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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF SOUTH CAROLINA
CHARLESTON DIVISION

NANCY MELLETTE AND THE UNITED STATES OF AMERICA
Plaintiffs,
v.
JAMES E. JONES, JR, et al.,
Defendants.

CASE NO. 2:93-0488-2
_____________________________________

CONSENT ORDER

This matter is before the court upon the motion of the United States for further relief; filed on November 20, 1996.

On June 28, 1996, following the Supreme Court's decision in United States v. Virginia, _ U.S. _, 116 S.Ct. 2264 (1996), the Board of Visitors of The Citadel, The Military College of South Carolina ("The Citadel"), voted to eliminate the gender requirement from its admission policy for the Corps of Cadets and to begin immediately accepting qualified women into the Corps of Cadets, effective the 1996-97 school year. On July 27, 1996, the Board approved a plan for assimilating women into the fourth class of the Corps of Cadets for the 1996-97 school year. At a hearing on August 12, 1996, the court ordered a recess and directed the parties to negotiate their differences concerning the plan. The parties agreed on a number of measures to be implemented, but several issues remained unresolved.

On August 14, 1996 this court entered an order directing The Citadel to "adopt a policy that requires the admission of women to the Corps of Cadets on terms constitutionally equal to those applied to men. It shall also develop a plan for the assimilation of women into the Corps in such a way as to 'eliminate [so far as possible] the discriminatory effects of the past and to bar like discrimination in the future.' [citation omitted]. In addition, said plan shall provide for this court to receive on a regular, timely basis sufficient information for it to determine that this order is being properly complied with." The defendants appealed from that order, contending that the plaintiff's request for declaratory and injunctive relief was moot. That appeal is still pending before the Fourth Circuit Court of Appeals.

On August 24, 1996, four women enrolled as freshmen in The Citadel's Corps of Cadets. On November 18, 1996, the defendants filed their plan for making reports to the court of defendants' integration and assimilation of women into the Corps of Cadets at The Citadel. On November 20, the United States filed its motion for further relief, including its proposal for the defendants making reports to the court. The United States' motion is now before the court.

On December 13, 1996, the defendants reported to the court that a report had been made of violations of the Fourth Class System involving two of the female cadets. Those two female cadets subsequently withdrew from the Corps of Cadets, and a number of male cadets left The Citadel or were disciplined for violations of the Fourth Class System as a result of the women's allegations.

On January 7, 8 and 9, the court held a hearing to determine whether any immediate precautions needed to be taken for the safety of female cadets. The court made no findings at that hearing but directed the parties to engage in discovery in preparation for an evidentiary hearing to evaluate the defendants' assimilation plan and the effectiveness of their assimilation efforts. By order entered on February 5, 1997, the court appointed Colonel Robert M. McDannell (USA, Ret.) as an expert witness pursuant to Rule 706 of the Federal Rules of Evidence to evaluate the assimilation plan and the defendants' assimilation efforts. Colonel McDannell conducted a study and filed his report on March 5, 1997.

The parties have engaged in extensive discovery, and this matter was scheduled for hearing beginning on May 19, 1997. On Friday, May 17, The Citadel's Board of Visitors approved a revised assimilation plan. The revised plan was made available to counsel for the United States on the afternoon of Sunday, May 18. At the start of the hearing on May 19, the parties and the court agreed to recess the hearing so that the United States could review the revised assimilation plan and meet with representatives of The Citadel to discuss its provisions. The parties met on May 19 and 20 and announced on the afternoon of May 20 that they had reached substantial agreement on virtually all provisions of the plan. The plan was revised again to reflect the agreement of the parties. This plan is entitled "Revised Plan for Assimilation of Female Cadets" and is attached to this order and incorporated herein by reference as Exhibit A. The Office of Attorney General for the State of South Carolina has been informed and was aware of the negotiations that culminated in this consent order and has voiced no objections to the attached plan. On May 22, 1997, the court heard testimony from various Citadel officials concerning details of the plan.

Upon review of the proposed plan presented by the parties and consideration of the evidence and testimony submitted to the court concerning the plan, the "Revised Plan for Assimilation of Female Cadets," attached hereto and incorporated herein as Exhibit A, is hereby approved, and the defendants are hereby directed and ordered to proceed immediately to fully execute and implement its terms and provisions as required to meet the deadlines set forth therein. The defendants are further directed to notify the court and counsel for the United States promptly in the event of any circumstance expected to result in failure to achieve the stated terms of the plan as approved.

This order is entered without prejudice to the position that the defendants have taken with regard to this court's August 14, 1996 order, and it is understood and agreed that by consenting to this order the defendants have not waived their position with regard to that order or with regard to the appeal presently pending before the Fourth Circuit Court of Appeals. The parties agree and stipulate, however, that this court possesses the jurisdiction and authority to enter this consent order. The defendants further stipulate that this consent order shall remain in full force and effect regardless of the outcome of the appeal.

