in Allen v. Wright (1983) that the standards were too low. The appellees had asserted that "there are more than 3,500 racially segregated private academies operating in the country having a total enrollment of more than 750,000 children." The court considered whether the parents had standing to sue, and concluded not, because they did not allege that they or their children had applied to, been discouraged from applying to, or been denied admission to any private school or schools. Specifically, it ruled that citizens do not have standing to sue a federal government agency based on the influence that the agency's determinations might have on third parties (such as private schools). The judges noted the parents were in the posture of disappointed observers of the governmental process. The IRS would continue to enforce the regulations it had promulgated in 1970. Any school that was not tax-exempt in this period was likely a segregation academy, the standard for non-discrimination being low. Not many of the 3,500 appear in lists, if there were 3,500. After 1983, any school named in a judgement or IRS document in this period absolutely was. Many schools did not regain tax-exempt status until the 1990s. By state Virginia was an early adopter of techniques to establish and finance segregation academies. Virginia was the first state to respond to Brown with the establishment of segregation academies and was also the first to be told in federal court that segregation academies were unconstitutional (Runyon v. McCrary (1976)), leading to their decline. The state was a bellwether for other states. Eventually, five states—Alabama, Georgia, Mississippi, South Carolina and Virginia—defied the court's decision in Brown by 1970. Segregated private schools lost their tax-exempt status in Coit v. Green (1971). Between 1961 and 1971, non-Catholic Christian schools doubled their enrollments nationally. By 1969, 300,000 of 7,400,000 white students attended segregated school in eleven southern states. Virginia In Virginia, segregation academies were part of a policy of massive resistance declared by U.S. Senator Harry F. Byrd, Sr. He worked to unite other white Virginia politicians and leaders in taking action to prevent school desegregation after the Brown v. Board of Education Supreme Court ruling in 1954. In its September/October 1956 special session, the Virginia General Assembly passed a series of laws known as the Stanley Plan to implement massive resistance. In January, Virginia's voters had approved an amendment to the state constitution to