Coffey V. State Educational Finance Commission
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''Coffey v. State Educational Finance Commission'' (1969) was a federal case that addressed state support of
segregation academies Segregation academies are private schools in the Southern United States that were founded in the mid-20th century by white parents to avoid having their children attend desegregated public schools. They were founded between 1954, when the U.S. ...
in Mississippi. More broadly, it established the standards the Internal Revenue Service would use to determine the tax-exempt status of private schools based on their segregation policies.


History

The state of Mississippi had supported the establishment of private schools in the wake of '' Brown v. Board of Education'' ruling by the US Supreme Court to integrate public schools, by provision of tuition grants to schools that had all-white enrollments. Mississippi negro school children and their parents challenged the state policy in this case. The United States joined as an intervenor, citing violations of §902 of the
Civil Rights Act of 1964 The Civil Rights Act of 1964 () is a landmark civil rights and United States labor law, labor law in the United States that outlaws discrimination based on Race (human categorization), race, Person of color, color, religion, sex, and nationa ...
.


Arguments

Joe Patterson Joseph Heste Patterson (August 15, 1912 – May 23, 1939) was an American naval officer who also competed at the 1936 Summer Olympics. He went by "Pat" Patterson while in the Navy. Early life A native of Oklahoma City, Oklahoma, Patterson grad ...
represented Mississippi, arguing before Judges John Golbold, William Cox, and Dan Russell. The gist of the argument in favor of the grants was that they represented "freedom of choice." During the course of the trial, administrators of twenty-five schools were deposed. Twenty-four were segregation academies, recently founded to avoid court-ordered integration. One, Saints Academy in Lexington, Mississippi, was an all-black private school founded in 1918 when public schools were segregated. The plaintiffs argued successfully that parents were free to choose the school for their children, but that the state should not engage in policy that "will significantly encourage and involve the State in private discriminations."


Criteria

The court in its judgement included the following criteria to identify a segregation academy: *"The private school began operation the same year public schools in county were desegregated." *"No Negro pupils enrolled in the private school." *"No Negro pupils would be admitted to the private school."


Aftermath

''Coffey'' was aimed specifically at Mississippi. In 1976, the Supreme Court decided ''
Runyon v. McCrary ''Runyon v. McCrary'', 427 U.S. 160 (1976), was a case heard before the United States Supreme Court, which held that federal law prohibited private schools from discriminating on the basis of race.. Dissenting Justice Byron White argued that the l ...
'', which declared that segregated private schools nationwide were illegal. Parents of Mississippi black children subsequently filed suit to revoke federal tax-exemption status for non-profit segregation academies. The case went to the Supreme Court as ''
Coit v. Green ''Coit v. Green'', 404 U.S. 997 (1971), was a case in which the United States Supreme Court affirmed a decision that a private school which practiced racial discrimination could not be eligible for a tax exemption. Summary of findings In ...
'' (1971), which found against segregation academies. Concurrently, in July 1970, the Internal Revenue Service announced it could "no longer legally justify allowing tax-exempt status to private schools which practice racial discrimination."


References


External links

* {{caselaw source , case = ''Coffey v. State Educational Finance Commission'', {{ussc, 427, 160, 1969, el=no , cornell = , courtlistener = , findlaw = , justia =https://law.justia.com/cases/federal/district-courts/FSupp/296/1389/1982533/ , oyez = , other_source1 = , other_url1 = , other_source2 = , other_url2 = , other_source3 = , other_url3 = United States school desegregation case law 1969 in United States case law Education segregation in Mississippi