Following the second Brown v. Board of Education of Topeka decision (1955), states using segregated school systems faced a difficult, and unwelcome challenge to comply with the U.S. Supreme Court decree. Some of the Jim Crow states took reactionary measures of massive resistance, while others such as North Carolina took an ostensibly more compliant route. Although North Carolina did not fully embrace massive resistance outwardly, the state government chose to find creative ways to undermine the order of the U.S. Supreme Court to desegregate their public school system. Granting the authority to determine integration decisions to the people of the state, and their respective local school districts, provided a solution to school integration while simultaneously complying with the U.S. Supreme Courts words of “with all deliberate speed.”
Although the opinions of North Carolinas’ citizens were mixed regarding the states intended course of action, elections to adopt school pupil assignment plans and state constitutional amendments showed overwhelming support. The response of local school boards after the referendum election also echoed that support; as did the lack of school closings, public riots, and murders portrayed in other Jim Crow states.
The states’ adoption of the North Carolinas’ Pupil Assignment Act and the Pearsall Plan became problematic for states attorneys. North Carolina legal counsels were continuously bombarded with local attempts to challenge the Pupil Assignment Act in the Carson v. McDowell County case. The North Carolina Legislature also faced challenges to the Pearsall Plan from an in state African American law graduate. The challenges to the enacted school legislation had become so problematic that more legislation was proposed for the purposes of targeting civil rights groups; specifically, the NAACP. To combat the presence of the NAACP, the North Carolina legislature began to discuss “barratry” laws to use against “propaganda groups” in the House and Senate. By the close of the 1956-57 school year North Carolinas’ enacted school laws challenged the people of the state, the state and local school boards and to the legislature, to uphold segregation. Minimal desegregation began in state colleges and no desegregation occurred in public schools of North Carolina that year.
The case of Brown v. Board of Education ended the long standing rule of “separate but equal” in American public schools. The case was won for desegregationists from years of cases put in motion by African American attorney Charles H. Houston. Houston’ victories in such cases as Murray v. Pearson (1936) and Missouri ex rel. Gaines v. Canada (1938) proved to be the ground work to ultimately end Jim Crow. Other cases brought to the U.S Supreme Court, such as McLaurin v. Oklahoma (1950) and Sweatt v. Painter (1950), moved forward with the aid of the NAACP; continuing the work of creating precedence for the soon to be landmark case of Brown v. Board of Education after Charles Houston’s untimely death in 1950.
The Brown v. Board of Education case was broken down into two parts commonly referred to as Brown I and Brown II. Brown I (1954) provided the nation with the U.S. Supreme Courts’ decision proclaiming that separate was not equal in regard to the nations’ state funded public school systems. Brown II (1955) was an appeal by states’ attorneys contesting the first Brown decision. The U.S. Supreme Courts official decree of Brown II ordered that “[dismantling] of separate school systems for blacks and whites could proceed with ‘all deliberate speed’”. The phrase “all deliberate speed” within the decree gave state governments the authority to dismantle the segregated schools at a pace they felt to be most befitting for their respective states.
In efforts to resist the U.S. Supreme Court, Virginia U.S. Senator Harry F. Byrd called for massive resistance on February 25th 1956. Massive Resistance was a call to Southern state legislators to develop inventive laws that would allow the state to continue with segregation while staying within compliance of Federal law. On March 12th 1956 Chairman of the House Rules Committee, Howard Smith of Virginia, introduced the Declaration of Constitutional Principles with the support of 19 U.S. Senators and 82 members of the U.S. House of Representatives. The official document calling for massive resistance informally retained the title, the Southern Manifesto. The Southern Manifesto sought to keep with the traditions of segregation through legal means, reflecting the call to Massive Resistance. While Pledging “all lawful means to bring about a reversal” and requesting their “people not to be provoked” as southern politicians contested the decision as an affront to the rights of the states. The Manifesto states this outright, as it claims:
We regard the decision of the Supreme Court in the school cases
as clear abuse of judicial power. It climaxes a trend in the federal
judiciary undertaking to legislate, in derogation of authority of
Congress, and to encroach upon the reserved rights of the states
and the people.
