Case: Singleton v. Jackson Municipal Separate School District

63-22527 | U.S. District Court for the Southern District of Mississippi

Filed Date: 1963

Closed Date: 1981

Clearinghouse coding complete

Case Summary

This school desegregation case was filed in 1963 in the U.S. District Court for the Southern District of Mississippi. Plaintiffs, black students and their families, sought injunctive relief requiring the Jackson Municipal Separate School District to desegregate its public schools.In an unavailable 1964 district court opinion, District Judge Sidney C. Mize approved a desegregation plan proposed by the School District. The plaintiffs then appealed and argued that the School District's plan was no…

This school desegregation case was filed in 1963 in the U.S. District Court for the Southern District of Mississippi. Plaintiffs, black students and their families, sought injunctive relief requiring the Jackson Municipal Separate School District to desegregate its public schools.

In an unavailable 1964 district court opinion, District Judge Sidney C. Mize approved a desegregation plan proposed by the School District. The plaintiffs then appealed and argued that the School District's plan was not in compliance with the 5th Circuit's minimum standards for desegregation, which required that schools integrate at a rate faster than one grade per year, new students in the school district could not be assigned to schools by race, both elementary and secondary schools had to be covered in the plan, dual attendance areas were banned, and African-American students had to be admitted to any schools that they were eligible for without regard to race. Armstrong v. Bd. of Educ. of Birmingham, 333 F.2d 47 (5th Cir. 1964); Davis v. Bd. of Sch. Comm'rs of Mobile Cty., 333 F.2d 53 (5th Cir. 1964); Stell v. Savannah-Chatham Cty. Bd. of Educ., 333 F.2d 55 (5th Cir. 1964). Because of the delays associated with appeals, the plaintiffs also filed a motion for injunctive relief pending appeal in June 1965 because they would not get the relief they sought before the 1965-1966 school year. The United States then intervened because it decided this case was of general public importance and would impact desegregation efforts throughout Mississippi and the region. The 5th Circuit held that the School District was required to submit a desegregation plan that would allow at least four grades to be integrated in the 1965-1966 school year in order for the U.S. Office of Education's target date of 1967 for full desegregation (and the ability to receive federal funding) to be possible in Jackson. The School District was instructed to create a plan in compliance with Title VI of the Civil Rights Act using the Office of Education's policies as a guide. 348 F.2d 729 (5th Cir. 1965).

Since the 1965 order granted only tentative relief, the 5th Circuit returned to the appeal the following year. The 5th Circuit evaluated whether the plan submitted by the School District after the 1965 order, which integrated grades 1, 2, 3, and 12 in 1965 and four grades in each succeeding year thereafter, was in compliance with U.S. Department of Health, Education, and Welfare (HEW) standards and the Jefferson decree, which held that school districts could no longer adopt freedom of choice plans because they did not produce unitary schools. United States v. Jefferson Cty. Bd. of Educ., 372 F.2d 836 (5th Cir. 1966). The United States objected to the School District's plan, but the 5th Circuit approved the plan because the plan met the HEW standards for desegregation. Additionally, the 5th Circuit held that it did not "require immediate total desegregation of all twelve grades" so long as complete desegregation was achieved by September 1967. 355 F.2d 865 (5th Cir. 1966).

The case returned to the 5th Circuit in 1969 and had been consolidated with a number of other school desegregation cases from across the 5th Circuit. The 5th Circuit held that all school districts were required to immediately begin operating as unitary systems in accordance with the Supreme Court's decision in Alexander v. Holmes County Board of Education, 396 U.S. 19 (1969), which held that schools were to be immediately unified and courts could no longer use the doctrine of deliberate speed in school desegregation cases. The 5th Circuit adopted a two-step approach to achieve complete desegregation: first, school faculties, staff, services, athletics, and other extracurricular activities were to be desegregated by February 1970; second, the student bodies were to be merged by fall 1970. The 5th Circuit adopted this approach because it recognized that it would be challenging to merge student bodies in the middle of the school year. 419 F.2d 1211 (5th Cir. 1969).

The Supreme Court granted certiorari and reversed the 5th Circuit's opinion in early 1970. The Court held that the 5th Circuit misconstrued its holding in Alexander and the case was remanded, with many other cases it had been consolidated with, back to the 5th Circuit. Carter v. West Feliciana Parish Sch. Bd., 396 U.S. 290 (1970) (per curiam). Accordingly, the 5th Circuit was not allowed to defer student body merging beyond February 1, 1970, but all other provisions of the 1969 5th Circuit decision remained in effect. 425 F.2d 1211 (5th Cir. 1970).

