“Segregation academy”的意思、由来-开放百科全书

While some of these schools still exist — most with low percentages of minority students even today — they are not, legally speaking, segregation academies. The laws that permitted their operation, including government subsidies and tax exemption, were invalidated by U.S. Supreme Court decisions. After Runyon v. McCrary (1976), all of these private schools were forced to accept African-American students. As a result, segregation academies changed their admission policies, ceased operations, or merged with other private schools.

History

The first segregation academies were created by white parents in the late 1950s in response to the U.S. Supreme Court ruling in Brown v. Board of Education (1954), which required public school boards to eliminate segregation "with all deliberate speed" (Brown II). Because the ruling did not apply to private schools, founding new academies provided parents a way to continue to educate their children separately from blacks. At that time, most adult blacks were still disfranchised in the South, excluded from politics and oppressed under Jim Crow laws.^[5]^[6] Private academies operated outside the scope of the Brown v. Board of Education ruling and could therefore have racial segregation.^[7] Virginia's massive resistance to integration resulted in Prince Edward County, Virginia closing all public schools from 1959 to 1964; the only education in the county was a segregation academy, funded by state "tuition grants."

A 1972 report on school desegregation noted that segregation academies could usually be identified by the word "christian" or "church" in the school's name.^[8] The report observed that while individual protestant churches were often deeply involved in the establishment of segregation academies, Catholic dioceses usually indicated that their schools were not meant to be havens from desegregation.^[8] Many segregation academies claimed they were established to provide a "Christian education" but the sociologist Jennifer Dyer has argued that such claims were simply a "guise" for the schools' actual objective of allowing parents to avoid enrolling their children in racially integrated public schools.^[8]

Reasons why whites pulled their children out of public schools have been debated: whites insisted that "quality fueled their exodus", and blacks said "white parents refused to allow their children to be schooled alongside blacks".^[9] Scholars estimate that, across the nation, at least half a million white students were withdrawn from public schools between 1964 and 1975 to avoid mandatory desegregation.^[5] In the 21st century, Archie Douglas, the headmaster of Montgomery Academy (founded as a segregation academy), said that he is sure "that those who resented the Civil Rights Movement or sought to get away from it took refuge in the academy".^[10] But in the 21st century, the school no longer practiced any type of discrimination.

IRS involvement and definitions

In 1969, parents of Mississippi black children brought suit to revoke tax-exemption status for non-profit segregation academies (Green v. Connally). They won a temporary injunction in the D.C. Circuit in early 1970 and the suit in June 1971. The United States government appealed to the Supreme Court, where the lower court's decision was summarily affirmed in Coit v. Green (1971). Meanwhile, on July 10, 1970, the Internal Revenue Service announced it could "no longer legally justify allowing tax-exempt status to private schools which practice racial discrimination."^[11] For a school to get or keep its tax-exempt status, it would have to publish a policy of non-discrimination and not practice overt discrimination. Many schools simply refused. A decade later, similarly aggrieved appellees argued again in Allen v. Wright (1983) that the standards were too low. The appellees had asserted that "there are more than 3,500 racially segregated private academies operating in the country having a total enrollment of more than 750,000 children."^[12] The court considered whether the parents standing to sue, and concluded not, because they did not allege that they or their children had applied to, been discouraged from applying to, or been denied admission to any private school or schools.^[13] Specifically, it ruled that citizens do not have standing to sue a federal government agency based on the influence that the agency's determinations might have on third parties (such as private schools). The judges noted the parents were in the posture of disappointed observers of the governmental process. The IRS would continue to enforce the regulations it had promulgated in 1970. Any school that was not tax-exempt in this period was likely a segregation academy, the standard for non-discrimination being low.^[14] Not many of the 3,500 appear in lists, if there were 3,500. After 1983, any school named in a judgement or IRS document in this period absolutely was.^[15] Many schools did not regain tax-exempt status until the 1990s.

By state

Virginia was an early adopter of techniques to establish and finance segregation academies. Virginia was first to respond to Brown with the establishment of segregation academies and first to be told in federal court that segregation academies were unconstitutional (Runyon v. McCrary (1976)), leading to their decline. The state was a bellwether for other states. Eventually, five states—Alabama, Georgia, Mississippi, South Carolina and Virginia—defied the court's decision in Brown by 1970.^[16] Segregated private schools lost their tax-exempt status in Coit v. Green (1971). Between 1961 and 1971, non-Catholic Christian schools doubled their enrollments nationally.^[20] By 1969, 300,000 of 7,400,000 white students attended segregated school in eleven southern states.^[17]

Virginia

In Virginia, segregation academies were part of a policy of massive resistance declared by U.S. Senator Harry F. Byrd, Sr. He worked to unite other white Virginia politicians and leaders in taking action to prevent school desegregation after the Brown v. Board of Education Supreme Court ruling in 1954.

In its September/October 1956 special session, the Virginia General Assembly passed a series of laws known as the Stanley plan to implement massive resistance. In January, Virginia's voters had approved an amendment to the state constitution to allow tuition grants to parents enrolling their children in private schools. Part of the Stanley plan established tuition grants program, which allowed parents who refused to allow their children to attend desegregated schools funding so each could attend a private school of choice. In practice, this meant state support of newly established all-white private schools which became known as "segregation academies".

On February 18, 1958, the General Assembly passed (and Governor Almond signed) additional legislation protecting segregation, what the Byrd Organization called the "Little Rock Bill" (responding to President Eisenhower's use of federal powers to assist the court-ordered desegregation of schools in Little Rock, Arkansas).^[18] Since new segregation academy facilities often failed to meet construction, health and safety standards for public schools, these were also loosened.

