The U.S. Coast Guard 

Academy Must Take 

Additional Steps to Better 

Address Allegations of 

Race-Based Harassment 

and Prevent Such 

Harassment on Campus 

June 3, 2020 

OIG-20-36 
June 3, 2020
	
 

 

 

DHS OIG HIGHLIGHTS
 

The U.S. Coast Guard Academy Must Take Additional Steps to

Better Address Allegations of Race-Based Harassment and Prevent 

Such Harassment on Campus
 

June 3, 2020 

Why We Did 

This Evaluation 

Multiple sources have alleged 

racial harassment at the 

Academy. We evaluated Coast 

Guard’s handling of race-based 

harassment incidents to 

determine whether there were 

issues jeopardizing the Coast 

Guard’s commitment to 

broadening its diversity to reflect 

the population it serves. 

What We 

Recommend 

We made five recommendations to 

ensure the Academy consistently: 

investigates allegations; 

appropriately documents 

disciplinary decisions; includes 

civil rights staff; and improves 

training related to race-based or 

ethnicity-based harassment or 

hate incidents. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

We identified 16 allegations of race-based harassment 

involving cadets between 2013 and 2018 that the Coast 

Guard Academy (the Academy) was aware of and had 

sufficient information to investigate and address 

through internal hate and harassment procedures. We 

identified issues in how the Academy addressed 11 of 

them. First, in six incidents, the Academy did not 

thoroughly investigate the allegations and/or did not 

discipline cadets. In some instances, cadets committed 

similar misconduct again. The Academy also did not 

include civil rights staff as required in six instances 

(including two of the instances noted previously). 

Therefore, civil rights staff could not properly track 

these incidents to proactively identify trends and offer 

the Academy assistance. In addition, in one incident 

involving potential hate allegations, the Academy did 

not follow the Coast Guard process for addressing hate 

incidents. Finally, our review determined race-based 

harassment is underreported at the Academy for 

various reasons, including concerns about negative 

consequences for reporting allegations. Underreporting 

is especially concerning because our questionnaire 

results and interviews indicate harassing behaviors 

continue at the Academy. 

Coast Guard Response 

Coast Guard concurred with all five recommendations 

and described corrective actions they have taken and 

plan to take. We consider one recommendation closed, 

and the remaining four recommendations resolved and 

open. 

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OFFICE OF INSPECTOR GENERAL 

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Table of Contents 

Introduction.................................................................................................... 3 

Background .................................................................................................... 3 

Results of Review ............................................................................................ 7 

The Academy Did Not Thoroughly Investigate All Harassment Allegations, 

and Did Not Always Discipline Cadets for Documented Violations of 

Cadet Regulations.................................................................................. 8 

Headquarters and Academy Civil Rights Professionals Did Not Oversee 

and Track All Academy Harassment and Hate Investigations 

........................................................................................................... 10 

Race-Based Harassment Is Underreported at the Academy, in Part 

Because of Concerns about Negative Consequences ............................. 15 

Recommendations......................................................................................... 18 

Appendixes 

Appendix A: Objective, Scope, and Methodology ................................. 22 

Appendix B: Coast Guard Comments to the Draft Report ..................... 24 

Appendix C: DHS OIG’s Previous Whistleblower Retaliation Report ...... 29 

Appendix D: Questionnaire Results..................................................... 31 

Appendix E: Office of Special Reviews and Evaluations Major 

Contributors to This Report ............................................. 42 

Appendix F: Report Distribution .......................................................... 43 

Abbreviations 

AHHI Anti-Harassment and Hate Incident Policy 

CRD Civil Rights Directorate 

CRSP Civil Rights Service Providers 

DEOCS Defense Equal Opportunity Management Institute 

Organizational Climate Survey 

OID Office of Inclusion and Diversity 

OIG Office of Inspector General 

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Introduction 

The United States Coast Guard Academy (Academy) prepares young men and 

women to become leaders of the United States Coast Guard (Coast Guard). 

Coast Guard leadership has stated it is committed to broadening the diversity 

of the Coast Guard workforce to be more reflective of the population it serves.1 

In May 2017, then-Commandant of the Coast Guard, Admiral Paul Zukunft, 

stated its “core values of honor, respect and devotion to duty demand [its] 

commitment and dedication to a workplace free of discrimination and 

harassment” and “harassment is incompatible with [its]...values.”2 However, in 

recent years, multiple sources, including Congress, news reports, and a 

whistleblower, have alleged racial harassment and inadequate responses at the 

Academy. Specifically, cadets alleged racial slurs, ignorant comments, and 

instances of disrespect were common on campus, and, when reported to 

leadership, were not taken seriously.3 Furthermore, in December 2018, our 

office released a whistleblower retaliation report substantiating allegations of 

reprisal against a Lieutenant Commander stationed at the Academy.4 The 

complainant alleged she was retaliated against after she complained of 

discrimination and harassment at the Academy. Appendix C contains further 

information regarding this whistleblower report. 

Background 

The Academy’s 4-year, maritime-oriented program includes academic, military, 

and athletic training. Upon completion of their degrees, Academy cadets 

become commissioned officers of the Coast Guard and are required to serve on 

active duty for at least 5 years. As of September 2019, there were 1,069 cadets 

enrolled at the Academy, with 34 percent of the cadets identifying as 

minorities. 

The Superintendent of the Academy exercises command over the entire 

Academy, including cadets, faculty, and staff. The Commandant of Cadets 

oversees the student body (corps of cadets) and employs a staff of Company 

Officers and Company Chiefs. These officers and chiefs are military personnel 

1 Diversity and Inclusion Policy Statement, Admiral Karl Schultz, Commandant, United States
 

Coast Guard, May 30, 2018. 

2 Anti-Discrimination and Anti-Harassment Policy Statement, Admiral Paul Zukunft, 

Commandant, United States Coast Guard, May 17, 2017.
 3 See Julia Bergman, CGA works to address concerns of minority treatment, retention, THE DAY, 

Sept. 2, 2017; Coast Guard Academy whistleblower speaks up on discrimination, retaliation, 

THE DAY, July 27, 2019 (available at https://www.theday.com). For summary of Congressional 

Interest, see Ltr. from Rep. Elijah E. Cummings, Committee on Oversight and Government 

Reform, and Rep. Bennie G. Thompson, Committee on Homeland Security to Admiral Karl 

Schultz, Commandant, United States Coast Guard, Aug. 19, 2019. 

4 Department of Homeland Security Office of Inspector General, Whistleblower Retaliation 

Report of Investigation, Case No. W17-USCG-WPU-16018, Dec. 4, 2018 (OIG WB ROI).
 

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assigned to the Academy who interact closely with the cadets on a daily basis 

to oversee cadet performance and development. 

Coast Guard policy, which applies to the Academy, defines prohibited 

harassment as unwelcome conduct that has the purpose or effect of 

unreasonably interfering with an individual’s work performance or creating an 

intimidating, offensive, or hostile environment on the basis of an individual’s 

protected status, including race, color, religion, national origin, political 

affiliation, or any other basis protected by law.5 

Coast Guard policy further states, “the most effective way to limit harassing 

conduct is to treat it as misconduct.”6 The Academy addresses harassing 

misconduct through two related processes, the misconduct process and the 

anti-harassment process: 

x 	 Misconduct Process. Through the misconduct process, outlined in the 

Regulations of the Corps of Cadets, the Academy assigns a cadet or staff 

member to investigate whether an individual committed the alleged 

harassment. If the investigation substantiates the harassing 

misconduct, the Academy must initiate appropriate disciplinary action. 

The Regulations of the Corps of Cadets categorizes misconduct from Class 

I (most serious) to Class III (least serious) offenses. The Academy uses 

various Class I offenses to cite cadets for harassing misconduct, 

including: 

o 1230 (Discrimination), 

o 1232 (Conduct: unbecoming Cadet), and 

o 1233 (Judgment: failure to use good judgment). 

Cadet disciplinary measures include probation; demerits;7 room 

restriction; marching tours; loss of leave and privileges; suspension from 

intercollegiate sports, club sports, or activities; and disenrollment.8 In 

addition to or in lieu of discipline, the Academy may require cadets to 

 5 COMDTINST M5350.4C, Civil Rights Manual, Ch. 2, Sec. C.1.a. 

6 COMDTINST M5350.4C, Civil Rights Manual, Ch. 2, Sec. C.1. 

7 Demerits document a cadet’s failure to abide by applicable regulations and comport himself 

or herself in the manner expected of a cadet and future officer. See SUPINST M52515.2M, 

Regulations of the Corps of Cadets at 84. 

8 Cadets disenrolled from the Academy may be required to either: 1) serve as enlisted members 

in the Coast Guard if considered suitable, or 2) pay back the costs incurred by the Academy for 

their education. For example, a cadet recently recommended for disenrollment during his last 

semester at the Academy would have been required to either serve 44 months as an enlisted 

member or reimburse the Coast Guard $223,819. See SUPINST 5340.3A, Obligated Service or 

Recoupment From Cadets Disenrolled From the Coast Guard Academy at Encl. 1. 

