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**Equal Housing Opportunities inNew York: An Evaluation of Section 8 Housing Programs in Buffalo, Rochester, and Syracuse**

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**Chapter5**

**Section8 Housing in the Buffalo Area**

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Thischapter provides a portrait of the Section 8 housing situation in the Buffaloarea, covering such topics as demographics of the area, barriers to fairhousing, and tenant experiences. Divided into six sections, it first describesthe demographic characteristics of the city and surrounding area. Next itdescribes the administrative structure and process of the two housing agencies,the Rental Assistance Corporation and Belmont Shelter Corporation, which run thearea�s Section 8 programs. Then it focuses on the Section 8 housing issuesgermane to Buffalo, including residency requirements and waiting lists.

Inaddition, the chapter contains presentations from three tenants who describetheir personal experiences with the Section 8 program, and statements from localcommunity advocacy organizations, including Housing Opportunities Made Equal,Neighborhood Legal Services, and the Western New York Law Center. Finally asection is included on the refusal of Buffalo�s Section 8 administrators, theRental Assistance Corporation and Belmont Shelter Corporation, to attend themeeting.

**DemographicCharacteristics **

Accordingto the 1990 census, Buffalo has a population of 328,000, with minoritiesconstituting approximately 35 percent of the population.1Buffalo is at the center of a hypersegregated metropolitan area in which none ofthe surrounding suburbs has a minority population greater than 5 percent.2Over 90 percent of all minority renters in the metropolitan area live within thecity of Buffalo.3 The housing stock in Buffalo is primarily of pre-1940 construction and has suffered a high degree ofdeterioration. The suburban housing stock is almost entirely of post-1940construction and is generally in good condition.4 Compared with its suburbs, Buffalo ispoorer5 and has higher unemployment.6

**Section8 Housing Agencies  **

Twohousing agencies provide Section 8 programs in Buffalo: the Rental AssistanceCorporation (RAC) for the central city, and the Belmont Shelter Corporation(Belmont), a private, nonprofit organization for the suburbs. Belmontadministers the Section 8 program on behalf of a consortium of 41 suburban townsand villages. Each program maintains separate offices, separate wait lists, andseparate application procedures.

Approximately64,000 Section 8 eligible renter households live in the city of Buffalo, andapproximately 54,000 eligible renter households live in Erie County outside thecity.7Since 1976, HUD has allocated approximately 6,500 Section 8 subsidies to theentire metropolitan area, with about half going to the Buffalo program. As aresult, the wait list for a subsidy from the city program has been several yearslonger than the list for the suburban program.8In 1995 the RAC Section 8 program administered 2,796 certificates and voucherswithin the city of Buffalo, while Belmont administered more than 3,300subsidies, making its Section 8 program the largest among Syracuse, Rochester,and Buffalo.9 

**Barriers to Section 8 Mobility  **

Whenthe Section 8 program came to Buffalo and its suburbs in the mid-1970s, theAfrican American population in the suburbs was less than 1 percent, while in thecity of Buffalo it was over 26 percent.10 Despite this pronounced disparity, in1976 HUD approved the use of local residency preferences by the suburban HA. Theresult was to put over half of the Section 8 subsidies in the Buffalo area outof the reach of almost all minority applicants.

Thisresidency preference has had negative effects on the minority population of thecity of Buffalo. City residents who applied to the suburban program forsubsidies were passed over whenever a suburban resident applied, regardless ofwhether that suburban resident applied months, or even years, after them. WhileAfrican American city residents waited over 10 years for subsidies they wouldnever receive, white suburban applicants received subsidies within 18 to 24months.11Fewer than 3 percent of the subsidies in the suburban program were provided tominorities.12

Alawsuit, *Comer v. Cisneros*, was brought against the Belmont program in1992 to challenge its use of residency requirements as being discriminatory andpromoting segregation in their effects.13 (The results of the lawsuit arediscussed later in this chapter.) Today the area still maintains separate cityand suburban programs.

**TenantExperiences  **

TheAdvisory Committee heard from three individuals who have had direct experiencewith the Section 8 program in Buffalo, either as recipients or as applicants.These three panelists described the difficulty they encountered in obtaining aSection 8 certificate, including unending waits, lost applications, and theinability to access a suburban landlord list. They also cited familial statusdiscrimination and poor public transportation as barriers.

***JituanJames****Endless WaitingLists and Lack of Transportation*

JituanJames applied for Section 8 benefits in late 1988 in Buffalo through RAC. Shesaid whenever she called to check on the status of her application, she was toldthat there was a long waiting list, and there was no need for her to call back.When she called in 1992, the RAC claimed that it had never received herapplication, so she was forced to reapply. In 1997 she was still waiting.

 Ms.James is a single mother with a 16-year-old son and lives in an inner-cityneighborhood with prevalent drug activity and prostitution. Her son, she said,has been asking if they could move because he said the majority of kids are intoselling drugs and he does not want to get into that kind of crowd. She said thatthe other kids call him a �Mom�s boy� because she makes him come home whenit gets dark.14 She continued:

> 
Where    I lived, all night long there would be hollering. . . . There�s a guy who    lived next door, he sold drugs. So, they would be hollering all night,    calling him, trying to get him to sell packages, and it�s like they might    as well sit in my house with me because that�s how loud it would be . . .    I was like, enough is enough, whatever I have to do, I�ll just do it. It    was time for me to go.15

Ms.James had been trying to find a different place to live since 1994, but all theapartments she looked at were prohibitively expensive. She was willing to dowhatever it took to move her son out of her neighborhood, but it was not until1995, after not being able to find an affordable apartment by calling theclassified ads, that she decided to take a new approach.

Shesucceeded, she said by �combing the streets� outside of the city, going tothe suburbs whenever she had extra money for gas. She found an apartment bydriving �up and down� the suburban streets and stopping and inquiring in asmany as 30 apartment complexes. At one complex, she was able to negotiate theprice down to an affordable level and signed a lease. Transportation is now theproblem facing Ms. James, although she does have a car:

> 
Sometimes    I don�t have gas. Once when my car was down, I took my daughter to the    doctor, we left for the doctor at 3:00 p.m., left the doctor�s office at    5:00 and didn�t get home till 9:00 p.m. We were waiting for a bus . . . it    don�t run regularly, and the way the bus route ran . . . for me to be able    to get home, I had to walk a ways to get there.16

Ms.James said she still enjoys living where she does, but that the expenses withoutSection 8 are getting prohibitive. �I called to check to see where I was onthe [waiting] list and they said they were still on 1991 . . . They�ve been on1991 for awhile.�17 She concluded by saying that she calledthe Section 8 office again in the summer of 1996 and was told that they were onApril 1991. She called again in December 1996 and was told that they were stillon April 1991.

***EllenMoore****Section 8and Familial Status Discrimination*

GraceAndriette, staff attorney for Buffalo Neighborhood Legal Services, described theexperience of a client, Ellen Moore, who is African American. Ms. Moore, aSection 8 recipient through the Belmont program, obtained her certificate 6years ago and used it to move out of the city of Buffalo and into the communityof Lancaster, northeast of Buffalo. Within the first 2 weeks of her move, she�had racial slurs painted on her door and a fire set in her doorway.�18She decided to remain and stayed without further incident for several yearsuntil she decided to try �to move closer to Buffalo because she was concernedwith transportation issues.�19

Accordingto Ms. Andriette, Buffalo has a fairly comprehensive public transportationsystem within the city, but in the suburbs the transportation system becomesfairly linear and difficult for people who do not have cars. For that reason,Ms. Moore decided to move to Cheektowaga, an area closer to the city and thepublic transportation hub.

Usingher Section 8 certificate, Ms. Moore attempted to rent an apartment in abuilding on the bus line. For many years she was rejected. She said she finallymet with a landlord but he was concerned how she as a single mother would carefor her daughter, even though she assured him that she had child care, etc. Thelandlord was also concerned that she was not financially able to rent theapartment, even though her Section 8 benefits could clearly cover the rent.