Segregation academies opened in various Virginia cities and counties subject to desegregation lawsuits, including Arlington, Charlottesville and Norfolk where Governor Almond had ordered the schools closed rather than comply with Federal court orders to desegregate.^[19] Arlington and Norfolk desegregated peacefully in February 1959. In Arlington, many (if not most) white students remained in the desegregated schools. However, that was not the case in Norfolk and other areas such as Richmond where whites largely abandoned the public schools for segregation academies and other private schools, home schooling, or moved to the suburbs. Today, more than a half-century after school desegregation, largely due to white flight, the Richmond City and Norfolk Public Schools are the school divisions with the most racially and economically isolated schools in Virginia.^[20]

Segregation academies in Warren and Prince Edward Counties and the City of Norfolk are discussed below, as examples of why even in the fall of 1963, only 3,700 black pupils or 1.6% attended school with whites. NAACP litigation had resulted in some desegregation by the fall of 1960 in eleven localities, and the number of at least partially desegregated districts had slowly risen to 20 in the fall of 1961, 29 in the fall of 1962, and 55 (out of 130 school districts) in 1963.^[21]

Warren County also planned to integrate its only high school, Warren County High School, but Governor Almond closed the school (along with schools in Charlottesville and Norfolk) in the fall of 1958. Education continued in private and church facilities for that school year. By the fall of 1959, John S. Mosby Academy (1-12) was constructed and opened as an all-white school. A public high school for black students was built and opened (Criser High School), and Warren County High School reopened with a significantly reduced white student population and 22 black students. Criser operated until 1966, and Mosby operated through the 1968–69 school year.

When faced with an order to integrate, Prince Edward County closed its entire school system in September 1959, and kept county schools closed until 1964, as it kept litigating (although Davis v. County School Board of Prince Edward County had been a companion case to Brown). The newly-founded private Prince Edward Academy operated as the de facto school system for white students. It enrolled K-12 students at several facilities throughout the county. Many black students were forced to move in with relatives in other counties, attend makeshift schools in church basements, or move to northern states to live with host families through a program of the Society of Friends in order to gain education. Even after public schools re-opened, Prince Edward Academy remained segregated as discussed below.

In Norfolk, churches and other organizations offered classes, teachers from the shuttered public schools formed tutorial groups, and classes were also held in private homes. The Norfolk Division of the College of William & Mary (now Old Dominion University) provided classes for some high school students. Other students from Norfolk attended schools in the neighboring cities of Hampton Chesapeake, Virginia Beach and Portsmouth. Some parents sent their children to live with relatives in other parts of Virginia or in other states. The Defenders of State Sovereignty and Individual Liberties founded the Tidewater Educational Foundation to create a private school for white students in Norfolk. The Tidewater Academy opened as a segregation academy on October 22, 1958, with 250 white students with classes meeting in local churches.{{Citation needed|date=November 2017}}

Although on January 19, 1959, the Virginia Supreme Court of Appeals struck down the new Virginia law that closed schools before integration, as contrary to a public schooling provision in the state constitution (and a three-judge federal panel struck down other provisions of the Stanley plan on the same day, (the Virginia state holiday honoring Robert E. Lee and Stonewall Jackson),^[22] individual state tuition grants to parents continued, allowing them to patronize segregation academies.

In 1964, the Supreme Court of the United States ruled in Griffin v. County School Board of Prince Edward County that Virginia's tuition grants where the public schools had been closed for reasons of race (such as in Prince Edward County) violated the U.S. Constitution.^[23] This decision finally effectively ended massive resistance within state governments, and dealt some segregation academies a fatal blow. Later rulings put the academies' tax exemption status in jeopardy if they practiced racial discrimination.^[28]

In 1978, Prince Edward Academy lost its tax exempt status. In 1986, it changed its admission policy to allow black students to attend but few black students can afford the tuition to attend the school, which today is known as the Fuqua School. All other Virginia segregation academies have either closed or adopted non-racial discrimination policies. Ironically, because the Catholic Church had desegregated its schools before Brown, the Huguenot Academy (a segregation academy implicitly disavowing that Catholic policy by its title), merged with Blessed Sacrament High School, a nearby Catholic High School, to become Blessed Sacrament-Huguenot.

In 1985 the Bollingbrook School, originally founded as a segregation academy for white students in 1958, merged with Gibbons High School, a nearby Catholic High School in Petersburg, to become St. Vincent de Paul High School.^[24]

Mississippi

In Mississippi, many of the segregation academies were first established in the black-majority Mississippi Delta region in northwestern Mississippi. The Delta has historically had a very large majority-black population, related to the history of the use of slave labor on cotton plantations. The potential for integration resulted in white parents' establishing segregation academies in every county in the Delta. Many academies are still operating, from Indianola, Mississippi to Humphreys County. These schools began to accept black students late in the 20th century, although many of them still enroll relatively small numbers of black students. In a region with low incomes among blacks, many African-American parents cannot afford the private schools. At least one school in Mississippi, Carroll Academy, receives substantial funding from the segregationist Council of Conservative Citizens.^[25]^[26] The governor of Mississippi Ross Barnett, said in September 1962, "I submit to you tonight, no school will be integrated in Mississippi while I am your governor".^[27]

Arkansas

Between 1966 and 1972, at least 32 segregation academies were established in Arkansas.^[33] By 1972, about 5,000 white students attended such schools.^[33]

Arkansas is one of twelve states that have not adopted the Blaine Amendment to their state constitutions. The amendment forbids direct government aid to educational institutions that have a religious affiliation. Many segregation academies have since adopted curricula with a "Christian world view".{{citation needed|date=March 2019}}

Louisiana

The United States District Court for the Eastern District of Louisiana mandated integration of public schools in Washington Parish (1969), St. Tammany Parish (1969), Tensas Parish (1970), Claiborne Parish (1970), and Jackson Parish (1969).^[28]

Alabama

Alabama, like Mississippi, largely ignored the 1954 ruling of Brown v. Board of Education. In 1958, a conflict over segregation in city parks brought Martin Luther King to Montgomery. The city closed its parks; King recommended that black parents attempt to enroll their children in city schools, expecting to establish cases testing the Alabama Pupil Placement Act. Montgomery Academy was the first segregation academy established in Alabama; others followed in the late 1960s.