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undergo a 10-week process called “respect remediation,” meant to 

“identify and correct deficient areas of professionalism and prudent 

decision-making” that resulted in their misconduct.9 The Commandant 

of Cadets is responsible for the maintenance of good order and discipline 

within the corps of cadets, and has broad discretion regarding whether, 

and how severely, to discipline cadets.10 Specifically, the Regulations of 

the Corps of Cadets states, “Just as the commanding officer of a ship has 

broad and discretionary powers of discipline, so does the Commandant of 

Cadets have broad and discretionary powers to discipline Cadets.”11 

Coast Guard policy does not require Academy officials to document their 

basis for disciplinary decisions. 

x 	 Anti-Harassment Process. The Academy also follows the Coast Guard’s 

anti-harassment process, outlined in the Anti-Harassment and Hate 

Incident Policy (AHHI) in the Coast Guard Civil Rights Manual, which 

includes provisions to ensure complaints are addressed timely, the 

complainant is aware of the Academy’s actions to resolve allegations, and 

Coast Guard civil rights staff have a full picture of the racial climate.12 

The Civil Rights Directorate (CRD) is responsible for oversight and tracking of 

harassment complaints in the Coast Guard, including the Academy. Civil 

Rights Service Providers (CRSP), CRD’s representatives in the field, assist 

commands and employees in complying with Coast Guard policy and civil 

rights laws and regulations. At the time of our review, the Academy had two 

CRSPs responsible for the cadets and staff at the Academy, as well as Coast 

Guard installations in the rest of Connecticut, New Jersey, and New York. 

Hate incidents are egregious forms of harassment requiring additional 

oversight and reporting. The Civil Rights Manual defines a hate incident as any 

intentional act (conduct or speech) of intolerance committed against a person, 

a group of individuals, or property which is motivated, in whole or in part, by 

the offender’s bias against a protected group and which is intended to or is 

more likely than not to have the effect of intimidating others or inciting others 

to similar conduct. Examples include the display, presentation, creation or 

depiction of a noose, a swastika, or any other symbol widely identified with 

oppression or hatred.13 

 9 SUPINST M5215. 2M, Regulations of the Corps of Cadets at 201.
 

10 The Superintendent is the last internal appeal of the Commandant of Cadets’ disenrollment 

decisions. See SUPINST M5215. 2M, Regulations of the Corps of Cadets at 267.
 11 SUPTINST M5215.2M, Regulations of the Corps of Cadets at 84.
 12 COMDTINST M5350.4C, Civil Rights Manual, Ch. 2, Sec. C.
 13 COMDTINST M5350.4C, Civil Rights Manual, Ch. 2, Sec. C.1.e.
 

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Although the Civil Rights Manual provides processes to address harassment, it 

also recognizes a need to address conduct that does not meet the legal 

threshold of harassment. The Civil Rights Manual states: 

[A] single utterance of an ethnic, sexual, or racial epithet that offends an 

employee would not be severe enough to constitute unlawful harassment 

in violation of federal law; however, it is the Coast Guard’s view that such 

conduct is inappropriate and must be stopped.14 

The Academy does not use one single method to track complaints of 

harassment. If the Academy addresses the allegation through the misconduct 

process, the information may be stored in investigative files, internal 

misconduct tracking spreadsheets, good order and discipline notices,15 or cadet 

disciplinary records. In addition, as noted earlier, the Academy uses various 

offense charges to cite cadets for harassing misconduct. If the Academy 

addresses the allegation through the AHHI process, records of the incident may 

also be maintained by the local CRSP, and in some cases, CRD. 

To identify the full universe of allegations, we requested and reviewed the 

aforementioned documentation from Academy files and data systems related to 

all Class I misconduct, and from CRD related to harassment, from 2013 to 

2018. We also interviewed cadets and staff for their recollection of instances of 

harassment and related misconduct that may not have been reported in the 

Academy’s files. We reviewed all incidents to determine whether: 

x 	 the nature of the action, regardless of intent, was reasonably tied to race 

or ethnicity; 

x the alleged transgressor and/or the alleged victim was a cadet; 

x 	 the allegations were suitable for investigation (i.e., they were specific in 

time and place and from a credible source such as a witness, a person in 

a position to know, or official documents); and 

x the Academy was aware of the alleged incident. 

Using this methodology, we identified 16 relevant hate or harassment-related 

misconduct allegations involving cadets from 2013 to 2018.16 

 14 COMDTINST M5350.4C, Civil Rights Manual, Ch. 2, Sec. C.1. 

15 Good order and discipline notices are summaries of disciplinary hearings the Academy 

leadership posts to inform the corps of cadets of the outcome of misconduct proceedings. 

16 Despite our efforts to do so, we cannot be certain we captured all harassing misconduct the 

Academy was aware of because of its decentralized approach to addressing and documenting 

these types of incidents. We also recognize these cases do not capture the full scope of 

incidents cadets may have experienced or observed in this time frame, as some may have gone 

unreported or undocumented. 

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Results of Review 

We identified issues in how the Academy addressed 11 of 16 allegations of hate 

or harassment-related misconduct from 2013 to 2018 (see table 1). 

Table 1: Issues identified in 11 harassment and hate incidents at the 

U.S. Coast Guard Academy between 2013 and 2018 

Source: OIG analysis of Coast Guard data 

First, in 6 of the 11 incidents, the Academy did not investigate thoroughly the 

allegations and/or did not address substantiated allegations with disciplinary 

action. In two instances, the cadets who had engaged in the misconduct were 

repeat offenders. We also identified six incidents (including two noted 

previously) in which the Academy did not notify civil rights staff of the 

allegations, as required. Finally, in one incident involving potential hate 

allegations, the Academy did not follow the Coast Guard process for addressing 

hate incidents, such as coordination with civil rights staff. As a result, civil 

rights staff could not ensure the Academy followed procedures, nor could they 

properly track these incidents to proactively identify and address trends. 

Lastly, we determined race-based harassment is underreported at the Academy 

for various reasons, including concerns about negative consequences for the 

reporting cadet. 

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The Academy Did Not Thoroughly Investigate All Harassment Allegations, 

and Did Not Always Discipline Cadets for Documented Violations of Cadet 

Regulations 

Per Coast Guard policy, commanders must “immediately conduct an informal 

investigation, preliminary inquiry or formal investigation as appropriate” when 

they become aware of an allegation of harassment.17 If an investigation 

substantiates harassment has occurred, Coast Guard policy requires 

commanders to initiate appropriate disciplinary action.18 

We identified 16 allegations of harassment-related misconduct involving cadets 

from 2013 to 2018 that the Academy was aware of and had sufficient 

information to investigate and address through the misconduct or AHHI 

procedures. We determined the Academy failed to investigate thoroughly the 

allegations, and/or did not discipline cadets when investigations documented 

violations of cadet regulations or Coast Guard policy, in 6 of the 16 instances. 

In two instances, cadets conducted similar race- or ethnicity-based misconduct 

again. These six incidents include: 

(1) In April 2016, a third-year cadet (Cadet #1) repeatedly referred to a firstyear cadet (Cadet #2) as a “n****” during a conversation. Cadet #2 tried 

to remove himself from the situation, but Cadet #1 followed him and 

continued to repeatedly use the epithet. Cadet #2 reported this incident 

to a professor and also explained cadets used the racial epithet 

frequently in the barracks. The Academy launched an investigation into 

the use of the racial epithet in the barracks, during which it 

substantiated Cadet #1 used the epithet. However, the Academy did not 

charge Cadet #1 with any offenses, did not discipline him or require him 

to take respect remediation, and did not note the incident in his official 

conduct record. In January 2017, Cadet #1 was eventually disenrolled 

from the Academy after committing another incident of misconduct (see 

incident 7 on page 11). 

Investigative materials from this case contained three additional 

allegations recent and specific enough for the Academy to investigate at 

the time. Specifically, cadets alleged the following: 

(2) A fourth-year cadet (Cadet #3), while at the officer on duty desk19 in the 

barracks, made a statement that “someone was playing n  music.” 

 17 COMDTINST M5350.4C, Civil Rights Manual, Ch. 2, Sec. C.1.d. 

18 COMDTINST M5350.4C, Civil Rights Manual, Ch. 2, Sec. C.1.d. 

19 Officers on duty enforce cadet regulations, track cadets’ whereabouts, enforce study hours, 

conduct inventory of keys and equipment, and maintain required documentation.
 

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(3) A first-year cadet (Cadet #4) told his roommate he would “hate being 

black” during a conversation with a prospective cadet they were hosting 

overnight. 

(4) Cadets watched and laughed at a blackface video in a recreational 

common area in the barracks. 

The investigating officer did not pursue these three allegations further. 

When we asked why these allegations were not addressed as required, 

the investigating officer said he followed oral instructions not to go on a 

“witch hunt.”20 

(5) In July 2016, a third-year cadet (Cadet #5) made what he claimed was a 

joke to an incoming cadet during summer training: “I heard if you go to 

the Muslim Faith Service, that they teach you how to make bombs.” 