This court shall issue a further order regarding reporting requirements.

AND IT IS SO ORDERED.

________________________________
C. Weston Houck
Chief United States District Judge
May __, 1997 Charleston, South Carolina

WE CONSENT:
THE CITADEL, ET AL.
_____________________________________
M. DAWES COOKE, JR.
Barnwell Whaley Patterson & Helms, LLC
P. O. Drawer H
Charleston, South Carolina 29203
(803) 577-7700

WE CONSENT:
UNITED STATES OF AMERICA
_____________________________________
MICHAEL S. MAURER
U.S. Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, N.W.
Room 7601
Washington, D.C. 20530
(202) 514-3812

The Citadel

Revised Plan for Assimilation of Female Cadets

1. ACTION ITEM 1: The Citadel shall establish a position in the Admissions and Recruitment Office not later than 1 July 1997, that will be responsible for coordinating all female recruiting and related tasks. This provision does not necessarily mandate a net increase in staffing. This person is responsible for developing and implementing recruitment activities with a specific focus on bringing qualified females into the Corps of Cadets. All recruitment staff will be responsible for recruiting both males and females.

2. ACTION ITEM 2: The Citadel shall immediately establish a position titled Assistant Commandant of Cadets and coded as Student Services Manager I, who reports directly to the Commandant, serves as an active role model for male and female cadets, provides input to policies and programs, serves as an assistant Title IX coordinator, and as a trainer in all assigned leadership classes. The main focus of this assistant commandant will be to plan, direct, coordinate, and supervise all aspects of the female cadet assimilation plan within the scope of the Commandant. This position shall be filled not later than 1 August 1997.

3. ACTION ITEM 3: The Citadel shall develop and conduct regular mandatory training in sexual harassment to include date rape and sensitivity for cadets, tactical officers, staff, and faculty. The schedule of training will be produced annually and disseminated to all No later than l August. The training will be progressive in nature utilizing a building block concept. The training will be needs based, tailored to The Citadel environment, and address both Title VII and Title IX issues. The training program and supporting materials will be developed in sufficient time to prepare instructors/facilitators to present the training effectively. An outside consultant will assist in the design and development of resource materials, training, presentation methods, and development/review of assessment tools and criteria as well as the assessment of the training program. The Citadel shall publish an annual program of instruction No later than l July 1997. Develop all lesson plans and supporting material by 15 July 1997. The Commandant, Vice President for Academic Affairs (VPAA), and the Director of Human Resources are responsible respectively for the training of cadets, faculty, and staff.

Training effectiveness will be assessed using instruments designed by The Citadel with the advice and assistance of an external expert consultant on both Title VII and Title IX issues. Copies of the training and assessment materials, as well as The Citadel consultant's recommendations, if any, will be provided to the Department of Justice's expert consultant for review and comment prior to August 1, 1997, for August and September training and No later than 30 Days prior to presentation for all other material. The consultant, training, and all training materials shall be fully funded. The trainers shall be certified by the Commandant of Cadets and the outside expert consultant through a certification program designed by the outside consultant.

4. ACTION ITEM 4: The Citadel shall maintain the Corps' support for coeducation. The Commandant shall provide a detailed leadership training program designed to obtain cadet support for females at The Citadel. A component of this leadership training is follow-up sexual harassment training. The training schedule and materials shall be provided to the Department of Justice for review and comment prior to 1 August 1997. The Citadel plans to conduct an exchange program with other coed military colleges to expand the number of upperclass role-models in the Corps and to provide Citadel cadets the opportunity to spend a semester at another military college starting in the fall of 1997.

5. ACTION ITEM 5: Two female members have been added to the Advisory Council to the Board of Visitors effective immediately.

Not later than the beginning of the fall 1997 semester, and until such time as a female is elected as a voting member, there shall be a female advisor to the Board of Visitors. This new member to the Board will be fully qualified for election to the Board. She will have non-voting power in her role as an advisor.

6. ACTION ITEM 6: At least eight additional TAC officers who have experience in mixed-gender settings shall be stationed in the barracks by fall semester 1997, with a goal of 17 to be stationed in the barracks by SY 1999-2000. Subject to the availability of qualified personnel, The Citadel shall assign a female tactical officer or female academic advisor in each battalion, beginning in the fall semester 1997. The Citadel shall aggressively seek out females to serve in these roles.

