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Coffey v. State Educational Finance Commission
Court S.D. Miss
Full case name Mildred COFFEY et al., Plaintiffs, United States of America, Plaintiff-Intervenor, v. STATE EDUCATIONAL FINANCE COMMISSION et al., Defendants, State of Mississippi, Added Defendant
Decided January 29 1969
Citation(s) 296 F. Supp. 1389
Holding
order enjoining the payment of tuition grants
Case opinions
Majority Golbold
Cox
Russell
Laws applied
Civil Rights Act of 1964

Coffey v. State Educational Finance Commission was an important federal court case from 1969. It looked at whether the state of Mississippi could support private schools that practiced racial segregation (keeping people of different races separate).

This case also helped set the rules for how the Internal Revenue Service (IRS), which collects taxes, would decide if private schools could be tax-exempt. A school is tax-exempt if it doesn't have to pay certain taxes. This status depended on whether the school allowed students of all races.

Why This Case Happened

After the US Supreme Court's Brown v. Board of Education ruling in 1954, public schools across the country were told to end segregation. This meant they had to allow students of all races to attend together.

In response, the state of Mississippi began supporting new private schools. These schools were often created to avoid integrating public schools. They usually only accepted white students. The state helped these schools by giving out money called tuition grants. These grants helped parents pay for their children to attend these all-white private schools.

Black students and their parents in Mississippi challenged this state policy in court. The United States government also joined the case. They argued that Mississippi's actions broke a part of the Civil Rights Act of 1964. This law made it illegal to discriminate based on race.

What Was Argued?

The state of Mississippi was represented by Joseph Turner Patterson. He argued that the tuition grants were about "freedom of choice." This meant parents should be free to choose any school for their children.

The case was heard by three judges: John Cooper Godbold, William Harold Cox, and Dan Monroe Russell Jr..

During the trial, administrators from 25 schools were questioned. It turned out that 24 of these schools were "segregation academies." These were private schools that had been started recently to avoid court orders to integrate.

However, one school, Saints Academy in Lexington, Mississippi, was different. It was an all-black private school that had been founded way back in 1918. At that time, public schools were segregated by law.

The students and parents who brought the lawsuit argued that parents could choose any school. But they also said that the state should not do anything that would "significantly encourage" or get the state involved in private discrimination. The court agreed with them.

How to Spot a Segregation Academy

The court's decision included some clear ways to identify a segregation academy. These were schools that were created to avoid integration. The court said a school was likely a segregation academy if:

  • The private school started in the same year that public schools in its county began to integrate.
  • No Black students were enrolled in the private school.
  • No Black students would be allowed to join the private school.

What Happened Next?

The Coffey case specifically focused on Mississippi. But its ideas had a bigger impact.

Later, in 1976, the Supreme Court made another important decision in a case called Runyon v. McCrary. This ruling said that private schools across the entire country could not be segregated.

Following Coffey, parents of Black children in Mississippi also sued to stop segregation academies from getting federal tax-exempt status. This case went all the way to the Supreme Court as Coit v. Green in 1971. The Supreme Court ruled against the segregation academies.

Around the same time, in July 1970, the Internal Revenue Service (IRS) announced a new policy. They said they could no longer legally allow private schools that practiced racial discrimination to be tax-exempt. This meant these schools would have to pay taxes like other businesses.

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