Agency Title VI Administrative Investigation Resolutions

Agency Title VI Administrative Investigation Resolutions


Department of Education Reaches Agreement with Oklahoma City Public Schools to Address Disproportionate Discipline of African-American Students:


On April 20, the U.S. Department of Education’s (ED) Office for Civil Rights (OCR) reached a settlement agreement with the Oklahoma City Public Schools of Oklahoma to address disproportionate discipline of African-American students. An investigation revealed African-American students were significantly overrepresented in disciplinary actions. Before OCR had completed its review, the district voluntarily entered into a settlement agreement to resolve the case. 


OCR's investigation found that African-American students were considerably overrepresented in all of the district's disciplinary actions. For example, for the 2014-15 school year, OCR's investigation revealed that African-American students accounted for 42% of in-school suspensions although they represent only 26% of the population. Likewise, for the 2011-12 school year, African-American students received in-school and out-of-school suspensions, were referred to law enforcement, and were arrested for school-related incidents at statistically significant proportions compared to their enrollment in the district.


During the course of OCR's investigation, the district initiated an internal audit. Both OCR's investigation and the audit found scores of concerns including: incomplete and inconsistent recordkeeping; inconsistent provision of due process rights; inconsistent discipline practices across the district; inconsistencies within individual schools themselves; inconsistencies in information provided to parents when their children were suspended; and unclear parameters of certain disciplinary sanctions, such as "defiance of authority" and "disrespect" among others.


In response, the district has undertaken a number of corrective steps, including initiating a review of its discipline policies and practices, and its discipline code. The district also created the Office of School Climate and Student Discipline and hired a director for the Office and three student behavioral specialists.


The agreement, in part:

· Designates an employee to serve as the district's discipline supervisor.

· Prohibits exclusionary discipline to the maximum extent possible.

· Requires the district to retain experts to advise the district on research-based strategies to prevent discrimination.

· Implements revised discipline policies and practices.

· Requires training for staff and administrators and programs for students and parents to explain the policies and behavioral expectations.

· Requires the district to provide teachers and administrators with the tools and training to support positive student behavior to prevent and address misconduct.

· Requires school staff to employ a range of corrective measures before referring a student to disciplinary authorities.

· Ensures a system of supports at each school to assess students who display behavior problems.

· Addresses school climate issues.

· Implements measures to engage students, staff and parents in the implementation of the revised policies, practices and procedures.

·  Requires a comprehensive review of the School Resource Officer program to assess the program's effectiveness and alignment with ensuring misbehavior is addressed in a manner that minimizes exclusionary discipline to the maximum extent possible.

·  Facilitates communication with the parent complainant should she choose to re-enroll her children.


For further information, please see the OCR letter ( to the Oklahoma City Public Schools and the agreement (


Department of Education Reaches Agreement with Toledo Public Schools to Address African-American Students’ Equitable Access to Resources:


On January 21, ED OCR and Toledo Public Schools of Ohio announced that the district has entered into a resolution agreement to ensure compliance with Title VI of the Civil Rights Act of 1964 in providing equitable resources to African-American students. 


The agreement, reached before OCR had completed its investigation, identifies and addresses OCR’s concerns about access to experienced teachers, teachers with master's degrees, libraries for K-8 students, and distance learning classes for high school students. The agreement acknowledges the district’s ongoing efforts to ensure equitable resources for students and students’ equitable access to resources, and other support for student success, but addresses OCR’s concerns identified during its investigation. The agreement provides that the district will:


· Disseminate and post a non-discrimination notice, which informs all members of the school community of their rights and the district's responsibilities under Title VI, and the procedure by which students, parents and employees may report concerns.

· Obtain OCR approval of revised policies and practices if its program assessments reveal the district's initiatives fail to ensure that equally effective and qualified teachers are equitably distributed to all district schools.

· Obtain OCR approval of revised policies and practices if its program assessments reveal the district's initiatives fail to continue to ensure that equally effective and qualified building leaders are equitably distributed to all district schools.

· Ensure that all students at the district's K-8 schools can access their schools' libraries with the same frequency and check out the same number of books.

· Deliver "live" instruction of distance learning courses, including Advanced Placement and other higher-level courses, across its high schools in a racially equitable manner; ensuring Advance Placement and other higher-level college preparatory courses are taught from the district's racially identifiable African-American high schools providing students the opportunity to engage in-person with course instructors.

· Conduct outreach activities for students and parents to better assess, provide, and monitor its distribution and allocation of resources.


For further information, please see the resolution letter ( and agreement (

Seal of the Department of Justice


Department of Justice Resolves Case after the Kentucky Administrative Office of the Courts Implements Language Access Reforms: 


On June 22, the U.S. Department of Justice’s (DOJ) Federal Coordination and Compliance Section (FCS) of the Civil Rights Division reached resolution ( in a Title VI investigation of the Kentucky Administrative Office of the Courts (KAOC). The complaint, received in September 2014, alleged a state court judge’s failure to provide interpreter services to limited English proficient (LEP) parties. During the course of FCS’s review, the KAOC strengthened its language access programming. FCS’s technical assistance included working with the KAOC to create and implement a language services complaint system, which will be translated into a dozen non-English languages. Additionally, FCS trained court staff on the importance of providing appropriate language services and developing systems to improve the efficiency and quality of interpreter services and translations. As a condition of closure, the KAOC agreed to a 12-month monitoring period, during which it will provide quarterly updates to FCS regarding developments related to providing language services, as well as any new complaints alleging failure to provide appropriate language assistance services. 


A press release and additional information is available at:



Department of Justice Closes Case after Colorado Courts Implement Language Access Reforms: 


On June 21, DOJ FCS closed a Title VI case concerning the provision of language assistance to LEP individuals by the Colorado state courts following the successful implementation of reforms by the Colorado Judicial Department (CJD). This matter began after FCS received an administrative complaint alleging that the state courts were not providing LEP parties with interpreters in civil proceedings. In 2011, the CJD signed a memorandum of agreement ( with DOJ and amended Chief Justice Directive 06-03 to mandate that, effective immediately, qualified interpreters and other approved language assistance would be provided at no charge for LEP individuals in all court proceedings, services and programs. The CJD’s Office of Language Access issued a DOJ approved, comprehensive strategic plan ( in 2012 that defined 35 needed improvements to court policies, standards, infrastructure and training in order to support the court system’s ability to deliver timely and appropriate language assistance statewide. This year, the courts completed the improvements specified in the plan and complied with the monitoring provisions of the memorandum of agreement. The Chief Justice Directive ( was updated on May 31. This case is one of several undertaken by FCS as part of its ongoing Courts Language Access Initiative ( 


A press release and additional information is available at: