Sexual Harassment - Its Not Academic


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Sexual Harassment - Its Not Academic Title IX 2008

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Sexual Harassment - Its Not Academic

  2. 2. SexualHarassment It Not Acadenric Seotember 2008 Office for Civil RightsU.S.Department of Education
  3. 3. U. S. Department of EducationMargaret SpellingsSecretaryOffice for Civil RightsStephanie MonroeAssistantSecretaryRevisedSeptember 2008.This publication is in the public domain.Authorization to reproduceit in whole or in part is granted.The publicationscitation shouldbe: U.S. Department of Education,Office for Civil Rights, SexualHarasmen I t Not A cademi s t: c,Washington, C., 2008. D.To order copiesof this publication,write to: EDPubs EducationalPublicationsCenter U.S.Departmentof Education P.O.Box 1398 MD 20794-1.398 Jessup,You may fax your order to: 30I-470-7244 or sendan e-mail requestto: may alsocalltoll-free:7-877-433-7827 (1.-877-4-ED-PUBS).If877 service not yet avallable your area,yoltmay cal),I-800-872- is in5327 (1,-800-USA-LEARN).Thosewho usea telecommunicationsdevicefor the deaf (TDD) or a teletypewriter(TTY) should call1.-877-576-7734.To order online, point your Internet browser to: publication alsois available the DepartmentsWeb site onathttp://www.ed.govlocr.Any updatesto this publication willbeavailableat this Web site.On request, this publication is available alternateformats,such as inBraille,large print, or computerdiskette.For more information, youmay contactthe Departments AlternateFormat Center at202-260-0852or 202-260-0818.Ifyou useaTDD, call 1-800-877-8339. ii
  4. 4. ContentsIntroduction.... IPart One: Defining SexualHarassment 3 aWhat is sexual harassment?. . . . J aWhat aresomeexamples sexual of conduct?. JIs all physicalcontact sexualin nature? 4What if the sexualconduct is criminal in nature? 4Mustthesexualcond u c t b e u n we lc o me ? . . ........ 5When doessenualconduct "deny or limit a studentsability toparticrpatein or benefit from a schoolseducationprogram?".. . . . . 5Can young school children engagein sexualharassment?. . . . . . . . 7Ate gayand lesbianstudentsprotectedfrom sexralharassment?.. 8 .PartTwo: RespondingtoSexualHarassment .... 9How shoulda schoolrespondwhen it receives information aboutallegedsexualharas s me n t ? . . . . ....9What if the victim requestsconfidentiality or asksthat thecomplaintnotbepurs u e d ? ........9Does a schoolhaveto do anythingaboutsexralharassment a ifparticularincident is not reportedto the school? . . . 10What actions,tf schoolstake while investigatingacomplaint?.... ^y,should ....LIWhat doesa schoolhaveto do oncethe investigation complete? 11 isWhat aresomeexamples the stepsa schoolshouldtaketo end ofharassment andpreventitfrom happeningagun? . . . . . . . . 73What aresomeexamplesofhowa school canrcmedythe effectsofsexualharassment? . . . . .....13 lu
  5. 5. PartThree: Reporting and Preventing SexualHarassment . . . . . 15Who shouldreportincidentsofsexualharassment?.. . . . . . . . . . .15 .To whom should a victim or other individual reporttheharassment?. ....15What if the harasser threatensto retaliareagainstthe victim ifhe orshereports theinc id e n t ? . . . . ........15What proceduresmust a school havein placeto prevent sorualharassmentandres o lv e c o mp la in t s ? ........16W hataregrievancep ro c e d u re s ? . . . . .......16W hatdoestheTitlelXc o o rd in a t o rd o ? . . ........16Howdo I knowwho myschools TitleIX coordinator . . . . . . .,17 is?What other stepscan a schooltake to prevent socualharassment? 17What is OC& and how do I report incidents of sorualharassmenttothatoffice? .......17Where can I get more information about a schoolsresponsibilitiestoaddressandpreventsexualharassment? .... ....18 lv
  6. 6. IntroductionSexualharassment studentsis illegal A federallaw, Title IX of the ofEducationAmendments1972 (Titk 1,$, prohibitsdiscrimination 0fon the basisof sex,including sexualharassment, education inprogramsand activities. public and private educationinstitutions A1lihai receiveany federalfunds must comply with Title IX. Title IXprotectsstudents from harassment connected any of the academic, toeducational, extracurricular, athletic,and other programsor activitiesof schools,regardless the location. Title IX protectsboth male and offemale studentsfrom sexualharassmentbyanyschoolempioyee,another student,or a non-employeethird party.Preventingand remedyingsexual harassment schoolsis essential into ensurea nondiscriminatory, safeenvironmentin which studentscan learn.Unfortunately,students, Parents,and schoolstaff maynot know what sexual harassment how to stoPit, and what is,can be done to preventit from happening. This pamphlet usesaquestion-and-answer format to provide students,Parents,schooladministrators,schoolemployees, otherswith fundamental andinformation on recognizingand, addressing sexualharassmentunder Title IX asit is interpretedby the U.S.Department ofEducationt Office for Civil Rights (OCR). OCR is the federalagencyresponsible enforcing Title lXin schools for that receivefederalfunds from the U.S. Department of Education.
  7. 7. Part One: Defining Sexual Harassment What is sexualharassment? Sexualharassmentis conduct that: 1) is sexual nature; in2) is unwelcome; and3) deniesor limits a studentsability to participatein or benefit from a schoolseducationprogram.Sexualharassmentcan take different forms depending on theharasser and the nature of the harassment. The conduct can becarried out by school employees, other students,and non-employeethird parties,such as a visiting speaker.Both male and femalestudentscan be victims of sexualharassment. and the harasserandthe victim can be of the samesex.The conduct can occur in any schoolprogram or activity and cantake placein schoolfacilities,on a schoolbus,or at other off-campuslocations,suchas a school-sponsored field trip or a trainingprogram at anotherlocation.Tlie conductcan be verbal,nonverbal,or physical.The judgment and common sense teachersand school ofadministrators arevery important elementsin determining whethersexualharassmenthas occurredand in determining an appropriateresponse,especiallywhen dealing with young children.What are someexamples sexualconduct? ofExamplesof sexual conductinclude: making sexual propositionsor pressuring students sexual for favors; touching of a sexualnature; writing graffiti of a sexualnature; displaying or distributing sexuallyexplicit drawings,pictures,or written materials:
  8. 8. performing sexual gestures touching oneselfsexualiy front or in of others: telling sexualor dirty jokes; spreading sexualrumors or rating other studentsasto sexual activitlr or performance;or circulatingor showinge-mailsor Web sitesof a sexualnature. Example; A school official sendsa student a text message to arrangea time to meet for a sexualencounter.Sending such a text messagewould constitute sexualconduct.Is all pbysicalcontact sexualin nature?No. Legitimate nonsexual touching or conductgenerallywill notbe considered sexualharassment. However,it may rise to that levelif it takeson sexual connotations. Example: A high school athletic coachhugs a srudent who makesa goal.This by itself is not consideredsexual conduct. However, a coachshugging of a student could be consideredsexualconduct if it is unwelcomeand occurs under,inappropriatecircumstances.LVhat thesexualconduct criminal in nature? if isSexualharassment includesconductthat is criminal in nature,such as rape,sexualassault,dating violence,and sexuallymotivatedstalking.Even if a schoolreportspossiblecriminal conduct to thepolice,that doesnot relievethe schoolof its responsibilities underTitle lX,which are discussed Part Two. in
  9. 9. Must thesexualconduct unwelcorne? beYes.Conduct is considered unwelcomeif the studentdid notrequestor invite it and considered conductto be undesirable theor offensive. The ageof the student,the nature of the conduct,and other relevantfactors affectwhether a student was capableof welcoming the sexual conduct.A students submission the toconduct or failure to complain doesnot alwaysmean that theconductwaswelcome. F-xample1: A middle school student makesoffensivesexual jokes to another student,but the student doesnot object to the jokes or speakout againstthem.The studentsfailure to object doesnot mean that he or shehaswelcomedthe comments- F-nample2:A femalehigh schoolstudentwillingly kissesa male studenton one occasion. When the student subsequently attemptsto kiss her again,sheobjects, he but kisses anyway. her This subsequent is considered be kiss to unwelcomedespitethe welcomeness the first kiss. ofWbendoes sexualconduct "denyor limit a student ability toparticipate in or beneftfrom a scboolseducationprogram?"Two generaltypesof sexual conductcan deny or limit a studentsability to participatein or benefit from a schoolt program.Asdiscussed below,teachers and other schoolemployees engage canin either type of conduct,while studentsand third partiescanengage only one type. inOne form of sexual harassment occurswhen a teacheror otherschoolemployee conditionsan educational decisionor benefiton the studentssubmission unwelcomesexual to conduct.If this
  10. 10. occurs,it doesnot matter whether the student resistsand suffers the threatenedharm or submits to and avoidsthe threatenedharm.Sexualharassmentalso occurswhen a teacher,school employee,other student,or third party qeatesa hostile environmentthat is sufficiently seriousto deny or limit a studentsability toparticipate in or benefit from the schoolsprogram.Whether sucha hostile environment has been createddependson the particularcircumstances the incident(s).Relevantconsiderations of include,but are not limited to: how much of an adverseeffect the conduct had on the studendseducationl the type, frequency,or duration ofthe conduct; the iddntiry age,andsex the harasser(s) the victim(s), of and and the relationship betweenthem; the number of individuals who engagedin the harassing conduct and atwhom the harassment was directed; the sizeof the school,locationof the incidents,and contextin which they occurred;and whether other incidents occurredat the school involving different students.