In an unavailable opinion, District Judge Dan M. Russell approved the School District's desegregation plan that was created in accordance with the Supreme Court's holding in Alexander . The plaintiffs appealed. The 5th Circuit held that the desegregation plan did not achieve a unitary system because 7 of 38 elementary schools within the School District had all black student bodies, 6 elementary schools had over 90 percent black student bodies, 6 elementary schools had all white student bodies, 2 elementary schools had over 90 percent white student bodies, and 4 secondary schools had mostly black student bodies. The 5th Circuit remanded the case to the district court to initiate proceedings to end the dual system by calling for new desegregation proposals from the parties, HEW, and a court-created biracial committee. The district court was also given jurisdiction to monitor the ongoing desegregation efforts. 426 F.2d 1364 (5th Cir. 1970).

The district court (again, in an unavailable opinion) adopted one of three HEW plans even though the judge knew that the plan would have to be modified in order to be fully workable. HEW submitted modifications for the junior and senior high schools that were approved by the 5th Circuit. The court expressed its continued monitoring of the situation in Jackson because demographic patterns were constantly shifting and the court was concerned that some schools would not remain integrated and, as a result, the School District would not have a permanent unitary status. 430 F.2d 368 (5th Cir. 1970) (per curiam).

The district court approved a modification plan to desegregate the School District's elementary schools and the plaintiffs then appealed. The elementary school modification, in contrast to the secondary school modification, was not approved by the 5th Circuit and was remanded to the district court. The 5th Circuit found that the elementary plan would not help the School District achieve unitary status because 70 percent of all black students would attend school in predominantly black schools. 432 F.2d 927 (5th Cir. 1970), cert. denied, 402 U.S. 944 (1971).

Later that year, the case returned to court. The Mississippi governor issued an executive order shortly after the 1971-1972 school year began that barred state officials from allocating educational funding to the School District until it was in full compliance with Mississippi school pupil transportation laws, which prohibited students from being bussed to school if they lived within a city's corporate limits. The School District lost approximately 40 percent of its operating budget due to the executive order. The School District added myriad state officials to the litigation after the executive order and, after an emergency hearing, the district court issued a temporary restraining order to allow the School District to receive its funding and to prohibit the state from interfering in its efforts to be in compliance with the court-approved desegregation order. The district court later granted a preliminary and permanent injunction barring the state officials from withholding any state funds due to the School District or from acting in any way that interfered or impeded with the desegregation plan. The School District proved to the district court that state funds were not used for intra-city bussing and, therefore, the court was not obligated to decide whether the Mississippi statute was constitutional. 332 F. Supp. 984 (S.D. Miss. 1971). In 1975, the state officials implicated in the 1971 district court decision appealed to the 5th Circuit. The 5th Circuit affirmed the district court's decision. 509 F.2d 818 (5th Cir. 1975).

The School District moved to dismiss the desegregation suit in 1981. The district court sustained this motion and held that the School District had successfully operated a unitary system for a decade and was in full compliance with all desegregation directives because the student body, faculty, staff, transportation, extracurricular activities, and facilities were fully integrated. 541 F. Supp. 904 (S.D. Miss. 1981).

We are unaware of any appeal, and it seems likely that the case ended there. However, in 2007, the U.S. Commission on Civil Rights published a report on unitary status findings, and in an appendix, reported this case as still open, with the note "District does not plan to seek unitary status." We are not sure of whether/how the case ended.

Available Opinions

Singleton v. Jackson Mun. Separate Sch. Dist., 348 F.2d 729 (5th Cir. 1965).

Singleton v. Jackson Mun. Separate Sch. Dist., 355 F.2d 865 (5th Cir. 1966).

Singleton v. Jackson Mun. Separate Sch. Dist., 404 F.2d 353 (5th Cir. 1968).

Singleton v. Jackson Mun. Separate Sch. Dist., 419 F.2d 1211 (5th Cir. 1969), cert. denied, 396 U.S. 1032 (1970).

Carter v. W. Feliciana Parish Sch. Bd., 396 U.S. 226 (1969) (per curiam).

Carter v. W. Feliciana Parish Sch. Bd., 396 U.S. 290 (1970) (per curiam).

Singleton v. Jackson Mun. Separate Sch. Dist., 425 F.2d 1211 (5th Cir. 1970) (per curiam).

Singleton v. Jackson Mun. Separate Sch. Dist., 426 F.2d 1364 (5th Cir. 1970).

Singleton v. Jackson Mun. Separate Sch. Dist., 430 F.2d 368 (5th Cir. 1970).

Singleton v. Jackson Mun. Separate Sch. Dist., 432 F.2d 927 (5th Cir. 1970) (per curiam), cert. denied, 402 U.S. 944 (1971).

Singleton v. Jackson Mun. Separate Sch. Dist., 332 F. Supp. 984 (S.D. Miss. 1971).

Singleton v. Jackson Mun. Separate Sch. Dist., 509 F.2d 818 (5th Cir. 1975).

Singleton v. Jackson Mun. Separate Sch. Dist., 541 F. Supp. 904 (S.D. Miss. 1981).

Summary Authors

Amelia Huckins (3/5/2017)

People


Judge(s)

Ainsworth, Robert Andrew Jr. (Louisiana)

Amaker, Norman C. (New York)

Bell, Griffin Boyette (Georgia)

Black, Hugo Lafayette (District of Columbia)

Brennan, William Joseph Jr. (District of Columbia)

Brown, John Robert (Louisiana)

Carswell, George Harrold (Florida)

Clark, Charles (Mississippi)

Coleman, James Plemon (Louisiana)

Collins, Robert Frederick (Louisiana)

Judge(s)

Ainsworth, Robert Andrew Jr. (Louisiana)

Amaker, Norman C. (New York)

Bell, Griffin Boyette (Georgia)

Black, Hugo Lafayette (District of Columbia)

Brennan, William Joseph Jr. (District of Columbia)

Brown, John Robert (Louisiana)

Carswell, George Harrold (Florida)

Clark, Charles (Mississippi)

Coleman, James Plemon (Louisiana)

Collins, Robert Frederick (Louisiana)

Douglas, William Orville (District of Columbia)

Dyer, David William (Georgia)

Gee, Thomas Gibbs (Louisiana)

Gewin, Walter Pettus (Alabama)

Godbold, John Cooper (Louisiana)

Goldberg, Irving Loeb (Louisiana)

Harlan, John Marshall (District of Columbia)

Hutcheson, Joseph Chappell Jr. (Texas)

Ingraham, Joe McDonald (Texas)

Marshall, Thurgood (District of Columbia)

Morgan, Lewis Render (Georgia)

Russell, Dan Monroe Jr. (Mississippi)

Simpson, John Milton Bryan (Florida)

Sobol, Richard B. (Louisiana)

Stewart, Potter (District of Columbia)

Thornberry, William Homer (Texas)

White, Byron Raymond (District of Columbia)

Wisdom, John Minor (Louisiana)

Zarr, Melvyn (New York)

Documents in the Clearinghouse

Document

Appeal from the United States District Court for the Southern District of Mississippi

U. S. Court of Appeals for the Fifth Circuit

348 F.2d 729

June 22, 1965 Order/Opinion

Appeal from the United States District Court for the Southern District of Mississippi

Singleton v. Jackson Municipal Separate School District

U. S. Court of Appeals for the Fifth Circuit

355 F.2d 865

Jan. 26, 1966 Order/Opinion

[Order]

U. S. Court of Appeals for the Fifth Circuit

419 F.2d 1211

Dec. 1, 1969 Order/Opinion

Order and Opinion

Carter v. West Feliciana Parish School Board

Supreme Court of the United States

396 S.Ct. 226

Dec. 13, 1969 Order/Opinion

[Order]

U. S. Court of Appeals for the Fifth Circuit

425 F.2d 1211

Jan. 21, 1970 Order/Opinion

[Order]

Carter v. West Feliciana Parish School Board

Supreme Court of the United States

396 U.S. 290

Jan. 29, 1970 Order/Opinion

[Order]

U. S. Court of Appeals for the Fifth Circuit

426 F.2d 1364

May 5, 1970 Order/Opinion

[Order]

U. S. Court of Appeals for the Fifth Circuit

430 F.2d 368

July 20, 1970 Order/Opinion

[Order]

U. S. Court of Appeals for the Fifth Circuit

432 F.2d 927

Aug. 12, 1970 Order/Opinion

[Order]

332 F.Supp. 984

Oct. 19, 1971 Order/Opinion

Resources

Title Description External URL

Docket

Last updated May 12, 2022, 8 p.m.

Docket sheet not available via the Clearinghouse.

State / Territory: Mississippi

Case Type(s):

School Desegregation

Special Collection(s):

Civil Rights Division Archival Collection

Key Dates

Filing Date: 1963

Closing Date: 1981

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Plaintiffs were black students and their families residing in Jackson, Mississippi.

Plaintiff Type(s):

Private Plaintiff

U.S. Dept of Justice plaintiff

Attorney Organizations:

U.S. Dept. of Justice Civil Rights Division

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Jackson Municipal Separate School District (Jackson, Hinds), School District

Defendant Type(s):

Elementary/Secondary School

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Equal Protection

Availably Documents:

Any published opinion

U.S. Supreme Court merits opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Preliminary injunction / Temp. restraining order

Source of Relief:

Litigation

Order Duration: 1965 - 1981

Content of Injunction:

Busing

Develop anti-discrimination policy

Discrimination Prohibition

Goals (e.g., for hiring, admissions)

Monitoring

Preliminary relief granted

Student assignment

Issues

General:

Buildings

Education

Language access/needs

Racial segregation

School/University Facilities

School/University policies

Transportation

Discrimination-basis:

Race discrimination

Race:

Black

Type of Facility:

Government-run