Brief in support of defendant's motion to dismiss in Civil Action No. 42: Lucile Bluford v. S.W. Canada. The defendant's attorneys argue for the dismal of Bluford's suit against Canada, the registrar of the University of Missouri, stating that she has no standing for the damages she seeks. They state that Missouri requires "separation of the white and negro races for purposes of higher education," and that Lincoln University has "the mandatory duty to provide for negro residents ...
Reply brief of defendant on motion to dismiss in Civil Action No. 42: Lucile Bluford v. S.W. Canada. The document responds to a memo by Bluford's attorneys, which in turn responds to Canada's attorneys brief requesting dismissal of the case. Canada's attorneys reject Bluford's assertion that Canada, as registrar, is a "ministerial officer" of the university, and insist he is a "mere subordinate employee." The defense team also argues that Bluford and her attorneys misunderstand the requirements of the decision in Gaines v.
Defendant's motion for directed verdict in Civil Action No. 42: Lucile Bluford v. S.W. Canada. The defendant's attorneys argue for a verdict in their favor by stating that Bluford has failed to state a claim, nor prove one, that justifies relief, nor has she proven that she applied to the graduate program in journalism at the University of Missouri in good faith. They also assert that Bluford provided no evidence that she had ever applied to Lincoln University.
Subpoena request for St. Louis Call managing editor Elwood E. Randol or Chester E. Stovall, editor of the paper, in Civil Action No. 42: Lucile Bluford v. S.W. Canada. The defense team requests that the U.S. District Court order Elwood E. Randol, managing editor of the St. Louis Call, or Chester E. Stovall, editor of the paper, appear in court on October 21, 1940.
Defendant's requested instructions to the jury in Civil Action No. 42: Lucile Bluford v. S.W. Canada. Instructions include statements that Missouri law mandates "separate but equal" educational facilities, that Lincoln University is mandated to provide a journalism program "upon timely request of any qualified negro resident," that "there is no evidence that plaintiff applied to Lincoln University for graduate work," and other arguments in the case.
Motion to dismiss in Civil Action No. 42: Lucile Bluford v. S.W. Canada.
Motion for more definite statement under Rule 12(e) and to require plaintiff to separately state and number in Civil Case No. 128: Lucile Bluford v. S.W. Canada. The defense team moves that the plaintiff be required to "make a more definite statement of the several claims for relief and causes of action," and to "state in separate counts the various claims founded upon separate transactions or occurrences under Rule 10(b)." They argue that the different types of claims being made must be dealt with separately. The defendant also demands a jury trial in the case.
Motion for directed verdict on Count 1 and motions to dismiss Counts 2 and 3 in Civil Case No. 128: Lucile Bluford v. S.W. Canada. The defense team moves the court to direct the jury to return a verdict against the plaintiff in Count 1 of the amended complaint, arguing that evidence is insufficient to prove the claims, that there is no evidence Bluford applied to Lincoln University in time for the university to establish a graduate journalism program, that University of Missouri registrar Canada acted in accordance with state law in refusing Bluford registration, and other points.
Defendant's requested instructions in Civil Case No. 128: Lucile Bluford v. S.W. Canada.
Answer in Civil Case No. 128: Lucile Bluford v. S.W. Canada. The defense responds to Bluford's complaint by arguing that she has no grounds upon which to make this claim, by denying that Canada acts as an "officer" of the University of Missouri in his role as registrar, and affirming the role of Lincoln University to serve the black residents of Missouri by establishing equivalent programs to MU, among other points.
Brief written by attorneys representing the University of Missouri and it's registrar, S. W. Canada, in Lucile Bluford's appeal in her suit attempting to gain admission to the university's graduate journalism program.