  11. 11. The conductdoesnot necessarily haveto be repetitive. Ifsufficientlysevere, singleor isolatedincidentsCancreateahostile environment. Example 1: Throughout the school year,Student A repeatedlypasses sexuallyexplicit photographsto Student B during class.Thephotographs are offensiveto Student B, and, consequently, Student B is unable to concentrate during classor focus on the subject.Student A has created a hostile environment that limits Student Bs ability to participate in the class. Ellample 2: A high school student sexuallyassaulted another high school student on one occasionwhen the two were alone in a classroom. a result, the victim is As afnid of attending any classes coming into contact with or the harasser. Although this was an isolated incident, it is sufficiently severe create,a to hostile environment.Canyoung school cbildrenengage sexualltarassment? inSchoolpersonnelshouldconsiderthe ageand maturity ofstudentsin respondingto allegations ofsexual harassment.When determiningwhether a young child hascommitted sexualharassment, is important for teachers it and schooladministratorsto usegoodjudgment and common sense. Example 1: On one occasion,a first-grade student kisses gr"tb"lfirst-grade student on the cheekin the playground. This behavior doesnot constitute sexualharassmentl
  12. 12. Example 2zOn numerousoccasions over a period of severalmonths, a fifth-grade student inappropriately touchesanother fifth-grade student and makesoverdy sexualcomments and gesturesto that student.The conduct is unwelcome and resultsin the victims gradesfalling because or she is unable to concentrateon studying.This he behavior constitutessexualharassment.Are gay and lesbianstudents protectedfromsexualharassment?Title IX prohibits harassingconduct that is of a sexualnature if itis unwelcomeand deniesor limits a studentsability to participatein or benefit from a schools program,regardless whether the ofharassment aimed gayor lesbianstudentsor is perpetrated is by ^tindividualsof the sameor oppositesex.Title.IX doesnot addressdiscriminationor other issues relatedto sexual orientation. Example 1: Throughout football season, male member a of the high school football team makesunwelcomesexual advances toward another member of the football team. who is a homosexualmale.As a result,the victim quits the football team.This conduct is sexualin nature,unwelcome, and has denied the victim the ability to participate on the school,football team.This is sexualharassmentcoveredbv Title IX. Example 2: Studentsheckle another student with comments that are basedon the studentb sexualorientation but are not sexualin nature (r.g.,"g y studentsare not welcome at this table in the lunch roorrt).Even if these comments are unwelcomeand deny the studentsability to benefit from br participate in the schoolseducation program,the conduct is not sexual,and this is not sexual harassmentcoveredby Title IX. 8
  13. 13. PartTwo: Responding to SexualFlarassmentHora shoulda school respondwhen it receiwes information aboutaIIege sexuaI lt aras ment ? d sIf a student,his or her parent,or a responsibleemployee reportsthe harassment, a schoolemployee or observes harassment, thethe schoolshouldinform the harassed student(and the studentsparent dependingon the studentsage)of the options for formaland informal action and of the schools responsibilities, which arediscussed below.Resardless whether the victim files a formal ofcomplaint or r.q.r.ri, action,the schoolmust conducta prompt,impartial, and thorough investigationto determinewhat happenedand must take appropriatestepsto resolve situation. theIf other sources,suchas a witnessto the incident,an anonymousletter or phone call,or the media,report the harassment, theschoolshould respondin the samemannerdescribed aboveif itis reasonable the schoolto conductan investigationand the forschoolcan confirm the allegations. Considerations relevantto thisdeterminationmay include,but are not limited to, the: sourceand natureof the information: seriousness the allegedincident; of specificityof the information; objectivityand credibility of the sourcethat madethe report; ability to identify the allegedvictims; and cooperationfrom the allegedvictims in pursuingthe matter.What if the victim requests confdentiality or asksthat the complaintnot bepursued?The schoolshould take all reasonable stepsto investigateandrespondto the complaint in a manner consistent with a requestforconfidentialityfrom a student.If a studentinsiststhat his or her
