[nfbmi-talk] Fw: could i have this in accessable format?
joe harcz Comcast
joeharcz at comcast.net
Thu Nov 17 19:35:39 UTC 2011
----- Original Message -----
From: joe harcz Comcast
To: Robin Jones
Cc: Peter Berg
Sent: Thursday, November 17, 2011 2:35 PM
Subject: Fw: could i have this in accessable format?
Do I have to hold the hand of everyone including enforcement agencies? Whatever happened to html and other accessable documents?
----- Original Message -----
From: joe harcz Comcast
To: Ussery, Karla
Sent: Thursday, November 17, 2011 2:31 PM
Subject: Re: could i have this in accessable format?
Again Ms. Ussary,
This goes to issues of 504, 508 and the general requirements of the OCR to make its documents accessable in the first instance to all people with disabilities including those who are blind.
You can clearly see this OCR document isn't very legable let alone accessable.Frankly if a first grade student handed in a document like this to his/her teacher he/she would be given an "F".
Bottom line is you see what I see.
Can you make out things here?
Sincerely,
Paul Joseph Harcz, Jr.
----- Original Message -----
From: Ussery, Karla
To: joe harcz Comcast
Sent: Wednesday, November 16, 2011 4:34 PM
Subject: RE: could i have this in accessable format?
Dear Mr. Harcz:
If you are seeking a copy of a letter from our agency, then that would constitute a request for information under the Freedom of Information Act, or FOIA. Those requests are not processed out of individual OCR offices, at least initially. They may end up being processed by the individual office that handled the complaint at issue. Instead, you make your request to a centralized location, using the contacts below.
You have in the past expressed a desire for contacts to be by email. If you wish to file a request by email, you may direct your request to the following email address: EDFOIAManager at ed.gov
Requests may also be sent via fax to (202) 401-0920 or via mail to the following address:
U.S. Department of Education
Office of Management
Regulatory Information Management Services
400 Maryland Avenue, SW, LBJ 2W220
Washington, DC 20202-4536
ATTN: FOIA Public Liaison
Please include with your request notice that you have a disability and that you need the response to your request in a format accessible to you, and please explain what that would be for you individually so that the Department can issue you a response in an appropriate format.
If you would like additional information on the Freedom of Information Act process, I believe it is available at:
http://www2.ed.gov/policy/gen/leg/foia/foiatoc.html
I hope this information is helpful to you,
Karla Ussery
Team Leader
OCR Cleveland
From: joe harcz Comcast [mailto:joeharcz at comcast.net]
Sent: Tuesday, November 15, 2011 1:26 PM
To: Ussery, Karla
Subject: could i have this in accessable format?
I
UNiTrED STATES D!CPA TMENT OF EDU(:ATION
Diane Y. Bower, Esq.
OFfiCE FOR CIVIL RIGHTS !
Clf~VELANI) onree I
600 SUPERIOR AVENUE EAST, SUITE 750
CLEVElAND, OHIO 44114-2611
The Law Offices of Marcoux Allen
145 South Jackson Street
P.O. Box 787
Jackson, Michigan 49204
Dear Ms. Bower:
Nonresponsive
The domplaint also
L..,---:--::----,-------:-=--::-:------:----:-:---:th:-e-U:;:~-ii:-'lversit . ~iscriminated
"------'
\\.'hich was necessary because ofbi:; disability.
OCR is responsible for enforcing Section 504 of the Rehahilita~ion Act or 1973,
29 U.S.C. § 794, and its implementing regulation, 34 C.P.R. Pmt 104. S+ction 504
prohibits discrimination on the basis of disability by recipients of Federa' financial
assistance, including recipients of such assistance from the Department. ~A..s a reoipient of
Federal financial assistance from the Department, ~cUni,versity is subjeetlo Section
504. Therefore, OCR had jurisdiction to inves(ik2~elthis.'cornplaint. ; . . ~.' . ;
., .
