ABSTRACT
In the aermath of Brown (1954) and Brown II (1955), in which the Supreme Court directed states to desegregate “with all deliberate speed” (p. 301), 77 congressional representatives and 19 senators representing 11 states signed the Southern Manifesto, a “Declaration of Constitutional Principles,” asserting that the Supreme Court exceeded its bounds in interference with states’ rights by ruling school desegregation illegal (1956). is began a period known as massive resistance. Brown II itself is an enigma in constitutional law in that it acknowledged a constitutional harm but did not require an immediate remedy. It may have, in fact, invited the Manifesto ( Klarman, 2007).
