The counsel of record from the New York office of the ACLU, representing the plaintiffs, urging the introduction of busing into DeKalb County, Georgia, received strong support by way of amici briefs. Annexed to the supporting amici brief of the NAACP, DeKalb County, Georgia, Branch of the NAACP and seven other organizations, as the Appendix, is a document dated June 1991, entitled School Desegregation: A Social Science Statement.

At page 17a is a paragraph which epitomizes the objective of these organizations to have the judiciary mandate busing, without using the term, for the purpose of "desegregation" indefinitely, in disregard of parental and student objections, within a school district:

The benefits of desegregation take place over the long-term. When judicial requirements are unambiguous, and enforcement agencies promulgate precise regulations, desegregation is much more likely to succeed than when opposition leads judicial or agency principles to be stated in ambiguous or unclear terms. Schools that allow their desegregative goals to be derailed will often have paid the costs but not achieved the benefits of desegregation. Persistence allows schools to move past the period of community opposition and white flight, which may be strong within the first year of a plan but then decline rapidly.... [footnotes omitted]

The impersonal reference to "community opposition" and "white flight" as temporary impediments to achieving the objective of "desegregation" treats pupils as "elements" rather then "persons" in an open-ended school desegregation plan.

Also of great concern is the undemocratic way in which the