Jackson v. Rawdon Overview

            After the U.S. Supreme Court issued its “Brown I” ruling in 1954 and “Brown II” in 1955, which held that racially segregated school systems must integrate “with all deliberate speed,” African American citizens in Mansfield, Texas, made requests of the school board in the Spring of 1955 for improvements to the “colored” elementary school and a bus for the older students.  When there was no response from these requests, on October 7, 1955, NAACP attorney L. Clifford Davis filed a suit with the United States Federal District Court in Fort Worth.  In this original suit, Judge Estes declared that the school board had worked in good faith toward integration.  Later, on June 18, 1956, Chief Judge Hutchison of the United States Court of Appeals reversed and remanded an earlier decision of the Fifth Circuit Court in the case of Jackson v. Rawdon. This order stated in part, “plaintiffs have the right to admission to, and to attend, the Mansfield High School on the same basis as members of the white race; that the refusal of the defendants to admit plaintiffs thereto on account of their race or color is unlawful.”[1]  Even after this decision by the US Court of Appeals, African American students were not allowed to attend Mansfield High School until August 1965, nine years after the court ordered the district to allow students admission. To better understand the significance of this case, we must first go back to the beginning.

            T.M. Moody acted as a representative for the African American community of Mansfield to the Mansfield School Board; he was a deacon at the Bethlehem Baptist Church and a well-known member of the community.  According to Robin Ladino in Desegregating Texas Schools: Eisenhower, Shivers, and the Crisis at Mansfield High School, after the 1954 Brown v. Board decision, Moody was “anxious to see the decisions on implementation…and surmised that African Americans were on the brink of great changes for their race and the nation.”[2]  During the 1954-1955 school year, Moody submitted requests that the school district make improvements to the black elementary school and to provide buses for students attending James E Guinn Middle School and I.M. Terrell High School in Fort Worth.  By Spring 1955 these requests had been dismissed by the Board with no actions.[3]  Moody was President of the Mansfield chapter of the National Association for the Advancement of Colored People (NAACP) and attended regional meetings of the NAACP in Dallas.  At one of these regional meetings, Moody and John Lawson, another African American citizen of Mansfield, approached L. Clifford Davis, an attorney “seasoned in school equalization cases in Arkansas” and raised the possibility of filing suit against the Mansfield school district.[4] 

            Davis agreed to take on the case and made a formal request of the school board with six specific items: improvements for the “colored” school’s water well, a lunch program for the colored school, updated teaching materials, a flagpole for the front of the school to display the United States flag, a fence for the front of the school to keep children safe from a busy and dangerous intersection, and a bus to Fort Worth for the students in middle school and high school.  (Mansfield did not even provide schools for African American students beyond the elementary grades.) According to Ladino, “By late June, the school board had made no move toward passing any of the requests.”[5]

            By this time Brown II had already been decided and the U.S. Supreme Court had issued directives for a reasonable start to integrating schools. Davis, Moody, Lawson and other sub-trustees followed these directives in making requests of the Mansfield School Board.  They started with the requests for improvements to the school and the high school bus.  Davis recalled to Ladino, “At first we were trying to get these small things, and then, when we could not get those things, [we decided] if we’re going to have to fight, we’re going ot just fight the whole battle.”[6]

            T.M. Moody and others sent a petition to the school board on July 26^th requesting that the board take steps to end segregation immediately.  According to Ladino, the school board decided that a committee would study the situation further.[7]  Late in the summer at a meeting in Davis’ office a group of Mansfield parents, along with Davis, decided to make an attempt to enroll three students into Mansfield High School.  The students attempting to enroll were Floyd Moody, Nathaniel Jackson, and Charles Moody.  In an interview with Floyd Moody in April 2015, he remembers sitting at the table with Superintendent Huffman and hearing him say, “That will never happen.”[8]

            In a meeting at the home of T.M. Moody on September 2, Davis and T.M. Moody committed to initiating a school integration lawsuit that would eventually name only the three students that had requested enrollment at Mansfield High School.  The risk would be high for involvement in this lawsuit. Floyd Moody’s father even lost his job and home as a sharecropper as a result of the lawsuit.

            On October 7, 1955, Davis filed a suit with the United States Federal District Court in Fort Worth.  The plaintiffs were the three students, Nathaniel Jackson, Floyd Moody, and Charles Moody—along with “others ‘so numerous as to make it impracticable to bring all of them’ into court.”[9]  The defendants named in the case were O.C. Rawdon, school board president, other school board members, and Superintendent R.L. Huffman.  The official title of the case was: Nathaniel Jackson, a minor, et al. v. O.C. Rawdon, et al.  

            The court heard testimony on November 7, 1955. J.A. “Tiny” Gooch was the lawyer representing the school board and Davis represented the three African American students requesting admission to Mansfield High School.  Ladino said, “The school board was operating under Texas State Statutes that legalized the establishment of segregated school systems.”[10]  Davis’s argument on behalf of the plaintiffs was simple: these statutes had been determined to be unconstitutional in Brown I, Brown II, and McKinney v. Blankenship.  They court heard testimony from school board members, Superintendent Huffman, Floyd Moody, and Nathaniel Jackson.  The school board argued that there had not been sufficient time to change this separate school system, but that they were working toward preparing for the change to happen. 

            On November 21, 1955, Judge Estes announced his decision.  Estes said that because only two of the three students named in the suit attended the trial, and that there were only three of the twelve negro students in Mansfield named in the suit, “this indicated that the other nine negro students did not wish this action at this time.”[11]  Additionally, Estes said he felt that the school board had worked in good faith toward integration and that the United States Supreme Court allowed time for achieving the end of integration.

            On May 7, 1956, Davis filed an appeal to the United States Court of Appeals for the Fifth Circuit.  On May 23, 1956, Gooch filed an Appellee’s Brief. On June 28, 1956, after review of the November 21^st judgment, the US Court of Appeals reversed and remanded the decision made by Judge Estes.  The Appeals judges did not feel that the school board had “made serious consideration not to delay, but to proceed with integration…quite to the contrary, had taken definite action to continue segregation there throughout the coming school year.”[12]  The judgment filed on August 17, 1956, read in part, “plaintiffs have the right to admission to, and to attend, the Mansfield High School on the same basis as members of the white race.”[13]  On September 5, 1956, Gooch filed a Petition to Stay the Execution and Enforcement, on behalf of Rawdon and the school board.  Gooch believed that the decision of the lower court should stand. The petition stated, “this appeal is not for delay, but in order that justice may be done.”[14]  The petition was denied on December 3, 1956.

            Based on the decision by the United States Court of Appeals filed on August 17, 1956, at least the three named plaintiffs should have been enrolled at Mansfield High School, but they were not.  A few weeks later, effigies of African Americans hung at the high school, and local citizens and law enforcement supported by Governor Allen Shivers surrounded the high school on the day of registration for the 1956-1957 school year.   Floyd Moody recalled, “Davis was a very wise man, he didn’t pursue things any further after he saw what was happening, they kind of backed off, and then [said that] ’time will take care of it. You might not get it now, but you stay on the course.’  You see, they didn’t take us back anymore, but the idea was there.”[15]  It would be nine years before African American students were admitted to Mansfield High School, but the idea was there after Jackson v. Rawdon.