Ms.Moore filed a lawsuit against the landlord, and its ensuing investigationsrevealed the following: (1) the landlord had in fact rented to white Section 8recipients, and (2) he had rented to individuals on public assistance who werefinancially less able to afford the apartment for which Ms. Moore was applying.The lawsuit was still pending as of the December 1997  factfinding meeting.20

***SharonSmith****Refusal ofSuburban HA to Share Landlord List*

SharonSmith is a Section 8 recipient with a four-bedroom apartment voucher. She livesin the city and is the guardian of her two grandchildren, ages 9 and 14, andcares for two mentally disabled women. She wanted to move to a safer and betterplace for her grandchildren outside of the city. She recently found out that theschool that her grandchildren attended had been cited for chemicalcontamination:

> 
They    said that they�ve known about the contamination since 1993, but they    didn�t want to get everybody into an uproar. The bottom line is I [wanted    ] to move. I�m not going to stay in Pine Harbor because I feel like I have    a four-bedroom voucher, and I can live anywhere I want to live, any place. I    could take that voucher anywhere, all over the United States, if I want to.    So, I�m going to move.21 

Sheasked the RAC to transfer her case to Belmont Shelter. She was told by her caseworker at RAC to first locate a house and she would then transfer her case. Ms.Smith pointed out that she did not know exactly where to begin looking and RACwas not able to help her:

> 
I    need the [suburban rental] list because the list would help me. How am I    supposed to know exactly where to look or where to call for these houses? In    other words, I could sit down, call four, five, six landlords and make    appointments and go see the apartments. But a lot of times, when you call in    the paper about an apartment, a lot of people don�t accept Section 8. Why    should I scout all over the suburbs and all different places � that�s    not going to do me any good.22

Shedecided to go to Belmont Shelter and ask for its rental listings. When it wasrevealed that she was not a Belmont client, she was told by the Belmontpersonnel to �go back to [her] own program,�23and that they couldn�t give her the listing. When Ms. Smith asked abouttransferring into their program, she was again told to �go back to your ownprogram.�24

Shewent back to her case worker and was told that they could not make Belmont giveher the list and instead offered her the list for the city of Buffalo. �I saidI don�t want that. I have one. I said that�s not what I want because I donot want to stay in the city of Buffalo,�25she told the Committee.

Shesaid she next contacted HUD in Washington, and after numerous calls andrun-arounds, talked to the area coordinator for the Buffalo office and was toldit would be looked into. Several months later, she received a call from HUDsaying that they cannot make Belmont give her the list. She was given the nameof James Morrissey, executive director of the Western New York Law Project, apublic interest legal service center, who has taken her case, which was pendingbefore a judge as of the December 1997 factfinding meeting.26

Ms.Smith recently reported to Mr. Morrissey that she is now residing on the northside of Buffalo, in a neighborhood of much lower poverty concentration. She isone of very few minorities in the neighborhood but is very happy with herhousing and her move. She expressed concern that the policy of refusing thesuburban landlord list to RAC clients continues. She stated that a friend ofhers recently went through a similar problem in obtaining a list of noncitylandlords from Belmont. At first her friend was given a list with only cityproperties. She asked for more referrals and was told there were no othersavailable. When she insisted, however, the Belmont staff person located a secondlist that included properties outside the city.27Mr. Morrissey said that he intends to follow-up on this issue with HUD.

**HousingAdvocates**

TheAdvisory Committee heard presentations from representatives of three localagencies that provide support and legal services to low-income individuals whofeel that they are the victims of housing discrimination: Housing OpportunitiesMade Equal; the Western New York Law Center; and Neighborhood Legal Services ofBuffalo, Inc. Among the concerns brought to the Committee�s attention were thefollowing:

-  Shortcomings    of mass transit in the Buffalo area.Continued    subtle discrimination against Section 8 recipients by landlords.Lack    of knowledge about housing opportunities in suburban communities.
Thepanelists provided the Advisory Committee with examples of these concerns andothers during their presentations.

***HousingOpportunities Made Equal***

ScottGehl is the executive director of Housing Opportunities Made Equal (HOME), anot-for- profit organization that provides comprehensive services to victims ofhousing discrimination. HOME is under contract with the city of Buffalo, thetown of Hamburg, and 34 municipalities in the Erie County Block Grant Consortiumto provide fair housing services.

