n his fifth year of cxperilencc as
washington High Séhool, a public high school maintained and
ated under the direct control, supervision, rules and regulations
per
He successfully completed the course of inst
f the defendantse ruct-
llege for Negroes, an accrcdited
on.provided at Virginia State Co
f Virginia for thoe
ollege maintained and operatcd by the State o
nstruction and preparation of Negrocse as teachers in the public
schocls of the Statec. He holde a Colleglate Professional Certificate,
the highest certificate jssued by the Virginia State Board of Educa-
teaching in the public high schocls of Virginia.
tificate plaintiff has gatisfied the sanc
tion for I¥oerder
to qualify for this cor
requirencnts as those exescted of all other teachers, white as wecll
as Negro, qualifying thorefor, and he exerciscs the same dutics and
performe &grvices substantially equivalent to those performecld by
certificate, white as well as Negro, yet
other holders of the sald
the said certificate with
all whitc nalc teachers in Norfolk who hold
equal and lcss cxperience receive salaries nuch larger than the
salary paid the plaintiff.
m1l, White male high school teachers cnployed by defendants
whose qualificaticns, cortification, duties and scervices arc the
gamc as plaintiffts arc belng pald by defendants a nininun annual
salary of Twelve Hundred ($1200.00) Dollars.
"15, Plaintiff Alston is belng pald by the defendante for
his serviccs this ebhool yocar as a regular nale higl. school teacher
alary of Ninc Hundred ancd Twenty-onc (921.00)
h
as aforesaid an annual s
Dollars, being the anount fixed by dcfendants for Negro rnalc hig
school tcachers in their fifth ycar of teaching expericnce anc solely
custon conmplained of in porastaph
scheduls GeSCTIDEA ANl DATOEIADIE 40 Ghi @[ wa vewmw ————
beoause of the practicc, usage ond
plaintiffs have been, aroe, and unless relicf shall be grantcd by this
Honorable Court as hercinafter prayed, will continue to be deniled,
solely by reason of race and color the opportunity to receive a higher
salary equal to that paid to any white tecachers similarly situated.
116, Puramant to the policy, custon and usage sct out in
paragraph 12 the defendants acting as agents and agencics of the
Comnonwealth of Virginia have esteblished and maintainecd a salary
