Agreelnent 

between 

The United States of Alnerica 

and 

The Jefferson Parish Public School Systeln 
lNTRODUCTlON 

The United States Department of Justice, Civil Rights Division, Educational 

Opportunities Section (the "Division"), th e United States Department of Education, Office for 

Civil Rights ("OCR") (together, the "United States"), and the Jefferson Parish Public School 

System ("JPPSS") (coll ec tively, th e "Parties") enter into this Resolution Agreement 

("Agreement") to resolve the United States' investi ga tion into complaints conceming (a) 

JPPSS 's polici es and practices for student registration, enrollment, and graduation; (b) JPPSS's 

polici es and practices for communicating with national origin minority parents who have limited 

English profi ciency ("LEP"); and (c) JPPSS's response to alleged harassment creating a hostil e 

environment for Latino students based on their national origin, of which JPPSS knew or 

reasonably should have known. Without admitting any unlawful conduct, JPPSS voluntarily 

agrees to impl ement the tem1S of th e Agreement, which includes school-specific and parish-wide 

remedial measures. 

BACKGROUND AND JURISDICTION 

On August 22,20] 2, the Division and OCR received a written complaint all egin g 

national origin discrimination by JPPSS against La tino students and national origin minority LEP 

parents; the Division and OCR received a suppl emental complaint with additional allegations of 

national origin discrimination on November I, 20] 2 (together, the "Complaint"). On September 

26,20] 2, the Division and OCR notified JPPSS that, based on the August 22, 20] 2 complaint, 

they had initiated a joint investiga tion into JPPSS's policies and practices rega rding the 

documentation required for student registration, enrollment, and graduation. On November 13 , 

2012 , the Division and OCR notified JPPSS th at, based on the supplemental complaint, they 

were expanding the investigation to examine whether JPPSS communicates with national origin 

minority LEP parents in a language they understand, and whether JPPSS took prompt and 

effective action to respond to alleged incidents of harassing conduct creating a hostile 

environment for Latino students based on national origin. The Division and OCR initiated the 

investi gation under Title VI of the Civil Ri ghts Act of] 964,42 U.S.c. § 2000d ef seq., and its 

implementing regulations, at 34 C.F.R. part] 00 ("Title VI"). The Division also initiated the 

investi ga tion under th e Equal Educational Opportunities Act, 20 U .S.c. § 1703(f), ("EEOA "), 

and Titl e ]V of the Civil Rights Act of 1964, 42 U .S.c. § 2000c-6 ("Title IV"). 

The United States requested and reviewed documents and infom1ation provided by 

JPPSS and, from May 6, 2013 through May 10,2013, the United States visited JPPSS's central 

office, several high schools, middle schools, and elementary schools, conducting interviews with 

JPPSS administrators, faculty, and staff. JPPSS has cooperated fully throughout the course of 

the investi gation. Additionally, the United States acknowledges that JPPSS has taken steps to 

improve communications with LEP students and parents, and to revise documentation 

requirements for student enrollment and registration. 
DEFINlTlONS 

For the purposes of the Agreement, the fo ll owing words, phrases, and acronyms have th e 

following meanings: 

I. "Central Office" means the main Jefferson Parish Public School System administrative 

building cunently loca ted at SO l Manhattan Boulevard, Harvey, Lou isiana 70058. 

2. "ELL" means an English Language Leamer, Limited English Proficient, or Non-English 

Proficient student who requires assistance to overcome language baniers that impede his or her 

p3J1icipation in JPPSS 's instructional programs. 

3. "Effective Date" means the date on which counsel for the United Sta tes executes the 

Agreement. 

4. "Handbook" means the Policies and Procedures for Parents and Students booklet, 

which usually is published each school year and contains important infomla ti on regarding 

Jefferson Parish Public Scbool System's parish-wide policies and procedures and code of 

conduct. 

S. "Jefferson Parish Publi c School System" or "JPPSS" means the Jefferson Parish School 

Board and its individual members, the Superintendent, and the system of public schools located 

in Jefferson Parish, Louisiana, including all schools operated and/or supervised by the 

Superintendent and/or School Board of Jefferson Parish, Louisiana . 

6. "Major Languages" means Spanisb, Arabic, and Vietnamese. I 

7. "LEP parent" means all parents, guardians, or any oth er person legall y responsible for a 

student under state law, who, because oftheir inabi lity to adequa tely communicate in English, 

need to bave communication (written and oral) from a school or JPPSS provided in a language 

other than English in order to make meaningful, infonned choices among JPPSS's ELL 

programs and services and to effectively p3J1icipate in all aspects of JPPSS 's educati onal 

process. 

8. "Lower Incidence Languages" means all non-English languages that are spoken by the 

Jefferson Parish Public School System's Limited English Proficient parents, except for tbe Major 

I The enumerated list of three languages shall constitute JPPSS's Major Languages for the entire 2014-

2015 school year. During the 2015-20J 6 school year, JPPSS shall phase into its Major Languages the 

next two most common non-English languages spoken by LEP parents. 

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Languages. 

9. "Registrar" means all members of the Jefferson Parish Publi c School System 's staff who 

are resp onsibl e for student registrati on and/or stud ent enrollment at ea ch school or at the Cen tral 

Offi ce. 

10. "Parent" means parent , guardi an, or any oth er person legall y responsibl e for a stud en t 

under state lav,' . 

II. " Speci al Educ ati on" means servi ces or infoJl1l ati on provided pursuant to the Indi v iduals 

with Disabiliti es Edu ca ti on Act or Secti on 504 of th e Rehabilitati on Act. 

SPECIFIC REQUIREMENTS 

Stud ent Enrollment and Registrati on 

12. Consistent with Titl e IV and Titl e VI, JPPSS shall not requ est infoJl1lati on from p arents 

or students with the purpose or result of denyin g or limiting access to th e publi c schools on the 

basis of race, color, or national ori gin . JPPSS also acknowl edges its obligations und er federal 

law to ensure th at its stud ent enrollment poli cies and practices do not chill or discourage th e 

p articipa tion, or lead to th e exc lusion, of stud ents based on their or their parents' actu al o r 

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p erceived citi zenship and/or immigrati on status

13. JPPSS shall not, as a conditi on of enrollment or registration, require any parent or 

stud ent to provide a social security number or socia l security card, state-issued identity 

document, or olll er document th at requires proof of citizenship or immigrati on status to obtain. 

14 . Before stud ent enrollment commences for th e 20]4-2015 school year, JPPSS shall have 

compl eted an intern al review of all enrollment and registration materi als and p oli cies, includin g 

but not limited to any registration or enrollment materials and poli cies crea ted by individual 

schools or posted to individual schools' websites, and shall have ensured th at all such m a terials 

and policies comply with Paragraphs 12 and 13 above. 

IS . JPPSS shall ensure th at all employees who are responsibl e for student registrati on and/or 

student enrollment at each school and in the Central Offic e receive training annually regardin g 

th e documentation required for stud ent registrati on and/or enrollment and the appropri ate, nondiscrimin atory mann er of communi catin g such requirements to ELL stud ents and LEP p arents. 

2 See M ay 8,20]4 joint Dear Coll eague Lett er from OCR and the Division on school enrollment 

procedures, ava ilabl e at http://www2 .ed.gov/abouUoffices/list/ocr/letl ers/coll eague-20 1405 .pdf. 

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Student Record Updates and Graduation 

16. JPPSS shall not , as a condition of graduation or of updating student records for 

graduation , require any parent or student to provide a soc ial security number or social security 

card , state-issued identity document, or other document that requires proof of ci ti zenship or 

immi gration status to obta in . 

] 7. JPPSS shall ensure that ELL students attending high school and the LEP parents of high 

school students receive infol111ation regarding graduation procedures, scholarship requirements, 

and college admissions procedures in a language th ey understand. 

18. JPPSS sha ll ensure that all employees who advise students regarding coll ege admissions 

receive training annually regarding the procedures for obtaining required infon11ation for 

scholarship purposes and the appropriate, non-discriminatory manner of communicating such 

requirements to ELL students and LEP parents. 

Translation and Interpretation Services 

] 9. By September 5, 20] 4, JPPSS sha ll implement policies and procedures to ensure that 

national origin minority LEP parents are notified, in a language understood by such parents, of 

school activities and other information and matters that are called to the attention of other 

parents. Specifically, JPPSS shall revise its procedures to specify how JPPSS will provide 

language assistance services, including interpreters and written translations, to LEP parents, 

including parents who speak the Major Languages and Lower Incidence Languages. 

20. JPPSS shall develop and maintain an accurate and current electronic list of all available 

p ersonnel in each school building who speak a language other than English whom JPPSS has 

detemlined are competent and are authorized to provide translation and/or interpretation services. 

The list sha ll include the translators' and interpreters' current phone numbers, building 

location(s), and email addresses. JPPSS sha ll maintain this list, and each school's principal, 

assistant principal(s), and registrar(s) shall make the relevant parts of this list available to all 

personnel at each school. JPPSS shall update the electronic list at lea st annually before the 

commencement of each school year and, when necessary, during th e school year to reflect 

substantial changes in the persOlmel available for translation and interpretation services at each 

school. 

21. JPPSS shall ensure that principals, assistant principals, and registrars are aware of, have 

access to, and understand how to use Language Line or any other telephone-based language 

interpretation service to which JPPSS subscribes. 

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22. JPPSS shall ensure that all employees at each school are in structed to contact the 

principal, assistant principal(s), or registrar to obtain translation and int ellJretation services. 

23 . JPPSS shall ensure that principals, assistant principals, and registrars are advised th at a 

school may request th e assistance of employees at other schools to meet th e translati on and/or 

int erpretati on needs of ELL students and LEP parents. 

24. ]f JPPSS chooses to use a vendor, such as I-World Language, to provide outside 

translati on and interpretation for its schools, JPPSS shall maintain and distribute to its principals, 

assistant principals, and registrars a list of langua ges offered and interpretation and translation 

services provided by th e vendor. Principals shall promptly forward requests for translators 

and/or interpreters for languages not represent ed on JPPSS's translation and interpretati on 

servi ces employee list or the list of languages offered by its outside vendor(s) to the Central 

Offi ce, or another designated department or administrator. The Central Office and/or designat ed 

administrator shall be responsible for fulfillin g such translation and/or interpretation requests. 

(a .) In the event that JPPSS ceases using a vendor to provide outside translators and 

interpreters for its schools, JPPSS shall maintain a current list of outside 

translators and interpreters not employed by JPPSS who may be contacted to 

provide translation and interpretation services and shall ensure that its principals, 

assistant principals, and registrars have access to and understand how to use th e 

outside translator and interpreter list. 

25. JPPSS shall ask all parents of current ELL students in writing in English and in the Major 

Languages whether the parents desire written tran slations or oral interpretations of parish-wide 

and school-level infonnation, and if so, to specify the language(s) needed. Beginning in th e 

2014-2015 school year, JPPSS shall ask all parents of all newly enrolled students on th e Home 

Language Survey in English and in the Major Languages whether the parents desire written 

translations or oral interpretations of parish-wide and school-level infonnation, and if so, to 

specify the language(s) needed. For parents of current ELL students (and all parents of students 

who newly enroll beginning in the 20] 4-20] 5 school year), JPPSS shall also publici ze in the 

Lower Incidence Languages the availability of language assistance. 

26. JPPSS shall record the language preferences requested by LEP parents in Infinite Campus 

or via some other electronic student infomlation system such that parents' language requirements 

are readil y accessible to JPPSS administrators and teachers. JPPSS shall require school 

administrators and teachers to consult parents' language requirements in the student infomlation 

system before scheduling meetings with parents of ELL students, and JPPSS shall provide such 

langua ge assistance consistent with Paragraph 28. 

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27. Except in the event of an emergency, JPPSS shall not re ly upon, use, or ask any JPPSS 

student to provide translation and/or interpretation services for any JPPSS employee, parent, o r 

anoth er JPPSS student, even where the stud ent 's parent has asked or grant ed the stud ent 

pell11ission to provide translation and/or interpre tation servi ces. 

28. JPPSS shall provide translation and interpretation services as fo ll ows: 

3 (a.) When notices or documents containing essenti al information are distribut ed at 

th e parish-wide or school level: 

(i.) such notices and documents containing essenti al infoll11ation shall be 

tran slated into the Major Lan gua ges and distributed to LEP parents who 

have requested tran sla tion s in those languages, including requ ests 

reflected in the stud ent information system as required by Paragraphs 2S 

and 26 above; 

(ii .) LEP parents who hav e requ ested tran slations in Lower Incidence 

Langua ges shall be provided written translations or shall b e advised of 

whom to contact at JPPSS if th ey need assistance in understanding noti ces 

or documents containing essential infoll11ation, and JPPSS shall provide 

oral interpreta tion of th e notices or documen ts as necessary for su ch 

parents. 

(b.) When a JPPSS employee needs to communicate ora ll y w ith LEP paren ts who 

speak the Major Languages or Lower Incidence Languages regardin g essential 

infoll11ation: 

3 "Essenti al info1111 ation" is infonnation provided to parents, including but not limited to information 

regardin g: (a) special education matters arising under the Individuals with Disabilities Education Act or 

Secti on 504 of the Rehabilitation Act (e.g., IEP or 504 meetings), (b) academic perfonnance, aca demic 

planning, and progress reports (e.g., report cards, midterm eva luations, summer school , honors classes, 

and emichment programming); (c) disciplinary actions and the disciplinary process (e.g., behavioral 

expectations, wamings, deten tion, minor and major in frac tion noti ces, disciplinary conferences, in-school 

suspension , out-of-school suspension, disciplinary due process, rest-of-school-year suspension, and 

expulsion); (d) announcements about school-specific or parish-wide activities for whi ch notice is needed 

or parental pennission is required to participate in such activities (e.g., testin g, school performances, fi eld 

trips, ac tiviti es requiring an application); (e) public hea lth and sa fety ; (f) screening procedures requesting 

a student's language background and/or a parent's prefened language of communication; (g) th e 

Handbook ; (h) graduation , enrollment, and registrati on; and (i) any other written information describing 

th e ri ghts and/or responsibilities of parents or students and the benefits and/or services available to 

parents and stud ents. 

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(i.) the communi ca ti on shall be provided in a language th e parent und erstand s 

by means of a qu ali fied interpreter at th e request of the LEP parent ; and 

(ii.) the qualifi ed interpreter must be prov ided as soon as feasible such th at tlle 

LEP parent or stud ent is not deni ed th e ability to take appropri ate ac ti on 

regarding the essentia l infon11ati on, or to parti cipate in or benefit from 

JPPSS's services and/or programs. 

(c .) JPPSS shall provide written translati ons or oral interpretati on of infon11 ati on th at 

is not deemed "essenti al informati on" upon receiving reasonabl e, specifi c writt en 

or oral requ ests for such infonn ation from LEP parents who speak the Major 

Languages or Lower Incidence Languages. 

29. JPPSS shall make ava il abl e to all appropri ate personnel a list of the parish-wide and 

school-l evel documents that have already been translated, with electronic' access to such 

documents, and shall enable school personnel to include school-specifi c noti ces in an electroni c 

f0n11 at that may be used by other schools to meet their translati on needs. 

30. JPPSS shall develop and impl ement an additional method for notifying LEP parents, in a 

language that th e parents can understand, of the ava il ability of free language assistance services 

(as described in Paragraph 28 above) with respec t to school programs and activiti es and 

infonnation as to how this assistance may be obtained. The noti ce shall , at a mi nimum, be 

published and displ ayed as follows: 

(a.) JPPSS shall maintain and prominentl y display a sign in a hi gh-traffi c area in 

each of its schools that publicizes the ava il ability of free translati on and 

interpretati on services. The sign shall be posted in English and in the M ajor 

Languages and shall list the name and contact infonnation of a JPPSS employee 

who can answer qu esti ons regardin g parent al communication and assist p arents 

with accessing interpreter servi ces and/or translated documents. 

3 1. JPPSS shall continue to provide infon11ati on to LEP parents vi a local bilingual radi o 

stati ons, and to ensure that its website is translated into the Major Languages and accessible to 

LEP parents. JPPSS shall translate annuall y th e Handbook into the Major Languages and shall 

post th e Handbook to its website. 

(a.) JPPSS shall revise the Handbook to include information for LEP parents 

regarding JPPSS 's translation and interpretation servi ces and the procedures for 

requ estin g such services. JPPSS shall include a description of the translati on and 

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interpretation services and procedures in th e Handbook for the 20 ]4-20 ] 5 school 

year or in a suppl ement in the event that the 20 ]4-20] 5 Handbook is published 

before the Effective Date of the Agreement. JPPSS shall update th e description 

of the translation and interpretation services and procedures as needed for all 

subsequent school years. 

(b.) All supplements to the Handbook required by the Agreement shall be distribut ed 

by JPPSS to students, parents, and JPPSS personn el in a manner consisten t with 

the distribution procedures for the Handbook. All suppl ements to th e Handbook 

shall be posted to JPPSS's website and translat ed into the Major Languages. 

32. All JPPSS schools with LEP parents who have requested translation and interpretation 

services shall have interpreters avail able for parish-wide school events and school events that 

JPPSS requires schools to host, including but not limited to open houses and parent-teacher 

conferences, for exampl e, and at other school events or meetings upon request with reasonable 

noti ce . 

33 . All JPPSS schools that educate ELL studen ts and provide school-wide announcements 

orall y using an intercom system shall make a good faith effort to interpret regul arly its schoolwide, oral announcements to the language(s) spoken by their ELL students. 

Trainin g 

34 . JPPSS shall ensure that all individuals who provide translation and/or interpretation 

services for JPPSS are: 

(a.) Demonstrably competent to interpret and/or translate in both languages; 

(b.) Trained in providing the interpretation and/or translation they are asked to 

provide or sufficiently knowledgeable in both languages of any speciali zed 

tenninology n eeded (e.g., special educa tion tenninology) to provide the 

requested interpretation and/or translation accurately; and 

(c.) Trained on the role of the interpreter and translator, the impOJ1ance of accuracy 

and completeness, the ethics of interpretati on and translation, and the need to 

maintain confidentiality. 

35. JPPSS shall maint ain documentation to verify that the interpreters and translators have 

the skills and proficiency to interpret and translate in English and a particul ar non-En glish 

langua ge. 

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36. JPPSS shall train annually all JPPSS personnel who interact with LEP parents or may 

interact with LEP parents during the course of th eir dea lings with th e public, including but not 

limit ed to all school principals, deans, secretari es, registrars, and teachers, regarding: 

(a.) effectively communi cating with LEP parents; 

(b .) the purpose and content of the Agreement ; 

(c.) the documents and essential info1l11ation that must be translated and interpret ed; 

and 

(d .) any communi cations that mu st be translated and/or interpreted. 

Community Engagement 

37. Not later than September 8, 20]4 , JPPSS shall recruit members for and maintain for the 

duration of th e Agreement a bilingual parent advisory committee (the "Committee"). The 

Committee's members shall include but shall not be limited to: 

(a.) at least 10 LEP parents; 

(b .) at least] parish-level Central Offi ce administrator; 

(c.) an ELL director, principal, regular education teacher, bilingual paraprofessional, 

and bilingual counselor/social worker, who shall be chosen as representativ e 

staff from JPPSS 's elementary schools, middle schools, and high schools; and 

(d .) at least 2 ELL students who attend a JPPSS high school. 

38. For the entire 20] 4-2 0] 5 school year, JPPSS shall invite all LEP parents identified in the 

Complaint to join the Committee if the parents' children are still enrolled in JPPSS schools. 

Committee membership shall be open to other individuals that JPPSS deems appropriate, such as 

representatives from relevant community-based organizations. JPPSS shall endeavor annuall y in 

good faith to constitute the Committee with individuals from various schools who reflect the 

diversity of the community that JPPSS serves and who speak the Major Languages and Lower 

Incidence Languages. 

39. The Committee shall meet no fewer than 3 times each school year, starting in the 20]4-

20]5 school year and throughout the duration of the Agreement. The Committee shall discuss 

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and provide recommendations to the Superintendent and th e Chi ef Student Support Officer 

regarding JPPSS's ELL program, registration, enrollment, bullying, harassment, and 

communications with LEP parents. JPPSS shall designate an employee to coordinate the 

Committee's meetings and work ("Committee Coordinator"). The Committee Coordina tor shall 

distribute th e minutes of the Committee's meetings and any recommendations to the 

Superintendent and the Chi ef Student Support Officer. 

Hara ssment Policy and Procedures 

40. JPPSS shall review and revise its cunent poli cy and procedures to ensure that all 

complaints received, whether verbal or written, all eging discrimination on th e basis of race, color 

or national origin, including allegations of harassment on the basis of race, color or national 

origin, are appropri ately investiga ted and responded to as required by Title IV , Title VI and its 

implementing regulations, and are consistent with the guidance provid ed in OCR's Bullying and 

Harassment "Dear Colleague" Letter dated October 26, 20 10. The poli cies/procedures shall 

ensure a prompt and equitable response and resolution of complaints alleging race, color, or 

nati onal origin discrimination. Responsive actions taken by JPPSS mu st be reasonabl y 

calculated to prevent recunence and assure that students are not limited in their p3J1icipation or 

benefits as a result of a hostil e environment created by students, employees, or non-employees 

by the all eged conduct. JPPSS shall ensure that th e revised policies/proc edures include , but are 

not limited to th e following provisions: 

(a.) detail JPPSS's responsibilities for addressing bullying and harassment incid ents 

about which it knows or reasonabl y should have known; 

(b .) define bullying and harassment in sufficient detail such that students and JPPSS 

personnel may identify wha.t constitutes such misconduct; 

(c.) explain the steps that students should take to rep0l1 bUllying and harassment 

incidents; 

(d .) include JPPSS's obligation to take immedi ate and appropriate action to 

investigate bullying and harassment allegations, and to conduct a prompt, 

thorough, and impartial inquiry; 

(e.) identify JPPSS 's obligation to take prompt and effective steps, when appropriate, 

to end the harassment or bullying, eliminate any hostil e environment and its 

effects, and prevent the harassment or bullyin g from recUlTing, without 

penalizing the student who was harassed or bulli ~ and 

4 The Un it ed States recognizes that the specific circumstances Dlay vary, and th at there Dlay be circumstances where 

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(f.) explain JPPSS 's responsibility to take steps to stop furth er bullying and 

harassment and prevent any retali ation aga inst the person who reported 

harassment/bullying or again st th ose who provided information as witnesses. 

41. JPPSS shall submit its revised anti-harassment and bull ying policy and procedures to th e 

United States for review and approval no later than 30 business days after the Effective Date. 

The United States shall have 30 busin ess days aft er receivin g th e proposed revisions to provide 

comments and recommendations to JPPSS rega rding the revised policy and procedures. JPPSS 

shall include the final, revised harassment and bullying policy and procedures in the Handbook 

for the 2014-20 IS school year or in a suppl ement in the event that JPPSS 's intemal publication 

deadlines preclude its inclusion in the 2014-2015 Handbook. JPPSS shall ensure that th e revised 

hara ssment and bullying policy is included in th e Handbook for all subsequent school years. 

42. JPPSS shall retain the South Central Coll abora tive for Equity / Intercultural Development 

Research Association, also known as th e Equity Assistance Cent er for Region VI ("Equity 

Center"), or another third-party consultant to be approved by the United States, to implement 

anti-harassment, anti-bullying, and diversity training during th e fall semester of the 20]4-20]5 

school year for the faculty, staff, and students of West Jefferson High School eWest Jefferson"). 

The training shall include: 

(a .) an overview of JPPSS 's revised anti-harassment and anti-bullying policy and 

procedures; 

(b.) stra tegies for preventing harassment and bullying and ensuring that JPPSS's 

students understand their right to be protected from discrimination, including 

national ori gin-based harassment, and to be protected from retaliation for 

reporting alleged discrimination; 

(c.) strategies to ensure that students understand how to report possible violations of 

the policies and intemal guidance related to harassment and bullying, including 

national origin-based harassment, and that students are aware of JPPSS' s 

obligation to promptly and effectively respond to complaints alleging harassment 

and/or bullying; and 

(d.) specific suggestions for developing an effective student anti-harassmentlantiJPPSS detennines that a student who was subj ec ted to harassment also engaged in harassment of other studen ts. 

Nothing in this paragraph is intended to alter JPPSS's authority or obligation to respond appropriately to such 

conduct, consistent with this Agreement and with th e Handbook. 

II 
bull ying program th at promotes respec t and tolerance for oth ers and takes steps 

reasonabl y designed to prevent th e crea ti on of a hostil e environment, wi th an 

emphasis on nati onal ori gin-based harassment. 

School Climate Assessment 

43. With th e assistance of the Equity Center or anoth er third party consultan t approved by the 

Unit ed States, JPPSS shall develop and admin ister an annual school climate survey to tIl e 

students of West Jefferson in order to assess th e presence and effects of harassment and of 

bull ying on the basis of a protected class, th e in clusiveness and safety of the educa ti onal 

environment, and th e effectiveness of the measures taken pursuant to the Agreement. Th e survey 

shall be administered in English and Spanish, translated into the other Major Languages and 

Lower Incidence Languages to the extent necessary for other LEP students, and shall be 

compl eted anonymously. TIl e first surveys shall be administered during th e 20 14-20 15 school 

year. The surveys shall be administered annually each school year th ereafter throughout th e 

dura ti on of th e Agreement. The Committee Coordinator or designee shall submit draft surveys 

to th e United States for revi ew and approval at least 30 business days prior to th eir 

administrati on. The Committee Coordinator or designee shall analyze the results of the surveys 

and incorporate this analysis into JPPSS 's annual climate assessment report described below. 

44. At th e conclusion of ea ch school year (beginning with the 20 14-201 5 school year), JPPSS 

shall conduct an assessment of the effectiveness of its anti-harassment and anti-bullyin g efforts 

at West Jefferson. The assessment shall be conducted by the Committee Coordi nator or 

designee. JPPSS shall include a final written report summarizing the school climate 

assessment's results and recommendations in its July 31 annual report to the United States. The 

school climate summary report shall be posted annually on JPPSS's main website and W est 

Jefferson's website in English and Spanish and made avail able to LEP parents in the other Major 

Languages and Lower Incidence Lan guages upon request. The summary report shall include: 

(a.) a revi ew of school climate survey data and findin gs and the actions taken by 

JPPSS in response to those findin gs; 

(b.) a revi ew of all reports of harassment and of bullyin g on the basis of a protected 

class and Central Office-l evel and school-level responses at West Jefferson; 

(c.) a detennination of whether repOJ1ed incidents of harassment and bull yin g have 

increased or decreased in number and severity, overall and by protected class; 

(d.) the efforts of JPPSS and investi gating offici als to ensure incidents of harassment 

and of bull ying on th e basis of a protected class are investigated and addressed in 

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accordance with the Agreement and federal law; 

(e.) identification of areas in need of further conective action, if any; and 

(f.) recommendations for improving JPPSS 's anti-harassment and anti-bullying 

practices and timeline s for th e implementation of such recommendations. 

MONITORING AND ANNUAL REPORTING 

TO THE UNITED STATES 

45. JPPSS understands that the United States will not close the monitoring of the Agreement 

until the United States detem1ines that JPPSS has fulfilled the tenl1S of the Agreement in 

compliance with the EEOA, Title VI, and Title IV, which were at issue in the Complaint. 

46. JPPSS shall maintain electronic and/or hard copy records of all infonnation pertinent to 

compliance with the tenns of the Agreement and shall provide such infonnation to the United 

States upon request. 

47. Upon providing reasonable notice to JPPSS , the United States shall have the right for its 

representatives, and any consultant or expeJ1 retained by th e United States, to conduct site visits, 

observe trainings, interview JPPSS staff and students, confer with the Equity Center, and request 

such additional repOJis or data as are necessary for the United States to evaluate JPPSS's 

compliance with the terms of the Agreement and federal law. 

48. JPPSS shall provide annually to the United States a report detailing its efforts to comply 

with the Agreement (the "Annual RepOJ1"). JPPSS shall submit the Annual Report in an 

electronic fOl1nat each year for 3 years, by July 3] (or the next business day thereafter whenever 

July 3] occurs on a weekend), with the first repOJ1 due by July 3],20] 5. If any of the 

infol1nation required for the Annual RepOJ1 for a particular school year is available in a 

document that JPPSS already has prepared to comply with federal law, state law, or regulation, 

JPPSS may include the document in its Annual Report and indicate the section of the Annual 

Report to which the document applies. The Annual Report shall include the following 

infom1ation about the school year preceding each Annual Report: 

(a .) a copy of all complaints received by JPPSS conceming barriers to registration 

and enrollment on the basis of a protected status, including complaints regarding 

JPPSS employees requesting or requiring- during the registration or enrollment 

process-social security numbers, social security cards, state-issued identity 

documents, or other documents that require proof of citizenship or immigration 

status to obtain; 

J 3 
(b.) a copy of all complaints received by JPPSS concerning requ ests made by JPPSS 

employees for students' social security numbers, social security cards, stateissued identity documents, or oth er documents that require proof of citi zenship or 

immi gration statu s to obtain for the purpose of updating JPPSS 's intern al records 

prior to graduation or for th e purpose of gradua tion from JPPSS 's schools; 

(c .) a chart showin g the number of ELL students and the number of students with 

LEP parents, organized by the school the students attend and identifying the 

primary langua ge spoken by the student and by th e student 's LEP parent as 

required by Paragraph 26; 

(d .) the total number of requests for translation and interpretation servi ces made by 

LEP parents, th e number of such requests that were denied , an d the basis for 

each deni al; 

(e.) the date of each Individualized Education Program meeting where an interpreter 

was present, including th e name and job titl e of the interpreter and the language 

interpreted (if the interpreter is not a JPPSS employee, please identify the 

interpreter organization or employer with which the interpreter is affiliat ed); 

(f.) a copy of the current JPPSS Handbook; 

(g.) a copy of JPPSS's employee translator and interpreter lists, and the list of 

languages and interpretation and translations services offered by JPPSS' s 

language vendor(s) or JPPSS 's outside translator and interpreter list, as required 

by Para graphs 20, 24, and 24 (a); 

(h.) the names and languages spoken by the members of th e Committee (and the job 

titles of the Committee members employed by JPPSS), a copy of the 

Committee's minutes, and a description of any actions taken by JPPSS to 

implement recommendations made by the Committee; 

(i.) a summary of each training session required by the Agreement, including all 

trainings regarding interpretation and translation, graduation/scholarship 

advising, enrollment/registration, effective LEP parent communications, and 

bullying and harassment prevention, the date and duration of the trainin gs, copies 

of all agendas for and any materials distributed or used during the trainin gs, the 

name and position of the employees who attended the trainings; 

]4 
(j .) copies of all incident reports, discipline referrals, informal compl aints, and 

fonnal compl aints related to th e bull ying or harassment of Latino or Spanishspeaking students based on nati onal ori gin at West Jefferson by other students or 

by JPPSS's employees, and all document ati on related to such incidents occulTin g 

at West Jefferson (e.g., interview notes, correspondence with the offendin g 

JPPSS employee, cOlTespondence with the parents of the student subj ect to the 

harassment and offending student(s), discipline referral(s), statements of fi ndings 

and remedi al acti on, and prior incidents of discrimin ati on or harassment 

involving the student subj ect to the harassment or the offending student(s» ; 

(k.) a description expl aining how th e inc ident, allegati on, or compl ain t involvin g th e 

bull ying or harassment of La tin o or Spanish-speaking stud ents at West Jefferson 

was resolved; 

(1.) a written report summari zing the results of the annual school climate assessment 

administered at West Jefferson an d recommendati ons as required by Paragraph 

44 ; and 

(m.) any other info1111 ation th at JPPSS beli eves will be helpful. 

ENFORCEMENT 

49. The undersigned representatives of th e Parti es affi1111 th at they are authori zed to enter into 

and consent to the tenns and conditions of th e Agreement and to execute and legally bind the 

PaJi ies to it. The Agreement shall be binding upon JPPSS, all current and successor members of 

the Jefferson Parish School Board (the "Board ") in th eir offici al capacity, the current 

Superintendent, and all successor Superint endents until the Agreement is dissolved. 

SO. In consideration for the commitments made in the Agreement by JPPSS, the United 

States agrees not to initiate legal proceedings regarding the matters contained in the Compl aint, 

specificall y: (a) the documentation required for student registration , enrollment, and graduation ; 

(b) JPPSS's policies and practices for communicating with LEP parents; and (c) JPPSS 's 

responses to all eged discriminatory harassment of Latino students as identifi ed in the 

s Complaint.

5 The Agreement is not intended to address any lega l issues not specifically discussed herein, including 

other legal issues relatin g to JPPSS's compli ance with the EEOA, Title IV , and/or Titl e Vl. The 

Agreement does not restrict or limit the United States' ability to investi ga te or resolve all ega ti ons not 

specifi ca lly discussed herein regarding JPPSS's compli ance with the EEOA, Title IV , and/or Titl e Vl. 

IS 
5 I. The United States, consistent with its responsibility to enforce the EEOA, Titl e IV , and 

Ti tl e VI, retains th e right to investi ga te and, where appropriate, initi ate administrative 

enforcement and/or judi cial proceedings concerning any fu ture all eged violations of the EEOA, 

Title IV and/or Titl e VI by JPPSS. 

52 . In th e event of a material breach of th e Agreement by JPPSS or if JPPSS has fa il ed to 

comply in a timely mann er with any requirement of the Agreement, th e United States will notify

JPPSS in writing and will attempt to resolve the issue(s) in good fa ith with JPPSS. ]f th e Unit ed

States is unable to reach a sa tisfactory resolution of the issue(s) within 60 calendar days of 

providing notice to JPPSS, the United States may initi ate civil enforcement proceedings in 

federal court and/or administrative enforcement proceedings. 

53. If any part of the Agreement is for any reason held to be invalid, unlawful, or otherv"ise 

unenforceable by a court of competent jurisdi cti on, such decision shall not affect the va lidity of 

any other paJ1 of the Agreement. 

54. The Agreement shall remain in effec t for the entire 2014-2015,2015-2016, and 2016-

20 17 school years and until such time as the Agreement is tern1inated. Prior to the Agreement's

tern1inati on, th e United States shall have 60 calendar days from the receipt of the Annual Report

for the 2016-2017 school year to identify concerns or objecti ons regarding JPPSS 's compli ance.

The Parties shall work in good faith to resolve all concerns, deficiencies, or obj ections identified

by the United States regarding JPPSS 's implementation of the Agreement. 

55. The following signatures indicate the consent of the Pal1ies to all of the tem1S of the 

Agreement, which is effective on the Effective Da te. 

16 
For the United States of America: 

JOCELYN SAMUELS 

Acting Assistant Attorney General 

Civil Rights Division 

URIMA BI·IARGAV 

HAHEENA S. SIMONS 

JONATHAN D. NEWTON 

U.S. Department of .lustil:e 

Civil Rights Division 

Educational Opportunities Section 

601 J) Street, N.W., Sllite 4300 

Washington, D.C. 20530 

Telephone: (202) 514-4092 

Facsimi le: (202) 514-8337 

nC.u I j,J q 

I 

GL.0 S - JDlL../ 

dOR AUGUST lj ) 

Director 

Office ror Civil Rights 

Dallas Office 

U.S. Department of Edueation 

1999 Bryan Street, Suite 1620 

Dallas, Texas 75201·6810 

Telephone: (21 4) 661 ·9600 

Facsimile: (21 4) 66 1-9587 

17 
ystem: 

Date: ~Jy erintendent 

Jefferson Parish Public School System 

501 Manhattan Blvd. 

Harvey, Louisiana 20058 

Telephone: (504) 349-7600 

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