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Case 1:10-cv-00061-GHD-JAD

Document 22

Filed 03/19/2010

Page 5 of 10

Supporting Affidavit of Jim Keith

In support of its Response and Opposition to Plaintiff’s Motion for Preliminary Injunction,

Defendant submits the affidavit of Jim Keith, an attorney with extensive experience representing,

consulting and training boards of education throughout the State of Mississippi. Mr. Keith represents

ten school districts as board attorney and consults frequently with over 100 school districts on

various legal issues. He is the attorney for the Mississippi Board of Education Association and for

the Mississippi High School Activities Association. In his role as attorney for the MSBA, Mr. Keith

assists in the training for all new Board of Education members as required by state law, providing

approximately three hours of legal training to every board member who is appointed or elected to

a Board of Education in Mississippi. He has been providing this legal training for approximately

ten years and has made presentations nationally on special education, employment in the school

setting, and student related matters. Mr. Keith has represented school districts in Federal and State

Court and various administrative agencies, represented the Jackson Public School District in Knox

v. Jackson Public School District involving prayer over the intercom and subsequent litigation by

the principal for his suspension for allowing the prayers, and also represented the Jackson Public

School District in Ingebretsen v. Jackson Public School District, a case involving the challenge to

the state law that allowed prayer at school-related events.

The affidavit of Jim Keith established certain critical matters regarding board

decision-making and handling of controversial matters such as the one that is the subject of the

present litigation. Mr. Keith interviewed board members and school personnel knowledgeable of

the facts of the present controversy, reviewed board policy and relevant documents to become

familiar with the facts of this case.


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