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Educational separation in the US prior to Brown v.
Board of Education

Coit v. Green, 404 U.S. 997 (1971), was a case in which the United States Supreme Courtmarker affirmed a decision that a private school which practiced racial discrimination could not be eligible for a tax exemption.

Historical Background

Several cases floundered after the landmark Brown v. Board of Education of Topeka, desegregation case. Ideas of free labor at the demise of the Lochner era caused federal lawyers in the Civil Rights Section to attempt to create a labor-infused civil rights framework, which the "all deliberate speed" of Brown v. Board of Education stood upon as a means to progress constitutional law that swamped Plessy v. Ferguson. Coit v. Green developed the framework for later cases such as Prince Edward School Foundation v. U.S., Allen v. Wright, and Doe and Rabago v. Kamehameha Schools/Bernice Pauahi Bishop Estate, et al.. All of these cases involve a post-civil war lawsuit banning racial exclusion in public buildings and facilities, as well as contracts, known as the Black Codes.

It is notable that U.S. Supreme Court Justice Hugo Lafayette Black, a former member of the Ku Klux Klan resigned from the Supreme Court Friday, September 17, 1971 after a debilitating stroke. He died eight days later. He was replaced by Warren E. Burger whereby this particular session of Burger court extended from Saturday, September 18, 1971 to January 6, 1972 when new Justices were appointed; thus dismantling the Hugo Black formed Warren Courts as John Marshall Harlan II disbanded, and Rehnquist and Justice Powell joined.

Coit v. Green became the foundation for later finding that state tax exemptions to private charitable foundation were sufficient to establish state action under the Equal protection clause of the Fourteenth Amendment.

Summary of Findings

In Green v. Connally, the court declared that neither IRC 501(c)(3) nor IRC 170 provided for tax-exempt status or deductible contributions to any organization operating a private school that discriminates in admissions on the basis of race. Since this time, if a school has adopted and announced a racially non-discriminatory admissions policy and has not taken any overt action to discriminate in admissions, the Service concludes that the school has a racially non-discriminatory admissions policy. The U.S. Supreme Court, however, specifically did not rule on the hypothetical possibility of a school which discriminated against minorities for religious reasons.

In the interim, the IRS took steps to implement the nondiscrimination requirement including Revenue Ruling 71-447, 1971-2 C.B. 230, Revenue Procedure 72-54, 1972-2 C.B. 834, Revenue Procedure 75-50, 1975-2 C.B. 587, and Revenue Ruling 75-231, 1975-1 C.B. 158. Without comment, the Supreme Court affirmed the judgment of the United States District Court for the District of Columbia at the end of 1971 for the families in this case.

Throwing off the shackles of Plessy v. Ferguson, the long-term effect of Coit v. Green is for Desegregation to be inclusive of all schools. Desegregation was never intended to be just for public schools or justify private fa├žades.

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