mo. 1988)

34. Motions ruled upon by:

Liddell v. Board of Education, 687 F. Supp. 1368, 1988 U.S. Dist. LEXIS 7319 (E.D. Mo. 1988)

35. Affirmed and remanded, with instructions:

Liddell v. Board of Education, 851 F. 2d 1104 (8th Cir. 1988) (per curiam)

36. Clarified by:

Liddell v. Board of Education, 687 F. Supp. 1368, 1988 U.S. Dist. LEXIS 7338 (E.D. Mo. 1988)

37. Opinions combined at:

Liddell v. Board of Education, 687 F. Supp. 1368 (E.D. Mo. 1988)

38. Affirmed in part and reversed in part by, remanded by:

Liddell v. Board of Education, 873 F.2d 191, 1989 U.S. App. LEXIS 5333 (8th Cir. 1989)

39. Rehearing denied by, motion denied by:

Liddell v. Missouri, 1989 U.S. App. LEXIS 8014 (8th Cir. May 31, 1989)

40. Opinion withdrawn by, clarified by:

Liddell v. Board of Education, 882 F.2d 298, 1989 U.S. App. LEXIS 10988 (8th Cir. 1989)

41. Subsequent appeal at:

Liddell v. Board of Education, 851 F.2d 1104, 1988 U.S. App. LEXIS 9449 (8th Cir. 1988)

42. Writ of certiorari denied:

Missouri v. Rockwood School District, 488 U.S. 825, 109 S. Ct. 74, 102 L.Ed.2d 50 (1988)

43. On remand at:

Liddell v. Board of Education, 696 F. Supp. 444, 1988 U.S. Dist. LEXIS 14460 (E.D. Mo. 1988)

44. Later proceeding at:

Liddell v. Board of Education, 696 F. Supp. 442, 1988 U.S. Dist. LEXIS 15962 (E.D. Mo. 1988)

45. Affirmed by:

Liddell v. Board of Education, 867 F.2d 1153, 1989 U.S. App. LEXIS 1644 (8th Cir. 1989)

46. Later proceeding at:

Liddell v. Board of Education, 1989 U.S. Dist. LEXIS 10200 (E.D. Mo. July 18, 1989)

47. Later proceeding at:

Liddell v. Board of Education, 718 F. Supp. 1434, 1989 U.S. Dist. LEXIS 10246 (E.D. Mo. 1989)

48. Later proceeding at:

Liddell v. Board of Education, 733 F. Supp. 1324, 1990 U.S. Dist. LEXIS 2703 (E.D. Mo. 1990)

49. Motion granted by, in part, motion denied by, in part:

Liddell v. Board of Education, 1990 U.S. Dist. LEXIS 5268 (E.D. Mo. Mar. 2, 1990)

50. Motion denied by:

Liddell v. Board of Education, 1990 U.S. Dist. LEXIS 8088 (E.D. Mo. May 3, 1990)

51. Affirmed by, remanded by:

Liddell v. Board of Education, 907 F.2d 823, 1990 U.S. App. LEXIS 11048 (8th Cir. 1990)

52. Later proceeding at:

Liddell v. Board of Education, 758 F. Supp. 499, 1991 U.S. Dist. LEXIS 2029 (E.D. Mo. 1991)

53. Modified by, affirmed by:

Board of Education v. Missouri, 936 F.2d 993, 1991 U.S. App. LEXIS 12040 (8th Cir. 1991)

54. Later proceeding at:

Liddell v. Board of Education, 771 F. Supp. 1493, 1991 U.S. Dist. LEXIS 12012 (E.D. Mo. 1991)

55. Later proceeding at:

Liddell v. Board of Education, 771 F. Supp. 1496 (E.D. Mo. 1991)

56. Later proceeding at:

Liddell v. Board of Education, 771 F. Supp. 1503 (E.D. Mo. 1991)

57. Supplemental opinion at:

Liddell v. Board of Education, 1991 U.S. Dist. LEXIS 12627 (E.D. Mo. Sept. 4, 1991)

58. Later proceeding at:

Liddell v. Board of Education, 795 F. Supp. 927 (E.D. Mo. 1992)

59. Later proceeding at:

Liddell v. Board of Education, 795 F. Supp. 930 (E.D. Mo. 1992)

60. Affirmed in part and reversed in part:

Liddell v. Board of Education, 976 F.2d 1241 (8th Cir. 1992)

61. Later proceedings at:

Liddell v. Board of Education, 795 F. Supp. 930 (E.D. Mo. 1992)

62. Reimbursement motion denied:

Liddell v. Board of Education, 814 F. Supp. 788 (E.D. Mo. 1993)

63. Affirmed and remanded, with instructions:

Liddell v. Board of Education, 988 F.2d 844 (8th Cir. 1993)

64. Remanded with directions to detail reasons:

Liddell v. Board of Education, 20 F.3d 324 (8th Cir. 1994)

65. Reversed by:

Liddell v. Board of Education, 20 F.3d 326 (8th Cir. 1994)

66. Affirmed by:

Liddell v. Board of Education, 26 F.3d 815 (8th Cir. 1994)

67. Vacating attorneys' fee order:

Liddell v. Board of Education, 73 F.3d 819 (8th Cir. 1996)

68. Affirmed by:

Liddell v. Board of Education, 96 F.3d 1091 (8th Cir. 1996)

69. State's appeals dismissed by:

Liddell v. Board of Education, 105 F.3d 1208 (8th Cir. 1997)

70. Remanded, for formal hearing and findings, by:

Liddell v. Board of Education, 121 F.3d 1201 (8th Cir. 1997)

71. Remanded, for findings, by:

Liddell v. Board of Education, 122 F.3d 1092 (8th Cir. 1997)

72. Affirmed by:

Liddell v. Board of Education, 126 F.3d 1049 (8th Cir. 1997)

73. Writ of certiorari denied by:

Missouri v. Liddell, 522 U.S. 1147 (1998)

74. Affirmed by:

Liddell v. Board of Education, 142 F.3d 1096 (8th Cir. 1998)

75. Appeal dismissed as moot by:

Liddell v. Board of Education, 142 F.3d 1100 (8th Cir. 1998)

76. Affirmed, in part and reversed, in part, by:

Liddell v. Board of Education, 142 F.3d 1103 (8th Cir. 1998)

77. Affirmed by:

Liddell v. Board of Education, 142 F.3d 1106 (8th Cir. 1998)

78. Attorneys' fee award affirmed by:

Liddell v. Board of Education, 142 F.3d 1109 (8th Cir. 1998)

79. Appeal dismissed as moot by:

Liddell v. Board of Education, 142 F.3d 1111 (8th Cir. 1998)

80. Vocational education order affirmed in part, reversed in part, and remanded with instructions by:

Liddell v. Board of Education, 149 F.3d 862 (8th Cir. 1998)

In addition to the above list of reported decisions, which are accessible in the Civil Rights Litigation Clearinghouse database, the database includes many unreported decisions, motions, and documents concerning this case, through March 5, 2017.