Griffin v. County School Board
Fourth Circuit
363 F.2d 206 (1966)
After being ordered to desegregate and later to reopen its long-closed public schools, Prince Edward County (defendant) sought to keep paying private-school tuition grants (which effectively funded segregated white-only schools) for the prior school year; when the trial court enjoined only the 1963-64 grants without addressing future years, plaintiffs appealed and asked the County to stipulate it would pay no tuition grants pending appeal. The County refused late one evening, and that same night its Board of Supervisors enlarged the tuition grants, with white parents collecting roughly $180,000 in checks before 9 a.m. the next morning.
Whether a party's willful action to place the subject matter of pending appellate litigation beyond the court's reach, timed specifically to preempt an adverse ruling, constitutes contempt of the appellate court's jurisdiction.