P000015
January 22, 2002
Mr. Kenneth L. Zwick
Director
Office of Management Programs, Civil Division
U.S. Department of Justice
Main Building, Room 3140
Re: September 11 Victim Compensation Fund of 2001
Dear Mr. Zwick:
The Puerto Rican Legal Defense and Education Fund, Inc. ("PRLDEF") is
a national non-profit civil rights organization founded in 1972. It seeks to
ensure the equal protection of the laws and to protect the civil rights of
Puerto Ricans and other Latinos through litigation and policy advocacy.
As an organization dedicated to advancing and securing the rights of
Latinos, PRLDEF is deeply concerned that the Interim Final Rules
proposed by the Special Master to implement the September 11th Victim
Compensation Fund (the "Fund") may discriminate against minority and
female victims of September 11th by the use of race-based and gender-
based calculations. We write to let you know that we are immensely
troubled by even the suggestion that the government would consider using
such discriminatory criteria to determine eligibility for disaster assistance.
In addition, we urge you to seriously consider and give great weight to the
detailed comments submitted to you on this date by the NOW Legal
Defense and Education Fund, Inc.
Located just blocks from the tragic events that occurred in New York on
September 11th , PRLDEF has been working in a variety of ways to offer
support and assistance to those directly affected by these events. In
October, PRLDEF began offering translation and support services to the
many non-English speaking Latino immigrant claimants seeking assistance
at the lower Manhattan disaster relief center. Realizing the need for these
services were greater than PRLDEF’s small staff could handle, PRLDEF
has provided training to close to two hundred volunteer translators who
have in turn assisted hundreds of claimants. In addition, PRLDEF is
collaborating with other groups who are working with immigrant families
affected by the tragedy to ensure that the needs of this population are not
overlooked. Through this work we have observed that non-English
speaking immigrants are disproportionately denied assistance for what we
believe to be discriminatory reasons.
Various estimates place the number of Latinos dead or missing at about
1,200 victims and although the exact number may be hard to pinpoint it is
clear that Latinos have been deeply impacted by this tragedy. It would be
adding insult to injury if Latino families, who are already facing
discrimination as they are attempting to have their basic needs met at the
family assistance centers, are also discriminated against by the federal
government by the use of race-based distribution of funds. A move in this
direction is contrary to the letter and spirit of our nation’s civil rights laws
and would negate decades of advancements that PRLDEF and other civil
rights groups have fought hard to achieve. We urge you not to follow this
path and to consider other means of determining eligibility that are
nondiscriminatory.
Sincerely,
Comment by:
Puerto Rican Legal Defense And Education Fund