The 17 segregated states requested that the states unaffected by the Brown decision “consider the constitutional principles involved against the time when they too, on issues vital to them, may be victims of judicial encroachment.” The Southern Manifesto appeared to reflect some of the actions that North Carolina had already begun to undertake.
Some of the 17 states were ostensibly more aggressive than North Carolina in their reaction to the Brown decree. North Carolina appeared more outwardly compliant in their state laws; however, the people of the state participated in discrimination actions in their own ways. Hate group participation had risen proceeding the Brown decision. According to the Anti-Defamation League:
By mid-1956, a marked rise in Klan activity was well under-
way- new Klan groups were drawing strength from the ferment
in the South. They gained members from extremist elements
among the White Citizens Councils themselves. These organizing
efforts succeeded in mobilizing former Klansmen who had been
inactive for years.
Although the Ku Klux Klan had begun to establish a foothold in North Carolina, by showing increased enrollment numbers after the Brown decision, North Carolina had previously taken measures to resist the hate group. Six white men were charged with violation of North Carolinas’ anti-hate literature law in July of 1956. Police discovered the location of the alleged culprits and found a collection of propaganda literature to enlist white candidates in organizations such as the Patriots of North Carolina, inc. the State Rights League, and Knights of the Ku Klux Klan. The police also found Klan attire, dynamite and other various weapons.
In Hillsboro North Carolina, William Polk Cheshire, a 25-year-old University of North Carolina student, set a cross on fire in the front yard of a home visited by Dr. Frank Graham, former president of the University of North Carolina and special United Nations representative. Burning crosses were a common trademark fear tactic used by the Ku Klux Klan; however, whether or not Cheshire was an actual Klansmen was not brought up in trial. When explaining his case to the arresting officers, Cheshire stated that “he burned the cross as a prank to let Dr. Graham ‘know how [he] felt about him.” William was the first person to be tried for violations of a 1953 Ku Klux Klan resistance law that made it a “crime to burn a cross on the property of another person without that person’s consent.”
White people of North Carolina had also been subjected to months of hate propaganda delivered to them via the White Patriots of North Carolina (also known as Patriots of North Carolina, inc., a North Carolina branch of the White Citizens Council). White Citizens Councils were segregationist groups that developed all throughout the South. White Citizens Councils “typically drew a more middle and upper class membership than the Ku Klux Klan and, in addition to using violence and intimidation to counter civil rights goals, they sought to economically and socially oppress blacks.”
The Patriots of North Carolina inc. were outspoken in the public and the media. The use of their political and economic clout also brought in political figureheads as keynote speakers to some of their public events. An address from “former State Sen. Julian R. Allsbrook of Roanoke Rapids” spoke on their behalf in August of 1956. In 1956 “from January to May, the Patriots held mass public meetings in Greensboro, Burlington, Hillsborough, Graham, Asheboro, and Charlotte.” The Patriots also relied heavily on appeals to authority as the organization was comprised of “mostly lawyers, ministers, professors, teachers, and a few textile magnates and state politicians.”
The president of Patriots of North Carolina inc., Dr. W.C. George of Chapel Hill, expressed his anger in a newspaper interview after a letter was received by Judy Gernier, a white girl from New York who attended a Methodist school for Negroes in Asheville North Carolina, from First Lady Eisenhower in February of 1956. During the interview Dr. George claimed “it is regrettable that Mrs. Eisenhower allowed herself to become an instrument of the politicians and propagandists who would force the mixing of white people and Negroes.”
Not all of North Carolina’s citizens responded to the Brown decision with negative responses. Various groups and individuals discussed their disappointment in the states actions in continuing segregation. In Chapel Hill a Pulitzer Prize winning playwright named Paul Green, urged not just North Carolina, but all of the South to “develop its real wealth” by “releasing the talents of its people- all the people irrespective of race, creed or calling.” The Bishop Vincent S. Water of the Catholic Diocese of Raleigh, spoke on behalf of the state (except Gaston County) opposing North Carolinas’ legislative ideas. Other opponents to segregation called simply for peace amongst all the violence. In Winston Salem, the pastor of Belmont Methodist Church in Nashville Tennessee spoke at a western North Carolina Methodist Conference proclaiming:
Warped emotions, unintelligent statements, quick reactions all
have stirred up hatred and even violence. What we in the South
need to remember now is that 87 schools in our area have integrated
without the aid of military but with peace, love and understanding 
Although there were some integration supporters, the overwhelming opinion regarding integration was negative for the white people of North Carolina.
Although North Carolina took a more passive route to Massive Resistance than some of the other seventeen states, there response to Brown was preemptive in nature. According to the Author Neil McMillen, North Carolina was “steering a middle course between prompt acquiescence and protected defiance. [North Carolina] enacted no resolution of interposition, it closed no public schools, and the concept of Massive Resistance was never seriously considered as official policy.” Though true that North Carolina pursued a more passive course of action, North Carolina had already taken pro-active measures. North Carolina quickly initiated the Pupil Assignment Act in March of 1955, two months before the Brown II decision. The state had already gotten an early start to generating anti-integration legislation before the call to massive resistances with the Pupil Assignment Act.
The pupil assignment law omitted racial references as grounds for student segregation, while also placing the responsibility of assigning pupils on local school boards. The pupil assignment law also gave parents the ability to appeal to school board authorities if they wanted their child to attend a different school. However, the process was complicated and intended to discourage the parents from doing so. The strategy of omitting legislative wording in regards to race, and placing the authority to integrate into the hands of their communities immersed in the Jim Crow tradition, was later “nicknamed ‘the North Carolina way’.”
Although the Pupil Assignment Act used no verbiage to denote discrimination based upon race, the law provided crushing obstacles for African American students despite their qualifications for entry. No African American students were enrolled in the public school system by the end of the 1956-1957 school year; the first school year after the Brown II decision. However, the state did continue with its minimal enrollment of African Americans in schools of higher learning.
Beginning in the school year of 1956 two African American freshmen had been enrolled for electrical engineering courses in the summer session at North Carolina State College in Raleigh with a third accepted to attend in the fall semester. The college boasted that they “admitted three graduate students in the past, these [were] the first Negro undergraduates admitted since the school was founded.” That same month, six women’s application to enroll in Greensboro Women’s College were being processed for enrollment as undergraduates.  By October 1956, Gastonia admitted a 23-year-old by the name of John O. Lyon to Gaston Technical Institute. White students interviewed about the event claimed “they did not like the admission of Lyon, a veteran” but no trouble seemed to be on the horizon according to the report. While minimal, North Carolina had begun the process of integration in schools of higher learning.
While integration had been avoided in the public schools, the Brown decision posed problems in North Carolina; not just for integration issues, but school financing issues as well. Anson County would quickly test the validity of the standing North Carolina laws in the face of desegregation. Anson County, located on the border adjacent to South Carolina, boasted a total population of 30,663 people fourteen years or older by the 1950 census. Although African Americans were a minority population in Anson, they comprised 42.4 percent of the total population of people fourteen or older. With an almost equal population of whites and African Americans the prospect of integration seemed more concerning to the people of Anson compared to counties with a more skewed population density.
The border county of Anson had voted to issue school bonds prior to the Brown case under the impression that the money would be used on segregated schools. However, Brown had made segregated schools unconstitutional. Issuing bonds for use in desegregated schools was not the intended use stated in the original ballot. R.K. Constantian, a white optometrist, claimed to be representing himself as well as the people of Anson county in contesting the issuance of school bonds that had been previously voted on prior to the Brown decision, in the case of Constantian v. Anson County Board of Education.
According to the case, a previous school bond of 1,250,000 dollars had been issued for the purposes of funding segregated schools. 500,000 dollars of the bond had already been issued; however, 750,000 dollars of the bond had yet to be issued and was awaiting the pending court decision. The court decided that although the bonds had been issued prior to Brown v. Board of Education, they were still to be dispensed to the Anson county school board. While additional money assured a victory for the Anson county school board, it officially decreed the North Carolina legislature to be in violation of federal law. As a result of the case, Chief Justice Bobbitt wrote in the courts decision:
Recognizing fully that [the U.S. Supreme Courts] decision
is authoritative in this jurisdiction, any provision of the
Constitution or statutes of North Carolina in conflict therewith
must be deemed invalid.
The N.C. Supreme Court decision ultimately “removed doubt over $25,000,000 of unissued state school bonds and $40,000,000 in unissued bonds voted by local units.” Shortly after, New York bond attorneys granted the unissued bonds totaling 64,000,000 dollars to Anson County for the use of school development and improvement.
Chief Justice Bobbitt had concluded that the N.C. Constitution was invalid in its wording; however, he did so begrudgingly. During the Constantian case he “expressed his ‘deep conviction’” that the U.S. Supreme Court was incorrect in their actions, yet he also continued to recognize the authority of the federal government over the states. On June 6, 1956 North Carolina Supreme Court Chief Justice William H. Bobbitt ruled in Constantian v. Anson County Board of Education that “the state’s constitutional requirement for racially separate schools [was no longer] valid.”
Although the N.C. Supreme Court had deemed provisions of the state’s constitution invalid in the Anson county decision, Chief Justice Bobbitt claimed that “two vital provisions” had not been affected. The General Assembly was still required to provide “for a general and uniform system of public schools, wherein tuition [would] be free of charge to all children of the state between the ages of six and 21 years.” The second provision required county commissioners to allocate funds for necessary buildings, equipment, maintenance and operation of county schools. However, the North Carolina government had been generating new legislation that would ultimately end up amending the states constitution to express its segregation stance without racial phrasing. Keeping the two vital provisions of the Constantian case in mind, the Pearsall Plan would continue segregation in like fashion as the Pupil Assignment act but at a state constitutional level.
The Pearsall Plan committee gave their plan to Governor Hodges on April 5th 1956. The committee recommended a referendum to adopt new amendments to the North Carolina constitution. The amendments would grant the initial pupil assignments to the local school boards, and after pupil assignments had been made, allow the students to transfer only after “application and hearing in due course.” The proposed amendments to the North Carolina constitution would also allow parents to remove their child from public schools and receive grants to assist in paying tuition at a private school should the parent not wish to send their child to an integrated school.
The constitutional provisions would also allow “local units” to redistrict school zones and close a public school within the new district by majority vote. Special cases of “consolidated schools” (schools that contained elementary and high school students) were also able to be broken into separate districts for the purposes of closing only one. Any child that lived in a local unit that had closed would “not be entitled as a matter of right to attend any other public school.” Elections were held for the voters of North Carolina in September and were favored in all 100 of its counties
It is important to note that in 1956, while the voter outcome adopted the Pearsall amendments four to one many African Americans in the state were denied the opportunity to cast their vote in North Carolina. The voting rights act would not be signed into law by former President Lyndon Johnson for another nine years. North Carolina denied racial minorities the right to vote by placing African Americans last in line at the voting polls, as white voters were allowed to cut ahead of them. African Americans were also required to take literacy tests that were easy to fail, and commonly given improperly by registrars asking questions outside of the scope of questions legally prescribed by state law, or claiming the voter failed due to mispronunciation of a word that appeared in the U.S. constitution.
Reverend Ernest Ivey, “a 62-year-old Negro preacher in Halifax County, filed a $5,000 damage suit in Federal District Court against a Halifax County registrar.” According to the law “a prospective voter can be asked to read and write any section of the U.S. Constitution as a prerequisite to voting. Instead, Ivey charged [the registrar] gave him an arbitrary academic test with the purpose of disqualifying him as a voter because he was a Negro.”
On August 13th 2013, North Carolina enacted the Voter Information Verification Act bringing 82-year-old Alberta Currie to the national spotlight in 2016. Mrs. Currie, the great-granddaughter of a slave, explained in an interview that she voted for the first time in 1956. She echoed the past complaints of Reverend Ivey to NPR about her first voting experience. Mrs. Currie stated that she was interviewed by white officials with such questions as “Why you want to vote, whose farm you lived on … what kind of work you do, or farming did you do, where your kids went to school at,” indicating that this practice was not uncommon. Mrs. Currie went on to say that “The white people went ahead of us. That meant the black people be last. And if we got home at dusk-dark, we was home at dusk-dark [sic].” Alberta Currie explained in the interview that the reason she had not been able to obtain a voter ID after the new 2013 N.C voter ID law was enacted that a birth certificate was required to receive the ID. Mrs. Currie explained that she had been born on a farm by a midwife in the Jim Crow south and therefore had never received a birth certificate.
In May of 1957 Helen Taylor, registrar for North Hampton county, claimed that “21 Negros [out of a total of 600 registered voters] were registered in 1956 and 20 were rejected.” Helen testified before a three judge federal court as three African American women were filing a permanent injunction to prohibit the literacy test. All three women contested that they were denied the right to vote because they “mispronounced a few words.” North Carolina Negro College (Durham) student, Alexander Faison stated that he had also been turned away because he mispronounced some of the words in the U.S. Constitution.
Court cases regarding voter discrimination were only a few of the legal issues facing North Carolina in 1956. North Carolina faced lawsuits challenging the Pupil Assignment Act and the Pearsall Plan immediately after their implication into state law as well. African Americans seemed shocked when Governor Hodges stated to the press that he was surprised at how quickly the Pearsall Plan had been challenged. Parts of the African American community had begun to apply for desegregation in McDowell county as soon as the pupil assignment law was enacted, and quickly began to challenge the law when their application for enrollment was denied.
The most notable and impacting case regarding pupil assignment laws in North Carolina was Carson v. McDowell County Board of Education (1955). plaintiffs were seeking integration into the Old Fort elementary school and claimed that they had been denied entry due to their race. The case decision sided with McDowell county school board in December of 1955 on the grounds that the plaintiffs had not exhausted all of the administrative appeals prior to the case; however, plaintiffs continued to appeal.
On August of 1956 Federal District Judge Wilson Warlick explained to the defendants that they had to exhaust all state administrative remedies prior to appealing to Federal courts dismissing the case. Judge Warlick also denied issuing an injunction against Old Fort elementary which would have forced the school to integrate. The case continued to be appealed in Superior Court where Judge George Patton ruled that each plaintiff would have to petition the school board individually, as individual petitions were required as part of the pupil assignment act.
The plaintiffs continued their case in the Fourth Circuit Court of Appeals were they asked the court to order Judge Wilson Warlick to hear the Carson v. McDowell case and order the McDowell county board of education to integrate the Old Fort school. The Fourth Circuit Court of Appeals denied the request and did not order Judge Warlick to permit the plaintiffs to amend their original complaint which Judge Warlick originally denied. Chief Justice John parker agreed with Judge Warlicks’ initial ruling in the case Carson v. Warlick based on the grounds that the plaintiffs had not exhausted the states administrative remedies pursuant to the Pupil Enrollment Act.
Plaintiffs of Carson v. Warlick ultimately petitioned the U.S. Supreme Court for review of the Carson v. Warlick case. In the plaintiffs’ petition, attorneys claimed the requirement to exhaust administrative remedies did not have “the same vigor” in desegregation of schools that it had in other administrative actions. The plaintiffs also claimed that school boards had no responsibility to actually desegregate the public school system. The U.S. Supreme Court refused the appeal, which upheld the requirement of exhausting state administrative appeals for integration. Governor Hodges claimed “We are very pleased. I think it’s a further vindication of the General Assembly’s good judgement in passing the assignment law.”
The U.S. Supreme Court had upheld North Carolinas right to create a lengthy and difficult appeals process. The appeals process was a vital staple not only to the Pupil Assignment Act, but to the Pearsall Plan amendments. The U.S. Supreme Court’s decision to uphold the appeals process did not leave the Pearsall Plan unchallenged however. The first African American to graduate from the University of North Carolina Law School, J. Kenneth Lee, challenged the Pearsall Plan only five days into the plans enactment. Lee filed a motion in the U.S. District Court to enlarge a Montgomery County school segregation case that had previously contested the Pupil Assignment Act to target Pearsall Plan policies. The premise of Lees’ case alleged that local option school closing elections and tax funded tuition grants “have as their singular and sole purpose and effect the continuation of racial segregation.”
A separate case generated by Caswell county African Americans also challenged the Pearsall Plan in January of 1957. The case was brought before the U.S. Middle District Court in a class action on behalf of segregated children. The case sought to prove that certain sections of the Pearsall amendments were unconstitutional and in violation of federal law. The plaintiffs were dismissed and were accused of purposely ignoring the states’ school administrative procedures, although they already petitioned the Caswell county school board and the State Board of Education.
The NAACP had been a presence in North Carolina since 1940, and was a continuous voice of support for civil rights. After the Brown decision the NAACP remained in the state and was active in assisting North Carolina African Americans with integration into public schools.  Throughout most of the 1956-57 school year the NAACP spoke out against segregation; however, the NAACP did not actively pursue lawsuits. None the less, North Carolina deemed the NAACP to be problematic.
The NAACP was forced to file a lawsuit against the North Carolina to avoid complying with two state statutes that had been requested in December of 1955 by the North Carolina Secretary of State; at the request of Patriots of North Carolina, inc. Secretary of State, Thad Eure had requested that the NAACP register as a foreign company in order to do business in the state, which fell under civil law. Secretary of State Eure also wanted the NAACP to file under a criminal law that required registration of organizations that attempted to influence public opinion and legislation.
North Carolina wanted to use the statutes to require the NAACP to reveal its membership list, in hopes that exposure would cause members to leave the organization. The NAACP was told in December of 1956 by the state supreme court that their case against North Carolina had been filed improperly. The NAACP challenged the decision in Superior Court again in February 1957, but the original ruling that the cases had been improperly filed remained. In March 1957 the NAACP filed the paperwork required of foreign corporations to do business in North Carolina to the Secretary of State listing its state headquarters and naming its state and national directors. North Carolina decided not to pursue the criminal statute in hopes that the NAACP would “go on and register under the law.”
North Carolina continued their attacks on the NAACP at the close of the school year, May 1957. Identical bills in the state House of Representatives and the Senate were generated to strictly regulate “propaganda groups.” One of the proposed bills would require any organization working for or against segregation to open their financial records to the public. The second bill would allow for the charge of barratry “a legal term for ‘inciting, directing or stirring up’” to be applied to any person or organization “not a real party to litigation.” The barratry bill carried fines up to $5,000 to organizations and a misdemeanor charge to individuals that were found guilty; however, attorneys found guilty of the crime could face disbarment. The barratry bill would also prevent lawyers from paying for the costs of litigation, which was intended to prevent the NAACP from paying costs in civil rights actions.
Following the second Brown v. Board of Education of Topeka decision, states using segregated school systems faced a daunting challenge to comply with the U.S. Supreme Court. Some Jim Crow states took reactionary measures of massive resistance, while North Carolina took more acquiescent route. Although North Carolina did not fully embrace the massive resistance outwardly, the state government found creative ways to undermine the order of the U.S. Supreme Court to desegregate their public schools. Granting the authority to determine integration decisions to the people of the state, and their respective local school districts, provided a solution to school integration while simultaneously complying with the U.S. Supreme Courts.
Opinions of North Carolina’s citizens were mixed regarding the states intended course of action, elections to adopt the school pupil assignment plans and state constitutional amendments to mirror previously adopted pupil assignment laws showed overwhelming support. The response of local school boards after the referendum election also echoed that support; as did the lack of general lawlessness.
