In March 1956, 101 members of Congress issued the Southern Manifesto, declaring war on the Brown decision. Governors in Virginia, Arkansas, Alabama, Georgia, and elsewhere then launched “massive resistance.” They created a legal doctrine, interposition, that supposedly nullified any federal law or court decision with which a state disagreed. They passed legislation to withhold public funding from any school that abided by Brown. They shut down public school systems and used tax dollars to ensure that whites could continue their education at racially exclusive private academies. Black children
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