private schools opened throughout the state as part of the massive resistance plan. Over the course of the 1960s, white students gradually returned to Warren County High School, with the Mosby Academy eventually becoming the county's middle school. Freedom of Choice plans Multiple school systems replaced massive resistance with "Freedom of Choice" plans, under which schools allowed families and students to opt to attend the public schools of their choice. This way, schools were able to comply with court rulings against segregation, while remaining partially or fully segregated in practice. In New Kent County, a black parent, Calvin Green, sued the county school system to implement a more effectual desegregation scheme. This resulted in the U.S. Supreme Court ruling in Green v. County School Board of New Kent County that freedom of choice plans were unconstitutional. Court-ordered busing: Richmond and back to Norfolk The Richmond City Public Schools had attempted various schemes to avoid integration, including dual attendance zones and the "Freedom of Choice" Plan. After an unsuccessful annexation suit against Henrico County to the north, the city successfully annexed of neighboring Chesterfield County to its south on January 1, 1970 in what the federal court later determined to be an attempt to stem white flight, as well as dilute black political strength. In 1970, District Court Judge Robert Merhige Jr., ordered a desegregation busing scheme established to integrate Richmond schools. However, beginning the following school year, thousands of white students did not go to the city's schools, but instead began attending existing and newly formed private schools and/or moving outside the city limits. A forced consolidation of the Richmond City, Chesterfield County and Henrico County public school districts was proposed and approved by Judge Merhige in 1971, but the Fourth Circuit Court of Appeals overturned this decision, barring most busing schemes that made students cross county/city boundaries. (Note: Since 1871, Virginia has had independent cities which are not politically located within counties, although some are completely surrounded geographically by a single county. This distinctive and unusual arrangement was pivotal in the Court of Appeals decision). Richmond City Schools then went through a series of attendance plans and magnet school programs. By 1986, Judge Merhige approved a system of essentially neighborhood schools, ending Virginia's legal struggles with segregation. In 1970, the Norfolk City Public Schools and several other Virginia communities were also subjected to busing schemes, also returning to more