The U.S. Court of Appeals for the Fifth Circuit is considering whether to dissolve a 1965 permanent injunction requiring the School Board of St. Mary Parish in Louisiana to desegregate its schools, in a case that highlights the ongoing legacy of civil rights enforcement in American education.
The case, *Navy v. School Board of St. Mary Parish* (5th Cir. 2026), stems from a desegregation order issued 60 years ago during the height of the civil rights movement. According to court records filed Feb. 10, the School Board was placed under the permanent injunction in 1965 to ensure compliance with federal desegregation requirements.
The current dispute centers on competing motions filed in recent years. After two decades of enforcement by the original named representatives of the alleged class action, no modifications were sought until 2019, when new named representatives took charge of the case and requested changes to the injunction.
The School Board responded by filing two separate motions: one seeking to dissolve the injunction entirely due to alleged procedural problems, and another to dismiss or strike the modification request for similar reasons. The district court denied both motions and refused to allow the Board to present evidence under Federal Rule of Civil Procedure 60(b)(5) at an evidentiary hearing.
Rule 60(b)(5) allows courts to relieve parties from judgments when "the judgment has been satisfied, released, or discharged; it is based on an earlier judgment that has been reversed or vacated; or applying it prospectively is no longer equitable." The Board's attempt to invoke this rule suggests they believe circumstances have changed sufficiently to warrant ending the six-decade-old court supervision.
The plaintiffs in the case include Joshua J. Navy and Waynisha D. Navy, acting individually and on behalf of J.N., as well as Ashley Mayfield and Michael Mayfield, representing three children identified by initials M.D.P.M., A.E.P.M., and A.M.P.M. These families serve as the current named representatives of the class action.
The case originated in the U.S. District Court for the Western District of Louisiana under case number 6:65-CV-11351, reflecting its origins during the 1960s civil rights era. The permanent injunction was issued as part of the broader federal effort to enforce the Supreme Court's 1954 decision in *Brown v. Board of Education*, which declared segregated schools unconstitutional.
St. Mary Parish, located in south-central Louisiana along the Gulf Coast, has a population that is approximately 51% white and 46% Black, according to recent census data. The parish encompasses several communities including Franklin, Morgan City, and Berwick, with a school system serving thousands of students across multiple campuses.
The Fifth Circuit panel reviewing the case consists of Chief Judge Leslie H. Elrod and Circuit Judges Jerry E. Smith and Don R. Willett. Judge Smith authored the opinion, noting the significant timeline involved in the case's enforcement history.
According to the court records, enforcement of the desegregation injunction proceeded for approximately 20 years under the original named representatives before entering a period of apparent dormancy. The resurgence of activity in 2019 with new representatives seeking modifications suggests ongoing concerns about compliance or changed circumstances in the district.
The School Board's current challenge represents a significant test of when and how decades-old desegregation orders can be modified or dissolved. Federal courts have historically maintained supervision of school districts under such orders until they achieve "unitary status" – meaning they have eliminated the vestiges of past discrimination and can operate without court oversight.
Many Louisiana school districts have operated under federal desegregation orders for decades. The state's history of resistance to integration following *Brown v. Board* led to numerous court-supervised desegregation plans throughout the 1960s and beyond. Some districts have successfully petitioned for release from court supervision, while others remain under various forms of federal oversight.
The procedural issues raised by the School Board likely center on questions of class certification, adequate representation, and whether the current named representatives have standing to continue enforcement of the original injunction. Such procedural challenges have become increasingly common as decades-old civil rights cases encounter changes in personnel, demographics, and legal standards.
The district court's refusal to allow an evidentiary hearing under Rule 60(b)(5) suggests the judge found the Board's arguments insufficient to warrant consideration of dissolving the injunction. This procedural ruling now forms the basis of the School Board's appeal to the Fifth Circuit.
The case represents part of a broader national conversation about the ongoing role of federal courts in overseeing school integration efforts. While significant progress has been made since the 1960s, questions remain about when court supervision should end and how to address continuing disparities in educational opportunities.
The Fifth Circuit's decision in this case could have implications for other long-standing desegregation cases throughout Louisiana, Texas, and Mississippi – the three states within the court's jurisdiction that have numerous districts still operating under various forms of federal oversight related to civil rights compliance.