Case Data and Exhibits for Brown III, a relitigation of Brown v. Topeka Board of Education (1954) that corrected resegregation issues caused by open enrollment school choice in 1992. Document to the plaintiffs from the defense answering questions about predecessor districts. The defense says that it’s impossible to pinpoint any older districts.
A complete historical breakdown of the effect of administrative decisions on the racial makeup of Topeka schools. Includes full reports on every school in the district as well as analysis on decisions made by the school board and administrators.
Case Data and Exhibits for Brown III, a relitigation of Brown v. Topeka Board of Education (1954) that corrected resegregation issues caused by open enrollment school choice in 1992. This paper is a full summary of the case up to December 1986. Includes some handwritten notes from William Lamson.
Lead Defense Attorney K. Gary Sebelius writes to ACLU Attorney Chris Hansen to inform him of changes made to the pre-trial deposition schedule. William Lamson's name is handwritten on the top of page one and refers to his deposition dates of August 19-21, 1986, in Jackson, Mississippi.
ACLU Attorney Chris Hansen writes to plaintiff expert witnesses Dr. Gordon Foster, William Lamson, Hugh Spear, and Bob Crain to inform them that dates and witness lists did not change after his appearance before the judge in early December. Attached is an early draft of findings of facts that he has shared with the defense.
Handwritten letter from ACLU Attorney Chris Hansen to William Lamson asking Lamson if he has copies of the United States Department of Health, Education, and Welfare (HEW) race figures for 1981-1983 and 1985.
ACLU Attorney Chris Hansen sends William Lamson the order of activities for the case between December 1985 and March 1986. Also attached is the designation of fact witnesses by individually-named defendants associated with the State Board of Education.
ACLU Attorney Chris Hansen writes to the members of the Brown Counsel team to inquire about their thoughts on a possible settlement. Attached is the court document containing the order of activities for the case between May and September 1986.
ACLU Attorney Chris Hansen writes to Lead Defense Attorney K. Gary Sebelius to outline a possible settlement for the case since the court has again pushed the date of the trial back. Mr. Hansen lists the principles on which a settlement would have to be based, including community involvement in any plans for the district.
Lead Defense Attorney K. Gary Sebelius writes to ACLU Attorney Chris Hansen to provide a list of the 5 expert witnesses the defendants will call in the trial and also to request the names and subject matters for the plaintiffs' fact witnesses.
Lead Defense Attorney K. Gary Sebelius writes to ACLU Attorney Chris Hansen, stating that he might need more time to respond to certain interrogatories and that the scope of the discovery period might need to be narrowed.
ACLU Attorney Chris Hansen writes to Dr. Gordon Foster and William Lamson to inform them that he is unavailable for the requested meeting date of June 13th, 1985, but can meet on June 20th instead. Dr. Foster and Lamson were to meet with the plaintiff team about their roles as expert witnesses in the Brown III case.
Lead Defense Attorney K. Gary Sebelius writes to Attorney Richard E. Jones Mr. Sebelius seeking clarification on a number of interrogatories and responses submitted by the plaintiff team. Specifically, there are questions on the meanings of some terms (“full time,” for example) and questions about cumulative vs. individual teacher salaries.
Associate Dean of Washburn University School of Law (Topeka, Kansas) William Rich writes to William Lamson to send him the United States Department of Health, Education, and Welfare (HEW) housing data for Topeka and to inform him that Attorney Richard Jones has sent him more maps as well.
E. Richard Larson of the ACLU writes to William Rich of Washburn University School of Law (Topeka, Kansas), Attorney Richard Jones, and Deborah Jones to inform them that he will be in Topeka from October 25th through November 1st. Also, William Lamson will be coming to Topeka October 27th-29th and they intend to immerse themselves in the case.
E. Richard Larson of the ACLU writes to William Lamson to thank him for coming to Topeka to work on the case. He also summarizes some of the things they talked about while there and asks Lamson to send over a resume and some information on his expertise in the matters involved with the case.
E. Richard Larson of the ACLU writes to Dr. Kenneth Clark of Clark, Phipps, Clark, & Harris to outline what the plaintiff team is looking for with Dr. Clark’s expert testimony in the Brown III case. They hope for Dr. Clark to speak to the psychological and sociological effects of racial isolation on students in segregated schools.
E. Richard Larson of the ACLU writes to William Lamson to inform him of some files and maps he is sending him including school board documents and preliminary working maps Lamson prepared in the Fall of 1982. Larson notes that the maps of Topeka secondary school zones are missing from these files and will be sent back at a later date.
Elvia Rosales Arriola of the ACLU writes to Attorney Richard E. Jones to inform him that the ACLU is preparing a motion to compel discovery on questions a witness in the case refuses to answer. She also writes that her fellowship with the ACLU has come to end and will no longer be working on the case and knows the case is in good hands.
Elvia Rosales Arriola of the ACLU writes to William Lamson to inform him that her time working on the Brown III case has reached an end. She regrets that she won’t be able to see him testify in the case and hopes she can stay on at the ACLU part-time if the budget permits.
Letter from Elvia Rosales Arriola of the ACLU to William Lamson. Cover letter for a copy of the summary of the State of Topeka’s supplemental responses and a copy of the booklet "Accreditation Regulations Applicable to Kansas Elementary and Secondary Schools and School Districts."
ACLU Attorney Chris Hansen writes to William Lamson to express his gratitude for working on the case. Hansen thanks Lamson on behalf of the class of Black school children in Topeka and writes that he feels the team presented a strong case that Topeka schools have never been fully desegregated and he expects a ruling sometime in early 1985.
ACLU Attorney Chris Hansen Chris Hansen writes to Elvia Rosales Arriola of the ACLU, William Lamson, Attorney Richard Jones, and Attorney William Rich to send an update on the round of depositions he completed. He also attached superintendent's and principal's annual reports for each school that he obtained on his recent trip to Topeka.
ACLU Attorney Chris Hansen writes to Robert Longman of Central Surveys Inc. to confirm a pre-test survey. Mr. Hansen gives background on the case and talks more specifically about the two questions he wants answered in the survey about Topeka residents' perception of whether schools are white or Black and if some schools are less adequate.
Handwritten letter from ACLU Attorney Chris Hansen asking William Lamson about updates for a report about boundary changes for junior high schools in Topeka dating back to 1941 when the state supreme court ordered the schools to be integrated.