Accordingto Mr. Gehl, housing discrimination occurs with some frequency in western NewYork. In the past 3 years alone, HOME has recorded more than 900 incidents ofdiscrimination. According to data collected by HOME, 37 percent of complaintsinvolved race. Familial status accounted for 34 percent of complaints received,while sex or marital status and disability accounted for 20 percent and 13percent, respectively.28 

HOME has also recorded discrimination due to age, national origin, religion,sexual orientation, and lawful source of income.29In 1996 HOME filed 30 discrimination cases with administrative agencies andcourts as a result of their investigation, all of which are still pending. WhileHOME receives more complaints of housing discrimination than any other agency inwestern New York, Mr. Gehl believes that complaints received represent only asmall portion of discrimination that actually occurs:

Today    discrimination tends to be so subtle that most often its victims are unsure    when it has occurred. Others may recognize it but be uncertain about their    rights or whom to call. Still others in the midst of the frenzied search for    housing, which is when most discrimination occurs, simply can�t afford to    take the time to report it.30

Hecited four other barriers besides discrimination that prevent minorities in theSection 8 program from moving out of predominantly minority and impoverishedneighborhoods:
-  Shortcomings    of mass transit in the Buffalo area, �especially after crossing the city    line.�Lack    of knowledge about both housing opportunities in suburban communities and the    services and facilities existing there.Absence    of a support network of family and friends, which makes a move to a suburban    community seem all the more forbidding.The    feeling that minorities are not welcomed.31
Stressingthe seriousness of the public transportation issue, Mr. Gehl told the story ofCynthia Wiggens, a young black mother from the inner city who was killed whiletrying to cross seven lanes of traffic on her way to work in a fast foodrestaurant at a suburban shopping mall. After her death, it was revealed thatthe developers of the mall had refused permission from the Buffalo PublicTransit Authority to route their inner-city, outbound Walden Avenue bus ontomall property. Allegedly, the mall owners feared that such access would increasethe number of minority shoppers who came to the upscale mall.32A civil lawsuit has been filed against the mall developers, and since theincident public transportation has been routed into the mall.

Severalyears ago, one public official told Mr. Gehl �that the town fathers of hiscommunity believed HOME to be a �radically pro-integrationist organization,�which wanted to introduce undesirable elements into his community.�33Mr. Gehl concluded, �Until [local] government attitudes toward fair housingchange, minority families will not feel welcome in suburban communities, and theincreased opportunities in choice, which are the benefits of the Section 8program, will remain an unkept promise.�34

**NeighborhoodLegal Services of Buffalo**

GraceAndriette is a staff attorney with Neighborhood Legal Services, Inc., anonprofit organization that investigates allegations of discrimination andprovides community education on the issues of fair housing and housingdiscrimination to consumers and housing providers.

Ms.Andriette believes that �discrimination in the nineties can be a very subtleaffair, and often victims of discrimination are not aware that they have beendiscriminated against,� making it necessary to provide tenant education onfair housing laws and education to landlords or providers of housing.35Persistent discrimination, in her opinion, underscores the proactive value ofthe Section 8 program. She said:

Given    the history of racial discrimination and segregation in Buffalo, I don�t    believe that it�s surprising that many low-income individuals decide not    to venture out of known neighborhoods when they are given Section 8    benefits. As far as the affirmative duty of HAs to provide fair housing, I    think it�s not simply enough for Section 8 providers to advise recipients    of Section 8 benefits that they can now use their vouchers and certificates    to travel outside of the Buffalo metropolitan area. There needs to be active    participation by the Section 8 providers in encouraging housing mobility.36

Accordingto Ms. Andriette, Section 8 beneficiaries need information about transportation,the lack of which is often the obstacle that ultimately discourages people frommoving out of the inner city. �A person who doesn�t have a car, who�straveling to unfamiliar communities that bus lines don�t service, often has adifficult time in securing housing. It is very expensive, for example, to take ataxi to travel from one available apartment to the next.�37

Sherecommended a Section 8 housing mobility center that would provide informationabout public transportation, shopping centers, churches, and schools as aresource that would be important in assisting people in their attempts to findhousing.38

***WesternNew York Law Center, the*Comer*Settlement, and the Community HousingCenter***

TheWestern New York Law Center, according to its executive director James M.Morrissey, was created to handle class action lawsuits throughout western NewYork. The center chose to focus on the use of residency preferences in theBuffalo area. Concerning the impact of the residency preference policy, hestated:

 If    you looked at the clientele that were being served by the two programs [RAC    in the city and Belmont in the suburbs], the hole of the doughnut was black    and the rest of the doughnut was white. The effect was to prevent entirely,    almost without exception, African Americans from using their subsidies    outside of the city of Buffalo. Under the local preference policy, if Sharon    Smith �in the event that she wasn�t discouraged from applying in the    first place, had gone to Belmont in 1990 and asked for a subsidy, her name    would have been put on the list. However, Ms. Smith is a resident of the    city of Buffalo; therefore, if a resident of the town of Amherst comes in 6    years later asking for an apartment [subsidy] and it becomes available, who    gets it? Not Sharon Smith. The resident of Amherst would get it, and    that�s one of the reasons that the *Comer* lawsuit was brought.39

