Nathan Margold resigned from the NAACP in 1933 to join the Interior Department as a solicitor. In 1934 the Joint Committee of the NAACP and the American Fund for Public Service retained Charles Houston on a part-time basis to direct a legal campaign against discrimination in education and interstate transportation. Houston reviewed the Margold Report, then later composed this memorandum, in which he advocated using the scant $10,000 funds available to fight “the more acute issue of discrimination in education.” Houston diverged from Margold by delaying a direct strike on public schools, instead attacking state graduate and professional schools. He devised a systemic assault that would “us[e] the court as a laboratory” to develop a succession of test cases and gradually chip away at the “separate but equal” doctrine.