Jackson State University

Items

• Letter from ACLU Attorney Chris Hansen to Brown III Counsel, July 30, 1984.
  ACLU Attorney Chris Hansen writes to the members of the Brown III Counsel team to inform them that Lee Henson of the Federal Community Relations Service has offered their service in the case. Mr. Hansen is suspicious of this because of his opinion of the Justice Department under then-president Ronald Reagan.
• Letter from ACLU Attorney Chris Hansen to Elvia Rosales Arriola of the ACLU and William Lamson, June 19, 1984.
  ACLU Attorney Chris Hansen writes to Elvia Rosales Arriola of the ACLU and William Lamson to outline the discovery schedule for the Brown III case. The schedule runs from July 15, 1984 to January 15, 1985 and includes depositions, due dates for interrogatories, tours of sites, and pre-trial orders.
• Letter from Jennifer Hirsch of the ACLU (on behalf of Elvia Rosales Arriola) to William Lamson, June 6, 1984.
  Jennifer Hirsch of the ACLU (on behalf of Elvia Rosales Arriola) writes to William Lamson seeking descriptions for data he compiled for their response to Topeka School District’s first set of interrogatories. Some of the descriptions about data on optional attendance zones transfer plans are missing.
• Letter from ACLU Attorney Chris Hansen to William Lamson, September 4, 1984.
  ACLU Attorney Chris Hansen writes to William Lamson requesting a first draft of a report and to alert him that depositions are now scheduled for September 18-20, 1984. Hansen writes that Lamson should be present at this round of depositions and they will discuss the matter further.
• Letter from ACLU Attorney Chris Hansen to Lead Defense Attorney Gary K. Sebelius and Kansas Assistant Attorney General Dan Biles, May 3, 1984.
  This letter from ACLU Attorney Chris Hansen to lead defense Attorney Gary K. Sebelius and Kansas Assistant Attorney General Dan Biles confirms deposition dates for June 7, 8, and 11, 1984 with a completion date of June 12. Hansen notes that formal notice of deposition will be served and a court reporter will be in the depositions.
• Letter from Elvia Rosales Arriola of the ACLU to William Lamson, April 16, 1984.
  Elvia Rosales Arriola of the ACLU writes to William Lamson to update him on potential dates for depositions in May. She writes that lead defense attorney K. Gary Sebelius doesn’t want to hold depositions in May but the ACLU is trying to negotiate for an early May deposition date.
• Letter From Lisa Gross, Volunteer Intern for Elvia Rosales Arriola of the ACLU, to William Lamson, May 7, 1984.
  Lisa Gross, Volunteer Intern for Elvia Rosales of the ACLU, writes to William Lamson to inform him that she has enclosed data on the number and percent of Black, Hispanic, and minority students enrolled in the Topeka schools from 1954-55 to 1956-57 and 1966-67 to 1980-81.
• Letter from Elvia Rosales Arriola of the ACLU to William Lamson, May 22, 1984.
  Letter from Elvia Rosales Arriola of the ACLU to William Lamson. Arriola informs Lamson that attached to the letter is a list from the official map of Topeka, Kansas, showing annexations from January 1950 to September 1981. She also indicates that maps are available in the Topeka-Shawnee Metropolitan Planning Commission.
• Letter from Attorney Richard E. Jones to Attorney Jon C. Dubin of the ACLU, March 29, 1983.
  Attorney Richard E. Jones writes to Attorney Jon C. Dubin of the ACLU about his recent court appearance and the agreement that was made with the judge about proceeding with trial. The agreement was that depositions would be delayed until August of 1983 and the trial itself would probably commence in March of 1984.
• Letter from Attorney Jon C. Dubin of the ACLU to Brown III Co-Counsel, August 22, 1983.
  Attorney Jon C. Dubin of the ACLU writes to Brown III co-counsel attorneys to update them about pre-1951 discovery which had been previously ruled too burdensome for the defense to deliver, but a new ruling has made those documents available. Dubin includes a list summarizing the status of all requested documents.
• Letter from Elvia Rosales Arriola of the ACLU to William Lamson and ACLU Attorney Chris Hansen, June 1, 1984.
  Elvia Rosales Arriola writes to William Lamson and ACLU Attorney Chris Hansen about discrepancies found in student enrollment number reports from different charts. A chart summarizing the discrepancies is included.
• Letter from Steven R. Howe of the Southwest Ohio Regional Data Center at the University of Cincinnati to William Lamson, April 15, 1982.
  Steven R. Howe of the Southwest Ohio Regional Data Center at the University of Cincinnati writes to Willam Lamson to inform him that he has sent the place report for Hamilton County (Ohio) from the 1980 Census first summary file tape. Howe writes that they have census data available down to the block level for any area of Ohio, Kentucky or Indiana.
• Letter from Lead Defense Attorney K. Gary Sebelius to Attorney Richard E. Jones, June 30, 1989.
  The letter contains several questions for Attorney Richard E. Jones as well as copies of two reports: comparative report on percentage of minority student enrollment in Topeka Public Schools for the 1988-1989 school year and a minority staffing report by building for certificated (CT) and non-certificated (NC) staff of the school district.
• Letter from Attorney Richard E. Jones to ACLU Attorney Chris Hansen, July 5, 1989.
  Letter from Attorney Richard E. Jones to ACLU Attorney Chris Hansen concerning data that Lead Defense Attorney K. Gary Sebelius sent to him. Jones notes that he also forwarded the data to William Lamson to save time.
• Letter from Lead Defense Attorney K. Gary Sebelius to ACLU Attorney Chris Hansen, August 6, 1986.
  A cover letter from Lead Defense Attorney K. Gary Sebelius in response to ACLU Attorney Chris Hansen’s request for documents pertaining to the expert defense witness Dr. Herbert Walberg. Sebelius says he will send the documents before the deposition of Dr. Walberg even though they are marked “confidential and privileged.”
• A Letter from ACLU Attorney Chris Hansen to Lead Defense Attorney Gary K. Sebelius, Attorney Dan Biles, and Attorney Karen Nichols, May 21, 1985.
  ACLU Attorney Chris Hansen writes to the defendant lawyers to ask for identification of errors they find in reports from their expert witnesses before depositions to avoid spending too much time arguing over simple factual errors. He recommends that the trial focus on conclusions drawn from facts.
• Letter from Lead Defense Attorney K. Gary Sebelius to ACLU Attorney Chris Hansen, March 5, 1985.
  In this letter, Lead Defense Attorney K. Gary Sebelius responds to requests from ACLU Attorney Chris Hansen about several outstanding interrogatories of the fourth set and third request for documents. Sebelius offers explanations for some of the missing documents and also reports that some of the documents have already been delivered.
• Letter from Elvia Rosales Arriola of the ACLU to Dr. Gordon Foster, June 26, 1984.
  A cover letter for a student-intern written paper that Elvia Rosales Arriola of the ACLU believes will be helpful to Dr. Gordon Foster in the Brown III case. Chris Hansen of the ACLU and William Lamson are cc’d on the letter.
• A Letter to Chris Hansen of the ACLU from Bob Longman of Central Surveys Inc. of Shenandoah, Iowa, March 24, 1986.
  The letter includes a memo with Bob Longman of Central Surveys Inc.'s observations regarding R. Harrison Hickman’s critiques of the Topeka Survey about public schools. Hickman criticized the sampling method, the use of screening questions, and more. Longman calls his critiques “trivial and intended to attract attention away from the findings.”
• A Survey of Topeka Residents Regarding Public Schools Conducted by Central Surveys Inc. of Shenandoah, Iowa, August 27th to September 1st.
  Report on a telephone survey conducted with 400 Topekans selected randomly from the phone directory, conducted by Central Surveys Inc. of Shenandoah, Iowa. In general, the respondents believed the schools were performing well, but they also recognized patterns of segregation with the schools.
• William Lamson Handwritten Notes and Charts, Unknown Dates.
  Handwritten notes and charts by William Lamson. Included topics: elementary school boundary changes through the 1950's and 1960's; notes on the meaning of "demographic changes" in Topeka schools; yearly rank of school size by students; and an analysis of what these findings show. Some original, some photocopies of originals.
• Meeting Minutes From a Topeka Board of Education Meeting on June 21, 1965.
  Meeting minutes From a Topeka Board of Education meeting on June 21, 1965. Topics discussed include the adoption of the Topeka Plan; a report on the five year projection of building and site needs; a new site for Highland Park Junior High School; and an experimental remote teaching project.
• Meeting Minutes From a Topeka Board of Education Meeting on September 8, 1964.
  Meeting minutes From a Topeka Board of Education meeting on September 8, 1964. Topics discussed include the naming of a new school; a report on the five year projection of building and site needs; an enrollment report; and purchases.
• A letter from the Director of the Office of Civil Rights in the United States Department of Health, Education, and Welfare (name redacted) to U.S. District Court Judge (name redacted), September 9, 1976.
  The Director of the Office for Civil Rights in the United States Department of Health, Education, and Welfare (name redacted) writes to U.S. District Court Judge (name redacted) about their concern that the desegregation efforts made by the Topeka School System are not acceptable under the requirements of Title VI in the Civil Rights Act of 1964.
• Arguments Offered in Brown Trial, Newspaper Article.
  A newspaper article from The Topeka Capital Journal about opening arguments in the Topeka desegregation case. The opening day also saw the opening of testimony by expert witness for the plaintiffs William Lamson who used maps and charts to argue that the Topka School System continues to remain segregated.