BEFORE THE UNITED STATES DEPARTMENT OF EDUCATION
OFFICE FOR CIVIL RIGHTS
_______________________________________________
)
MC HENRY, RICARDO HENRY, and WEDDEE )
HENRY, ) COMPLAINT UNDER
) TITLE VI OF THE CIVIL
) RIGHTS ACT OF 1964
Complainants, )
)
v. )
)
)
)
AMOS A. LAWRENCE SCHOOL and PUBLIC
)
SCHOOLS OF BROOKLINE, )
)
)
Respondents.
_______________________________________________
1
I. INTRODUCTION
In the last year, MC Henry, a Black eighth-grade student who attended Amos A. Lawrence
School (“AALS”), experienced multiple incidents of egregious racial harassment and physical
violence by other students. MC and their1 parents, Ricardo and Weddee Henry (collectively,
“Complainants”), bring this Complaint against AALS and Public Schools of Brookline (“PSB”)
(collectively, “Respondents”), for their ongoing and persistent failure to prevent and remedy the
racial harassment that MC experienced while in the school’s care. This harassment ranged from
being called racially derogatory slurs, such as “cotton picker,” to the most recent incident, where
a white student placed his knee on MC’s neck while MC was on the ground, and yelled, “George
Floyd! George Floyd!”––a painful reference to the Black man whose murder at the hands of
Minneapolis police officers sparked a nationwide outcry for racial justice.2
Instead of adequately addressing the harassment, Respondents attempted to sweep it under
the rug, diminishing the severity and harm of these traumatic incidents. Skeptical of AALS’s and
PSB’s ability to protect MC, Complainants have left PSB altogether seeking a safer educational
setting for MC. Respondents’ delayed response and failure to address these incidents of racial
bullying violates Title VI of the Civil Rights Act of 1964 (“Title VI”), 42 U.S.C. § 2000d et. seq.,
divests MC of their right to a safe learning environment, and places other Black students like MC
at risk.
1
MC’s pronouns are they/them. This Complaint uses these pronouns accordingly. See Foote v. Town of Ludlow, No.
22-CV-30041, 2022 WL 18356421, at *5 (D. Mass. Dec. 14, 2022) (“Addressing a person using their preferred
name and pronouns simply accords the person the basic level of respect expected in a civil society generally, and,
more specifically, in Massachusetts public schools where discrimination on the basis of gender identity is not
permitted.”).
2
Manny Fernandez & Audra D.S. Burch, George Floyd, From ‘I Want to Touch the World’ to ‘I can’t Breathe,’
New York Times (April 20, 2021), https://www.nytimes.com/article/george-floyd-who-is.html. See also U.S.
Department of Justice, Office of Public Affairs, Three Former Minneapolis Police Officers Convicted of Federal
Civil Rights Violations for Death of George Floyd (February 24, 2022), https://www.justice.gov/opa/pr/three-
former-minneapolis-police-officers-convicted-federal-civil-rights-violations-death.
2
Racial harassment among youth, such as that experienced by MC, is a significant and
growing problem in Massachusetts and throughout the country.3 These types of incidents are
devastating to students, as race-based bullying and harassment can have significant long-term
social, emotional, and physical impacts on adolescents, including lower grades, low engagement,
and greater risk for depression, suicide ideation, and substance abuse.4
Accordingly, Complainants respectfully request that the U.S. Department of Education’s
Office for Civil Rights (“OCR”) open an investigation and enforce compliance with civil rights
laws at AALS and PSB. We further urge OCR to mandate Respondents to take immediate and
decisive action to address racial bullying and the racially hostile educational environment that
Respondents have created and allowed to persist.
II. JURISDICTIONAL FACTS
A. The Parties.
MC Henry is a 14-year-old Black student who attended AALS in Brookline, Massachusetts
starting in kindergarten. They have recently completed eighth grade at AALS. Complainants
Ricardo and Weddee Henry are MC’s parents.
3
For example, in October of 2023, a 13-year-old Black student was called a “monkey” at Concord Middle School; a
group of white students yelled the N-word during Hamilton-Wenham Regional High School’s 2023 junior prom; a
Black student at Wayland Middle School was called the N-word during a track meet in 2023; and in February 2024,
a white student spit on a Black student from Pittsfield during a basketball game at Worcester State University. See
Alexis Rickmers & Oren Sellstrom, Racial bullying in schools is on the rise-including here in Mass., WBUR
(October 19, 2023), https://www.wbur.org/cognoscenti/2023/10/19/racial-bullying-george-floyd-alexis-rickmers-
oren-sellstrom; see also Michael Goot, Pittsfield player: Being spat on ‘traumatic’; School rips athletic association
for not addressing racial slurs, WNYT (March 14, 2024), https://wnyt.com/top-stories/pittsfield-player-being-spat-
on-traumatic-school-rips-athletic-association-for-not-addressing-racial-slurs/.