7. ACTION ITEM 7: In order to have mechanisms for discussing lessons learned and for collecting feedback from female cadets, the Commandant shall appoint female cadets as appropriate to existing College Committees. At a minimum, there will be female representation on the College Human Affairs Committee. The Citadel shall establish a Female Assimilation Study Group (FASG) to be formed in the fall semester that meets twice each semester and reports each semester to the President in writing. At least one of the two meetings each semester will include a briefing by the FASG to the female advisor to the Board of Visitors and will include, if possible, the female members of the Advisory Council.

8. ACTION ITEM 8: The Vice President for Engineering and Facilities shall conduct an annual assessment of the facilities needs on campus to meet requirements for an expanded coeducational Corps of Cadets for the near term and long term. This assessment will be done in concert with the appropriate level vice presidents. The recommendations for modifications to campus facilities requiring approval will be briefed to the President No later than 1 June of each year. Required modifications will be completed prior to 1 August. For 1997, female latrine facilities will be built in barracks 3 and 4 along the model of the 2nd battalion female latrine. Seven single room latrines in the stairwells of Watts barracks will be modified. Modesty screens for male latrines will be constructed in barracks 2, 3, and 4. Female lockers will be placed in the boat house.

9. ACTION ITEM 9: The Citadel shall sustain the procedure that requires maintenance personnel of the opposite sex entering an occupied cadet room to be escorted. The Citadel shall require all maintenance personnel who will have contact with cadets to attend a mandatory sexual harassment class oriented on Title IX issues prior to the arrival of cadats for cadre training. Classes in draft form to be completed by 1 July. Required review by consultant by 17 July 97. Presentation completed to all employees no later than 1 Aug 97.

10. ACTION ITEM 10: Inside latches shall be placed on the doors and blinds on the windows of female cadet rooms for 1997-1998 school year and this issue shall be restudied annually. As the presence of females expands into barracks that were previously all male, there will be a need for a period of transition which provides female cadets the privacy and security that latches and blinds provide. A decision brief shall be submitted in Fall 97 to Major General Grinalds on master plan for future years. Vice President for Engineering and Facilities is prepared to order latches and blinds for rooms as soon as they are identified for the fall of 1997. Room identification will be based on the number of female cadets who will matriculate.

11. ACTION ITEM 11: The Commandant shall ensure strict compliance with the uniform policy in the Blue Book to reflect a bath uniform (bathrobe, hat, shower shoes) and adopts the wording which states in substance that, "A bathrobe will be worn when not otherwise clothed (a towel wrapped around the body is not considered clothes and is prohibited) to go from cadet room to the latrine and return." Additionally, the current policy on uniform standards shall be maintained: "Cadets may not be improperly dressed in doorways or windows. Cadets indecently dressed in their rooms must not be visible to persons outside of the barracks or in the sallyports."

12. ACTION ITEM 12: The Citadel shall review, publish, and enforce policies under Title IX and Title VII dealing with sexual harassment. The cadet policy will focus on peer-on-peer harassment and cover both quid pro quo as well as hostile environments. The Blue Book will refer the cadet to the College policy on Sexual Harassment which will be issued to each cadet at the initial sexual harassment training session of the semester. The new policy is in final draft form and is in staffing at the VP level. The policy will be reviewed by The Citadel's outside expert consultant and shall be provided to the Department of Justice by 15 July 1997. After completion of staffing it will be published prior to 1 August and distributed to all cadets, faculty, and staff.

The Citadel shall publish complaint procedures in both the Blue Book and in a revised policy memorandum that will be posted on all unit Bulletin Boards. The policy statement will include the following, at a minimum:

1) The Citadel's policy prohibiting discrimination or harassment.
2) Formal and informal complaint procedures to be followed by cadets who believe that they have been victims of harassment or discrimination.
3) A listing of all persons who are available to cadets to receive reports of complaints.
4) The right and requirement for confidentiality in handling complaints.
5) Procedures to be followed in those cases of cadets who deliberately make false accusations.

The Citadel's outside consultant shall participate in the design of the training, the development of resource materials and lesson plans, the development of assessment tools and criteria, and the assessment of the training program. Copies of the training and assessment materials, as well as The Citadel consultant's recommendations, if any, shall be provided to the Department of Justice for review and comment prior to 1 August 1997 for August and September training. The remainder of training material for the year will be due No later than 30 days before class presentation. The training schedule has been tentatively drafted, subject to review by the consultant. Training will be fully funded. The trainers shall be certified by the Commandant of Cadets and the outside consultant based on a certification program established by the outside consultant.

The policies and procedures shall include but are not limited to the following: (1) A cadet Bill of Rights, to be issued to every cadet, setting forth each cadet's rights and responsibilities, and including appropriate numbers for cadets to contact; (2) Formal resolution procedures as described in the Blue Book; (3) Informal resolution procedures, including identified individuals such as the Ombudsman, who will be trained by the outside consultant; and (4) A readily identifiable, well qualified and properly trained Ombudsman, with specific job responsibilities, to be appointed by ths President by l5 August 1997, who shall serve as a trained and confidential source of informal resolution to receive complaints, to answer inquiries and to informally address a wide range of sexual harassment behavior. All communications with the ombudsman are to be absolutely confidential except violations of federal or state criminal law.

13. ACTION ITEM 25: Female cadets shall be afforded the opportunity and encouraged to participate in all intramural programs. The following intramural programs are open to all cadets in SY 97-98: flag football, (3x3,5x5 basketball), badminton, team racquetball, volleyball, softball, wallyball, soccer, cycling, swimming, Sigma Delta Psi, steeplechase, jogging, tennis, basketball free throw, basketball, golf, weight lifting, track, horseshoes, croquet, billiards, wrestling, canoe, and triathelon. Participation in a varsity or intramural program is required of all cadets.

14. ACTION ITEM 26: The Citadel shall identify female interest in club sports by issuing surveys to accepted students. During SY 1997-98, The Citadel shall make all efforts to establish female club sports as interest warrants. The Citadel currently offers the following Club Sports: cycling, boxing, crew, fencing, lacrosse, judo, skydiving, rugby, pistol, rifle, sailing, volleyball, scuba, and Tae Kwon Do. The Citadel shall allocate all necessary funds through the club sport program to support women teams when they are established. The Citadel places no restrictions on such activities and permits female cadets to participate in all club sports. Notice of the availability of sports activities shall be sent to all prospective female applicants. Recognizing the inherent difficulty of establishing female club sports because of the relatively small number of women presently enrolled in the Corps of Cadets, The Citadel shall provide reasonable financial support for club sports for women as correlated to their interest and increasing presence.

15. ACTION ITEM 27: The Citadel shall use the current locker/shower system for women in Deas Hall for SY 97-98. Based on the projected female cadet population for SY 97-98, the facility is adequate to meet current needs. The Citadel shall add the partitioning of the main locker room into the planning process for future years. The Citadel shall review the requirements each year in the early part of the second semester to ensure that the project is funded as required and that sufficient lead time for construction is available.

16. ACTION ITEM 28: Female cadets shall be encouraged to join all existing cadet activity organizations for which they are qualified. The qualifications shall be the same for all cadets. New cadet activity organizations for females may apply for charter in the same manner as any new organization. Female cadet membership in current Cadet Activities shall not require any changes to membership criteria.

17. ACTION ITEM 29: The Director of Cadet Activities shall continue to include female cadets in The Citadel Family Circle (Fourth Class Sponsor) Program as they were in SY 96-97. They will be given the full opportunity to be hosted by a Charleston area family in the same manner as male cadets.

18. ACTION ITEM 30: The Citadel shall identify female interest in the Bulldog Bullpup Program. The Director of Cadet Activities shall include female cadets in the Bulldog Bullpup Program if interest exists among elementary school girls and female cadets. Currently this program only includes members of the upper three classes based on the availability of time and transportation.

19. ACTION ITEM 34: The Vice President for Business and Finance shall insure adequate medical treatment and privacy for female cadets at the Infirmary. The Citadel medical staff shall perform the initial medical assessment on female cadets and treat any general illness. Treatment requirements beyond the capability of the Infirmary will be referred off campus, as is the case with male cadets. The Citadel shall continue the use of its agreement with an OB-GYN doctor for this year. The Citadel shall review ths contract status for on-site OB-GYN in future years based on the number of female cadets in the Corps on an annual basis. The Citadel shall also assess the adequacy of the infirmary facility for privacy of male and female cadets on an annual basis. The Citadel shall modify the facilities as required to meet privacy requirements based on the number of female cadets who will report in August. The Citadel has an agreement to have an OB-GYN available for female cadets on an as-needed basis.

Additional modifications to the Infirmary may require new funding or reprogramming of funds. The Vice President for Engineering and Facilities completed his on-site assessment on 12 May. The next milestone is a cost estimate to complete modifications and a funding source, if required, before 1 June 1997. If modifications are required, work must be completed no later than 1 Aug 97.

The Citadel shall develop a written temporary disability policy, not later than 1 August 1997, to be submitted to The Citadel's outside expert and to the United States' expert for review and comment, and shall be in effect for SY 97-98.

20. ACTION ITEM 35: The Vice President for Finance and Business Affairs shall insure that adequate bed, shower, and latrine facilities are available to accommodate in-patient females in the infirmary for SY 97-98 and beyond. Use the room currently set aside for female cadets which has its own latrine and shower. Assess the number of female cadets who will arrive in the fall and determine the need to construct an expanded facility. If expansion is required, complete modifications before the start of SY 97-98.

21. ACTION ITEM 36: The pregnancy policy was written last year for SY 96-97. The policy has been reviewed internally and determined adequate for SY 97 -98. The policy will be reviewed by The Citadel's outside expert consultant no later than 1 June 97. Any required revisions in the policy will be reprinted before 1 August 1997. The policy shall be consistent with The Citadel's temporary disability policy and Title IX. The consultant's recommendation and the policy will be provided to the Department of Justice by l5 July 1997 for review and comment.

22. ACTION ITEM 37: The Commandant of Cadets shall insure that the Fourth Class System applies equally to all cadets without regard to gender as to which members of the upper class may correct and discipline them. Make no changes to the Blue Book in terms of who may train, correct, counsel, or inspect members of the fourth class (male or female). The Citadel shall continue to emphasize, during the cadre training period, that direct interaction between the fourth class and upper classes is limited to cadre only. The Citadel shall also emphasize during cadre training that the use of sexually derogatory terms and references to gender in relation to fourth class cadets (male or female) regarding, conduct, appearance, or activities as a cadet is a poor leadership technique that will not be tolerated. The Citadel shall provide the same type of training to all upperclass cadets during leadership instruction to be received prior to the end of cadre training period and before the fourth class officially enters the Corps. The Citadel's training shall sensitize all cadet leaders, human relations officers, and tactical officers to be on alert for violations. The Citadel shall insure that on-the-spot corrections are made and report those cadets who do not comply for counseling and/or disciplinary actions as appropriate. The Citadel shall provide three additional hours of training during cadre for cadet leaders in companies with female cadets assigned.

The Citadel's outside consultant shall participate in the design of the training, the development of resource materials and lesson plans, the development of assessment tools and criteria, and the assessment of the training program. Copies of the training and assessment materials, as well as The Citadel consultant's recommendations, if any, shall be provided to the Department of Justice for review and comment prior to August 1997 for August and September training. The remainder of training material for the year will be delivered to the Department of Justice not later than 30 days before class presentation. The training schedule has been tentatively drafted, subject to review by the consultant. The consultant, training, and all training material will be fully funded. The trainers shall be certified by the Commandant of Cadets and outside expert consultant based on a certification program established by the outside consultant.

23. ACTION ITEM 38: The Commandant of Cadets shall take appropriate steps to insure that all members of the Fourth Class receive the same adversative system without regard to gender. The Fourth Class System as outlined and described in the Blue Book and further explained in the Citadel Training Model is applicable to all members of the Fourth Class, except as modified elsewhere in this Plan. The Commandant shall focus leadership training classes for all upperclass cadets on strict adherence to the provisions of the regulations and the focus on positive leadership techniques in all senior-subordinate relationships. The training shall sensitize all cadet leaders and tactical officers as to the provisions of the regulations and the need for them to correct and report violations of the system. A new Program of Instruction (POI) for leadership training shall be developed by the Citadel. The outside consultant shall review the materials and procedures. Review of Fourth Class system by the Commandant is completed as an initiative outside of the assimilation of female cadets. Program of Instruction for Corps Leadership training for SY 97-98 has been approved. Lesson plans for modules required by the end of the summer before the start of cadre on 1 August.

The Citadel's outside consultant shall participate in the design of the training, the development of resource materials and lesson plans, the development of assessment tools and criteria, and the assessment of the training program. Copies of the training and assessment materials, as well as The Citadel consultant's recommendations, if any, shall be provided to the Department of Justice for review and comment prior to August 1997 for August and September training. The remainder of training material for the year will be due not later than 30 days before class presentation. The training schedule has been tentatively drafted, subject to review by the consultant. The consultant, training and all training materials shall be fully funded. The trainers shall be certified by the Commandant of Cadets and the consultant based on a certification program established by the outside consultant.

The Counseling Center and the infirmary shall promptly inform the Commandant and the President of all incidents or suspected incidents of violence within the Corps of Cadets. Each semester, the Director of the Counseling Center and the doctor in charge of The Citadel's infirmary shall provide to the President through the Commandant a written report of incidents or suspected incidents of violence within the Corps of Cadets.

24. ACTION ITEM 45: As an example of an effective recruitment strategy, the Commandant of Cadets shall insure that female applicants for the band be aggressively recruited and assigned to the Band Company in close proximity to the existing female latrine on the 1st Division of Padgett Thomas Barracks. Facilities are available to meet the needs of approximately 20 female cadets without expanding current facilities.

25. ACTION ITEM 46: The Commandant of cadets shall insure that female cadets be assigned in order of priority to barracks 2, Watts barracks, 3, and 4 if density permits. Female latrines will be constructed in all four barracks this summer. As soon as female rooms are identified, a determination will be made concerning the need for window shades in female rooms. If possible, assign females to all four barracks. Females will be assigned in groups to create critical mass in a company to optimize success. Plan on a number of 24 female fourth class cadets in order to assign them to each barracks. With a number of 24 or more, female cadets shall be assigned to each barracks with six female cadets in each company for four companies. Assign upperclass female role models in those companies with female fourth class cadets. The goal is to have female cadets aligned to each barracks as quickly as possible.

26. ACTION ITEM 47: The Commandant of Cadets shall adopt an initial assignment policy for billeting female cadets in groups to a single company in each barracks. If females qualify for the Band, they shall be assigned to the Band area in No. 2 barracks. If only 3 females are in a company, place all in a four person room to minimize moving. The latrines shall be completed prior to the arrival of cadets in August. Cadet Commanders and subordinates have been selected and positions announced. The Commandant of Cadets is in ths process of identifying the company in each barracks that will have female cadets assigned if numbers permit. Once companies have been identified records of all cadet upperclass leaders in the company shall be screened to identify potential problem cadets.

27. ACTION ITEM 48: The Commandant of Cadets shall Review, publish, and evaluate the policy on proper leader-subordinate relationships, personal relationships, and social behavior to include dating and fraternization. The policy in place during SY 96-97 will be reviewed by the Citadel's outside expert consultant by 1 June 1997 and provided to Department of Justice by 1 July 1997 for review and comment, and published in the SY 97-98 Blue Book.

28. ACTION ITEM 52:The Commandant of Cadets shall use the Army's physical fitness standards for women at The Citadel. There shall be an annual assessment of the physical fitness standards and tests to be conducted by Citadel personnel, including a physician. Using the current testing standards, all cadets shall take the same test but are graded under scales developed by the U.S. Army based on physiological differences according to gender. Published standards are included in the SY 96-97 Blue Book and will be republished in the SY 97-98 Blue Book.

29. ACTION ITEM 53: The Commandant shall take aggressive steps to eliminate the use of offensive and/or derogatory terms by cadets concerning women or that would offend women. These steps shall include but are not limited to continuous reinforced training, severe punishment for cadets found to have violated the prohibition, and the issuance of memorandums periodically by the Commandant and/or the President.

30. ACTION ITEM 54: The Citadel's Strategic Plan has been updated to include the change of mission and goals and objectives to align the strategic plan with a coeducational Corps of Cadets. The new mission statement and strategic goals have been reworked and approved by the Board of Visitors.

31. ACTION ITEM 55: The Interim President has designated a specific staff officer to monitor and coordinate all aspects of the assimilation plan at the college level. This officer is detached from the implementation level of plans and policies in order to evaluate the effectiveness of implementation through an assessment process. This officer reports to the President through the VPAA. This officer has the authority to coordinate actions both internal and external to the college. The officer filling this position is detailed from another position and this is a temporary commitment. Major General Grinalds will continue the function and determine the permanent status for this position.

32. ACTION ITEM 56: The Public Affairs Officer shall publish a Public Relations Plan by 1 August 1997 that supports the efforts laid out in The Citadel recruiting strategy and in support of Citadel themes in relation to female assimilation. This plan shall be submitted to the President for approval and a copy forwarded to the Department of Justice prior to 15 July 1997 for review and comment.

33. ACTION ITEM 57: The Citadel highly encourages but does not require a prior campus visit for all candidates for admission. The requirement for a campus visit for all candidates for admission would severely restrict the applicant pool for out-of-state applicants. The Citadel shall, during the 1997-1998 school year, update The Citadel viewbook and video and make them more descriptive of the rigors and responsibilities of cadet life and the presence of female cadets. The Citadel shall produce a new viewbook, update the recruitment video, and update college literature. The Citadel shall pursue an aggressive personal contact campaign using the recruiting office as well as alumni.

34. ACTION ITEM 58: The Dean for Planning and Assessment shall develop a formal assessment plan for female assimilation in coordination with the Female Assimilation Staff Officer and all Vice Presidents having assimilation responsibilities. Assessment criteria and success outcome will be assigned for each action item in the female assimilation plan. The Citadel shall use an outside expert consultant to assist in the development of the assessment instruments and the assessment process. The Citadel's outside expert consultant shall be provided with a copy of The Citadel's current strategy and proposed assessment instruments and to make modifications as required before the start of 1 August 1997.

The Citadel's outside consultant shall participate in the design and development of assessment tools and criteria, and in the implementation of them. Copies of the assessment materials, as well as The Citadel consultant's recommendations, shall be provided to the Department of Justice for review and comment prior to 1 August 1997.

35. ACTION ITEM 59: The Commandant of Cadets shall assess all candidates for cadet leadership positions to insure that they are affirmatively supportive of the assimilation efforts. Cadets' support for assimilation shall be established as a specific criterion for selection to leadership positions. TAC officers shall be instructed to apply this criterion to their selection of lower ranking cadet leaders. The Office of the Commandant shall manually screen the records of all cadet leaders to dateline if there are any past discipline matters that are potential problems requiring reassignment or resolution prior to the start of the cadre period. This records review shall be completed and final decisions made by the Commandant in time for cadre training in August 1997.

36. ACTION ITEM 61: The Board of Visitors sent a resolution to the Association of Citadel Men ("Association") to change its name to gender neutral terminology. This resolution has been received by the Association and is an action item for November 1997. A name change will require a resolution by the Association and a vote of the membership.

37. ACTION ITEM 62:The Citadel shall adopt the theme of "Make The Citadel the best coeducational military college in America." The theme was adopted by the Board of Visitors and articulated through speeches and interviews given by Board members as well as the President. This theme shall be used as the common thread in all publications and marketing campaigns.

38. ACTION ITEM 63: The Vice President for Business and Finance shall develop a cost coding system that identifies all funding expended for the Assimilation Plan. All departments shall utilize this code whenever they expend funds for the assimilation of females for the purpose of documenting the cost of assimilation. Cost data should be used for future assessments and to justify additional State funding if required. This system shall be in place before the start of FY 97-98.

The Citadel shall take all necessary measures to fund this assimilation plan including but not limited to solicitation of funds from the State, the Citadel Development Foundation, and other sources.

39. ACTION ITEM 65: The Citadel shall form a task force whose membership includes representatives from the Health & Physical Education Department, the Office of the Commandant, the Infirmary, and the trainers. The task force shall develop a physical fitness training and marching plan for SY 97-98 that will reduce the numbers and negative effects of all injuries and illnesses that have a disparate effect on women. The Citadel shall provide comprehensive in-service training for all Citadel infirmary personnel and contractors on an annual basis. For 1997-98, such training shall include but not be limited to six (6) hours of training in gynecological-related medical issues and six (6) hours of training in women's orthopedic issues to increase knowledge and awareness; thereafter on an annual basis, an equivalent amount of training in related health issues shall be provided. The task force shall meet during the summer months and develop a proactive training strategy to minimize injuries in these areas. The strategy shall be in place prior to the start of the cadre training period.

Training shall be fully funded and shall be completed by the end of September the first year and by the end of the first semester each year thereafter.

40. ACTION ITEM 66: The Citadel shall develop and execute a comprehensive human affairs plan to include goals, training, an action plan, milestones, and benchmarks for assessment. Initial staffing is completed. The training schedule has been tentatively drafted.

The Citadel's outside consultant shall participate in the design of the training, the development of resource materials and lesson plans, the development of assessment tools and criteria, and the assessment of the training program.

The formal staffing at the Vice President level and decision by the President will occur on or about 1 July 1997.

Copies of the training and assessment materials, as well as The Citadel consultant's recommendations, shall be provided to the Department of Justice for review and comment prior to 1 August 1997. The plan shall be implemented in SY 1997-1998.

41. ACTION ITEM 67: The Commandant shall form a task force to develop a proactive strategy to determine the scope of special dietary problems among cadets and how to prevent them. The task force shall meet at least annually prior to the school year, and shall include membership from the Office of the Commandant, Health and Physical Education Department, the Counseling Center, Aramark, and the medical doctor. The task force shall report in writing to the President.

42. ACTION ITEM 68: The Dean for Enrollment Management shall implement an aggressive recruitment program that expands the number of women in The Citadel's Corps of Cadets. The Citadel is committed to increasing female representation in the Corps to a minimum of 5 percent by 1999 and a minimally sustained growth towards reaching Major General Grinalds's goal of approximately 12 percent hereafter. The Citadel's aggressive recruitment program shall include but is not limited to the following fully funded activities:

- Providing in-service training on recruiting female students for all Citadel recruiters and admissions counselors and all participants in The Citadel Volunteers who attend the Fall training session.

- Modifying The Citadel's web site to incorporate gender-neutral language and expanding the web site to encourage women to apply and to provide information on scholarships and athletic opportunities.

- Coordinating with The Citadel's Athletic Department as well as The Citadel's Public Relations Office for the recruitment of female athletes.

- Developing and disseminating brochures specifically targeted to women.

- On an annual basis, the President shall send letters to guidance counselors at all South Carolina high schools, to all Citadel Alumni Club Presidents, and to the Association of Citadel Men encouraging the nomination of women for The Citadel Scholars Program.

- For the 1997-1998 School Year, the Office of Enrollment Management shall continue to purchase lists from the College Board and Educational Testing Service of both female and male test takers of the Scholastic Assessment Test ("SAT") or the American College Test ("ACT") with the appropriate search characteristics as defined by The Citadel and as subject to the review of the colleges Title IX coordinator/affirmative action officer. Thereafter, The Citadel is committed to expend funds to purchase dual gender lists.

43. ACTION ITEM 69: The Athletic Director shall develop an aggressive strategy to establish an appropriate women's athletic program at The Citadel in accordance with the provisions of Title IX. This strategy shall include, but is not limited to, recruitment of female athletes with the goal of establishing club and intercollegiate teams this year or at the earliest possible date. The Athletic Department shall coordinate with the Health and Physical Education Department to ensure that these goals are met. The Athletic Director shall coordinate with the Dean of Enrollment Management in developing an aggressive recruitment program for female athletes. All reasonable funds will be expended to support this program, and a copy of this written strategy shall be submitted to the Department of Justice for review and comment by 1 August 1997.

44. ACTION ITEM 71: The Citadel shall immediately designate one of the two positions in the Office of the Dean of undergraduate Studies as the Dean of Women. This portion shall be filled effective 1 August 1997.

45. ACTION ITEM 72: The Citadel shall commit all necessary funds for outside expert consultants in Title IX issues and in military programs in a coeducational environment; to assist in program development; to review of policies and procedures; to develop assessment plans and instruments, and conduct workshops and training; to provide climate assessments; and to develop a plan for certifications of trainers.

46. ACTION ITEM 73: The Citadel shall designate the Affirmative Action Officer in Human Resources as The Citadel's Title IX coordinator. The Citadel shall appoint the Assistant Commandant of Cadets, the Multi-cultural Officer in the Counseling Center, and the Dean of Women as assistant Title IX coordinators. The Citadel shall use an outside expert consultant in Title IX to train and certify these coordinators during the summer of 1997. The Citadel shall widely publicize the names, phone numbers, and office locations of these officers so that cadets, faculty, and staff have information regarding who they are, their functions, and how to contact them.

47. ACTION ITEM 74: By 1 August 1997, The Citadel shall insure that gender neutral terminology is used throughout The Citadel and contained in all college publications and official college materials. The Citadel shall review and republish the following documents this summer in gender neutral terminology: The Blue Book, Functions and Procedures Manual, Citadel Training Model, the Honor Manual, Guidon, College Catalog, College Regulations, Leadership Development Guide, The Art of Good Taste, all recruiting materials, and all memoranda/letters sent out to incoming or current cadets.

48. ACTION ITEM 77: The Commandant shall be responsible for developing Date Rape training and a policy of crisis intervention with the assistance of, including but not limited to, the Counseling Center, the Infirmary, and an outside expert consultant in the area of date rape. The Citadel shall provide mandatory training to all cadets annually beginning in SY 97-98.

49. ACTION ITEM 78: The Citadel shall review all current scholarships available to Citadel cadets and notify the donors that The Citadel is now a coeducational institution and request that the donor lift the gender specificity in the deed of trust. The Citadel's attorney shall research the legal implications for the college in those cases where the donors do not change their deeds of trust. The Citadel's attorney shall report the status of these efforts to the Department of Justice by 1 June 1997.

50. ACTION ITEM 79: Regarding The Citadel's Summer Camp for Boys, the Commandant shall conduct a feasibility study during tho Fall of 1997 on options for operating the camp the following summer. The Commandant shall provide the study and recommendations to the President in the Fall of 1997 for a decision by the President and implementation in the summer of 1998. The Citadel commits to providing equal opportunities for girls for the Summer of 1998 and thereafter.

51. ACTION ITEM 80: The Director of the Counseling Center shall coordinate and oversee all sexual harassment and sensitivity training in the Corps of Cadets, and shall be responsible for obtaining and disseminating reports, literature, and other relevant research concerning women's counseling issues.

The Counseling Center shall conduct, on an annual basis, an analysis and needs assessment regarding gender-related counseling issues, including, among other things, the need for additional trained counselors and/or training. The Director shall make a written report of his/her annual needs assessment to the President of the college.

The Director shall insure that, on at least an annual basis, all staff members of the Counseling Center receive in-service training regarding gender-related issues. The Citadel shall insure that all such training is fully funded.

52. ACTION ITEM 76:The Board of Visitors shall request that the Association of Citadel Men design an appropriate Citadel cadet ring for females during SY 97-98. All qualified female cadets shall be given the opportunity to receive THE RING that has been historically given to male graduates of The Citadel Corps of Cadets under the same circumstances as said male graduates have received the same in the past.

General Information Educational Opportunities Section
 
Leadership
Anurima Bhargava
Chief
Contact
How to file a complaint.
Educational
Opportunities Section
(202) 514-4092
1-877-292-3804 (toll-free)
(202) 514-8337 (Fax)
Email: education@usdoj.gov
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