## Facts

- Black schoolchildren in Prince Edward County, Virginia, were plaintiffs in litigation that began as part of the school desegregation cases resolved in *Brown v. Board of Education* and later proceedings requiring nondiscriminatory admission to public schools.
- After desegregation was ordered, the Prince Edward County Board of Supervisors refused to appropriate funds for public schools in 1959, causing the county’s public schools to close while public schools elsewhere in Virginia continued to operate.
- A private foundation operated schools limited to white children; beginning in 1960, students attending those schools became eligible for state and county tuition grants.
- No comparable private schools were available for Black children, leaving them without access to formal education in the county for several years.
- In 1961, plaintiffs filed a supplemental pleading adding parties and challenging (1) the county’s failure to operate public schools and (2) the use of tuition grants and tax benefits that supported private segregated schooling while public schools remained closed.
- The district court barred tuition grants and tax benefits while the public schools were closed and ruled that the county could not keep schools closed to avoid desegregation when other Virginia counties operated public schools.
- The Fourth Circuit reversed on abstention grounds, directing federal courts to await state-law determinations concerning the legality of the school closings and tuition-grant program.
- The Supreme Court granted review.

## Issues

1. Whether closing all public schools in one county to avoid desegregation, while public schools elsewhere in the state remained open and public support flowed to private segregated schools, denied Black students equal protection under the Fourteenth Amendment.
2. Whether federal courts could grant effective equitable relief, including ordering the reopening of public schools and requiring local officials to use available taxing authority to fund a nondiscriminatory public school system.
3. Whether the plaintiffs’ supplemental pleading and joinder of additional defendants were procedurally proper under Federal Rule of Civil Procedure 15(d).
4. Whether a three-judge district court was required under 28 U.S.C. § 2281 and whether the Eleventh Amendment barred the action.
5. Whether federal courts should abstain in favor of state-court proceedings on related state-law questions.

## Decision

- The Supreme Court reversed the Fourth Circuit and remanded for further proceedings consistent with its opinion.
- The Court held that Prince Edward County’s closure of public schools, while other Virginia counties maintained public schools, denied the plaintiffs equal protection.
- The Court found the school shutdown and related public support for private segregated schooling were intended to prevent Black and white children from attending school together and were unconstitutional.
- The Court held abstention was improper given the delay and because the relevant state-law questions had been resolved by the state’s highest court.
- The Court approved the district court’s authority to order reopening and nondiscriminatory operation of public schools and, if necessary, to require county officials to exercise their power to levy taxes sufficient to fund such schools.
- The Court rejected procedural objections, concluding that the supplemental pleading was proper, a three-judge court was unnecessary, and the Eleventh Amendment did not bar prospective relief against officials.

## Legal Principles

- Equal protection is violated when a county uniquely terminates public education to avoid desegregation while public schools elsewhere in the state remain open.
- Government may not frustrate desegregation by closing public schools and channeling public support to private segregated schools that are effectively available only to white students.
- Federal courts may issue effective equitable remedies to end and prevent constitutional violations in public education, including orders requiring reopening and nondiscriminatory operation of schools.
- Where local officials possess taxing authority necessary to operate a constitutionally required public school system, a federal court may, if needed, require officials to exercise that authority to provide adequate funding.
- A supplemental complaint under Rule 15(d) is proper when later events are part of continuing efforts connected to the original constitutional violation.
- A three-judge court is not required when the challenged discrimination is specific to a single locality rather than an effort to enjoin enforcement of a generally applicable statewide statute on its face.
- The Eleventh Amendment does not bar suits seeking prospective relief against officials for ongoing violations of federal constitutional rights.

## Conclusion

The Court held that Prince Edward County’s decision to close its public schools to avoid desegregation, while supporting segregated private schooling and leaving Black children without education, denied equal protection, and it confirmed broad federal equitable power to order reopening and, if necessary, compel use of local taxing authority to fund a nondiscriminatory public school system.


Griffin v. Cnty. Sch. Bd. of Prince Edward Cnty., 377 U.S. 218 (1964)