## Facts

- Black minor students, suing through parents as a class, challenged Savannah–Chatham County’s operation of separate public schools for white and Black children.
- The school board and officials admitted the existence of a dual system but denied that school assignment was based solely on race and asserted administrative and educational reasons against immediate integration.
- White minor students intervened as a class, contending separation was based on asserted “racial traits of educational significance,” with race used as an index for claimed differences in learning rates, maturity, and behavioral traits.
- The court held a trial on the merits featuring extensive testimony, including expert psychological and educational evidence offered to support or refute claims of meaningful racial differences and the educational effects of integration.
- Plaintiffs relied on the Fourteenth Amendment and the principle that state-imposed segregation in public education is unconstitutional.

## Issues

1. Whether maintaining a dual public school system in Savannah–Chatham County violated the Equal Protection Clause of the Fourteenth Amendment.
2. Whether asserted educational and psychological differences between racial groups could constitutionally justify continuing racially separate public schools after controlling Supreme Court precedent condemning race-based segregation.

## Decision

- The court dismissed the complaint and denied injunctive relief.
- The court held that, on the record presented, the dual system did not amount to unconstitutional discrimination under the Fourteenth Amendment.
- The court accepted that the separation could be treated as a “reasonable” educational classification rather than segregation imposed solely because of race.
- The court credited claimed administrative and educational concerns and declined to order desegregation or require submission of a desegregation plan.

## Legal Principles

- Equal protection analysis permits classifications if they are not arbitrary and have a reasonable relationship to a legitimate governmental objective.
- A dual school system could be upheld, under the court’s approach, if racial separation was justified as serving educational objectives based on asserted group differences rather than as mere racial discrimination.
- Plaintiffs seeking injunctive relief bore the burden to prove the challenged school policy was an unconstitutional racial classification lacking a rational educational basis.

## Conclusion

The district court refused to enjoin the Savannah–Chatham County school board’s racially separate school system, concluding that the separation was supported by a reasonable educational rationale on the evidentiary record and therefore did not violate equal protection.


Stell v. Savannah-Chatham Cnty. Bd. of Educ., 220 F. Supp. 667 (S.D. Ga. 1963)