Several incoming cadets reported the incident to a staff member and the 

Academy investigated the matter. Cadet #5 was initially charged with 

two Class I offenses and recommended for disenrollment. He was 

ultimately retained, however, and did not receive any discipline, though 

he was made to complete respect remediation.21 

The investigator later learned Cadet #5 told another third-year cadet 

(Cadet #6) about the “joke” the day after making it; Cadet #6 did not 

report Cadet #5 as required by Academy policy.22 When asked about the 

comment during the investigation, Cadet #6 said he did not think any of 

the incoming cadets in that group were Muslim and he did not think the 

incident needed to be reported. Cadet #6 was not charged, disciplined, 

or given respect remediation for not reporting the “joke.” 

(6) In October 2017, Cadet #6 allegedly wrote the word “Kool Aid” on his 

omelet station order slip. As a result, when the cadet’s order was ready, 

cafeteria staff were forced to call out the word to identify to whom it 

belonged. At the same time, another cadet (Cadet #7) with whom he was 

dining allegedly said, “put that cotton up” to another cadet (Cadet #8), 

who had pulled cotton out of his pants. Two fourth-year cadets (Cadet 

#9 and Cadet #10) observed the incident. Cadet #10 indicated to Cadet 

#9 that he considered the reference to “Kool Aid” to be a racial stereotype 

and inappropriate, and Cadet #9 raised their mutual concerns regarding 

 20 Although the Commandant’s written order directed the investigating officer to pursue 

information regarding any suspected offenses discovered during the investigation, the Assistant 

Commandant later orally instructed him (using the term “witch hunt”) to not identify 

individuals. Based on this oral instruction, the investigating officer ended his investigation. 

21 The Commandant of Cadets recommended disenrollment. Cadet #5 appealed his 

disenrollment to the Superintendent, and the Superintendent granted the appeal. 

22 All cadets have a military duty to report Class I offenses, including discrimination, they 

observe or have knowledge of. Failure to do so could result in disciplinary action. See 

SUPTINST M5215.2M at 231. 

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the incident to Academy officials. According to the preliminary inquiry, 

the investigator was unable to extract complete statements from the 

accused cadets. Although the investigator believed the cadets were being 

untruthful and recommended them for further investigative proceedings 

to extract truthful statements, the Academy did not do so. Instead, the 

Academy held an informal meeting between the accused cadets and 

Cadet #9, who reported the behavior. The accused cadets were neither 

charged nor disciplined. 

We asked Academy officials why these incidents were not investigated further, 

and why cadets proven to have violated regulations were not disciplined. With 

respect to incidents (2) through (4), the Academy “[acknowledged] that multiple 

instances of inappropriate comments and terms” occurred, but did not explain 

why no further investigations were conducted into these inappropriate 

comments and terms. When asked why Cadets #6 through #8 were not 

disciplined, the Academy stated the Assistant Commandant of Cadets 

determined informal counseling was appropriate. The Commandant of Cadets 

has discretion to make cadet disciplinary decisions, and at the time of our 

review, Academy officials were not required to document their bases for 

investigative or disciplinary decisions. Therefore, we do not evaluate any 

specific disciplinary decision. 

Nevertheless, by not thoroughly investigating or consistently disciplining cadets 

for this misconduct, the Academy missed opportunities to: (1) demonstrate to 

cadets their behavior was unacceptable, (2) prevent repeat misconduct, and (3) 

show cadets reporting harassment that the Academy takes these reports 

seriously. 

Headquarters and Academy Civil Rights Professionals Did Not Oversee and 

Track All Academy Harassment and Hate Investigations 

The Academy did not consistently notify civil rights staff as required when 

investigating allegations of misconduct that could involve harassment. The 

Academy also did not consistently involve civil rights staff in hate 

investigations. Without being notified, civil rights professionals at the Academy 

and Coast Guard headquarters could not sufficiently oversee or assist the 

Academy in addressing harassment. 

Civil Rights Staff Were Not Informed of the Academy’s Response to Misconduct 

That Potentially Involved Harassment 

The AHHI process runs in parallel to the misconduct process and includes 

additional steps specific to harassment allegations. According to the AHHI 

policy, upon receiving a harassment complaint, Coast Guard commanders, 

including those at the Academy, are required to take certain actions, including: 

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x notifying the CRSP; and 

x 	 reporting the findings and outcomes to the CRSP or Director of CRD 

within 30 days from the date the incident was reported. 

These additional steps allow the CRSP to ensure the command is complying 

with procedures, and allow CRD to track the harassment complaint, as 

required.23 Such steps also allow the CRSP to advise the command whether a 

harassment complaint may actually constitute a hate incident. 

We identified six instances in which the Academy investigated allegations of 

misconduct involving race- or ethnicity-based hate or harassment, but did not 

fully involve civil rights staff as required. These cases were not part of CRD’s 

documentation on harassment incidents at the Academy and the CRSP did not 

have oversight of these cases. These involved two of the incidents described 

previously (i.e., (5) and (6)), as well as the following four incidents: 

(7) In January 2017, Cadet #1 (described on page 7 in incident (1)) and two 

other fourth-year cadets (Cadets #10 and #11) were having a 

conversation during which they remarked that many Asian American 

cadets were moving into rooms near theirs. Cadet #1 then used an 

ethnic slur, proposing signs at a water fountain near their dorm rooms 

banning Asian American cadets from using it. A Company Officer 

overheard the comment and later brought Cadet #1 into his office to 

discuss the incident. Cadet #1 eventually admitted to making the 

statement and knowing what the slur meant. The day after the incident, 

Cadet #10 approached the Company Officer to justify the use of the slur, 

saying terms like this were acceptable. Cadet #1 was eventually 

disenrolled from the Academy for this misconduct. Cadets #10 and #11 

were each found in violation of a Class II offense — failure to 

demonstrate proper leadership — for participating in a conversation of a 

discriminatory nature. They each received 2 weeks of room restriction 

and 30 demerits. 

(8) In February 2016, a group of fourth-year engineering students was 

working on an engineering project. One of the cadets (Cadet #12) 

emailed a project update document to the project sponsor, a Coast 

Guard lieutenant not assigned to the Academy. Upon opening the 

update document, the lieutenant observed “sup n** *” written in the 

progress notes. The lieutenant admonished Cadet #12 by email, and the 

cadets’ advisors notified the head of the engineering department. The 

Academic Dean requested a preliminary inquiry during which neither 

 23 COMDTINST M5350.4C, Civil Rights Manual, at 2-C.5 – 2-C.6. 

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Cadet #12 nor his teammates admitted to writing the epithet. Cadet #12 

suggested someone “played a prank” on him and wrote the epithet in the 

document while his workstation was unlocked. The investigator outlined 

multiple concerns, including that the epithet was being used casually. 

During the inquiry, Cadet #12 tried to distinguish the difference between 

“the soft ‘a’ and the hard ‘r’” when using the epithet. The investigator 

stated, “If [the cadet’s] views mirror those of the Corps of Cadets, 

significant training is required.” 

The preliminary inquiry was forwarded to the Commandant of Cadets, 

who ordered a standard investigation. The investigation did not uncover 

additional information. Cadet #12 was found in violation of a Class I 

offense (failure to use good judgment); he received 50 demerits and was 

recommended for disenrollment, but was ultimately retained at the 

Academy.24 The other cadets were not disciplined. In its explanation to 

cadets on the outcome of this incident, the Academy stated, “One of the 

main takeaways from this case is that it is always important to maintain 

positive control of documents, either electronic or physical. Leaving a 

workstation unlocked can lead [to] many problems, some with dire 

consequences. It is also important to note that racism is not acceptable 

in any form and will be met with severe consequences.”25 

(9) In the Fall of 2016, Academy leadership tasked Company Officers and 

Chiefs with communicating major takeaways to cadets regarding the 

April 2016 investigation into the use of the racial epithet “n****” (incident 

(1) described previously). Academy leadership wanted to provide 

guidance that using the epithet, even when not meant to be hateful or 

when used between friends, created an intimidating, offensive, or hostile 

work environment and was a violation of Academy policy. However, one 

Company Officer used the epithet in the very briefing intended to 

communicate to cadets that they should not use that word. The 

Assistant Commandant of Cadets learned about the incident and during 

the inquiry into this incident, the Company Officer said he used the 

epithet as part of a “shock and awe” approach. The Company Officer was 

counseled and given training. 

(10) In October 2017, a second-year cadet (Cadet #13) was providing a tour 

of the Academy to prospective students and their families. At one point 

during the tour, Cadet #13 referred to the USCG EAGLE, a ship used for 

training, as a “slave ship.” One family was offended and reported the 

incident to the staff member who had invited them. The Academy 

investigated the incident; Cadet #13 was ultimately found in violation of 

 24 An Academy official subsequently asked the Superintendent not to disenroll Cadet #12. 

25 Good Order and Discipline Notice at 4 (Dates of coverage: April 1-30, 2016). 

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a Class II offense (Conduct: unbecoming a cadet), and received 30 

demerits and room restriction for 2 weeks. 

Our review of documentation indicated only one of these incidents — all of 

which involved potential race- or ethnicity-based harassment — had been 

referred to the CRSP, as required.26 In no instance did the command notify the 

CRD within 30 days of finalized findings and outcomes. We asked Academy 

officials why civil rights staff were not made aware of these incidents; the 

Academy provided no answer and instead forwarded our question to CRD. We 

reviewed these cases with CRD staff, who confirmed the six cases should have 

been reported to them. A CRD official further explained that their inability to 

see the full range of incidents at the Academy would prevent them from 

identifying “red flags” and proactively assisting commands with their racial 

climate. Because CRD was not aware of these cases, none of these incidents 

was included in CRD’s data. We only found these cases through interviews 

and by reviewing internal conduct trackers, investigative documents, and good 

order and discipline notices. 

Civil Rights Staff Were Not Fully Involved in Addressing Potential Hate 

Incidents 

Hate incidents are egregious forms of harassment and have the potential not 

only to intimidate, but to incite others to behave similarly. The Civil Rights 

Manual describes specific actions Coast Guard officials must take when 

encountering a hate incident, which are in addition to the harassment 

procedures described in the previous section. They include, among others: 

x 	 Upon becoming aware of any potential hate incidents in their 

respective areas of responsibility, Commanders or CRSPs must
 

immediately notify the Director, CRD via their chain of command, 

and be prepared to provide sufficient information to describe the 

incident, e.g., photographs, informal statements, etc. 

x 	 A commander who becomes aware of a hate incident will
 

electronically report the incident within 48 hours to a CSRP.... 

x 	 CRSPs will assist unit commanders in determining if a harassment
 

complaint constitutes a hate incident. Additionally, they shall notify
 

 26 During the preliminary inquiry for incident (8), the head of the engineering department 

stated he contacted the CRSP to discuss the incident. However, the CRSP stated the Academy 

did not notify him of any of these incidents. 

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unit commanders if they determine that a harassment complaint 

constitutes a hate incident but has not been reported as such. 

x 	 ...Commanders shall continue to follow up via their CRSP as the 

situation continues to develop.27
 

Of the two potential hate incidents the Academy addressed during the time 

period we reviewed, one did not involve civil rights staff as fully as required. 

Specifically: 

(11) In April 2017, the Academy investigated an incident when two secondyear cadets (Cadet #14 and Cadet #15) posed in front of a confederate 

flag and posted the picture on Cadet #14’s social media. In his profile 

picture, Cadet #14 is wearing a Coast Guard uniform. Later in the 

evening, a classmate approached Cadet #14 and advised him to take 

down the post because it could be offensive; the cadet did so. By then, 

other cadets had already seen the post and ultimately reported the 

incident. During the Academy’s investigation of the incident, Cadet #14 

said he intended to “make a joke” by taking the picture with the 

confederate flag in the background. 

The Academy investigated the social media posting under AHHI as a 

hate incident. However, the command did not report it to the Director of 

CRD immediately; did not report the incident to the CRSP within 48 

hours; and did not follow up with the CRSP as it developed further 

information, as required by procedures for hate incidents. Furthermore, 

per harassment procedures, the command was required to provide the 

findings and outcomes of the investigation to the Director of CRD 

through the CRSP within 30 days, which it did not do. Therefore, this 

incident was not part of the CRD tracking database for AHHI hate 

incidents. In addition, because the CRSP was not fully involved, the 

command proceeded without the benefit of the CRSP’s expertise in the 

harassment process. 

Ultimately, the command found hate to be unsubstantiated. However, 

the command made no finding on whether the posting constituted 

harassment, which is required even if the allegation of hate is not 

substantiated.28 In his report, the investigator stated the cadet should 

have been aware the photo he posted could have the effect of 

“intimidating or offending people” who followed his Instagram activity — 

this language mirrors the Coast Guard’s own language for the definition 

of prohibited harassment. The investigator concluded the cadet should 

 27 COMDTINST M5350.4C, Civil Rights Manual at 2-C.6. 

28 COMDTINST M5350.4C, Civil Rights Manual at 2-C.5. 

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be disciplined; however, the Academy did not discipline any of the 

cadets involved. 

In May 2019, the Coast Guard updated its Civil Rights Manual to require 

commands to articulate, in writing, the basis for the determination of whether 

harassment or hate occurred, and the evidence reviewed to reach the 

determination, in its reports of findings and outcomes to the CRSP.29 The 

updated Civil Rights Manual also emphasizes that, when hate is not 

substantiated, the command must consider whether the incident could be 

considered harassment and whether it should be investigated as such. The 

Civil Rights Manual further emphasizes that, while commands retain decision 

authority on whether a hate incident occurred and the appropriate response, 

they must consult the CRSP as well as legal counsel.30 Given the issues we 

identified with the Academy’s handling of several harassment and hate 

incidents, as well as these recent updates and clarifications to Coast Guard 

policy, additional training for Academy staff and cadets on how to respond to 

these types of allegations could ensure the new policies are known and 

enhance the Academy’s ability to better address such incidents in the future.

Race-Based Harassment Is Underreported at the Academy, in Part Because 

of Concerns about Negative Consequences 

In December 2018, we sent a questionnaire to 1,072 cadets; 122 cadets 

responded.31 Respondents indicated they were aware of certain harassing 

behaviors occurring at the Academy. Although cadets indicated in the 

questionnaire that they are aware of how to report race-based harassment, 

they may not do so for various reasons, the most troubling of which is fear of 

negative consequences. 

Cadets Responding to Our Questionnaire Indicated They Understand How to 

Report Harassment, But May Not Do So Out of Fear of Negative Consequences 

All cadets have a military duty to report Class I offenses, including 

discrimination, they observe or have knowledge of.32 To understand cadets’ 

experiences with racial or ethnicity-based harassment, including their comfort 

with reporting such behavior, we sent a questionnaire to the entire corps of 

cadets. 

 29 COMDTINST M5350.4D, Civil Rights Manual at 3-12.i (harassment incidents); and 

COMDTINST M5350.4D, Civil Rights Manual at 3-15.b (hate incidents). 

30 COMDTINST M5350.4D, Civil Rights Manual at 3-15.c. 

31 The full results of our questionnaire are included as appendix D to this report. The survey
 

results included in the report represent the experiences and observations of those who 

responded only, and not of the entire student body. 

32 SUPTINST M5215.2M at 231. 

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More than 80 percent of the 122 respondents stated they understood how to 

report race-based harassment at the Academy. However, of the cadets who 

provided details on their likelihood to report harassing behavior, only 59 

percent said they would report it through designated channels. The main 

influences listed by cadets as affecting whether they would report include: 

x 	 the seriousness of the action, as well as the offender’s intent or overall 

character; 

x 	 their ability to address the problem on their own; and 

x 	 their assessment of whether they would be negatively affected by the 

reporting. 

Academy policy encourages cadets to try resolving issues themselves, and this 

policy may result in the reporting influences described in the first two bullets. 

However, one-third (36 of 108)33 of the cadets who responded to a question 

about reporting said their decision to report harassment would be influenced 

by whether they believed they would be negatively affected by reporting. 

Similarly, our interviews with cadets and former cadets identified concerns 

about negative consequences. For example, two individuals we interviewed told 

us they experienced negative consequences after participating in investigations 

into potential harassing misconduct. One of the individuals said, after taking 

part in the investigation of a fellow cadet of the same race, an officer at the 

Academy counseled the cadet to “support” others of the same race. This cadet 

also reported facing repercussions and being ostracized for reporting 

harassment, even after graduation from the Academy.Other cadets we 

interviewed said cadets know how to report, but will not because of the 

potential for backlash from the cadet community. 

At the Time of Our Review, Race-Based Harassing Behaviors Were Still 

Occurring at the Academy 

Underreporting is especially concerning because, based on our questionnaire 

results and interviews with cadets and Academy officials, harassing behaviors 

continue. During our interviews with cadets, they described offensive 

comments of which they were aware. They explained that, at least on some 

occasions, they understood the comments were not intended to be offensive. 

Cadets provided the following examples of behavior or language they had 

experienced or witnessed: 

x 	 cadets called African American cadets “sensitive” because they called out 

a white cadet for addressing them by saying “what’s up my n***”; 

 33 Cadets were not required to answer all questions. Furthermore, some questions were not 

presented to cadets depending on their prior responses. 

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x 	 cadets asked an African American cadet, “Why do you talk so white for a 

black person”; 

x cadets asked Hispanic cadets about drugs and Pablo Escobar; 

x 	 cadets heard Company Officers calling each other by slurs in a “friendly” 

way, such as “chapo”; and 

x 	 an African American cadet said a white cadet was feeling “extra white” 

that day because he was listening to sea shanties.34 

Questionnaire responses provide further evidence that these types of behavior 

continue to occur at the Academy. In the survey, we provided cadets with a list 

of harassing behaviors and asked whether they were directly or indirectly 

aware of these behaviors while attending the Academy. Of the 84 cadets who 

chose to respond to this question, 68 cadets (81 percent of respondents) stated 

they were aware of the harassing behaviors, including: 

x jokes; 

x stereotyping; 

x microaggressions; 

x demeaning comments; 

x derogatory epithets or slurs; and 

x retaliation for reporting or complaining about derogatory behaviors. 