South Carolina

In South Carolina, where private schools have existed since the 1800s, there were no fully racially integrated private schools before 1954. Some 200 private schools were created between 1963 and 1975; private school enrollment hit a peak of 50,000 in 1978.^[29] In Clarendon County, for example, the private academy Clarendon Hall was established in late 1965, after four black students enrolled in a previously all-white public school in the fall term. By 1969, only 281 white students were left in the public school system, and only 16 white students were in public schools when they officially desegregated a year later.^[30]

Texas

Texas was an early opponent of desegregation. In 1956, blacks were turned away from Mansfield High School in defiance of Brown and other federal orders to integrate. In Dallas, for example, the DISD subdivided itself into six subdistricts, each of which was "one race" (more than ninety percent white or black).^[31] The Texas Education Agency was ordered in November 1970 to desegregate Texas public schools (United States v. Texas).^[32] The state did not offer any financial assistance to private schools as Virginia, Mississippi, and Alabama had.

List of schools founded as segregation academies

1. ^¹²Moye, J. Todd. Let the People Decide: Black Freedom and White Resistance Movements in Sunflower County, Mississippi, 1945-1986. UNC Press Books, 2004. [https://books.google.com/books?id=KZ4IoG1nQuUC&pg=PA243 p. 243]. Retrieved from Google Books on March 2, 2011. "Sunflower County's two other segregation academies— North Sunflower Academy, between Drew and Ruleville, and Central Delta Academy in Inverness— both sprouted in a similar fashion." {{ISBN|0-8078-5561-8}}, {{ISBN|978-0-8078-5561-4}}.
2. ^{{cite book|url=https://books.google.com/?id=pZTV92FCRXQC&pg=PA13&lpg=PA13&dq=%22Mosby+Academy%22+front+royal+va#v=onepage&q=%22Mosby%20Academy%22%20front%20royal%20va&f=false|title=They're with you win or tie|last1=Carl|first1=Harold|date=2011|isbn=978-1-4670-3727-3|page=13|accessdate=30 August 2017}}
3. ^{{Cite web|url=http://www.southerneducation.org/Our-Strategies/Research-and-Publications/Race-Ethnicity-Landing-Pages/A-History-of-Private-Schools-Race-in-the-American.aspx|title=A History of Private Schools & Race in the American South|last=|first=|date=|website=Southern Education Foundation|access-date=2017-08-22}}
4. ^¹{{Cite news|url=https://www.corpun.com/ussc7512.htm|title=Segregated Academies|last=White|first=Jack|date=December 15, 1975|work=Time|access-date=August 23, 2017}}
5. ^¹{{cite book|title=Market Education: The Unknown History|first= Andrew J. |last=Coulson|publisher= Transaction Publishers|year= 1999| page =275|isbn=0-7658-0496-4}}
6. ^{{cite book|title=Educational Freedom in Urban America: Brown V. Board After Half a Century|editor= David Salisbury|publisher= CATO Institute|year= 2004| page= 32|isbn=1-930865-56-2}}
7. ^{{cite news|last=Younge|first=Gary|date=2004-11-30|url=https://www.theguardian.com/usa/story/0,12271,1362581,00.html|title=Alabama clings to segregationist past|publisher=The Guardian|accessdate=2006-05-02 | location=London }}
8. ^¹²{{Cite thesis|url=http://etd.library.vanderbilt.edu/available/etd-03142007-161353/|title=The Core Beliefs of Southern Evangelicals: A Psycho-Social Investigation of the Evangelical Megachurch Phenomenon|last=Dyer|first=Jennifer Eaton|date=2007-04-12|website=etd.library.vanderbilt.edu|type=PhD|page=23|access-date=2018-01-02|publisher=Vanderbilt University}}
9. ^{{cite web|last=Crowder|first=Carla|date=2002-10-27|url=http://www.al.com/specialreport/birminghamnews/index.ssf?blackbelt/blackbelt16.html|title=Private white academies struggle in changing world|publisher=The Birmingham News|accessdate=2006-05-02|deadurl=yes|archiveurl=https://web.archive.org/web/20121115072320/http://www.al.com/specialreport/birminghamnews/index.ssf?blackbelt%2Fblackbelt16.html|archivedate=2012-11-15|df=}}
10. ^{{cite news|first=Regan Loyola|last=Connolly|title=Private schools diversify|publisher=The Montgomery Advertiser|page=1|date=2004-01-12}} Archie Douglas, the headmaster of The Montgomery Academy, said that the school was started in 1959 in what he believed was a reaction to desegregation of public schools. He said, "I am sure that those who resented the civil rights movement or sought to get away from it took refuge in the academy. But, it's not 1959 anymore and The Montgomery Academy has a philosophy today that reflects the openness ... and utter lack of discrimination with regard to race or religion that was evident in prior decades."
11. ^{{cite news|last1=Hall|first1=Isabelle|title=IRS sets the rules|url=https://www.newspapers.com/newspage/39193867/|accessdate=8 January 2018|publisher=Pittsburgh Courier|date=July 18, 1970}}
12. ^{{cite web|title=Wright v. Miller, 480 F. Supp. 790 (D.D.C. 1979)|url=https://law.justia.com/cases/federal/district-courts/FSupp/480/790/1531559/|publisher=U.S. District Court for the District of Columbia|accessdate=8 January 2018|date=November 26, 1979}}
13. ^{{cite web|year=1983|url=http://www.usdoj.gov/osg/briefs/1983/sg830167.txt|title=No. 81-757, No. 81-970|publisher=Office of the solicitor general, United States department of justice|accessdate=2006-05-02|deadurl=yes|archiveurl=https://web.archive.org/web/20050523021011/http://www.usdoj.gov/osg/briefs/1983/sg830167.txt|archivedate=2005-05-23|df=}} Text of the Allen v. Wright ruling, Supreme Court of the United States.
