VIA FACSIMILE

May 11, 2000

Mr. Jim Castress, Area Case Director
c/o Ms. Loni Hancock, Sec.'s Reg. Rep.
U.S. Dept. of Education, Region IX
50 United Nations Plaza, Room 205
San Francisco, CA 94102-4987

Dear Mr. Castress:

A recent article "Quality of Campus Justice Varies Widely" published in the May 10th Los Angeles Times contains information that indicates several colleges and universities in California may be in violation of 20 USC 1092 (f) otherwise known as the "Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act." Copies of the article and the security disclosures from one of the mentioned schools are included in this transmission.

Pursuant to "Dear Colleague" letter GEN-96-11 your office has responsibility for reviewing complaints brought under this Act and we ask that you look into these matters.

Although there is no obligation under the Act to publish individual statistics for student disciplinary actions, as the article notes, all campus security authorities are required to report statistics, not just campus police. Two of the schools, UCLA and Cal. State Fullerton, surveyed for the article indicated that they kept no statistics from their disciplinary proceedings.

The director of UC Riverside's student conduct office, J. Lance Gilmer, is quoted as saying that there "is no doubt that colleges are underreporting crimes." He specifically indicates that he is aware of 6 rapes that were omitted from last year's statistics. A quick review of UCR's disclosures (which are "provided in compliance" with the Act) seems to indicate that they are not reporting using the proper crime categories and may be excluding offenses known to campus officials other than police.

Please take the time to review the issues raised by this article and work with the schools involved to ensure that they are in compliance. Should you have any questions please don't hesitate to call on me directly at (865) 693-4316. I would also appreciate being apprised of any actions that you take regarding this complaint and receiving copies of any related documents under the Freedom of Information Act. Thank you for your time and attention to these matters.

Sincerely,

S. Daniel Carter