2:69-cv-00043-CIV Date Filed 10/06/17 Entry Number 3 Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF SOUTH CAROLINA
CHARLESTON DIVISION

UNITED STATES OF AMERICA, )

)
Plaintiff, )
) CIVIL ACTION NO.: 2:69-cv-0043-civ
)
)
v. )
)
GEORGETOWN COUNTY SCHOOL )
DISTRICT, )
)
Defendant. )
____________________________________)

JOINT MOTION FOR DECLARATION OF PARTIAL UNITARY STATUS

Pursuant to Fed. R. Civ. P. 7(b) and Local Rule 7, Defendant, Georgetown County School

District (the District) and Plaintiff United States of America (United States) jointly move this

Court to enter a declaration of partial unitary status in the areas of facilities, extracurricular

activities, and transportation. See Green v. County School Bd. of New Kent County, 391 U.S. 430,

435 (1968). To obtain a declaration of unitary status on these factors, the District must show that

its schools have (1) fully and satisfactorily complied with the Courts decrees in those aspects of

the system where supervision is to be withdrawn for a reasonable period of time; (2) eliminated

the vestiges of de jure discrimination to the extent practicable; and (3) demonstrated a good-faith

commitment to the whole of the Courts decrees and to those provisions of the law and the

Constitution that were the predicate for judicial intervention in the first instance. See Missouri v.

Jenkins, 515 U.S. 70, 88-89 (1995); Freeman v. Pitts, 503 U.S. 467, 491-92, 498 (1992); Bd. of

Educ. of Oklahoma City Pub. Sch., Indep. Sch. Dist. No. 89 v. Dowell, 498 U.S. 237, 248-50

(1991). As described in more detail in the Memorandum in Support of the Parties Joint Motion,
 2:69-cv-00043-CIV Date Filed 10/06/17 Entry Number 3 Page 2 of 2

the parties stipulate that the Georgetown County School District has eliminated the vestiges of its

prior de jure segregated system to the extent practicable in the areas of (1) facilities, (2)

extracurricular activities, and (3) transportation, and jointly move the Court to enter a declaration

that the Georgetown County School District is partially unitary.

WHEREFORE, the District and the United States respectfully request that the Court enter

its Order declaring partial unitary status of the District.

Dated: October 6, 2017 Jointly Submitted By:

JOHN M. GORE
Acting Assistant Attorney General

s/Jennifer Maranzano______________ s/David T. Duff ______________

SHAHEENA A. SIMONS DAVID T. DUFF (Fed. I.D. No. 623)
RENEE M. WOHLENHAUS Duff & Childs, L.L.C.
JENNIFER MARANZANO P.O. Box 1486
Jennifer.Maranzano@usdoj.gov Columbia, SC 29292
United States Department of Justice Telephone: (803) 790-0603
Civil Rights Division Facsimile: (803) 790-0605
Educational Opportunities Section dduff@duffchilds.com
Patrick Henry Building Suite 4300
950 Pennsylvania Avenue, N.W. Lindsay Anne Thompson
Washington, D.C. 20530 Georgetown County School District
Telephone: (202) 305-0185 2018 Church Street
Facsimile: (202) 514-8337 Georgetown, SC 29440
Telephone: (843) 436-7000
Attorneys for Plaintiff United States of America Facsimile: (843) 436-7171
lathompson@gcsd.k12.sc.us

Attorneys for Defendant Georgetown

County School District