14. ^{{cite news |title=IRS vs. 'segregation academies' |url=https://www.csmonitor.com/1980/0527/052708.html |accessdate=30 November 2018 |publisher=Christian Science Monitor |date=May 27, 1980}}
15. ^{{cite journal |last1=Johnson |first1=Olati |title=The Story of Bob Jones University v. United States: Race, Religion, and Congress' Extraordinary Acquiescence |journal=Columbia Public Law & Legal Theory Working Papers |date=Feb 11, 2010 |page=25 |url=https://lsr.nellco.org/cgi/viewcontent.cgi?article=1076&context=columbia_pllt |accessdate=30 November 2018}}
16. ^{{cite news|last1=Evans|first1=Martin C.|title=Despite landmark ruling, schools still segregated.|url=https://people.hofstra.edu/alan_j_singer/202%20ISI%20Course%20pack/BX.ND.%20Brown.pdf|accessdate=6 December 2017|publisher=Newsday|date=May 16, 2004}}
17. ^{{cite news|title=Private Schools: The Last Refuge|url=http://content.time.com/time/magazine/article/0,9171,840365,00.html|accessdate=6 December 2017|publisher=Time|date=November 14, 1969}}
18. ^http://www.encyclopediavirginia.org/media_player?mets_filename=evm00001088mets.xml
19. ^Brian J. Daugherity, Keep on Keeping on (University of Virginia Press, August 2016), early draft available at http://scholarscompass.vcu.edu/cgi/viewcontent.cgi?article=1006&context=hist_pubs
20. ^http://www.thecommonwealthinstitute.org/2016/11/04/increasingly-separate-and-unequal-in-u-s-and-virginia-schools,
21. ^Brian Daugherity, Keep On Keeping On (University of Virginia Press, 2016) at p. 99
22. ^{{cite web|year=2004|url=http://www.vahistorical.org/civilrights/massiveresistance.htm|title=Massive Resistance|work=The Civil Rights Movement in Virginia|publisher=Virginia Historical Society}}
23. ^{{cite web|year=2004|url=http://www.vahistorical.org/civilrights/pec.htm|title= Closing Prince Edward County's Schools|work=The Civil Rights Movement in Virginia|publisher=Virginia Historical Society}}
24. ^{{cite journal|last1=Tobias|first1=Carl|title=PUBLIC SCHOOL DESEGREGATION IN VIRGINIA DURING THE POST-BROWN DECADE|journal=WILLIAM AND MARY LAW REVIEW|date=1996|volume=37|issue=4|page=1288|url=http://scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1732&context=wmlr}}
25. ^{{Cite news|url=https://www.nytimes.com/1999/01/14/us/lott-and-shadow-of-a-pro-white-group.html|title=Lott, and Shadow of a Pro-White Group|last=Kifner|first=John|date=1999|work=The New York Times|access-date=2018-01-04|language=en-US|issn=0362-4331}}
26. ^{{Cite news|url=https://www.splcenter.org/hatewatch/2010/10/28/white-supremacist-group-backs-private-academies-mississippi|title=White Supremacist Group Backs Private Academies in Mississippi|work=Southern Poverty Law Center|access-date=2018-01-04|language=en}}
27. ^{{cite news|last1=Ellis|first1=Kate|title=The Riot at Ole' Miss|url=http://americanradioworks.publicradio.org/features/mississippi/f1.html|accessdate=7 January 2018|publisher=American Public Media}}
28. ^{{cite web|title=Brumfield v. Dodd, 405 F. Supp. 338 (E.D. La. 1975)|url=https://www.courtlistener.com/opinion/1432702/brumfield-v-dodd/|publisher=E. D. La.|accessdate=1 September 2017|date=Dec 2, 1975}}
29. ^{{cite book|last1=Edgar|first1=Walter B.|title=South Carolina in the modern age|date=1992|publisher=University of South Carolina Press|isbn=9780872498310|page=129|url=https://books.google.com/books/about/South_Carolina_in_the_modern_age.html?id=RT0TAAAAYAAJ|accessdate=6 December 2017}}
30. ^Burton, Vernon and Lewie Reece. "The Palmetto Revolution: School Desegregation in South Carolina." In With all Deliberate Speed; Implementing Brown v. Board of Education, ed. Brian J. Daugherity and Charles C. Bolton, 59-91. Fayetteville, Ark.: The University of Arkansas Press, 2008.
31. ^{{cite news|title=Tasby v. Estes, 572 F. 2d 1010|url=https://scholar.google.com/scholar_case?case=9809318487278384136&hl=en&as_sdt=6&as_vis=1&oi=scholarr|accessdate=9 January 2018|publisher=Court of Appeals, 5th Circuit|date=April 21, 1978}}
32. ^{{cite news|last1=Kemerer|first1=Frank R.|title=UNITED STATES V. TEXAS|url=https://tshaonline.org/handbook/online/articles/jru02|accessdate=9 January 2018|publisher=Texas State Historical Association}}
33. ^¹{{Cite book|url=https://books.google.com/books?id=hkUQAQAAMAAJ|title=Judge Frank M. Johnson, Jr: a biography|last=Kennedy|first=Robert Francis|date=June 1978|publisher=Putnam|language=en}}
34. ^McDonald, Anna Catherine, Southern Normal?: An Exploration of Integration in a Deep South Town: Brewton, Alabama, 1954-1971.
35. ^{{cite news|last1=Cook|first1=Jim|title=Houston Academy has changed since Hillary Clinton's 1972 visit|url=http://www.dothaneagle.com/news/education/houston-academy-has-changed-since-hillary-clinton-s-visit/article_77a50aa4-5443-11e6-8344-8f90b519f7d2.html|accessdate=22 November 2016|date=27 July 2016}}
36. ^{{cite news|last1=Holthouse|first1=David|title=Activists Confront Hate in Selma, Ala.|url=https://www.splcenter.org/fighting-hate/intelligence-report/2008/activists-confront-hate-selma-ala|newspaper=Intelligence Report|access-date=January 25, 2018|date=Winter 2008}}
