Judge John J. Parker of the U.S. Court of Appeals for the Fourth Circuit interpreted the "Brown v. Board of Education" case as a charge not to segregate rather than an order to integrate. In 1963, the Court ruled in "McNeese v. Board of Education and Goss v. Board of Education" in favor of integration, and showed impatience with efforts to end segregation. In 1968 the Warren Court ruled in "Green v. County School Board" that freedom of choice plans were insufficient to eliminate segregation; thus, it was necessary to take proactive steps to integrate schools. In "United States v. Montgomery County Board of Education" (1969), Judge Frank Johnson's desegregation order for teachers was upheld, allowing an approximate ratio of the races to be established by a district judge.