  14. 14. name not be disclosedto the harasser, schoolsability to respond the maybg limited.The schoolalsomust consider responsibility its to provide a safeand nondiscriminatory environment for all students. Thus,the schoolmust weigh the confidentialityrequestagainstthe following factors: seriousness the alleged of harassment; age ofthe harassed student; and other complaintsthat the sameindividual hasharassed others. Elrample A female elementaryschool student describes an incident to her teacherthat involved another teacherforcing her to engagein sexualactivity.The student begsthe teacher to not tell anybodywhathappened.This a situationin is which the schoolsduty to provide all studentswith a safe environment might outweigh the studentsrequest.Additionally stateor local lawsmay requireschools report incidents toto the police.Doesa school bawe doanytbing aboutsexual to ltarassment aparticular ifincidentis not reported theschool? to If the harasser a teacheror anotherschoolemployee is and if theharassment occurswhile the schoolemployeeis acting,or reasonablyapperys be acting,in rhe contextof his or her responsibilities to toprovideaid,benefits, and services students, schoolis directly to theresponsible and must remedythe harassment for regardless ofwhetherthe schoolknew or shouldhaveknown that the incident occurred.If the harasser anotherstudent,a third party,ora schoolemployee iswho is n9t acjrfg within the contextof hii or her responsibiJityto provideaid,benefits, services students, or to then the schooiisresponsible investigatilg the conduct and taking appropriatesteps forto resolvethe situation onlywhen it knows or should hive known thatthe harassment occurred. l0
  15. 15. Example: It is well-known to studentsand staffthat graffiti of a sexualnature appears the sidesof on buildings throughout a schoolscampusin plain sight. The pervasiveness this harassmentmay be enough to of conclude that the school should have known that the harassment occurred.If so,then the schoolis responsible for investigating and respondingto the harassment regardless whether it receiveda specificcomplaint about of the graffitiWhat actions,if any, shouldschools while inaestigatinga takecomplaint?It maybe necessary schoolsto take interim measures for duringthe investigation of a complaint. For instance,if a student allegesharassment anotherstudent,the schoolmay keepthosestudents byseparated until the investigation complete. a teacheris the is Ifallegedharasser, may be appropriatefor the str-rdent transfer to it toanotherclass.It is a good practice for schoolsto keep the student who allegedthe harassment informed of the statusof the investigation.What does school a haoeto do once inaestigationis complete? theThe schoolmust notify the victim (and his or her parentsdepending on the ageof the victim) of the outcome of itsinvestigationand of anypunishments imposedthat directly relateto the victim, suchas an order for the harasser stay awayftom tothe victim.If the schooldetermines that a studentwas sexually harassed, theschool must take reasonable, prompt, age-appropriate,and effectiveaction to end the harassmentand prevent it from happeningagainto the victim or to others.If the schoolfails to do so,it mustremedy the effectsof the harassment the victim that could have onbeenavoided ifthe schoolhad responded prompdyand effectively. 11
  16. 16. In addition, if the harasser a schoolemployee is and if the harassmentoccurswhile the employee acting,or reasonably is appears be acting, toin the contextof carryingout his or her responsibiJities provide toaid,benefits,and services, schoolmust remedythe effectsof the theharassment the victim. on Erample 1: A teachersexuallyharasses eighth-gradestudent an in the schoolhallway.Thestudentis not in any of the teachers classes the teacheris not a hall monitor. However,in light of and the 4geand educational levelofthe studentand the statusand degreeofinfluence ofteachersin secondary the schools, student could reasonablvbelieve the teacherhad at leastinformal that disciplinaryu.rtjrority orr.r him or her.Therefore, conduct this is considered haveoccurredin the contextofthe teac-hers to responsibilityto provide aid,benefits,and services students, to and thus the schoolmust remedythe effectsof the harassment in addition to stoppingit and prlventing it from recurting. E><ample A faculty memberof a universitys 2: history departmentrepeatedly, overseveralweeks, touclresand makes sexually suggestive remarksto a femalegraduateengineering studentwhile waiting for the universityshutdebus,riding on the bus,and exiting the bus.As a result,the studentstopsusing the bu$and walftsthe long distances betweenher classes.This conductoccurredoutsideof the contextof the faculty members dutiesto provide aid,benefits,or services the student,and to thus the schoolis not requiredto remedythe effectsof the harassment. However,ifthe schoolfails to take reasonable and efFective action to end the harassment after it hasreceived notice of the harassment, schoolmust remedythe efibctsof the the harassment that could havebeenavoidedifthe schoolhad responded promptly and effectively. t2
  17. 17. What are someexamples oftbe stEs a scbool shouldtake to endbarassment prevent itfrom ltappening and again?The appropriatestepsshould be tailored to the specificsituation.Forexample, schoolmay needto developand publicize new policies theor conduct training. Depending on the natureand severityof theharassment, counseling, discipline,or further separation the victim ofand harasser y be necessary. mResponsive measuresshould be designedto minimize the burden onthe victim asmuch aspossible. the schoolkinitial response If doesnot stop the harassmentand preventit from happeningagain,theschool may needto take additional,strongermeasures.What are someexamples hozoa school remedy efectsof of can thesexualharassment?If the school is required to remedy the effectsof the harassmenton the victim, the rypesof action requiredwill vary dependingonthe circumstances. Example 1: A collegeprofessorsexually harassed student a in his or her classin the context of the professors duty to provide services the student.Consequendy, student to the was unable to concentrateduring classand did not learn the coursematerial.To remedythe effectsof the harassment, the schoolmay be requiredto take suchactionsas: . arrangingfor an independentassessment theof studentswork . xrungjng for the student to take the courseagain with a different instructor; providing tutoring; . making tuition adjustments; or . offering reimbursements professional for counseling. t3
  18. 18. Example 2: A high.schoolstudent informs the schoolanother srudent .tu* l,r, l..o r;*"11il;;il;"" that ; i:l avoid ,h"i;;;;" hirn,*: ti j!::.r,:rare.lrsa result, shehasmissed coming class ro some pop quizies.Ifthe schooldelays response this complaint its tovictim suffers andthe additionaieffects orirr. i."russment,missingadditional suchas p"p qurn;;;;; shehasto continue.gTing to classlate,the schoot *urtL*.ayrt.of the harassment couldnil;;;; that "d;;;,*" pr;.";J;f;;; responded::1"":ll1apqropriate promptly *nb.tir,.ly. this re.medy una In:":",,.": mayinclud. ..r.h actionsascalculating students the gradewithout a""rirg i; rh"-"students failureto taketfr. quirrrE,rJ"* the student opportuniryrake qi;,rr,;. ;;;d;;fo, to in.-n^1^.:mdependentassessment the srudent,s u of work. t4
  19. 19. PartThree: Reporting and preventing sexual Harassment Whoshouldre?ort incidentsof sexualharassment? AlFo-dl who sees sexualharassment occur shouldreport it; the individual neednot be the victim of the harassmenr. Schools should ensurethat employees clearlyunderstand extentof their the responsibilities reporting sexual for harassment. Tb ushomshoulda wictim or otherindiaidual reporttbe harassment?The harassment shouldbe reportedto a responsible schoolemployee, suchas a teacher, principal,faculiy member,administrator, security officer,uffir-utirr. u.iion oficer, orprofessional staffmemberin the office of studentaffaiis.Additionally, as every school must have a Titre-rxcoordinator, theharassment be reportedto this individual aswell. canA.t*9."j,pjr1nt, or other individual alsomay file a complainty]t!_the u.s. Department of Educations ofice for civilRights(OCR), asexplained below.what if the harasserthreatens retaliateagainstthe nictim if be or toshereportsthe incident? Title IX alsoprotects studentsfrom retaliation.The school must take stepsto prevent the allegedharasser anybody or elseat the school from retaliating againit the victim. s, ,,.p, i".r"a.informing students that lXprotects them from retaliation,making-surethat victimslitte how to report any future problems, know follow-up inquiries to seeif ihere t,irr. U."rrurryrr.*.an{ Sakin_gincidents.It alsomay be appropriate counser to the harasse, toensurethat he or she,.rnderstands retaliationis prohibited.If thatretaliationoccurs, schoolshouldtake strong responsive the actions. 15
  20. 20. What procedures must a schoolhatte in place to prewent sexualharassment and resolvecomplaints ?Every school must: issue a policy against sex discrimination;a adopt and publicize grievance procedures; and have a Title IX coordinator.What aregrieaance procedures?Grievanceprocedures internal schoolprocedures are that addressviolationsof a schoois policy againstdiscrimination,includingsexualharassment. Grievanceprocedures must providefor promptand equitableresolutionof complaintsof sexdiscrimination.The schoolshould make surethat its policy againstsexdiscriminationand grievance procedures widely distributed and areeasilyunderstoodby students, parentsof elementaryand secondaryschoolstudents, and employees. a minimum, studentsmust Atknow that the grievanceprocedure exists, know how it works, andknow how to file a complaint.When a studentor parent reportssexualharassment, schoolshould explainhow its grievance theprocedures work and offer the studentor parent the opportunity tousethem.If a studentor parentchooses not usethe schools to grievanceprocedures, doesnot relievethe schoolof its responsibilities that toinvestigateand take appropriateaction,asexplainedabovein PartTwo.WhatdoestbeTidelX coordinator do?The Title IX coordinatoris responsible coordinatinga schools forefforts to complywith and carry out its Title IXresponsibilities.Every schoolmust havea Title -IXcoordinator.Title lXcoordinatorsmust haveadequate training in sexualharassment and must be ableto explain the operationof the schoolsgrievance procedure. t6
  21. 21. Housdo I knouswho my schools is? Title IX coordinatorEvery schoolmust notify all studentsand employees the name, ofoffice address, telephonenumber of its Title lXcoordinator(s). and taketopreaent sexualharassment?What othersteps a school canOCRs experience showsthat the best way for a school to dealwith sexualharassment to prevent it from occurring in the first isplace.In addition to the requirements explained above(well-publicized nondiscrimination policy,grievance procedures, andTitle IX coordinator),a school may take a number of other stepsto preventharassment.For example, schoolmay conductperiodic sexual a harassmentawareness training for all schoolstafl including administrators,teachers, guidancecounselors, age-appropriate and and sexualharassment The training can include training for students.information on the rypesof conductthat will be considered sexualharassment and the rangeof possibleconsequences, damage thethat resultsfrom harassment, where studentscan find help,waystoopposeharassment, what to do about it. and toWhat is OCR, and hozudoI report incidentsof sexualharassmentthat ofice?OCR is the federalagencyresponsible ensuringthat schools forcomply with Title IX and other federal civil rights laws. One ofOCRs responsibilities to resolve is complaintsof discrimination,including sexual harassment complaints. OCR has L2enforcementofices locatedthroughout the country that carry outthis responsibility.An individual who wishesto file a complaintwith OCR should doso by contactingthe enforcement office responsible the statein forwhich that schoolis located. find out which office is responsible Tofor your stateand how to contactthem, cali 1-800-42L-3487or t7
  22. 22. check OCR Web http://www.ed.govlocr.complaint must be fiJedwithin Generally,the rso a."^ of the date of the incident. and parentsarenor required*9:1" to usea school,s grievanceproceduresbeforefiling a compliantwith OCRwhere canr get rnoreinlformation about a schoo,s responsib,itiestoaddress preoent sexualbarassrnent? andPleaseread ocRs Rerisedsexual HarassrnentGuidance: Harassmentof Studentsby Scbool Emptoyrrr,,Oiirl{ndents, oravailableotr-thr Deoartments Third parties, web site at http://www.ed,.gov/ocr/publications.html fr"- "i OCn."f"*ement office. ""y 18
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