37. ^{{cite news|title=Private white academies struggle in changing world |publisher=Birmingham News |author=Carla Crowder |date=October 27, 2002 |url=http://www.al.com/specialreport/birminghamnews/index.ssf?blackbelt/blackbelt16.html |accessdate=January 6, 2013 |deadurl=yes |archiveurl=https://web.archive.org/web/20121115072320/http://www.al.com/specialreport/birminghamnews/index.ssf?blackbelt%2Fblackbelt16.html |archivedate=November 15, 2012 }}
38. ^{{Cite web|url=https://blackthen.com/september-10-1963-state-funds-private-school-for-whites-to-avoid-integration-in-tuskegee-alabama-video/|title=SEPTEMBER 10, 1963: STATE FUNDS PRIVATE SCHOOL FOR WHITES TO AVOID INTEGRATION IN TUSKEGEE, ALABAMA [VIDEO]|last=|first=|date=August 13, 2017|website=Black Then|access-date=}}
39. ^{{cite journal|first1=Jerome C. |last1=Hafter |first2=Peter M. |last2=Hoffman|title=Segregation Academies and State Action|journal=The Yale Law Journal|volume=82|number=7|date=June 1973|jstor=795573|pages=1436–1461}}
40. ^{{cite web|title=Segregation Academies: Past, Still Present|url=http://www.southerneddesk.org/?p=8191|accessdate=14 November 2017}}
41. ^{{cite news | url=http://www.al.com/specialreport/birminghamnews/index.ssf?blackbelt/blackbelt16.html | title=Private white academies struggle in changing world | newspaper=The Birmingham News | date=27 October 2002 | author=Carla Crowder | deadurl=yes | archiveurl=https://web.archive.org/web/20121115072320/http://www.al.com/specialreport/birminghamnews/index.ssf?blackbelt%2Fblackbelt16.html | archivedate=15 November 2012 | df= }}
42. ^{{Cite web|url=http://www.cacmustangs.org/about/history-and-mission/|title=Our History and Mission {{!}} Central Arkansas Christian Schools|website=Central Arkansas Christian Schools|language=en|access-date=2017-11-14}}
43. ^{{cite web|title=Private Schools|url=https://www.edweek.org/ew/articles/1988/08/03/x40pris.h07.html|date=3 August 1988|accessdate=20 November 2017}}
44. ^{{cite web|title=Private Schools|url=https://www.edweek.org/ew/articles/1988/08/03/x40pris.h07.html|date=3 August 1988|accessdate=20 November 2017}}
45. ^¹²³⁴⁵⁶⁷⁸{{Cite web|url=http://www.encyclopediaofarkansas.net/encyclopedia/entry-detail.aspx?entryID=9384|title=Private School Movement - Encyclopedia of Arkansas|website=www.encyclopediaofarkansas.net|access-date=2017-11-13}}
46. ^{{cite news|last1=Clary|first1=Mike|title=School's racial divides blur on football field|url=http://articles.sun-sentinel.com/2006-12-19/news/0612190117_1_high-schools-three-schools-school-enrollment|accessdate=12 August 2015|agency=Florida Sun-Sentinel|date=December 29, 2006}}
47. ^¹Glenda Alice Rabby, The Pain and the Promise: The Struggle for Civil Rights in Tallahassee, Florida, Athens, Ga., University of Georgia Press, 1999, {{ISBN|082032051X}}, p. 255.
48. ^{{cite book|last1=Select Committee on Equal Educational Opportunity|first1=United States. Congress. Senate.|title=Equal Educational Opportunity: Hearings Before the Select Committee on Equal Educational Opportunity, Ninety-first Congress, Second Session-92nd Congress, First Session, Volume 10|date=1970|publisher=U.S. Government Printing Office|page=2018,2120|url=https://babel.hathitrust.org/cgi/pt?id=umn.31951d017860197;view=1up;seq=110|accessdate=14 January 2018}}
49. ^Valdosta Daily Times, Consolidation: A history of two systems, November 15, 2009
50. ^¹{{Cite news|url=https://www.nytimes.com/1979/05/09/archives/south-leads-the-country-in-school-desegregation-some-dramatic.html|title=South Leads the Country In School Desegregation|last=King|first=Wayne|date=1979-05-09|work=The New York Times|access-date=2017-11-13|language=en-US|issn=0362-4331}}
51. ^{{cite web|title=Brumfield v. Dodd, 405 F. Supp. 338 (E.D. La. 1975)|url=https://www.courtlistener.com/opinion/1432702/brumfield-v-dodd/|publisher=E. D. La.|accessdate=1 September 2017|date=Dec 2, 1975}}
52. ^{{cite book|author=Jim Carl|title=Freedom of Choice: Vouchers in American Education: Vouchers in American Education|url=https://books.google.com/books?id=UksSVHL0tx8C&pg=PA54|accessdate=7 September 2012|date=13 September 2011|publisher=ABC-CLIO|isbn=978-0-313-39328-0|pages=54–6}}
53. ^{{Cite book|url=https://books.google.com/books?id=UmjEhn-Hop0C&pg=PA124&lpg=PA124|title=If I Could Turn My Tongue Like That: The Creole Language of Pointe Coupee Parish, Louisiana|last=Klingler|first=Thomas|date=2003-08-01|publisher=LSU Press|isbn=9780807127797|language=en|page=124}}
54. ^¹²³⁴Brumfield v. Dodd, [https://law.justia.com/cases/federal/district-courts/FSupp/425/528/1513242/ 425 F. Supp. 528 (E.D. La. 1977)]
55. ^{{Cite book|url=http://hdl.handle.net/2027/uc1.31210024924332|title=Tax-exempt status of private schools: hearing before the Subcommittee on Oversight of the Committee on Ways and Means, House of Representatives, Ninety-ninth Congress, first session| date=November 1, 1985}}
56. ^¹²³⁴{{cite book|last1=Fabre Jr|first1=Alvin Joseph|title=Changes in the Pointe Coupee Parish School System During the Years of School Desegregation 1965-1972.|date=May 1975|publisher=Louisiana State University|url=http://digitalcommons.lsu.edu/cgi/viewcontent.cgi?article=3784&context=gradschool_disstheses|accessdate=13 November 2017}}