4
See Maria Xu, Natalia Macrynikola et al., Racial and Ethnic Differences in Bullying: Review and Implications for
Intervention, NATIONAL LIBRARY OF MEDICINE (October 18, 2019),
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7453877/; see also Valerie A. Earnshaw, Sari L. Reisner et al.,
Stigma-based bullying interventions: A systemic review, SCIENCEDIRECT (June 2018),
https://www.sciencedirect.com/science/article/abs/pii/S0273229717300138.
3
Respondents Amos A. Lawrence School is a kindergarten to eighth grade school within the
Public Schools of Brookline school district. Only 4.6% of students at AALS identify as Black.5
B. Timeliness.
This Complaint is filed within the applicable 180-day period required by OCR as the
incidents of racial harassment MC experienced occurred between December 2023 and April 2024.
C. Receipt of Federal Funds.
OCR has jurisdiction over this Complaint as Respondents receive significant federal
funding subjecting them to compliance with federal civil rights laws. For example, in 2024, PSB
received over $3 million dollars in federal funds.6
Under Title VI, public schools that receive federal funding are prohibited from
discrimination based on race, color, or national origin. See 42 U.S.C. § 2000d (“No person in the
United States shall, on the ground of race, color or national origin, be excluded from participation
in, be denied the benefits of, or be subjected to discrimination under any program or activity
receiving Federal financial assistance.”).
5
Massachusetts Department of Elementary and Secondary Education (“DESE”), School and District Profiles:
Brookline, Lawrence, https://profiles.doe.mass.edu/profiles/student.aspx?orgcode=00460030&orgtypecode=6& (last
visited June 10, 2024).
6
This includes an Early Childhood Special Education (“ECSE”) Program Federal Entitlement Grant, an Individuals
with Disabilities Education Act (“IDEA”) Federal Special Education Entitlement Grant, a Strengthening Career and
Technical Education for the 21st Century Act (“Perkins V”) Secondary Grant, a Title IV, Part A: Student Support
and Academic Enrichment Grant, a Title III: English Language Acquisition and Academic Achievement Program
for English Learners and Immigrant Children and Youth grant, Title 1, Part A, and Title II, Part A: Supporting
Effective Instruction––all separate sources of federal funding. See DESE, State and Federal Entitlement And
Allocation Grants by District: Brookline, https://www.doe.mass.edu/grants/entitlement-
allocation.aspx?view=district&fy=2024&code=0046 (last visited June 10, 2024).
4
III. FACTUAL BACKGROUND
During MC’s final year at AALS, they endured multiple instances of targeted and
racialized bullying, which Respondents failed to prevent and remedy.
A. “Cotton Picker” Incident.
In or about December 2023 during their health class, a male student sitting next to MC
accidentally dropped his dry cereal. When MC tried to help him pick it up, the other student
abruptly said: "I don’t want your help, you cotton picker.” Deeply upset, angry, and shocked, MC
immediately reported the incident to their teacher and later discussed it with their school counselor.
MC recognized that this derogatory slur evoked the painful legacy of U.S. chattel slavery and the
Jim Crow era and regarded it as a deeply offensive attack on their identity, culture, and racial
background.
When MC’s parents became aware of this racial incident, Ms. Henry contacted the school
counselor and requested mental health support for MC. In addition, Ms. Henry requested that the
school arrange a meeting between the Henrys and the perpetrator’s parents to be able to convey to
them the harmful nature of their son’s slur. The counselor initially assured the Henrys that they
would facilitate this meeting. However, the meeting was ultimately not held. Instead, all that the
counselor did was to tell the perpetrator to talk to MC and apologize. Unsurprisingly, given the
lack of any other meaningful consequences, this effort was unavailing, with the perpetrator
mouthing the required “apology” but refusing to acknowledge the harmful nature of the remark.
The Henrys were never given an adequate explanation for the school’s back-tracking;
however, the school counselor began referring to the slur as “just a joke.” She also began claiming
that a meeting between the parents would be “challenging” because the perpetrator’s parents do
not speak English (ignoring legal mandates to provide interpretation). Not only did the promised
5
meeting never occur, but, on information and belief, the perpetrator was never disciplined in any
way.
B. George Floyd Re-enactment Incident.
A subsequent incident of targeted racial bullying included an act of physical violence
against MC. On or about April 11, 2024, while attending their music conservatory class, MC
tripped over a piece of equipment. While MC was still on the floor, a white student knelt down,
placing his knee directly on MC’s neck, and exclaimed, “George Floyd! George Floyd!,”
grotesquely mimicking the horrific murder of George Floyd, who suffocated as a police officer
pressed his knee on Floyd’s neck. The student continued to press his knee forcefully into MC’s
neck until MC’s friend intervened. MC and other students were shocked by the behavior, leaving
many of them questioning how this student could feel emboldened to act in such a violent way.
After this horrific incident, MC was so traumatized that they did not want to reveal the
incident to their parents. The weight of the painful experience, however, became too much to bear,
and about two weeks later, MC finally confided in their mother about the violence. On April 29,
2024, at home around 10:30 P.M., MC paced in the living room. Mrs. Henry, alarmed by MC’s
anxious demeanor, asked if MC wanted to talk about anything. MC was initially hesitant, but
ultimately told their mother about the physical attack. This retraumatized MC, causing them to
again experience severe physical and emotional symptoms of anxiety.
MC felt deeply humiliated by this incident, leading to severe anxiety that manifested
physically through crying and body shakes. MC was also upset that a student would mock the
death of a Black man at the hands of police officers. This callous behavior made it difficult for
MC to process their complex and painful emotions. MC’s trauma manifested as a change of
character and demeanor noticed by their parents and teachers as MC became more reserved. MC
6
also avoided any interactions with the perpetrator and feared being ostracized and stigmatized at
school if they talked about the racist incident.
The same night that Mrs. Henry became aware of the George Floyd incident, she texted
the school counselor requesting immediate support for MC. The school counselor spoke to MC
the next day, and MC shared all the details of the attack, including the name of the perpetrator.
Afterwards, on April 30, 2024, the school counselor relayed to Mrs. Henry via text message that
she understood the gravity of the situation. She stated that she “was so upset to hear what [MC]
reported….” She also assured Mrs. Henry that the school would take appropriate action. She said
that “[AALS] will be taking this super seriously…[The principal] will consult with [the] office of
educational equity.”
The next day, AALS Principal Vanessa Bilello informed the Henrys that the perpetrator
was not present in school due to unrelated circumstances. Principal Bilello promised, however,
that AALS would keep them abreast of any further action. When the Henrys heard nothing further,
on or around May 2, 2024, Mr. Henry went in person to Principal Bilello’s office to urge the school
to take the incident seriously and to request a meeting with the perpetrator and his parents.
Principal Bilello reassured Mr. Henry that the school would take action, including working with
the Director of Education Equity. In the following days, Principal Bilello assured the Henrys that
the perpetrator’s parents would be meeting with her. However, the Henrys received no further
communication about whether the meeting was held or any action plans that followed, and no
follow-up meeting with the Henrys was ever scheduled.
On May 7, 2024, increasingly alarmed that the school was taking no action, Mr. Henry
emailed both Principal Bilello and Linus Guillory, Superintendent of Brookline Schools, regarding
the pattern of harassment MC was experiencing and AALS’s inaction. He received no response
7
for nearly two weeks. Finally, on May 18, 2024, PSB’s Senior Director of Education Equity
responded saying: “[AALS staff] have been actively remaining student-centered in supporting
[MC]. With that said, I also want to acknowledge your concerns and disappointment as parents did
not hear from the administration with a follow-up.” Even after acknowledging AALS’s inadequate
response, the school has yet to take meaningful steps to address the recurrent racial harassment.
These incidents of racial bullying underscore Respondents' failure to tackle the pervasive issue of
racial bullying within the student body.7
The Henrys are dismayed by the inaction and inadequate responses from AALS and PSB.
MC has been deeply hurt and humiliated by the racial harassment and fears social isolation and
stigmatization. This has led MC to become more withdrawn and rightfully skeptical of the school’s
ability to ensure their safety. Of particular concern is MC’s loss of trust in the school counselor,
who had previously been a vital source of support. Consequently, MC’s parents have been forced
to seek external mental health services to assist MC in overcoming the racial harassment, violence,
and trauma.
Respondents' failure to protect MC is also part of a larger pattern of systemic issues
affecting students of color within the district. PSB has a well-documented history of failing to
close the racial achievement gap, highlighting deeper, pervasive inequities. This year’s 2023
MCAS results starkly illustrate this persistent racial issue:
7
This is especially troubling given that PSB students have been circulating a PowerPoint filled with racist and
homophobic content. MC has personally seen and heard about it from other students. This further highlighting the
Respondents’ systemic neglect and inability to create a safe and inclusive environment for all students.
8
• In math, 76% of Black students and 60% of Hispanic students in grades three
through eight did not fully meet expectations, compared with 26% of white students
and 14% of Asian students.8
• In language arts, the gap was similarly alarming: 66% of Black students and 51%
of Hispanic students did not fully meet expectations, compared with 25% of white
students and 26% of Asian students.9
This broader context of systemic neglect magnifies the district's inadequate response to the racial
harassment MC faced, revealing a profound failure to create a safe and equitable learning
environment for all students, particularly students of color.
IV. Legal Analysis
A. Violations of Title VI of the Civil Rights Act.
Title VI states that recipients of federal funding may not exclude individuals from
participation in their programs or activities based on race, color, or national origin.10 Public
schools, such as AALS, and school districts, such as PSB, that receive federal funds are subject to
this mandate.11
Courts have long held that Title VI is violated where schools act with deliberate
indifference, failing to take adequate measures to prevent racial bullying and harassment against a
student. A hostile environment is created when race-based harassment is so severe, pervasive, and
8
See Jeremy Margolis, MCAS Scores Show Vast Racial Achievement Gap Remains in Brookline Schools,
Brookline.News (Sept. 25, 2023), https://brookline.news/mcas-scores-show-vast-racial-achievement-gap-remains-
in-brookline-
schools/#:~:text=According%20to%20the%20latest%20enrollment,%25%20identify%20as%20multi%2Dracial.
9
Id.
10
42 U.S.C. § 2000d.
11
34 C.F.R. § 100.13(i) (2000) (defining “recipient” to include any public “agency, institution, or organization, or
other entity. . . in any State, to whom Federal financial assistance is extended”); see also 34 C.F.R. §100.13(g)(2)(ii).
9
objectively offensive that it denies or limits a student’s ability to benefit from a school’s programs
or activities. Zeno v. Pine Plains Cent. School Dist., 702 F.3d 655, 665-66 (2d Cir. 2012); accord
Sewell v. Monroe City School Board, 974 F.3d 577, 584 (5th Cir. 2020); Bryant v. Independent
School Dist. No. 1-38, 334 F.3d 928, 934 (10th Cir. 2003). Depriving a student of a supportive,
scholastic environment free from racism and harassment constitutes a deprivation of educational
benefits under Title VI. Zeno, 702 F.3d at 667; see also DiStiso v. Cook, 691 F.3d 226, 242-43 (2d
Cir. 2012). Deliberate indifference is shown when a school’s response to harassment (or lack
thereof) is clearly unreasonable in light of the known circumstances. Davis Next Friend LaShonda
D. v. Monroe County Bd. of Educ., 526 U.S. 629, 631 (1999).12 Under the deliberate indifference
standard, the action or inaction by the school needs to “at a minimum, cause students to undergo
harassment or make them liable to or vulnerable to it.” Id. at 645.
Here, MC was subjected to a hostile environment based on race that was severe, pervasive,
and objectively offensive; and Respondents’ inaction to address the harassment was clearly
unreasonable in light of the known circumstances.
Courts have consistently found that repeated slurs and insults create a hostile
environment.13 Racially charged terms such as “cotton picker” 14 are widely recognized racial
epithets that conjure memories of the violent and dehumanizing experiences of Black people who
were forced into slavery in the U.S. They are a direct connection to the subjugation and oppression
of Black people for over 400 years,15 and as such are objectively offensive. In fact, courts have
12
While Davis construed the deliberate indifference standard in the context of Title IX, lower courts have used this
standard in Title VI cases where student-on-student harassment is alleged, since Congress based Title IX on Title
VI. See, e.g., Bryant v. Independent School Dist. No. I-38 of Garvin County, 334 F.3d 928, 934 (10th Cir. 2003).
13
See Pine Plains Cent. School Dist., 702 F. 3d 655, 666-67 (2d Cir. 2012) (explaining that being called the N-word,
‘homey’, and ‘gangster’ went beyond ‘simple acts of teasing and name-calling among school children’).
14
See also Gene Demby, When Boys Can’t Be Boys, NPR, (November 2, 2018),
https://www.npr.org/sections/codeswitch/2018/11/02/417513631/when-boys-cant-be-boys (explaining why terms
such as “boy,” directed at Black people, are racially charged).
15
Id.
10
consistently found that the term “cotton picker” is racially discriminatory. See, e.g., Wilson v. Port
City Air Inc., No. 13-CV-129, 2014 WL 2480082, at *3 (D.N.H. June 3, 2014) (allowing
discrimination lawsuit and finding that “cotton picker” is “racially offensive language”); see also
McGinnis v. U.S. Cold Storage, No. 16-CV-8841, 2018 WL 2320930, at *5 (N.D. Ill. May 22,
2018) (allowing discrimination lawsuit and finding that “cotton picking” is a “racially charged
epithet []”).
The severity of the racial harassment that MC endured can also be seen in the toll that it
has taken on their mental health. MC has become withdrawn, anxious, and fearful of social
interactions. The type of psychological impact that MC has experienced is not uncommon and, in
fact, has been well-documented for years in scientific literature: identity-based harassment can
impact an individual’s sense of self-worth and belonging;16 disrupt a healthy development of racial
identity;17 cause long term mental and physical health issues;18 and erode trust in peers and
authority figures.19
The U.S. Court of Appeals for the First Circuit has recently underscored this point by
highlighting the harmful psychological impact of identity-based derogatory messages on students
whose identities are demeaned. L.M. v. Town of Middleborough, 103 F.4th 854 (1st Cir. 2024).20
The court noted that derogatory messages “strike[] a person at the core of [a student’s] being” and
“poison the educational atmosphere due to [their] serious negative psychological impact on
16
Sidney H. Hankerson et al., The Intergenerational Impact of Structural Racism and Cumulative Trauma on
Depression, The American Journal of Psychiatry (June 2022).
17
Id.
18
Jonel E. Emlaw et al., Racial Discrimination and Hypothalamic-Pituitary-Adrenal Axis Dysregulation in
Adolescents With Overweight and Obesity: Does Context Matter?, Psychosomatic Medicine (October 2023).
19
Karen Chow, Bullying Prevention: Shaping Empathy and Understanding, Housman Institute (Feb. 15, 2024),
https://www.housmaninstitute.com/blog/bullying-prevention-shaping-empathy-and-understanding.
20
The L.M. case involved a student who asserted a First Amendment right to wear a shirt to school that said, “There
Are Only Two Genders.” Id. at 860. In ruling against the student, the First Circuit repeatedly noted that statements
that “demean [] personal characteristics – like race, sex, religion, or sexual orientation” can have significant
deleterious effects on students who identify with these characteristics. 103 F.4th at 868.
11
students with the demeaned characteristic.” Id. at 873-74 (citations and quotations omitted). Courts
have consistently found that such slurs are particularly dangerous when directed at young people,
and psychological harassment in educational settings may cause more permanent trauma and
damage than physical harassment.21
The severity and offensiveness of MC’s racial harassment was compounded by the most
recent incident where a white student placed his knee on MC’s neck, echoing the tragic events
surrounding George Floyd’s death. This student’s actions, reminiscent of Mr. Floyd’s final
moments, which sparked the largest mass protest movement in U.S. history for racial justice and
against police brutality,22 cannot be dismissed as innocuous. The re-creation of such circumstances
is unconscionable and constitutes severe harassment that is objectively repugnant. This constitutes
a violent physical attack.
MC’s harassment has also been pervasive. See Marion Independent School Dist., 804 F.3d
at 409 (concerted racial bullying constitutes pervasive harassment). Respondents’ failure to act
opened the door to heightened harassment, from racial epithets to physical escalation. In a matter
of months, MC’s bullying evolved from a racial slur to physical violence, mocking the murder of
George Floyd.
Moreover, Respondents have been deliberately indifferent to this racial harassment, and
have failed to take meaningful corrective action to prevent and remedy it. Respondents received
actual notice of the incidents and did not act. After MC was called a “cotton picker,” AALS staff
failed to impose any discipline or consequences at all. The only step they did take––to tell the
21
See e.g., Trachtman v. Anker, 563 F.2d 512, 520 (2d Cir. 1977) (Gurfein, J., concurring) (observing that in a high
school setting "a blow to the psyche may do more permanent damage than a blow to the chin"); see also Nuxoll ex
rel. Nuxoll v. Indian Prairie School District #204671, 523 F.3d 668, 671 (7th Cir. 2008) (collecting social science
literature).
22
Audra D. S. Burch et al., The Death of George Floyd Reignited a Movement. What Happens Now?, New York
Times (June 23, 2023), https://www.nytimes.com/2021/04/20/us/george-floyd-protests-police-reform.html.
12
perpetrator to apologize––was exceedingly minimal, and arguably harmful. A forced “apology”
trivializes the severity of racial bullying, suggesting that the harm is minor, and that the victim is
at fault if they do not immediately forgive the conduct. It provides no accountability for the
perpetrator, particularly where—as here—it is not accompanied by any meaningful consequences
or restorative actions. Respondents also failed to offer MC any additional support to help them
cope with the aftermath of the incident. Following the subsequent George Floyd incident, there
was again a failure by AALS to take meaningful or decisive action––only promises of intervention
without any actual implementation.
Courts have long acknowledged that student security encompasses more than just
protection from physical harm; it also includes protection from “psychological attacks that cause
[the child] to question their self-worth.” L.M., 103 F.4 at 869. That is because speech that attacks
“a ‘core characteristic’ of a minority group’s identity has a “detrimental” effect on [students’]
psychological heath … [and] educational development.” Id. Respondents failed to provide this
protection to MC. AALS’s failure to recognize the implications of the racial slur is in direct
opposition to the school’s inherent responsibility to keep all children emotionally and physically
safe. This oversight perpetuates racial inequality for Black students, obscuring MC and other Black
students’ access to a supportive, discrimination-free school environment. AALS has the utmost
responsibility to ensure that this behavior is not allowed by any students, and to educate their
students on the implications and harm of racial biases and hate speech.
This pervasive harassment has had a concrete, negative effect on MC’s education. See
Monroe County Bd. Of Educ., 526 U.S. at 654 (“The harassment must have a concrete, negative
effect on the victims’ education...”). MC has become more trepidatious of their peers, and their
social interactions have changed. MC has lost trust in the administrators, teachers, and students at
13
AALS. MC and the Henrys no longer believe that PSB is a safe, supportive environment. MC’s
reaction to this abuse is consistent with a vast body of social science research, which shows that
race-based bullying can have negative physical, mental, and emotional impacts on students and
has been linked to suicide, self-harm, depression, and substance abuse in severe cases.23
In sum, MC was deprived of a supportive and safe educational environment. Respondents’
failures have allowed the racially hostile environment to persist and escalate, culminating in
physical violence. Respondents’ actions and inactions are an affront to human decency and dignity.
Respondents’ actions and inactions also violate Title VI of the Civil Rights Act.
V. Relief Requested
For all of the above reasons, Complainants respectfully request that OCR:
1) Conduct a comprehensive investigation of Respondents’ policies and practices
regarding race-based bullying and harassment in each of the PSB’s schools;
2) Issue a finding that the Respondents have violated Complainants’ rights under Title
VI by failing to remedy and prevent a racially hostile educational environment;
3) Ensure future compliance with Title VI and its implementing regulations;
4) Require Respondents to create and implement policies to protect vulnerable
populations of students against racial bullying and identity-based harassment;
5) Require Respondents to create and implement processes and procedures for victims to
report incidents of racial bullying;
23
Muhammad Waseem & Matteo Angelo Fabris, Empowering Students Against Ethnic Bullying: Review And
Recommendations Of Innovative School Programs, National Library of Medicine (October 2023),
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC10605012/#:~:text=According%20to%20Carter's%20theory%20of,
%20trauma%20%5B15%2C16%5D.
14
6) Require Respondents to create and implement procedures to ensure prompt, thorough
investigations of race-based bullying and harassment allegations;
7) Require Respondents to create and implement affirmative steps to remedy and
prevent hostile environments caused by racial bullying and harassment, including but
not limited to, providing age-appropriate information programs for students to
address racial harassment;
8) Reimburse Complainants for expenses incurred related to past and future therapeutic
services resulting from the racially hostile environment;
9) Require Respondents to provide mental health, social service, and other support to
victims of racial bullying and harassment; and
10) Require Respondents to adopt and implement “zero tolerance” policies and
procedures that discipline responsible parties for racial bullying and harassment.
Dated: July 22, 2024
Respectfully submitted,
/s/ Mirian Albert
Mirian Albert, Esq.
Oren Sellstrom, Esq.
Emily Cortes
Lawyers for Civil Rights
61 Batterymarch St, 5th Fl.
Boston, MA 02110
[email protected][email protected][email protected] 15