Other surveys also indicate potentially harassing behavior occurs at the 

Academy. The Academy participates in the Defense Equal Opportunity 

Management Institute Organizational Climate Survey (DEOCS), a survey used 

across the Department of Defense to assess organizational effectiveness, equal 

opportunity, and sexual assault response and prevention.35 We compared 

cadet DEOCS results from 2017 and 2018 and observed worsening results in 

race/ethnicity climate-related topics. For example, the percent of cadets who 

said racial slurs, comments, or jokes were not used on campus decreased more 

than 35 percent between 2017 and 2018. Similarly, an increased percentage of 

respondents, regardless of race, reported experiencing disparate treatment 

based on race or ethnicity. Moreover, both the 2017 and 2018 survey results 

indicate that more than 70 percent of perceived disparate treatment based on 

race, gender, sexual orientation, or religion goes unreported at the Academy. 

 34 A sea shanty is a type of work song once commonly sung to accompany labor on board large 

merchant sailing vessels from at least the 15th century through the first half of the 20th 

century (such as “Blow the Man Down” and “Drunken Sailor”). 

35 At the Academy, DEOCS is administered within 180 days of a new Superintendent assuming 

command and annually thereafter. 

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Although cadets do receive basic equal opportunity training, they do not receive 

mandatory training on recognizing when they commit harassing behaviors 

themselves. Those limited number of cadets who receive this type of training 

receive respect remediation, which is meant to challenge cadets to reflect on 

their own backgrounds and perceptions. However, respect remediation is not 

administered proactively to cadets; instead, it is used as a corrective tool after a 

cadet commits an offense that is reported and investigated. 

Recommendations 

We recommend the Superintendent of the Coast Guard Academy: 

Recommendation 1: To the extent feasible, investigate all incidents involving 

race- or ethnicity-based harassment, documenting investigative actions taken 

in response to such incidents, including the basis for decisions not to 

investigate a particular incident. 

Recommendation 2: Require the reasons for disciplinary decisions be 

documented in writing, including the decision not to take disciplinary action, 

after each investigation of a race- or ethnicity-based harassment incident. 

Recommendation 3: Ensure appropriate notification is given to civil rights 

staff of all alleged misconduct when the nature of the misconduct, regardless of 

intent, could reasonably relate to race or ethnicity. 

Recommendation 4: Provide mandatory training for Academy personnel and 

cadets involved in investigating incidents of harassment or hate on applicable 

policies and procedures regarding how to properly handle these incidents. 

Recommendation 5: Provide mandatory training to cadets on how to recognize 

and avoid harassing behaviors. 

Management Comments and OIG Analysis 

Appendix B contains a copy of Coast Guard’s management response in its 

entirety. We also received technical comments and incorporated them in the 

report where appropriate. We consider one recommendation closed, and the 

remaining four recommendations resolved and open. A summary of Coast 

Guard’s responses and our analysis follows. 

Coast Guard concurred with all five recommendations, but expressed four 

specific concerns with the report. The Coast Guard’s concerns, as well as our 

response, are described below. 

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1. First, Coast Guard disputed the characterization of the CRSP as having 

oversight of harassment complaints, and stated the CRSP’s role 

regarding AHHI claims is “limited to civil rights policy guidance and 

tracking timeliness of command actions.” This description minimizes the 

importance of the CRSP in the Coast Guard’s own written policies in 

ensuring the Academy complies with harassment procedures. The Civil 

Rights Manual states “CRD is responsible for coordinating Coast Guard 

harassment policy and general oversight of the harassment complaint 

process....” The CRSP provides this guidance and oversight in the field. 

Furthermore, the Civil Rights Manual states “Civil Rights Detachments 

are required [emphasis added] to assist commands, employees, and 

military members in complying with the[se] procedures...CRSPs are 

process experts and act as facilitators to ensure that all harassment 

complaints are handled in a timely manner.” These excerpts from Coast 

Guard’s own policy establish the clear role the CRSP and CRD play in 

providing oversight and ensuring policy compliance.

2. Second, Coast Guard was concerned the draft report did not discuss the 

role the Office of Inclusion and Diversity (OID) plays in advising the 

Superintendent on disciplinary issues. Specifically, Coast Guard said 

the office provides oversight of diversity and inclusion programs at the 

Academy, recommendations regarding potential disciplinary action 

against cadets, and advice to the Superintendent on racial climate 

issues. While accurate, OID’s role is not relevant to the Academy’s 

compliance with its policies on addressing harassment incidents. The 

applicable Coast Guard policy does not include OID as part of the 

required AHHI process. 

3. Third, Coast Guard stated the report was not explicit about the 

questionnaire’s response rate, and infers corps-wide conclusions based 

on responses from a small number of cadets. This is not accurate; the 

report specifically describes feedback as coming from those who chose to 

participate only. For example, the report states “Cadets responding to 

our questionnaire indicated they understand how to report harassment, 

but may not so do out of fear of negative consequences.” The report also 

includes the number of respondents throughout this section and in 

appendix D, which contains the full results and specific response rates 

for each question. The report does not extrapolate any result to the 

entire student body. However, we added clarifying language in the body 

of the report to reinforce this. 

4. Finally, Coast Guard raised questions about the criteria underlying 

conclusions the draft report purportedly reaches regarding the 

thoroughness of some investigations and the appropriateness of 

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particular disciplinary actions. In assessing whether an investigation 

was sufficiently thorough, we relied on the following criteria: 1) whether 

an investigation occurred at all, and 2) whether investigators were 

permitted to explore all relevant topics and leads in conducting their 

investigations. These criteria were not met in the instances where we 

call into question the thoroughness of the investigation. Regarding 

disciplinary action, contrary to Coast Guard’s assertion, the report does 

not pass judgment on the appropriateness of particular disciplinary 

actions; it simply points out whether cadets were disciplined, and if so, 

what the disciplinary actions were. 

A summary of Coast Guard’s responses to the recommendations and our 

analysis follows. 

Coast Guard Response to Recommendation 1: Coast Guard concurred with 

the recommendation. Coast Guard requires commanding officers to investigate 

all incidents involving race- or ethnicity-based harassment. A May 2019 

update to the Civil Rights Manual now also requires commanding officers to 

“articulate, in writing, the basis for the determination of whether harassment 

and/or bullying occurred, and the evidence reviewed to reach the 

determination.” 

OIG Analysis: We consider this action responsive to the intent of the 

recommendation, which is resolved and closed. We note that although 

commanding officers have always been required to investigate all incidents 

involving race- or ethnicity-based harassment, this was not always done. It is 

our expectation that a written explanation of investigative actions taken in 

response to harassing misconduct will improve accountability in this area. 

Coast Guard Response to Recommendation 2: Coast Guard concurred with 

the recommendation. Coast Guard referenced the May 2019 updated policy 

requiring documentation of investigative actions taken in response to 

harassment, as well as a subsequent update requiring the memorandum 

documenting these actions be provided to the next level in the chain of 

command. Coast Guard is in the process of updating its policies to require 

written documentation of the reasons for no administrative or disciplinary 

action in cases where harassment is substantiated. Coast Guard anticipates 

completion by December 31, 2020. 

OIG Analysis: We consider this action responsive to the intent of the 

recommendation, which is resolved and open. We anticipate closing this 

recommendation when we receive the updated policy requiring written 

documentation of the reasons for no administrative or disciplinary action in 

cases where harassment is substantiated. 

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Coast Guard Response to Recommendation 3: Coast Guard concurred with 

the recommendation. Coast Guard policy already requires commanding 

officers to notify the local CRSP upon notification of a complaint of prohibited 

harassment. Coast Guard is also updating training courses for antiharassment and hate incident investigations for Commanding Officers, Officers 

in Charge, and individuals assigned as Investigating Officers. Coast Guard 

asked for the recommendation to be considered resolved and closed. 

OIG Analysis: We consider this action partially responsive to our 

recommendation, which is resolved and open. Our concern remains that 

commands are incorrectly identifying which cases should prompt antiharassment and hate procedures. We anticipate closing the recommendation 

when the Academy has a process to inform the CRSP of alleged misconduct 

that could reasonably relate to race or ethnicity early enough so cases are 

properly identified and the anti-harassment and hate processes are 

implemented consistently. 

Coast Guard Response to Recommendation 4: Coast Guard concurred with 

the recommendation. Coast Guard is considering ways to improve and update 

investigator training, and to provide investigators the necessary tools to ensure 

they appropriately investigate incidents. Coast Guard anticipates completion 

by December 31, 2020. 

OIG Analysis: We consider this action responsive to our recommendation, 

which is resolved and open. We anticipate closing this recommendation when 

we receive documentation of the updated training and the process by which 

this training will be provided to individuals involved in investigating 

harassment or hate incidents. 

Coast Guard Response to Recommendation 5: Coast Guard concurred with 

the recommendation. Coast Guard provides civil rights awareness training; 

sexual assault awareness and prevention training; initial core values training; 

and, if needed, core values remediation training. Cadets also receive Bystander 

Intervention training at various points during the 200-week training program, 

which empowers cadets to intervene if they see, among other problematic 

behaviors, sexual harassment. 

OIG Analysis: We consider this action responsive to our recommendation, 

which is resolved and open. The intent of the recommendation is to increase 

cadets’ awareness of offensive and inappropriate behavior regarding race and 

ethnicity. The documentation provided does not show training material that is 

preventative in nature. We will close this recommendation when we receive 

documentation of mandatory training for cadets that teaches them to recognize 

when they or their peers commit harassing behaviors. 

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Appendix A 

Objective, Scope, and Methodology 

The Department of Homeland Security Office of Inspector General was 

established by the Homeland Security Act of 2002 (Public Law 107ï296) by 

amendment to the Inspector General Act of 1978. 

We reviewed whether the Academy has effective processes for reporting, 

investigating, and taking corrective action in response to allegations of race- or 

ethnicity-based harassment. 

Review of Harassment Allegations 

As described in the body of the report, the Academy uses two channels to 

address potential misconduct that could involve discrimination or harassment. 

We requested information from several sources to identify possible incidents of 

harassment or discrimination at the Academy from 2013 to 2018. Specifically 

we requested and reviewed: 

x documentation for all harassment and discrimination cases; 

x a list of all harassment and discrimination complaints; 

x the Academy’s conduct tracker, which catalogs all Class I investigations, 

for all years in our scope; and 

x Good Order and Discipline Notices published by the Academy. 

We interviewed past and present Academy leadership, including the 

Superintendent, the Commandant of Cadets, the Assistant Commandant of 

Cadets, the Regimental Officer, legal counsel, and staff, including Company 

Officers and Chiefs. We also spoke with cadets involved in diversity and 

inclusion efforts on campus. We asked most of these interviewees if they were 

aware of any possible harassment incidents. 

Cadet Survey 

We administered a questionnaire to all 1,072 cadets at the Academy, providing 

them an opportunity to describe: 

x their knowledge of and adherence to procedures and processes in place 

to respond to harassment or discrimination based on race or ethnicity; 

x the Academy’s climate, i.e., the prevailing effect of conditions relating to 

race and ethnicity on cadet life, activities, and education at the Academy; 

and 

x their experiences with racial or ethnicity-based harassment and 

discrimination. 

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We asked cadets to focus on incidents during their time as a cadet at the 

Academy, including both on and off campus. The full results of our 

questionnaire are included as appendix D. 

We conducted this review under the authority of the Inspector General Act of 

1978, as amended, and according to the Quality Standards for Inspection and 

Evaluation issued by the Council of the Inspectors General on Integrity and 

Efficiency. 

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Appendix B 

Coast Guard Comments to the Draft Report 

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Appendix C 

DHS OIG’s Previous Whistleblower Retaliation Report 

In December 2018, our office released a whistleblower retaliation report 

regarding alleged reprisal against a Lieutenant Commander stationed at the 

Academy.36 Our office’s investigation substantiated the Lieutenant 

Commander’s claim that she was retaliated against after making discrimination 

and harassment complaints against her superiors. While this report and the 

whistleblower retaliation report generally address two different discrimination 

processes (the Coast Guard Academy’s internal discrimination process and the 

Military Equal Opportunity discrimination process, respectively), we found 

similar issues in both, as described in the following paragraphs. 

Lack of Thorough Investigations 

Pages 8–10 of this report contain examples of harassment allegations that were 

not investigated thoroughly. For example, the report describes one allegation 

in which a cadet used a racially insensitive term for his breakfast order. After 

a preliminary inquiry, the investigator recommended further investigative 

proceedings to obtain complete statements from the subjects, but the Academy 

did not do so. 

The whistleblower retaliation report describes a similar example in which, after 

a preliminary inquiry, an Academy official recommended a full administrative 

investigation of the complainant’s allegation. Instead, the Academy conducted 

a general climate and culture investigation, which was relatively superficial and 

did not address the complainant’s particular situation. 

Lack of Documentation 

Pages 8–10 of this report describes incidents in which cadets were not 

disciplined, including cases when the investigator recommended further action, 

but we could not determine why because Academy policy does not require 

Coast Guard officials to document their basis for disciplinary decisions. 

The whistleblower retaliation report found similar issues, in that while the Civil 

Rights Manual requires commanders to report “findings and outcomes” to CRD 

for harassment complaints, it does not specify any level of detail for the 

reasons for these findings and outcomes. The report stated, “[There] should be 

some written record explaining the basis for a commanding officer’s conclusion, 

particularly where it appears inconsistent with an investigator’s findings,” and 

recommended the Secretary direct the Coast Guard require commanding 

officers document in writing the reasons for their determinations, both when 

substantiating and unsubstantiating allegations. 

 36 Department of Homeland Security Office of Inspector General, “Whistleblower Retaliation 

Report of Investigation,” Case Number: W17-USCG-WPU-16018, December 4, 2018 

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Retaliation 

Page 16 of this report describes how one-third of questionnaire respondents 

reported their decision to report harassing behaviors would be influenced by 

their assessment of whether they would be negatively affected by the reporting. 

The report also describes how individuals at the Academy told us they 

experienced negative consequences after participating in the harassment 

process. 

Similarly, the whistleblower retaliation report substantiated the complainant’s 

claim that she was retaliated against on the basis of her discrimination and 

harassment complaints, and that the Coast Guard subjected the complainant 

to additional harassment and retaliatory actions after she filed the complaints. 

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Appendix D 

Questionnaire Results 

Of the 1,072 cadets who received the questionnaire, 122 cadets responded.37 

In some instances, we directed individuals to different questions based on their 

responses. In other instances, cadets may have chosen not to respond to 

certain questions. We indicate, where possible, when the total number of 

respondents was less than 122. Due to rounding, the sum of percents 

included in the following tables may not total 100 percent for all questions. 

Policies and Processes 

In this part of the questionnaire, we asked cadets about their knowledge of 

processes to respond to, and remedy, discriminatory or harassing behaviors, as 

well as their potential responses if faced with these behaviors. 

Question Strongly 

Disagree Disagree 

Neither 

Agree nor 

Disagree 

Agree 

Strongly 

Agree 

Prefer 

not to 

answer 

I understand what constitutes race 

and/or ethnicity-based 

discrimination according to 

Academy policy 

0 4 

3% 

4 

3% 

67 

55% 

46 

38% 

1 

1% 

I understand what constitutes race 

and/or ethnicity-based 

harassment according to Academy 

policy 

0 7 

6% 

9 

7% 

61 

50% 

44 

36% 

1 

1% 

I understand what actions and 

speech are permissible while on 

campus 

3 

2% 

6 

5% 

4 

3% 

59 

48% 

49 

40% 

1 

1% 

I understand what actions and 

speech are permissible while off 

campus 

4 

3% 

6 

5% 

6 

5% 

60 

49% 

45 

37% 

1 

1% 

I understand how to report race 

and/or ethnicity-based 

discrimination at the Academy 

3 

2% 

9 

7% 

12 

10% 

55 

45% 

42 

34% 

1 

1% 

I understand how to report race 

and/or ethnicity-based 

harassment at the Academy 

3 

2% 

8 

7% 

10 

8% 

59 

48% 

41 

34% 

1 

1% 

 37 We collected demographic information from respondents, including class year, race, and 

ethnicity. We do not publish these results because the small number of responses reduces the 

anonymity of minority respondents. 

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I would most likely report the disparate treatment on the basis of race and/or 

ethnicity to:38 

Reporting channel (120 respondents) # of 

respondents 

% of 

respondents 

Office of Superintendent 8 7 

Commandant of Cadets 12 10 

Company Officers or Company Chiefs 66 55 

Cadet Training 9 8 

Academy Office of Civil Rights 46 38 

Academy Staff Judge Advocate or other Coast Guard Attorney 7 6 

Coast Guard Civil Rights Directorate 24 20 

Office of Diversity and Inclusion 61 51 

Inclusive Excellence Council (IEC) 8 7 

Leadership and Diversity Advisory Council (LDAC) 13 11 

Diversity Peer Educators 54 45 

Diversity Council presidents and staff advisors 36 30 

Professors 32 27 

Company leaders 67 56 

Fellow cadets 62 52 

Another person/entity not listed: 

x Family 

x Close friends 

x Chaplains 

x Mentors 

x Media 

5 4 

Question (116 respondents) Strongly 

Disagree Disagree 

Neither 

Agree nor 

Disagree 

Agree 

Strongly 

Agree 

Prefer 

not to 

answer 

If I feel I am being subjected to 

treatment different from other 

cadets on the basis of my 

race/ethnicity, I would report it 

9 

8% 

19 

16% 

18 

16% 

45 

39% 

23 

20% 

2 

2% 

through designated channels 

If I experienced this treatment, the primary influences on my decision whether 

to report it would be:39 

Primary influence (108 respondents) # of 

respondents 

% of 

respondents 

My uncertainty over how to report 10 9 

The amount of effort it takes to report 23 21 

The likelihood my complaint would be taken seriously 31 29 

The offender’s overall character 37 34 

 38 Cadets were asked to select all that apply; totals may exceed 100 percent of respondents. 

39 Cadets were asked to select up to five choices; totals may exceed 100 percent of respondents. 

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Primary influence (108 respondents) # of 

respondents 

% of 

respondents 

The seriousness of the action 76 70 

The offender’s intent 69 64 

The fairness of the potential punishment in comparison to the action 31 29 

My ability to address the problem on my own 58 54 

My assessment of whether I will be negatively affected by using the 

process 

36 33 

My assessment of whether my leadership will support my decision 11 10 

The likelihood that someone else will report 7 6 

Whether the action took place off campus and/or off-duty 9 8 

The likelihood that a person in authority already knows about the action 11 10 

Other factor(s) not listed above: 

x Lack of diversity in staff and faculty 

x No representation in the individuals to report misconduct to 

x The Academy’s past leniency in discipline in response to racebased misconduct 

2 2 

Question (112 respondents) Strongly 

Disagree Disagree 

Neither 

Agree nor 

Disagree 

Agree 

Strongly 

Agree 

Prefer 

not to 

answer 

If I witnessed a cadet being treated 

differently from other cadets on the 

basis of their race/ethnicity, I 

would report it through designated 

1 

1% 

7 

6% 

16 

14% 

52 

46% 

35 

31% 

1 

1% 

channels 

If I witnessed this treatment, the primary influences on my decision whether to 

report it would be:40 

Primary influence (109 respondents) # of 

respondents 

% 

of respondents 

My uncertainty over how to report 9 8 

The amount of effort it takes to report 14 13 

The likelihood my complaint would be taken seriously 25 23 

The offender’s overall character 31 28 

The seriousness of the action 79 72 

The offender’s intent 60 55 

The fairness of the potential punishment in comparison to the action 31 28 

My ability to address the problem on my own 58 53 

My assessment of whether I will be negatively affected by using the 

process 

18 17 

My assessment of whether my leadership will support my decision 16 15 

The likelihood that someone else will report 22 20 

Whether the action took place off campus and/or off-duty 8 7 

The likelihood that a person in authority already knows about the action 9 8 

 40 Cadets were asked to select up to five choices; totals may exceed 100 percent of respondents. 

www.oig.dhs.gov 33 OIG-20-36 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Primary influence (109 respondents) # of 

respondents 

% 

of respondents 

Other factor(s) not listed above: 

x The desire of the victim to report the incident 

x My own understanding of what constitutes disparate treatment 

x My own lack of understanding from a cultural aspect why the 

victim believed they were treated differently 

5 5 

Question (107 respondents) Strongly 

Disagree Disagree 

Neither 

Agree nor 

Disagree 

Agree 

Strongly 

Agree 

Prefer 

not to 

answer 

If I became aware of a cadet being 

treated differently from other 

cadets on the basis of their 

race/ethnicity, I would report it 

1 

1% 

10 

9% 

19 

18% 

43 

40% 

32 

30% 

2 

2% 

through designated channels 

If I became aware of this treatment, the primary influences on my decision 

whether to report it would be:41 

Primary influence (100 respondents) # of 

respondents 

% of 

respondents 

My uncertainty over how to report 3 3 

The amount of effort it takes to report 16 16 

The likelihood my complaint would be taken seriously 21 21 

The offender’s overall character 35 35 

The seriousness of the action 71 71 

The offender’s intent 53 53 

The fairness of the potential punishment in comparison to the action 22 22 

My ability to address the problem on my own 49 49 

My assessment of whether I will be negatively affected by using the 

process 

12 12 

My assessment of whether my leadership will support my decision 14 14 

The likelihood that someone else will report 23 23 

Whether the action took place off campus and/or off-duty 7 7 

The likelihood that a person in authority already knows about the action 18 18 

Other factor(s) not listed above 1 1 


 

 41 Cadets were asked to select up to five choices; totals may exceed 100 percent of respondents. 

www.oig.dhs.gov 34 OIG-20-36 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



General Climate 

In this part of the questionnaire, we asked cadets to answer using a broad 

perspective regarding the Academy’s climate, i.e., the prevailing effect of 

conditions relating to race and ethnicity in cadet life, activities, and education 

at the Academy. 

Question (106 respondents) Positively Not at 

all Negatively 

Prefer not 

to answer 

The Academy’s climate relating to race and ethnicity 

impacts my academic work 

25 

24% 

67 

63% 

9 

8% 

5 

5% 

The Academy’s climate relating to race and ethnicity 

impacts my preparation to become an officer in the 

United States Coast Guard 

48 

45% 

39 

37% 

15 

14% 

4 

4% 

The Academy’s climate relating to race and ethnicity 

impacts my extracurricular or social activities 

31 

29% 

62 

58% 

10 

9% 

3 

3% 

The Academy’s climate relating to race and ethnicity 

impacts my opinion about the Academy 

35 

33% 

32 

30% 

29 

27% 

10 

9% 

Question (102 respondents) Strongly 

Disagree Disagree 

Neither 

Agree nor 

Disagree 

Agree 

Strongly 

Agree 

Prefer 

not to 

answer 

My fellow cadets help maintain an 

inclusive racial and ethnic climate 

3 

3% 

8 

8% 

15 

15% 

43 

42% 

31 

30% 

2 

2% 

The faculty and staff help maintain 

an inclusive racial and ethnic 

climate 

1 

1% 

3 

3% 

18 

18% 

40 

39% 

38 

37% 

2 

2% 

The company command structure 

helps maintain an inclusive racial 

and ethnic climate 

4 

4% 

7 

7% 

19 

19% 

36 

35% 

34 

33% 

2 

2% 

The Academy’s overall climate 

relating to race and ethnicity has 

improved since I arrived on campus 

6 

6% 

17 

17% 

46 

45% 

17 

17% 

13 

13% 

3 

3% 

I do not see any issues with the 

climate at the Academy 

15 

15% 

25 

25% 

14 

14% 

26 

25% 

20 

20% 

2 

2% 

I believe the media has accurately 

represented these issues at the 

Academy 

36 

35% 

26 

25% 

20 

20% 

11 

11% 

6 

6% 

3 

3% 

I believe I can engage my fellow 

cadets in conversations on issues 

related to race or ethnicity without 

suffering consequences 

11 

11% 

13 

13% 

17 

17% 

35 

34% 

25 

25% 

1 

1% 

My fellow cadets are culturally 

sensitive 

6 

6% 

15 

15% 

21 

21% 

35 

34% 

24 

24% 

1 

1% 

I believe all cadets have the same 

experience at the Academy 

regardless of their race or ethnicity 

22 

22% 

30 

29% 

20 

20% 

12 

12% 

16 

16% 

2 

2% 

www.oig.dhs.gov 35 OIG-20-36 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



We presented a list of behaviors that, if present, may affect the climate at the 

Academy. We asked cadets to select any behavior they were directly or 

indirectly aware of while attending the Academy, regardless of whether the 

communication or activity was directed at them personally.42 

We further explained selecting a behavior means they have seen it happen or 

are aware of it happening to a cadet they knew personally. Not selecting a 

behavior does not mean they believe it never happens. We also asked them not 

to include behaviors they only know about through media reports. 

Behavior (78 respondents selected at least one choice) # of 

respondents 

% of 

respondents 

Jokes about a certain race/ethnicity 57 73 

Demeaning comments about a certain race/ethnicity 31 40 

Stereotyping based on race/ethnicity 48 62 

Microaggressions toward people of a certain race or ethnicity (i.e., 

everyday verbal, nonverbal, and environmental slights, snubs or insults, 

whether intentional or unintentional, that communicate negative 

messages about people of a certain race or ethnicity) 

37 47 

Derogatory epithets or slurs used to describe an individual or group of 

individuals belonging to a certain race/ethnicity 13 17 

Derogatory epithets or slurs related to a certain race/ethnicity used in 

the context of reciting or describing popular media, e.g., music or film 17 22 

Excluding a cadet from a beneficial action/activity because of his or her 

race/ethnicity43 6 8 

Targeting a cadet for a detrimental action/activity because of his or her 

race/ethnicity 9 12 

Retaliation for reporting or complaining about derogatory behaviors 

toward a race/ethnicity 16 21 

Pressure, including threats, to not report derogatory behaviors toward a 

race/ethnicity 5 6 

Other type of communication or activity that is not listed above: 

x Being questioned why they would report a classmate 3 4 

Question (98 respondents) 

Never – I am 

not aware of 

these types 

Once or 

twice per 

Three or 

four times 

Five or 

six times 

More 

than six 

times 

Prefer 

not to 

of behaviors year per year per year per year 

answer 

How often have you been 

aware of the behaviors 

described in the previous 

question while attending 

16 

16% 

28 

29% 

19 

19% 

9 

9% 

12 

12% 

14 

14% 

the Academy? 

 42 Cadets were asked to select all that apply; totals may exceed 100 percent of respondents. 

43 One respondent stated white cadets, especially males, have fewer opportunities than 

minority cadets. The respondent stated the Academy has implemented programs to support 

minority students that creates inequality to the detriment of white cadets, such as mentorship 

and the ability to form affinity councils. 

www.oig.dhs.gov 36 OIG-20-36 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Experiences and Observations 

In this part of the questionnaire, we asked cadets about discriminatory 

behaviors they personally experienced or may have been aware of as a cadet 

while at the Academy. 

Question (98 respondents) Agree Disagree Prefer not 

to answer 

Since I arrived on campus, I believe I have been discriminated 

against on the basis of my race or ethnicity 

16 

16% 

72 

74% 

10 

10% 

Those who agreed were directed to the following questions: 

Question (16 respondents) 

Once or 

twice per 

year 

Three or 

four times 

per year 

Five or six 

times per 

year 

More than 

six times 

per year 

Prefer not 

to answer 

How often do you believe you 

have been discriminated 

against on the basis of your 

race or ethnicity? 

7 

44% 

5 

31% 

1 

6% 

1 

6% 

2 

13% 

Question (16 respondents) I reported 

them all 

I reported only 

some of them 

I did not report 

any of them 

Prefer not to 

answer 

Which best describes your 

reporting of the discriminatory 

incident(s)? 

0 

0% 

2 

13% 

13 

81% 

1 

6% 

Those who reported some of the incidents were directed to the following

series of questions: 

When I chose to report the discriminatory incident(s), I reported it to:44 

Reporting channel (2 respondents) # of 

respondents 

% of 

respondents 

Office of Superintendent 

Commandant of Cadets 

Company Officers or Company Chiefs 

Cadet Training 

Academy Office of Civil Rights 

Academy Staff Judge Advocate or other Coast Guard Attorney 

Coast Guard Civil Rights Directorate 

Office of Diversity and Inclusion 1 50 

Inclusive Excellence Council (IEC) 

Leadership and Diversity Advisory Council (LDAC) 

Diversity Peer Educators 

Diversity Council presidents and staff advisors 

Professors 

 44 Cadets were asked to select all that apply; totals may exceed 100 percent of respondents. 

www.oig.dhs.gov 37 OIG-20-36 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Reporting channel (2 respondents) # of 

respondents 

% of 

respondents 

Company leaders 1 50 

Fellow cadets 1 50 

Another person/entity not listed 

What was the outcome of your report? 

x Allegation was taken forward and addressed; individuals were disciplined 

x Individual collecting the report questioned why the individual was 

reporting; delayed feedback on any responsive actions 

The primary reason(s) that I did not report all the discriminatory incidents at 

that time were:45 

Primary influence (2 respondents) # of 

respondents 

% of 

respondents 

I did not realize I was being discriminated against at that time 1 50 

My uncertainty over how to report 

The likelihood my complaint would be taken seriously 2 100 

The amount of effort it would have taken to report 1 50 

The offender’s overall character 

The seriousness of the action 1 50 

The offender’s intent 

The fairness of the potential punishment in comparison to the action 1 50 

My ability to address the problem on my own 

I was concerned about confidentiality 

I believed reporting would negatively affect my studies at the Academy 

I believed reporting would negatively affect my career in the Coast Guard 1 50 

I did not believe leadership would support my decision 1 50 

The likelihood that someone else would report 

Whether the action took place off campus and/or off-duty 

The likelihood that a person in authority already knew about the action 

Other factor(s) not listed above [Drop Down] 

I do not know how to answer this question 

 45 Cadets were asked to select up to five choices; totals may exceed 100 percent of respondents. 

www.oig.dhs.gov 38 OIG-20-36 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Those who reported none of the incidents were directed to the following

question: 

The primary reason(s) I did not report being discriminated against at that time 

were:46 

Primary influence (13 respondents) # of 

respondents 

% of 

respondents 

I did not realize I was being discriminated against at that time 2 15 

My uncertainty over how to report 1 8 

The likelihood my complaint would be taken seriously 7 54 

The amount of effort it would have taken to report 3 23 

The offender’s overall character 2 15 

The seriousness of the action 3 23 

The offender’s intent 2 15 

The fairness of the potential punishment in comparison to the action 1 8 

My ability to address the problem on my own 1 8 

I was concerned about confidentiality 4 31 

I believed reporting would negatively affect my studies at the Academy 4 31 

I believed reporting would negatively affect my career in the Coast Guard 6 46 

I did not believe leadership would support my decision 6 46 

The likelihood that someone else would report 

Whether the action took place off campus and/or off-duty 

The likelihood that a person in authority already knew about the action 

Other factor(s) not listed above: 

x I did not think the media or command would consider the behavior 

discrimination because it was toward a white cadet 

x It was not a big deal; I had tough skin and moved on 

2 15 

In this part of the questionnaire, we asked cadets about discriminatory or 

harassing behaviors they personally experienced or may have been aware of as 

a cadet while at the Academy. 

Question (98 respondents) Agree Disagree Prefer not to 

answer 

Since I arrived on campus, I believe that I have been 

harassed on the basis of my race or ethnicity 

8 

8% 

84 

86% 

6 

6% 

Those who agreed were directed to the following questions: 

Question (8 respondents) 

Once or 

twice per 

year 

Three or 

four times 

per year 

Five or six 

times per 

year 

More than six 

times per 

year 

Prefer not 

to answer 

How often do you believe you 

have been harassed on the 

basis of your race or ethnicity? 

5 

63% 

2 

25% 0 0 1 

13% 

 46 Cadets were asked to select up to five choices; totals may exceed 100 percent of respondents. 

www.oig.dhs.gov 39 OIG-20-36 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Question I reported 

them all 

I reported only 

some of them 

I did not report 

any of them 

Prefer not to 

answer 

Which best describes your 

reporting of the harassment 

incident(s)? 

0 1 

13% 

5 

63% 

2 

25% 

Those who reported some of the incidents were directed to the following

series of questions: 

When I chose to report the harassment, I reported it to:47 

Reporting channel (1 respondent) # of 

respondents 

% of 

respondents 

Office of Superintendent 

Commandant of Cadets 

Company Officers or Company Chiefs 

Cadet Training 

Academy Office of Civil Rights 

Academy Staff Judge Advocate or other Coast Guard Attorney 

Coast Guard Civil Rights Directorate 

Office of Diversity and Inclusion 

Inclusive Excellence Council (IEC) 

Leadership and Diversity Advisory Council (LDAC) 

Diversity Peer Educators 

Diversity Council presidents and staff advisors 

Professors 

Company leaders 

Fellow cadets 1 100 

Another person/entity not listed 

What was the outcome of your report? 

x Allegation was elevated and addressed; individuals were disciplined 

The primary reason(s) at that time that I did not report all the harassment 

incidents were:48 

Primary influence # of 

respondents 

% of 

respondents 

I did not realize I was being harassed at that time 1 100 

My uncertainty over how to report 

The likelihood my complaint would be taken seriously 1 100 

The amount of effort it would have taken to report 1 100 

The offender’s overall character 

The seriousness of the action 

The offender’s intent 

 47 Cadets were asked to select all that apply; totals may exceed 100 percent of respondents. 

48 Cadets were asked to select up to five choices; totals may exceed 100 percent of respondents. 

www.oig.dhs.gov 40 OIG-20-36 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Primary influence # of 

respondents 

% of 

respondents 

The fairness of the potential punishment in comparison to the action 

My ability to address the problem on my own 

I was concerned about confidentiality 

I believed reporting would negatively affect my studies at the Academy 1 100 

I believed reporting would negatively affect my career in the Coast Guard 1 100 

I did not believe leadership would support my decision 

The likelihood that someone else would report 

Whether the action took place off campus and/or off-duty 

The likelihood that a person in authority already knew about the action 

Other factor(s) not listed above [Drop Down] 

I do not know how to answer this question 

Those who reported none of the incidents were directed to the following

question: 

The primary reason(s) I did not report being harassed at that time were:49 

Primary influence (5 respondents) # of 

respondents 

% of 

respondents 

I did not realize I was being harassed at that time 2 40 

My uncertainty over how to report 

The likelihood my complaint would be taken seriously 2 40 

The amount of effort it would have taken to report 1 20 

The offender’s overall character 1 20 

The seriousness of the action 2 40 

The offender’s intent 1 20 

The fairness of the potential punishment in comparison to the action 

My ability to address the problem on my own 

I was concerned about confidentiality 2 40 

I believed reporting would negatively affect my studies at the Academy 1 20 

I believed reporting would negatively affect my career in the Coast Guard 1 20 

I did not believe leadership would support my decision 2 40 

The likelihood that someone else would report 

Whether the action took place off campus and/or off-duty 

The likelihood that a person in authority already knew about the action 

Other factor(s) not listed above 

I do not know how to answer this question 

 49 Cadets were asked to select up to five choices; totals may exceed 100 percent of respondents. 

www.oig.dhs.gov 41 OIG-20-36 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Appendix E 

Office of Special Reviews and Evaluations Major Contributors 

to This Report 

Erika Lang, Chief Inspector 

Kimberley Lake de Pulla, Lead Inspector 

Brendan Bacon, Senior Inspector 

John Miller, Inspector 

Stephen Farrell, Independent Reference Reviewer 

www.oig.dhs.gov 42 OIG-20-36 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security



Appendix F 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Superintendent, United States Coast Guard Academy 

United States Coast Guard Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 43 OIG-20-36 
Additional Information and Copies 

To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General 

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

Follow us on Twitter at: @dhsoig. 

OIG Hotline 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click 

on the red "Hotline" tab. If you cannot access our website, call our hotline at 

(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305