57. ^{{Cite news|url=https://www.washingtonpost.com/archive/politics/1983/04/21/a-legacy-of-legal-segregation-returns-to-haunt-a-small-town/10d24d47-e19b-42d4-b8c1-4d4a5540e325/|title=A Legacy of Legal Segregation Returns to Haunt a Small Town|last=Thornton|first=Mary|date=1983-04-21|work=Washington Post|access-date=2017-11-04|language=en-US|issn=0190-8286}}
58. ^¹{{cite web|url=https://www.theatlantic.com/national/archive/2012/12/in-southern-towns-segregation-academies-are-still-going-strong/266207/|title=In Southern Towns, 'Segregation Academies' Are Still Going Strong|last=Carr|first=Sarah|date=December 13, 2012|website=The Atlantic|publisher=|access-date=}}
59. ^{{Cite news|url=http://www.jacksonfreepress.com/news/2018/nov/23/hyde-smith-attended-all-white-seg-academy-avoid-in/|title=Hyde-Smith Attended All-White 'Seg Academy' to Avoid Integration|last1=Pittman |first1=Ashton |quote=There's "no doubt that's why those schools were set up," said former U.S. Rep Ronnie Shows, a Democrat who was Hyde's junior high basketball coach at Lawrence County Academy in the 1970s. |access-date=2018-11-24|language=en}}
60. ^{{cite news |last1=Campbell |first1=Donna |title=Governor to speak at BA graduation |url=https://www.dailyleader.com/2017/05/09/governor-to-speak-at-ba-graduation/ |accessdate=24 November 2018 |publisher=The Daily Leader |date=9 May 2017 |quote=Anna-Michael Smith is one of 34 graduates who will be receiving diplomas in John R. Gray Gymnasium at BA Friday. The ceremony begins at 7 p.m. and it is open to the public. Smith is the daughter of Mike Smith and Cindy Hyde-Smith, of Brookhaven. Her mom is the commissioner of agriculture and commerce for the state. The Smiths also raise cattle, which makes Anna-Michael a fifth generation farmer.}}
61. ^¹²{{cite book|last1=Bolton|first1=Charles C.|title=The Hardest Deal of All|date=2005|publisher=University Press of Mississippi|location=Jackson|isbn=9781578067176}}
62. ^¹Coffey v. State Educational Finance Commission [https://law.justia.com/cases/federal/district-courts/FSupp/296/1389/1982533/ 296 F. Supp. 1389 (S.D. Miss. 1969) ]
63. ^{{cite web|title=About Carroll Academy|url=http://www.carrollacademy.org/about/|accessdate=4 November 2017}}
64. ^{{Cite book|url=https://books.google.com/?id=3xGrDgAAQBAJ&pg=PA224&dq=central+holmes+academy#v=onepage&q=central%20holmes%20academy&f=false|title=Hazel Brannon Smith: The Female Crusading Scalawag|last=Howell|first=Jeffery B.|date=2017-03-22|publisher=Univ. Press of Mississippi|isbn=9781496810823|language=en|page=224}}
65. ^{{Cite book|url=https://books.google.com/books?id=_HDEMfJrwWIC&pg=PT87|title=Thunder of Freedom: Black Leadership and the Transformation of 1960s Mississippi|last=Sojourner|first=Sue [Lorenzi]|date=2013-01-03|publisher=University Press of Kentucky|isbn=0813140943|language=en}}
66. ^{{citenews|title=Mayor J.W. Fore is worried over school situation|first=Bob|last=Boyd|newspaper=Delta Democrat Times|date=February 1, 1970|page=20}}
67. ^{{Cite news|url=http://articles.chicagotribune.com/1989-10-20/news/8901230911_1_east-holmes-academy-heritage-academy-racial-incident|title=A Goal-line Stand For Prejudice|work=tribunedigital-chicagotribune|access-date=2017-11-13|language=en}}
68. ^{{citenews|title=Belzoni private academy loses tax-exempt status|newspaper=Enterprise-Tocsin|page=1|date=September 17, 1970}}
69. ^¹²³⁴⁵⁶⁷⁸{{Cite book|url=https://books.google.com/books?id=Q_hk5Nh_z-8C&pg=PA40|title=James Meredith: Warrior and the America that Created Him|last=McGee|first=Meredith Coleman|date=2013-03-21|publisher=ABC-CLIO|isbn=9780313397400|language=en|page=40}}
70. ^¹{{Cite book|url=https://books.google.com/?id=7Z8aAQAAIAAJ&q=%22Lamar+School%22+segregation+mississippi&dq=%22Lamar+School%22+segregation+mississippi|title=Mississippi's Defiant Years, 1953-1973: An Interpretive Documentary with Personal Experiences|last=Johnston|first=Erle|date=1990|publisher=Lake Harbor Publishers|language=en|page=309}}
71. ^{{Cite news|url=http://www.jacksonfreepress.com/news/2018/nov/23/hyde-smith-attended-all-white-seg-academy-avoid-in/|title=Hyde-Smith Attended All-White 'Seg Academy' to Avoid Integration|last1=Pittman |first1=Ashton |quote=There's "no doubt that's why those schools were set up," said former U.S. Rep Ronnie Shows, a Democrat who was Hyde's junior high basketball coach at Lawrence County Academy in the 1970s. |access-date=2018-11-24|language=en}}
72. ^{{cite web|url=http://www.jacksonfreepress.com/news/2014/dec/17/what-segregation-academy/|title=What is a 'Segregation Academy'?|last=Wolfe |first=Anna |date=December 17, 2014 |publisher=Jackson Free Press|access-date=November 13, 2017}}
73. ^¹{{Cite news|url=|title=Desegregation Helps them Cope Now|last=Kanengiser|first=Andy|date=December 10, 1985|work=Clarion Ledger|access-date=}}
74. ^{{Cite book|url=https://books.google.com/books?id=Nswst5LbIaEC&pg=PA27|title=The Senator and the Sharecropper: The Freedom Struggles of James O. Eastland and Fannie Lou Hamer|last=Asch|first=Chris Myers|date=2011-02-01|publisher=Univ of North Carolina Press|isbn=9780807878057|language=en|page=27}}
75. ^{{citenews|date=November 29, 1982|first=Nancy|last=Weaver|work=Clarion Ledger|title=Race Remains a Factor in School Choice|page=12}}