Th: Del'~nmcnt of EduC!llion'$ nl,$,';O. ,S 10 p"':t:olc sluticn! ach't'·crr.cnf and preparat;o·; for global competitiveness by
foslering eden.llenal exctllence alld ensuring cqtrel acct!s
·,
I
t
Page 2 -Diane Y. Bower, Esq. .. \
Based on the complaint allegations, OCR investig~:ed the issu, .,fwhetL a qualified
petson w·th a disability was, on the basis of disability. excluded from pahicipation in.
denied the benefits of, or otherwise subjected to discrlmination by the Uruversity, or was
on th; ?asis. of ~sa?iliU: denied admis~ion or ~bj'eeted t~ discriJtlin~ti04.in admission by
the Umverslty, m vlOlatLOn of the Scellon 504ltupl~mcntmg regulatlon qt 34 C.F.R.
§§ I04.4(a) and 104.42(a). DW'i~g th~ in\'es~jgati~p)OC.R,alsoleviewed the University's
compliance with the provisions ofthe Section'504 regulation, at -34 C. F..R. §§ l04.7(a)
and I04.7(b), which require the University to designate an employee 10 900rdinate its
compliance ,'11th Secti.on 504 and to adopt grievance,procedures regardi! Section 504
complaints.
During the investigation of this complaint, OCR inter,iewed the CompI: 'nant and
University personnel. OCR also reviewed documenrs submitted by the Complainant and
the University, including t1 e Complainant's academic. admissiolJs, and j:dmiSSi'011S
files, notes eonceming the Complainant and hislNonmponsive lwithdr wal from the
University. e~mail correspondence concerning the Complainant and his pplication for
readmission to the University, and the University's grievance procedure. After a careful
ar.alysis of the information obtained, OCR determined that the Universi 'discriminated
against the COr:1plainant as alleged, The basis,for that determinution is s·t forth below.
Alleged Disability Oiscrimination
Summary orOCR's InvestigatiOl,!
The Com I.ainant enrolled at the Universi .
L-______---.land maint<;ine· s ,ertq·::b(~~m.~,thrpugh Nonresponsive .:ne
Complainant asserted that, at tJ1C tiipe he.en"~!1~~li~~,~P.~~s mO':her not~edhis
admissions representative that he,had a dis,nbl!ity,:;I!bd,~nqHfred abo.ut a 5q~ plan for him
that would provide him "yith extra time on tests, exl7.qsions on assLgnments and
~temati": testi.ng spaces: 1h: Complai?ant.assert~d t~~t .thc-a.fln:is:<ions\representative
dld not TeTer the Complainant to the Uruvers!t ,'s dIsabIlities senlce
Complainant said he 'was diagnosed wi.1hLN"...onr~e,...sp_o-,ns:-iv_e~--=----:~:-::r--:--:-:---'
1:he C01~nplainant explain~d to OCR t!l.at, during the fIrst few mO:lths foUpWi?g ~is
dIagnosIs, he struggled '7I'1th INonrespoume Ibeoau'i~ he waS adjustIng to
new medications. During that time period, the Complainant
Nonresponsive
He acknow1crl ed that he di not n tify anyone at the University. Mhis diagnosis
when he Nonresponsive nor did he formally identiry! himself as a
student with disabilities or request academic adjustfl1ents ~otig\rthe dis~billties service
office at any tir. e during his enrollment at the Unhterslty. .
The Complainant told OCR thaI onlNonresponsive Ihis residel~tial direclbr in~cted.
him to attend a meeting with the vice president of student development, the aSslstant vice
president of student development, and the residential director, to discuss iis success as a
student. The Complainant asserted, and the University did not dispute, tHat he was told
he was not in trouble and the meeting was not os~en~ibly.a discipline meeting. The
, ' 1:\l7,','t,,; ,:.
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Page 3 -Diane Y. Bower, Esq.
Complainant told OCR that the resident director of his donn assured hi twic-e thaI the
purpose of the meeting was to discuss the Complainant's success at the University.