Thecenter brought the case of *Comer v. Cisneros*, which sought to address theuse of local preference residency requirements by Belmont Shelter. After severalyears, the suit was settled in the center�s favor in 1997. The key provisionsof the settlement of the *Comer* lawsuit are as follows:
-  Extension    of the local residency preference to require that both programs have a    single countywide preference. A person residing anywhere in Erie County can    now obtain a subsidy from either the city or the suburban program, and would    be free to use that subsidy in the city of Buffalo or anywhere else in the    county.Cross-listing    of the two Section 8 programs.800    new Section 8 subsidies, the intent of which is to start remedying the    grievous damage that was done by the local preference policy.A    remedial selection preference system that would return a percentage of the    subsides Belmont receives when families leave their program to minority    residents of the city of Buffalo, in hopes of at least partially remedying    the damage done by local preference policy.The    creation of a Section 8 Community Mobility Housing Center.40
Accordingto Mr. Morrissey, removing the administrative barriers to moving out of the cityand into the suburbs was only half the job. �Because the fact is, unless weremove the practical barriers as well, the lawsuit was all for naught, andthat�s the reason that the lawsuit calls for the creation of a communitymobility housing center.�41 He continued:

It    is, in our view, perhaps the most critical element of [the settlement]    because we realize that if you come from the center of the city of Buffalo,    and want to move to Cheektowaga, you don�t know about available    neighborhoods, bus routes, schools, and without that information, the fact    that you theoretically have that right to do it frankly doesn�t mean much.42

 Themobility housing center will have four major components designed to increasemobility and choice:
-  *Motivational    counseling*.    It will provide information to Section 8 recipients on the potential    benefits of living in neighborhoods. Examples of potential benefits include    better housing stock, better job opportunities, and better schools than can    be found in the city of Buffalo.  *Logistical    assistance*.    This will provide needed information such as: Where are the available units?    How do you get to them? What bus routes are they on? Where are the local    schools? Churches?*Readiness    counseling*.    This will engage Section 8 recipients in skills development on such topics    as: (a) What are the interviewing skills needed when trying to find an    apartment? (b) What is it the landlord is looking for? (c) What does a    landlord expect from a good tenant? and (d) How do you fill out rental    applications?*Followup    assistance*.    It is crucial to know that the program is having a positive impact. After    families move, the housing center will assist them with school applications,    and in locating churches, child care, and employment.43
Thehousing center is critical to the success of Section 8 mobility and will reducethe sense of isolation that often accompanies a move not only to a strangeneighborhood but also to a completely different environment. Mr. Morrisseystressed that the housing center needs broad-based community support. �Itneeds to have complete and utter credibility within the African American andHispanic communities, and it can�t be business as usual.�44

Pursuantto the *Comer* settlement, in early 1998 the city of Buffalo issued arequest for proposals to select an administrator for the Community HousingCenter. The housing center was expected to begin operation in the fall of 1998.

***BuffaloPublic Housing Administrators� Failure to Appear Before the Committee***

Wheninvited to participate in the Buffalo factfinding meeting, the directors ofBuffalo�s Section 8 program and the suburban Section 8 program both declinedto participate. Subsequent written requests by the Committee for informationyielded only demographic and background data from one agency, the RAC, but itdid not respond to substantive questions (see appendix 4). Elizabeth Huckabone,director of the Belmont Shelter Corporation, responded through a letter (seeappendix 3) prepared by the attorney representing Belmont Shelter in the *Comer*lawsuit. The letter states that the *Comer* lawsuit lacks merit andthat: 

My    client and I take great offense in representations either in court, the    hearings recently conducted under your auspices in Buffalo, or otherwise    that our opposition to Mrs. Smith�s request for the available housing    listings of Belmont impeded fair housing or anyone�s ability to obtain    access to housing wherever they choose in the Western New York area.45

Neitherdirector would discuss in person with the Advisory Committee the use ofresidency requirements, waiting lists, or quality and location of housingavailable. This lack of cooperation by Belmont and RAC has impeded thefactfinding mission of the Committee in Buffalo.  

