Connecticut’s East Hartford Public Schools’ Enrollment, Registration Methods Found in Violation of Civil Rights

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Connecticut’s East Hartford Public Schools’ Enrollment, Registration Methods Found in Violation of Civil Rights

November 30, 2016

The U.S. Department of Education announced today that its Office for Civil Rights (OCR) has reached an agreement with Connecticut’s East Hartford Public Schools after finding that the district violated Title VI of the Civil Rights Act of 1964 by failing to provide adequate language services to limited English proficient (LEP) parents and guardians and by unlawfully imposing barriers to enrollment and applying additional registration and enrollment criteria to students based on national origin.

Title VI requires districts to address language barriers and prohibits discrimination based on national origin in education programs and activities receiving federal financial assistance.

“Through this agreement, East Hartford Public Schools has committed to correct its registration and enrollment process to ensure that its schools are open to all students and that it treats all its students fairly,” said Catherine E. Lhamon, assistant secretary for civil rights. “We will continue to work with the district to implement this agreement and support the district’s efforts.”

During its compliance review launched in 2015, OCR examined the district’s enrollment and registration policies, procedures, and practices to determine whether LEP parents and guardians received similar access to information as compared to non-LEP parents and guardians, and whether the district discriminated against national origin minority students.

OCR determined that the district violated Title VI by not providing adequate language services to LEP parents and guardians. OCR’s findings include the following:

  • The district told LEP parents and guardians to provide their own interpreters to register students.
  • The district did not properly assess whether LEP parents and guardians required language services.
  • The district failed to provide any training to its staff serving as interpreters, including responsibilities regarding confidentiality and use of specialized terms.
  • The district translated fewer than half of its registration and enrollment documents into Spanish, the highest incidence language for LEP parents and guardians.
  • The district failed to provide any written instructions regarding obtaining oral translation of registration and enrollment documents for LEP parents and guardians who speak languages other than Spanish.

OCR also found that the district violated Title VI by treating students differently in the enrollment and registration process based on their national origin by impermissibly requiring or requesting information or documentation, such as passports and social security cards, from students based on national origin, particularly based on language, or a belief that they were born outside of the U.S., while not making similar requests of other students.

Taking a comprehensive approach to address these violations, along with related matters, East Hartford Public Schools agreed to take actions under the resolution agreement to remedy Title VI violations, including, but not limited to, the following:

  • Revising its registration and enrollment policies, procedures, and practices to comply with Title VI.
  • Providing appropriate, qualified, and competent interpreters and translations during the enrollment and registration process.
  • Issuing a “Notice of Language Assistance” in the district’s 10 most commonly spoken languages about the district’s free translation and interpreter services. 
  • Requesting only permissible material and information from all students registering and enrolling in the district.

A copy of the resolution agreement is available here, and the resolution letter is available here.

In 2011 and 2014, the Departments of Justice and Education issued guidance to help schools understand their responsibilities under the Supreme Court's decision in Plyler v. Doe and federal civil rights laws to provide all children with equal access to an education regardless of their or their parents' immigration status.

OCR’s mission is to ensure equal access to education and promote educational excellence throughout the nation through the vigorous enforcement of civil rights. The office is responsible for enforcing federal civil rights laws that prohibit discrimination by educational institutions on the basis of race, color, national origin, disability, sex, and age, as well as the Boy Scouts of America Equal Access Act of 2001. Additional information about OCR is available here.