76. ^{{cite web|title=Private Academy Backlash|url=http://starkvillecivilrights.msstate.edu/wordpress/backlash/|accessdate=10 November 2017}}
77. ^{{cite news|last1=McLaughlin|first1=Eliott|title=Could Mississippi integration ruling trigger 'white flight'?|url=http://www.cnn.com/2016/05/27/us/cleveland-mississippi-sidebar-segregation-academies/|accessdate=11 October 2016|agency=CNN|date=May 27, 2016}}
78. ^{{cite news|last1=Herbert|first1=Bob|title=In America; Haunted by Segregation|url=https://www.nytimes.com/1999/05/16/opinion/in-america-haunted-by-segregation.html|accessdate=3 August 2016|publisher=New York Times|date=16 May 1999}}
79. ^{{Cite news|url=https://www.nbcnews.com/feature/education-nation/commentary-fight-education-equity-mississippi-n107711|title=Commentary: The Fight for Education Equity in Mississippi - NBC News|work=NBC News|access-date=2017-11-13|language=en}}
80. ^{{Cite book|url=https://books.google.com/books?id=3nR1qTErsLAC&dq|title=The book of resolutions of the United Methodist Church, 2008|last=Conference|first=United Methodist Church (U S. ) General|date=2008|publisher=United Methodist Pub. House|isbn=9780687032211|language=en|page=27}}
81. ^{{Cite news|url=https://www.nytimes.com/1970/09/11/archives/books-out-and-in-at-jackson-miss-segregated-school-regains-800.html|title=BOOKS OUT AND IN AT JACKSON, MISS.|last=Rosenthal|first=Jack|date=1970-09-11|work=The New York Times|access-date=2017-11-13|language=en-US|issn=0362-4331}}
82. ^{{Cite news|url=http://www.kinston.com/article/20150830/news/150828616|title=50 Years of Parrott Academy|last=George|first=Dustin|work=The Free Press|access-date=2017-11-01|language=en}}
83. ^{{Cite book|url=https://books.google.com/?id=KzfVP5PMOFEC&pg=PA205#v=onepage&q&f=false|title=Black Wilmington and the North Carolina Way: Portrait of a Community in the Era of Civil Rights Protest|last=Godwin|first=John L.|date=2000|publisher=University Press of America|isbn=9780761816829|language=en|page=205}}
84. ^{{Cite news|url=http://www.carolinamercury.com/2014/02/nc-naacp-amicus-brief-outlines-history-of-private-school-vouchers-in-nc/|title=NC NAACP Amicus Brief outlines history of private-school vouchers in NC|date=2014-02-14|work=The Carolina Mercury|access-date=2017-11-04|language=en-US}}
85. ^{{cite book|last1=Vaden|first1=Luci|title=Before the Corridor of Shame: The African American Fight for Equal Education After Jim Crow|date=2014|publisher=University of South Carolina Scholar Commons|page=147|url=http://scholarcommons.sc.edu/cgi/viewcontent.cgi?article=3764&context=etd}}
86. ^{{cite news|last1=Brown|first1=Martha Rose|title=Dwindling enrollment, weak economy force closure of Bowman Academy|url=http://thetandd.com/news/dwindling-enrollment-weak-economy-force-closure-of-bowman-academy/article_25d94eab-342e-54ca-9591-75ae506dfe8e.html|accessdate=4 November 2017|publisher=T&D|date=February 8, 2010}}
87. ^Calhoun Academy v. Commissioner United States Tax Court 94 T.C. 284 (March 1, 1990)
88. ^¹²{{Cite book|url=https://books.google.com/?id=C1m0CAAAQBAJ|title=Charleston in Black and White: Race and Power in the South after the Civil Rights Movement|last=Estes|first=Steve|date=2015-07-10|publisher=UNC Press Books|isbn=9781469622330|language=en|page=93}}
89. ^{{Cite news|url=http://grantland.com/features/seventh-woods-high-school-basketball/|title=The Seventh Coming|last=Wachter|first=Paul|date=2015-02-10|work=Grantland|access-date=2017-11-29|language=en-US}}
90. ^{{cite news|title=Charleston Collegiate weaves outdoors into curricula|work=Post and Courier|date=November 5, 2013|url=http://docs.newsbank.com/openurl?ctx_ver=z39.88-2004&rft_id=info:sid/iw.newsbank.com:AWNB:CPCB&rft_val_format=info:ofi/fmt:kev:mtx:ctx&rft_dat=149E283E6208C4C0&svc_dat=InfoWeb:aggregated5&req_dat=0D663DC0A81A15EA|author=David Quick|quote=And unlike many private schools, Collegiate's student body is diverse, with about 30 percent being minorities. That fact bears noting because the school, which originated as Sea Island Academy, was among a wave of low-cost, rural 'segregation academies' that emerged in the South during the 1970s as a reaction to desegregation.}}{{paywall}}
91. ^{{cite web|last=Hawkins|first=J. Russell Hawkins|title=Religion, Race, and Resistance: White Evangelicals and the Dilemma of Integration in South Carolina 1950-1975|url=http://scholarship.rice.edu/bitstream/handle/1911/62070/3421442.PDF?sequence=1|accessdate=4 January 2014}}
92. ^Canup, William Shane [https://libres.uncg.edu/ir/uncg/f/Canup_uncg_0154M_11774.pdf The Geography of Public-Private School Choice and Race: A Case Study of Sumter, Clarendon, and Lee Counties, South Carolina] (2015)
93. ^¹{{citenews|title=Black Education Martyrs|work=The Times and Democrat|page=2|date=May 26, 2006|first=Richard|last=Reid}}
94. ^{{citenews|first=David|last=Nelson|date=February 18, 1974|newspaper=The Times and Democrat|page=B1|title=Answer to problem in Williamsburg County could affect every American}}
95. ^¹{{cite journal|title=Landing on the Wrong Note: The Price We Paid for Brown|author=Gloria Ladson-Billings|pages=3–13|journal=Educational Researcher|volume=33|number=7|date=October 2004|jstor=3700092|doi=10.3102/0013189x033007003}}
96. ^{{Cite news|url=|page=1|title=New Private Schools Filled to Capacity|last=Ritter|first=Frank|date=December 12, 1971|work=The Tennessean|access-date=}}
