had resulted in some desegregation in eleven localities, and the number of at least partially desegregated districts had slowly risen to 20 in the fall of 1961, 29 in the fall of 1962, and 55 (out of 130 school districts) in 1963 (only 3,700 black pupils or 1.6% attended school with whites even in 1963). However, the Richmond court refused to declare the new attorney discipline laws unconstitutional. The NAACP appealed to the Virginia Supreme Court of Appeals, which upheld one statute but not the other. The NAACP appealed again to the U.S. Supreme Court, which granted certiorari. While Mays (who had argued the case previously before the U.S. and Virginia Supreme Courts) supervised the brief and attended the oral arguments (Robert L. Carter arguing for the NAACP), due to time constraints Mays let Wickham handle what turned out to be two arguments. The case was argued on November 8, 1961 and reargued on October 9, 1962, due to the resignation of two justices (Charles E. Whittaker and Felix Frankfurter) and their replacement (after a Senate confirmation process) by Byron White and Arthur Goldberg. Both resigned justices were in the majority in Harrison v. NAACP; both new justices were in the majority in this decision. Ruling The opinion was issued on January 14, 1963. Majority Associate Justice William J. Brennan, Jr. wrote the decision for the majority, and was joined by Chief Justice Earl Warren and Associate Justices Hugo Black and Arthur Goldberg. Associate Justice William O. Douglas concurred in the decision, but wrote an opinion expressing further views on the subject. For Brennan, the first issue before the court was a procedural one. In Harrison v. NAACP, the Supreme Court had ordered the district court to remand the case back to the state courts for disposition. However, the district court was to still maintain jurisdiction over the issue. The question before the Supreme Court was whether the NAACP could appeal the Virginia Supreme Court of Appeals' ruling directly to the U.S. Supreme Court, or was the NAACP required to go through the federal district court again? Brennan held that although the federal district court had reserved jurisdiction, this did not impinge on the Supreme Court's authority to review a supreme state court's decision. Having asserted the Supreme Court's jurisdiction over the matter, Brennan now turned to the constitutional issues. The Commonwealth of Virginia argued that it was not regulating