Because blacks and whites in Virginia generally lived in segregated neighborhoods, race-neutral measures would not
ensure racial balance in many schools, which was the new test of legitimacy under the
Green decision of 1968. Therefore,
race-conscious measures were taken. Supporters called them goals; opponents labeled them quotas.
In April 1971, in the case Bradley v. Richmond School Board, Federal District Judge Robert Mehrige, Jr.,
ordered an extensive citywide busing program in Richmond. Predictably, the result was further white flight
to private schools and to the suburbs. Calling it the "only remedy promising success," in January 1972
Mehrige sought to nullify white flight by extending the busing program to the suburban counties, so that
white children from the counties would be bused into the city, and black children from the city would
be sent into the counties. Opposition from white parents was fierce and was soon felt by politicians.
Except in predominantly black districts, few candidates for office in Virginia could be elected unless
they vociferously opposed busing.
On June 6, 1972, Mehrige's decision was overturned by a 5–1 decision of the U.S. Fourth Circuit
Court of Appeals, a ruling that was upheld by the U.S. Supreme Court, which subsequently invalidated
most busing across city-county boundaries. The 5–4 decision was the first defeat in memory for
desegregation since Brown. Unable to counteract white flight, many city schools again became
overwhelmingly black. This was called de facto ("in fact") segregation rather than de jure ("by law")
segregation because it happened in spite of rather than because of the law.
Governor A. Linwood Holton with daughter Tayloe
Tayloe Holton, daughter of then Governor A. Linwood Holton—
the first Republican governor of Virginia in the twentieth century—participated in Richmond's court-ordered
busing plan in the fall of 1970, although by precedent her parents could have placed her in one of the still mainly
white suburban county schools. This photograph, which ran in the New York Times, shows a progressive
governor escorting his daughter to her first day at the predominantly black John F. Kennedy High School.
It served as a counterpoint to Deep South images of further resistance. Virginia Historical Society.
Judge Robert R. Mehrige, Jr., with students
Federal District Judge Robert R. Mehrige, Jr., inherited more than twenty
school desegregation cases from his predecessor. Here he visits with students at Peabody High School in Norfolk
to see how desegregation is working. Saying "I don't agree with everything I do, but I took an oath." In Richmond
Mehrige ordered extensive pupil and teacher reassignment and citywide busing to promote desegregation in
his opinion in Bradley v. School Board of the City of Richmond.
Courtesy Richmond Times-Dispatch.
Students protest busing plan
The percentage of white students in Richmond city schools declined from
45 to 21 percent between 1960 and 1975. This so-called "white flight" prevented Richmond schools from
becoming truly integrated. After a voter referendum to combine the suburban school districts of Chesterfield
and Henrico counties with the city of Richmond's failed, Federal District Judge Robert Mehrige ordered
the merger by judicial action in the decision in Bradley v. School Board of the City of Richmond, to
facilitate busing to achieve racial balance in the schools. Marches, rallies, and other forms of protest
ensued. Courtesy Valentine Richmond History Center.
Next: Equal Access to Public Accommodations
Previous: The Green Decision of 1968
Virginia Historical Society | Online Exhibitions | Search