97. ^{{Cite news|url=|title=The 'Christian' schools are on the boom|last=O'hara|first=Jim|date=July 22, 1973|work=The Tennessean|page=1B|access-date=}}
98. ^{{Cite news|url=https://lakewood.advocatemag.com/2011/07/22/a-gray-matter/|title=40 years of DISD desegregation - Lakewood/East Dallas|date=2011-07-22|work=Lakewood/East Dallas|access-date=2017-11-21|language=en-US}}
99. ^¹²{{Cite book|url=https://archive.org/details/ERIC_ED065646|title=ERIC ED065646: It's Not Over in the South: School Desegregation in Forty-Three Southern Cities Eighteen Years After Brown.|last=ERIC|date=May 1972|language=english}}
100. ^{{citenews|title=Private School Enrollment $$$ Help for Institution|work=Baytown Sun|date=August 4, 1972|page=8}}
101. ^{{Cite news|url=https://www.washingtonpost.com/archive/local/1993/08/09/a-school-left-behind-by-the-times/f1ab83a4-cf6d-4203-9ca7-1b3405a81e08/|title=A SCHOOL LEFT BEHIND BY THE TIMES|last=Baker|first=Donald P.|date=1993-08-09|work=Washington Post|access-date=2017-11-13|language=en-US|issn=0190-8286}}
102. ^{{cite web|title=Runyon v. McCrary, 427 U.S. 160 (1976)|url=https://supreme.justia.com/cases/federal/us/427/160/case.html|publisher=Justia|accessdate=9 November 2017}}
103. ^{{cite journal|last1=Tobias|first1=Carl|title=PUBLIC SCHOOL DESEGREGATION IN VIRGINIA DURING THE POST-BROWN DECADE|journal=WILLIAM AND MARY LAW REVIEW|date=1996|volume=37|issue=4|page=1288|url=http://scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1732&context=wmlr}}
104. ^{{Cite web|url=https://broadwateracademy.org/about-us/|access-date=2019-02-10}}
105. ^{{Cite web|url=http://carlisleschool.org/about-us/at-a-glance/?doing_wp_cron=1510522877.6983950138092041015625|title=At-A-Glance {{!}} Carlisle School|website=carlisleschool.org|language=en-US|access-date=2017-11-12}}
106. ^{{cite web|title=Runyon v. McCrary, 427 U.S. 160 (1976)|url=https://supreme.justia.com/cases/federal/us/427/160/case.html|publisher=Justia|accessdate=9 November 2017}}
107. ^{{cite journal|title=Education in Prince Edward County, Virginia, 1953–1993|author=Wilbur B. Brookover|pages=149–161|journal=The Journal of Negro Education|volume=62|number=2|date=Spring 1993|jstor=2295190|doi=10.2307/2295190}}
108. ^{{cite web | url=http://docs.newsbank.com/openurl?ctx_ver=z39.88-2004&rft_id=info:sid/iw.newsbank.com:AWNB:RTDB&rft_val_format=info:ofi/fmt:kev:mtx:ctx&rft_dat=0EB4FAF9AC7D6BB2&svc_dat=InfoWeb:aggregated5&req_dat=0D663DC0A81A15EA | title=Disparate Pasts - Equal Future - Blessed Sacrament, Huguenot Academy Merger Promises Gains for Schools, Students | publisher=Richmond Times-Dispatch | date=August 9, 1998 | accessdate=November 2, 2011 | author=Wasson, Wynne W. | pages=B1}}
109. ^{{cite book|title=Public Education : 1964 Staff Report|date=1964|publisher=United States Commission on Civil Rights|page=277 |url=http://www.law.umaryland.edu/marshall/usccr/documents/cr12ed82964.pdf|accessdate=5 November 2017}}
110. ^{{cite news|last1=Keelor|first1=Josette|title=Classmates recall divided schools|url=http://www.nvdaily.com/news/local-news/2014/10/mosby-classmates-remember-front-royals-divided-schools/|accessdate=29 August 2017|publisher=Northern Virginia Daily|date=Oct 17, 2014}}
111. ^¹{{cite news|last1=Merritt|first1=Jonathan|title=Segregation Is Still Alive at These Christian Schools|url=https://www.thedailybeast.com/segregation-is-still-alive-at-these-christian-schools|accessdate=4 November 2017|publisher=Daily Beast|date=September 18, 2016}}
112. ^¹²³{{cite news|last1=HANTHORN|first1=Jessica|title=Overcoming Exclusion|url=http://www.dailypress.com/dp-brown16-private-story.html|accessdate=5 November 2017|publisher=Daily Press|date=May 16, 2004}}
113. ^¹{{cite web|last1=Gilliam|first1=George|title=Interview with Judge Barry Marshall|url=http://www2.vcdh.virginia.edu/saxon/servlet/SaxonServlet?source=/xml_docs/modernva/modernva_transcripts.xml&style=/xml_docs/modernva/interview_modernva.xsl&level=single&id=Barry_Marshall|publisher=Virginia Center for Digital History, University of Virginia|accessdate=26 August 2017}}
114. ^{{cite web|url=http://scholar.lib.vt.edu/theses/available/etd-121098-154942/unrestricted/DISSERTATION.PDF|title=The Desegregation of Southampton County, Virginia Schools|accessdate=2008-05-12|last=Modlin|first=Carolyn|pages=50}}
115. ^{{Cite news|url=https://pilotonline.com/news/the-norfolk-face-a-hostile-reception-as-schools-reopen/article_05745bcd-a24e-5d1d-9c5c-ce22313d963d.html|title=The Norfolk 17 face a hostile reception as schools reopen|last=Watson|first=Denise|work=Virginian-Pilot|access-date=2017-11-14|language=en}}
116. ^{{cite book|title=1964 Staff Report Public Education|date=Oct 1964|publisher=United States Commission on Civil Rights|url=https://www.law.umaryland.edu/marshall/usccr/documents/cr12ed82964.pdf|accessdate=31 August 2017}}
117. ^¹{{cite web|last1=Berkovsky|first1=Terry|title=Private School Update|url=https://www.irs.gov/pub/irs-tege/eotopicn00.pdf|publisher=Internal Revenue Service|accessdate=2 January 2018|date=2000}}

In federal law

Green v. Connally (1971) set the standard by which the Internal Revenue Service identifies a segregation academy, a so-called "Paragraph (1) School".^[117] The IRS must deny exemption to schools: