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Fred S. Calhoun v. A. C. Latimer

Citations: 12 L. Ed. 2d 288; 84 S. Ct. 1235; 377 U.S. 263; 1964 U.S. LEXIS 1211Docket: 623

Court: Supreme Court of the United States; May 25, 1964; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

This Supreme Court case involves a dispute over the adequacy of the Atlanta Board of Education's desegregation policies. The petitioners challenged the Board's new policy of allowing free transfers among high schools, arguing it failed to meet constitutional desegregation standards, especially concerning elementary schools, which they claimed would not be desegregated until the 1970s. Recognizing the complexity and evolving nature of desegregation efforts nearly a decade after Brown v. Board of Education, the Court underscored the need for rigorous judicial oversight of such plans. It vacated the previous judgment and remanded the case for an evidentiary hearing in the District Court. The Supreme Court mandated that the Atlanta plan be evaluated against established precedents, including Watson v. City of Memphis, Goss v. Board of Education, and Griffin v. County School Board, to ensure constitutional compliance. The case was sent back for further proceedings to scrutinize the Board's resolution and ensure adherence to desegregation mandates.

Legal Issues Addressed

Constitutional Standards for School Desegregation

Application: The Supreme Court examined whether the Atlanta Board of Education's new policies met constitutional standards for desegregation, especially concerning elementary schools.

Reasoning: The petitioners argued that the new policies did not meet constitutional standards for desegregation, particularly in elementary schools, which they claimed would not achieve desegregation until the 1970s.

Impact of Precedent on Desegregation Efforts

Application: The Court directed that the Atlanta plan be assessed against the standards set in prior landmark cases, ensuring that desegregation efforts align with evolving interpretations.

Reasoning: The entire Atlanta plan must be assessed against the standards set forth in prior cases, including Watson v. City of Memphis, Goss v. Board of Education, and Griffin v. County School Board.

Judicial Scrutiny of Local School Desegregation Plans

Application: The Court emphasized the necessity for ongoing judicial scrutiny of school desegregation plans to ensure compliance with constitutional requirements.

Reasoning: The ruling underscored the need for ongoing judicial scrutiny of local school desegregation plans to ensure compliance with constitutional requirements.

Vacating and Remanding for Further Proceedings

Application: The Supreme Court vacated the prior judgment and remanded the case to the District Court for an evidentiary hearing to evaluate the Board's resolution in light of established desegregation standards.

Reasoning: The Supreme Court found it necessary for the District Court to evaluate the Board's April 8, 1964, resolution through an evidentiary hearing. The Court vacated the previous judgment and remanded the case for further proceedings.