**Endnotes**

1Bureau of the Census, U.S. Department of Commerce, 1990 CH�1�1B, 1990Census of Housing, General Housing Characteristics, Metropolitan Areas, p. 69,table 4 (1993).

2  Ibid.,p. 70. According to the Census data, no suburban town in Erie County has a totalAfrican American or Hispanic population in excess of 2 percent. One nonsuburbanErie County community bordering Buffalo, the city of Lackawanna, has a minoritypopulation of 12.63 percent. Ibid.

3  Bureauof the Census, U.S. Department of Commerce, 1990 CH�1�34, 1990 Census ofHousing Characteristics, New York, p. 294, table 49; p. 434, table 58 (1992).

4 Approximately68.1 percent of all occupied units in the city of Buffalo were built prior to1940, whereas approximately 19.6 percent of all units in Erie County excludingBuffalo were built before 1940. Bureau of the Census, U.S. Department ofCommerce, 1990 CH�2�34, 1990 Census of Housing, Detailed HousingCharacteristics, New York, p. 225, table 66; p. 401, table 79 (1993).

5  Themedian income in Buffalo is about 55 percent of that in the suburban area.Bureau of the Census, U.S. Department of Commerce, 1990 CP�2�1B, 1990 Censusof Population, Social and Economic Characteristics, Metropolitan Areas, p. 62,table 3 (1993).

6  Theunemployment rate in 1989 was 11.6 percent for the city of Buffalo and 7 percentfor the entire county of Erie (including Buffalo). Bureau of the Census, U.S.Department of Commerce, 1990 CP�2�34, 1990 Census of Population, Social andEconomic Characteristics, New York, pp. 15, 17, table 2 (1993).

7  Ibid.,p. 185, table 19.

8  In1991 the waiting period for a subsidy from the city HA (the Rental AssistanceCorporation) was about 9 years, while the waiting period for the suburbanprogram (Belmont Shelter Corporation) was 12 to 30 months. This informationcomes from documents submitted in Comer v. Kemp, 824 F. Supp. 1113 (W.D.N.Y.).

9  Datafrom HUD Community 2020 Database, using FY 1996 data.

10 Bureauof the Census, U.S. Department of Commerce, PC80�1�B34, 1980 Census ofPopulation, General Population Characteristics, New York, pp. 34�30, 34�39,table 15 (1982).  

11  Thisinformation comes from documents submitted in Comer v. Kemp, 824 F. Supp. 1113 (W.D.N.Y.1993) (No. 89�1556C), vacated and *remanded sub.nom*Comer v. Cisneros,37 F.3d 775 (2d Cir. 1994).

12  Ibid.

13  Comerv. Cisneros, 37 F.3d 775 (2d Cir. 1994).

14  JituanJames, statement  before the New York Advisory Committee to the U.S.Commission on Civil Rights, factfinding meeting, Buffalo, NY, Dec. 12, 1996,transcript,  p. 71 (hereafter cited as Buffalo Transcript).

15  Ibid.,p. 72.

16  Ibid.,p. 68.

17  Ibid.,p. 69.

18  Andriettestatement, Buffalo Transcript, p. 60.

19  Ibid.

20  Ibid.,p. 62.

21  Smithstatement, Buffalo Transcript, p. 118.

22  Ibid.

23  Ibid.,p. 115.

24  Ibid.

25  Ibid.

26  Ibid.,p. 116

27  Telephoneconversation with James Morrissey, Apr. 2, 1998.

28  Gehlstatement, Buffalo Transcript, p. 22.

29  Ibid.

30  Ibid.

31  Ibid.,p. 24.

32  Ibid.,p. 25.

33  Ibid.,p. 28.

34  Ibid.,p. 29.

35  Andriettestatement,  Buffalo Transcript, p. 57.

36  Ibid.,p. 62.

37  Ibid.,p. 64.

38  Ibid.

39  Morrisseystatement, Buffalo Transcript, p. 105.

40  Ibid.

41  Ibid.,p. 107.

42  Ibid.

43  Ibid.,p. 108.

44  Ibid.,p. 110.

45  Letterfrom Charles C. Swanekamp to Fernando A. Serpa, U.S. Commission on Civil Rights,Dec. 20, 1996, Eastern Regional Office files.