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Coit v. Green

Coit v. Green, 404 U.S. 997 (1971), was a case in which the United States Supreme Court affirmed a decision that a private school which practiced racial discrimination could not be eligible for a tax exemption.[1]

Coit v. Green
Argued December 9, 1971
Reargued December 8, 1971
Decided December 20, 1971
Full case nameCoit v. Green
Citations404 U.S. 997 (more)
92 S. Ct. 564; 30 L. Ed. 2d 550
Case history
PriorJudgment for plaintiffs, Green v. Connally, 330 F. Supp. 1150 (D.D.C. 1971)
SubsequentJudgment explained in Bob Jones University v. Simon, 416 U.S. 725, 740, n. 11, 94 S.Ct. 2038, 2047, 40 L.Ed.2d 496 (1974), that this affirmance lacks precedential weight because no controversy remained in Green by the time the case reached this Court.
Holding
Using federal tax funds to finance private schools for purposes of segregation of students in segregation academies violates the IRS public tax fund rules, as well as the Equal Protection Clause of the Fourteenth Amendment, because discrimination coupled with segregation is inherently unequal. District of Columbia district court affirmed.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William O. Douglas · William J. Brennan Jr.
Potter Stewart · Byron White
Thurgood Marshall · Harry Blackmun
Case opinion
MajorityBurger, joined by unanimous
Laws applied
Section 501(c)(3) of IRC

Summary of findings

In Green v. Connally,[2][3] 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.

Results

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

A decade later, scores of schools had not changed policies and remained ineligible for tax-exempt status.[4]

See also

References

  1. ^ See Green v. Kennedy, 309 F. Supp. 1127 (D.D.C. 1970), later decision reported sub nom. Green v. Connally, 330 F. Supp. 1150 (D.D.C. 1971), summarily aff'd sub nom (African-Americans "need not be required to plead and show that, in the absence of illegal governmental encouragement, private institutions would not "elect to forgo 'favorable tax treatment, and that this will' result in the availability to complainants of services previously denied"); McGlotten v. Connally, 338 F. Supp. 448 (D.D.C. 1972); Pitts v. Wisconsin Dept. of Revenue, 333 F. Supp. 662 (E.D. Wis.1971) ("As perusal of these reported decisions reveals, the lower courts have not assumed that such allegations and proofs were somehow required by Article Three of the United States Constitution"); Simon v. Eastern Kentucky Welf. Rights. Org., 426 U.S. 26, 64 (1976).
  2. ^ Green v. Connally, 330 F. Supp. 1150 (D.D.C. 1971), aff'd sub nom, Coit v. Green, 404 U.S. 997 (1971).
  3. ^ "The Real Origins of the Religious Right". POLITICO Magazine.
  4. ^ TAYLOR Jr, STUART (January 12, 1982). "EX-TAX OFFICIALS ASSAIL SHIFT ON SCHOOL EXEMPTION STATUS". The New York Times. ISSN 0362-4331. Retrieved November 8, 2017.
  • Doe and Rabago v. Kamehameha Schools/Bernice Pauahi Bishop Estate, et al. (2007).
  • IRS (1982). Update on Private Schools.
  • Goluboff, R. L. (2000). "The Thirteenth Amendment and the Lost Origins of Civil Rights." Duke Law Journal, 50 Paper was presented at the 2000 Annual Meeting of the American Society for Legal History. p. 1609.

coit, green, 1971, case, which, united, states, supreme, court, affirmed, decision, that, private, school, which, practiced, racial, discrimination, could, eligible, exemption, supreme, court, united, statesargued, december, 1971reargued, december, 1971decided. Coit v Green 404 U S 997 1971 was a case in which the United States Supreme Court affirmed a decision that a private school which practiced racial discrimination could not be eligible for a tax exemption 1 Coit v GreenSupreme Court of the United StatesArgued December 9 1971Reargued December 8 1971Decided December 20 1971Full case nameCoit v GreenCitations404 U S 997 more 92 S Ct 564 30 L Ed 2d 550Case historyPriorJudgment for plaintiffs Green v Connally 330 F Supp 1150 D D C 1971 SubsequentJudgment explained in Bob Jones University v Simon 416 U S 725 740 n 11 94 S Ct 2038 2047 40 L Ed 2d 496 1974 that this affirmance lacks precedential weight because no controversy remained in Green by the time the case reached this Court HoldingUsing federal tax funds to finance private schools for purposes of segregation of students in segregation academies violates the IRS public tax fund rules as well as the Equal Protection Clause of the Fourteenth Amendment because discrimination coupled with segregation is inherently unequal District of Columbia district court affirmed Court membershipChief Justice Warren E Burger Associate Justices William O Douglas William J Brennan Jr Potter Stewart Byron WhiteThurgood Marshall Harry BlackmunCase opinionMajorityBurger joined by unanimousLaws appliedSection 501 c 3 of IRC Contents 1 Summary of findings 2 Results 3 See also 4 ReferencesSummary of findings EditIn Green v Connally 2 3 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 Results Edit Educational separation in the US prior to Brown v Board of Education A decade later scores of schools had not changed policies and remained ineligible for tax exempt status 4 See also EditUnited States Supreme Court cases during the Burger CourtReferences Edit See Green v Kennedy 309 F Supp 1127 D D C 1970 later decision reported sub nom Green v Connally 330 F Supp 1150 D D C 1971 summarily aff d sub nom African Americans need not be required to plead and show that in the absence of illegal governmental encouragement private institutions would not elect to forgo favorable tax treatment and that this will result in the availability to complainants of services previously denied McGlotten v Connally 338 F Supp 448 D D C 1972 Pitts v Wisconsin Dept of Revenue 333 F Supp 662 E D Wis 1971 As perusal of these reported decisions reveals the lower courts have not assumed that such allegations and proofs were somehow required by Article Three of the United States Constitution Simon v Eastern Kentucky Welf Rights Org 426 U S 26 64 1976 Green v Connally 330 F Supp 1150 D D C 1971 aff d sub nom Coit v Green 404 U S 997 1971 The Real Origins of the Religious Right POLITICO Magazine TAYLOR Jr STUART January 12 1982 EX TAX OFFICIALS ASSAIL SHIFT ON SCHOOL EXEMPTION STATUS The New York Times ISSN 0362 4331 Retrieved November 8 2017 Doe and Rabago v Kamehameha Schools Bernice Pauahi Bishop Estate et al 2007 IRS 1982 Update on Private Schools Goluboff R L 2000 The Thirteenth Amendment and the Lost Origins of Civil Rights Duke Law Journal 50 Paper was presented at the 2000 Annual Meeting of the American Society for Legal History p 1609 Retrieved from https en wikipedia org w index php title Coit v Green amp oldid 1124929689, wikipedia, wiki, book, books, library,

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