The states’ adoption of the North Carolina’s Pupil Assignment Act and the Pearsall Plan became problematic for states attorneys. North Carolina legal counsels were continuously bombarded with local attempts to challenge the Pupil Assignment Act in the Carson v. McDowell County case. The North Carolina Legislature also faced challenges to the Pearsall Plan. The challenges to the enacted school legislation had become so problematic that more legislation was proposed for the purposes of targeting civil rights groups; specifically, the NAACP. To combat the presence of the NAACP, the North Carolina legislature began to discuss “barratry” laws to use against “propaganda groups” in the legislature. By November of 1956, 87 schools had integrated to various degrees throughout Jim Crow states. North Carolina had integrated less than 10 people into previously segregated colleges but no public schools had yet been integrated.
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Virginia Historical Society. “Brown I and Brown II”. Virginia Historical Society: Collections and Resources. Accessed June 11 2016. http://www.vahistorical.org/collections-and-resources/virginia-history-explorer/civil-rights-movement-virginia/brown-i-and-brown
Virginia Historical Society. “Massive Resistance”. Virginia Historical Society: Collections and Resources. Accessed June 11 2016. http://www.vahistorical.org/collections-and-resources/virginia-history-explorer/civil-rights-movement-virginia/massive
 Charles Houston; James Conyers, “Charles H. Houston: an interdisciplinary study of civil rights leadership”, Lanham [Md.]: Lexington Books, Accessed 11 June 2016
 The Road to Brown, directed by Jeff Brown. Produced 1989, (San Francisco: California News Reel, 1990), DVD.
 Virginia Historical Society. “Brown I and Brown II”. Virginia Historical Society: Collections and Resources. Accessed June 11 2016. http://www.vahistorical.org/collections-and-resources/virginia-history-explorer/civil-rights-movement-virginia/brown-i-and-brown
 Virginia Historical Society, “Massive Resistance”, Virginia Historical Society: Collections and Resources, Accessed July 11th 2016.
 United States House of Representatives, “Historical highlights: The Southern Manifesto of 1956” History, Art & Archives: United States House of Representatives, Accessed June 11th 2016. http://history.house.gov/Historical-Highlights/1951-2000/The-Southern-Manifesto-of-1956/
 Alvarado History, “The Southern Manifesto: Members of the United States Congress”, Alvaradohistory.com, Accessed June 11 2016. http://alvaradohistory.com/yahoo_site_admin/assets/docs/4SouthernManifesto.1134251.pdf
 Anti-Defamation League, “Emergence of the UKA”, Anti-Defamation League, http://archive.adl.org/issue_combating_hate/uka/rise.html. Accessed June 14 2016.
 Jay Jenkins, “N.C. Supreme Court Validates Bonds, Holds School Act is Unconstitutional”, Southern School News, July 1956, Volume III
 Jay Jenkins, “N.C. Legislature May Be Asked to Readopt ’56 School Measures”, Southern School News, February 1957, Volume III
 Christopher Schutz; Elizabeth McRae, “White Citizens’ Councils”, In Encyclopedia of North Carolina, ed. William Powell, (Online: North Carolina Press) Published 2006. Accessed June 14 2016. http://ncpedia.org/white-citizens-councils
Stanford University, “Martin Luther King, Jr. and the Global Freedom Struggle”, Kings Encyclopedia, Online ed. (Stanford: Accessed July 15 2016)
 Jay Jenkins, “’N.C. Assembly Approves Referendum on Tuition, School Closings”, Southern School News, August 1956, Volume III
 Elizabeth McRae, “White Patriots of North Carolina”, In Encyclopedia of North Carolina. ed. William Powell, (Online: North Carolina Press) Published 2006. Accessed June 11 2016. http://ncpedia.org/white-patriots-north-carolina
 Duplin Times, “What About is Mrs. Eisenhower?”, Duplin Times (February 9 1956), DigitalNC.org. Accessed June 15 2016. Newspapers.digitalnc.org/lccn/sn92074110/1956-02-09/ed-1/seq-2/#
 Jenkins, “N.C. Supreme Court Validates Bonds” July 1956.
 Jay Jenkins, “N.C ‘Not Expecting Difficulty;’ College Enrolls 2 Negro Women”, Southern School News, September 1956, Volume III
 Jay Jenkins, “North Carolina Assignment Law Studied by Court; Queries Said to Hint Change”, Southern School News, November 1956, Volume III
 Neil McMillen, The Citizens’ Council: Organized Resistance to the Second Reconstruction 1954-1964. (Champaign, Illinois: University of Illinois Press, 1994) pg. 115.
 Karl Campbell, “Pupil Assignment Act”, In Encyclopedia of North Carolina, ed. William Powell, (Online: North Carolina Press) Published 2006, Accessed June 11 2016. http://ncpedia.org/pupil-assignment-act
 Jenkins, “N.C. Supreme Court Validates Bonds”, July 1956.
 Jay Jenkins, “N.C. Adopts ‘Pearsall Plan’ by 4 to 1; Challenge Quickly Filed in U.S. Court”, Southern School News, October 1956, Volume III
 Jenkins, “N.C. Supreme Court Validates Bonds”, July 1956.
 Free Law Project, “R.K. Constantian, a taxpayer of Anson County, on behalf of himself and all other taxpayers of Anson County v. Anson County”, Court Listener, Accessed June 11, 2016. https://www.courtlistener.com/opinion/1337619/constantian-v-anson-county/
 Jenkins, “N.C. Supreme Court Validates Bonds”, July 1956.
 North Carolina Advisory Committee on Education. Report of the North Carolina Advisory Committee on Education. April 5, 1956. https://archive.org/stream/reportofnorthcar00nort_0/reportofnorthcar00nort_0_djvu.txt
 Jenkins, “N.C. Assembly Approves Referendum”, August 1956
 Jenkins, “N.C. Adopts ‘Pearsall Plan’ by 4 to 1”, October 1956
 ACLU, “Voting Rights Act: Major Dates in History”, ACLU, Accessed June 13 2016. https://www.aclu.org/files/VRATimeline.html?redirect=timeline-history-voting-rights-act
 Jenkins, “N.C. Supreme Court Validates Bonds”, July 1956.
 Ari Berman, “How North Carolina is Discriminating Against Voters at the Polls”. thenation.com Published March 25, 2016. Accessed June 13, 2016. http://www.thenation.com/article/how-north-carolina-is-discriminating-against-voters-at-the-polls/
 Alberta Currie, “All Things Considered”. Interview by Ailsa Chang. NPR, August 16, 2013. http://www.npr.org/2013/08/16/212664895/in-rural-n-c-new-voter-id-law-awakens-some-old-fears
 Jay Jenkins, “N.C. School Board Tells Group Initiative Is Up to Individuals”. Southern School News. July 1956. Volume III
 Carolina Times. “Pearsall Plan Challenge Expected: Scheme Faces Court Test”. Carolina Times September 22, 1956. DigitalNC.org. Accessed June 15 2016. http://newspapers.digitalnc.org/lccn/sn83045120/1956-09-22/ed-1/seq-1/#
 Jenkins, “N.C. Assembly Approves Referendum”, August 1956.
 Jenkins, “N.C. Not Expecting Difficulty”, September 1956.
 Jay Jenkins, “N.C. Pupils Must ‘Exhaust Remedies,’ But Appeal Route Is Cut”, Southern School News. December 1956. Volume III
 Jenkins, “North Carolina Teacher Pay”, March 1957
 Jay Jenkins, “N.C. Law Passes Supreme Court Test on Validity”, Southern School News. April 1957. Volume III
 Jenkins, “N.C. Adopts ‘Pearsall Plan’”, October 1956.
 Jay Jenkins, “N.C Negro Parents Go to Court in Challenge of ‘Pearsall Plan’”, Southern School News, January 1957, Volume III
 Jenkins, “N.C. Legislature May Be Asked to Readopt”, February 1957.
 Jenkins, “N.C. Teacher Pay”, March 1957
 Jenkins, “N.C. Pupils Must ‘Exhaust Remedies’”, December 1956.
 Jenkins, “N.C. Legislature May Be Asked to Readopt”, February 1957
 Jenkins, “N.C. Teacher Pay”, March 1957
 Jay Jenkins, “N.C. Lawmakers Get Bills to Open NAACP Records, Ban ‘Barratry’”, Southern School News, June 1957, Volume III