However, \-vhen he arrived at (he meeting the vice president told the.COlhplainant that the
University had received co 'plaints about him from other students and p~esented him
with a behavior contract that would require hirQ ~o meet with's~'ci:fic in~ividua1s on
campus if he were having a crisis. He said he became vcry upset at the fuectmg, Within
the first fen minutes of the meeting, the Camplainant stated that he want~d to withdraw
from the University based on medical necessity, The University providqd the
Compl~an \l;j h. th,e necessary form to ~thdr(\w. neUnivers.ity did 10t give ~e
Complamant any mformatlon about returruno to school or a 1 ill for readmISSIon, At
the time he withdrew, the Com laln" thad " .1" ,
L--,--.--_-;-;--:-:-----::->for v,:hich he was responsible': The Gomp:tainant id that the vice
preSident told him that she would "go to bal for hirDl>;,to get that Nonresponsive
The Complainant applied for re.admis'\ion to the Ulii~'ersfty Nonresponsive
University's rransfer and readmissions re sentative initially toid the Complainant that
he needed to pay the Nonresponsive in order to enroll in cla<;ses. L.-'T~h:..::e:.....---..,.--,
Complainant said be t en spo e W1t the vice president abou having the Nonresponsiv He
told Iring the conversation with the vice president he explained that he had
L....,~___-'and described his medical prollress and his Ian for fll ute ue e s at the
University, The Complainant also requested Nonresponsive as an
accommodation for his disability, The Complainant said th the vice president told him
. She told rum that. to be
readmitted he would have to su mit N .
onresponSive
other students a
'Ihe Complainant was in good academic standing at the University when he v.'ithdrew,
and had not been coa.-ged with any code of co:nduc,t,Yi~la~ions while em lled at tl,e
U ~ : J I .. C-. ..:... :
Dlver~lt), '" !. l~ ~ ,,, .
. . ~ ! .. "
In response to the allegations, the University informed O~Rthat.. when the Complainant
first applied to the University in!Nonresponsive ~ he disclosed,informati in ,in ~s
admissions packet to indicate that he had a history 0 NonresponSive In hIgh school.
Additionally, at the time of his application, the Complainant's ID0tner no jfied the
's ndmissions office that the Com lainant had
was to attempt to have the Complainant sign a behavior contract to dr " , , , ' t1 N onresponSlvebehavior. The behavior contract \':os not dIsclplmary, nor was 1e L.-___---'
..... 1
Page 4 -Diane Y. Bower, Esq.
l...----;:=~~~~L.:::::~~~~~~!.J.!J1o..!_ll\...I..Ik.!.WJ...1_t,l.L'_1'0mplainant's behavior
1\C)' asserted tbt the
purpose e In the behavior contract vas to encourage the Complainan~ in mommts of
crisis. to see the assistant vice president, the dorm dhector, or the vice ptesident.
The behavior contract provided that the Complainant would do the fOIl~:Ving: (1) enter
into or maintain a relationship with a .counselor; (2) request a letter from the therapist sent
directly to the vke president, confimdng that he was a client and rcgul y under care;
(3) sign a Releas~ ofInformi'llion fon1l a110,\'ing Director ofthe! rolton ealth Center to
discuss his case with a pro'vider mentioned above; (4) ·abide by all recorrimendutions of a
counselor including taking prescrioed medication' and behavioral modifitatiol'.sj (5) keep
his com osure duriner class eriods
Nonresponsin (6) ~ d' . ,: '-[VOl SOCl
situations that may contribute to his stress and eventual crisis (l:(~ was inStructed that if he
felt a crisis was imminent then he was to contact his resident director, th¢ vice president,
the assistant vice presiden , the University chaplain. or the director of thd Holton Health
Center); 1lnd (7) because of the complexity of the issues that he seemed 16 gm Ie with
on a uent basis, the r asked that, at the times he \vas ex criendn a cbis
~ onresponSlve
!
The vice president said she believed the conditions in the behavior contr!ct were
necessary because bv
L-__--,-,--~Thevice president dra ed the behaVior contract thout ha'ving any
su stantial interaction 'A'ith the Complainant, 0t1l~I'thf.In having set>n him sc\'eral times on
campus, and possibly baving briefly spoken with him during his enrollmrnt at the
University.
The Un.iversity acknowledged that within ten minutes of meeting on INonresponsive lthe
Complainant ex ressed a desire to withdraw from the University based or medical
necessitv. The . onresponsive said he kft the meeting bdefiy to pbtain a
withdra~al form an then provided the Cornplai~.aJj·y.~th·tfe form he needed to complete
his withdrawal. The vice president revj.ewed {lie fori;} WIth him. and ask*d him if he had,
or would like to, discuss the decision with hjs famIly. No one at the meeting could recall
discussing with the Complainant the consequences Qf his decisio:J to witHdraw from the
University, or the requirements for his readmission', The meeting lasted ~etween five and
ten minutes. I
The University does not distInguish between types ofwithdra'....-als, nor ~its
readmission requirements based on whether the student withdrew for me1ica! reasons or
othenvise. The University did not place any restrictions on the Complainant's return to
the University.
Page 5 .. -Diane Y. Bower, Esq. , I ,':,'" ". \' i.~ .'jr~!~:\::~~';
Accordi.ng to 1hc""N'-onr-e-sp-o-ns"'-iv-e----,·after tl~~' C6~piainant withdreL from the
University on Nonresponsive lainapt's mother infortaed the
on a 504 plan in high school. :
The Com lainant submitted his a plicationJo( readmission to tr,e univJsitv
L-_:----:--' The University ~serl 0 th"t its readmission poli~ provides that, if
a student has aticnded the University's main campus in the past and wisHes to re-tum the
student will be revie,,"'ed for readmission using the following prclcess: J
I. Complete the Application for Readmission. 11lls can be completed
online at ..,,'\vw.arbor.edulaoplvonline or the s udent n contact his or
her Admission Representative for a paper applicationJ An Admission
Representative can also complete the Application for ~eadmission
over the phone with the student. I ,
I
2. Submit official transcripts from...~11 colleges attended ~ince leaving the
University.
3. Submit a compl~ted Rel~ase o';::JI~f~r;~~ti~n form. (~iS is only
requir~d iftbe l<!st colleg~. a1tetild~~,si,nce lea "ng th~ fniv('~itY was a
four-~'ear college and the stude'nt.lh:ed on campus.) I
I
4. Submlt a completed Student Agr~ement form signed Hy the student.
i
5. Approval must be granted from aU listed departments ~n order for the
student to re.turn to SAU. If any departments inform the Office of
Admissions of EI rcason the stlldcnt cannot be rcadmit1('d, the college
will notify t.~e student. It is the student's responsibilitf to contact
those dt'partments and take care of any items ~;randinglin the way of
lheir readmission: . '.'" i. I
Registrar \
Business Office
Financial Aid
Student Development andJ_eamin~
Perkins Loan Office
6. Once the student is approved h~'a\J departme:lts listedlabove, the
student will be accepted fO!1'e,~dw.is,si<?n,,\o tl~e. Univcri.ify a?d is
eligible to move forward ,:,,~th ~h.(f!h~Cial aId and re~lstratlOn
, . I I. p'.> processes. .
The University's written readmission policy does not include a requirem4nt that an .
applic.ant submit documentation of medical treatment, letters from therapists, or SectlOn
504 plans. Nei1her the University's transfer and admissions representatiVie nor the
" .."
,
Page 6 -Diane Y. Bower, Esq. J'
University's counsel knew whether this readmissions policy was publis ed anywhere in
the University's materials. OCR c·ould nol loea1e a copy ofthls policy oh the
Unive-rsity's website. The University bas a'one-paragraph ''Rcrdmit Pol~cy" in its
2010-2011 Student Handbook that provides: j
The Univc-rsity reserves the right to deny con1inllcd enrDllment 0 readmittance
to any stud"nt whose personal history indicates that his or her
presence at the University would endanger the health, safety or \~clfare of
the:melvcs or offlle members of the SAU community. '
OCR notes that this policy was not included in the University's Nonresponsive
Student Handbook, which was effective during the time the Corr plainan
\A;;thdrcw from the University and applied for.read~~~.sjon:·
The director of the business office at the Universliy Told OCR that the Umiversity
will not readmit students until their account balances arc paid in full, andl will not
waive amounts owed unless they result from University error, 1
Nonresponsive
A INonresponsh'e
Nonresponsive
he representa ive told OCR that at that.time she was not av.are of an:; other
requiremen s that tbe Complainant pad to satisfy fOr)r~d~ission. I
told him it may be too lateLN_onr_es~p:...o_ns_iv_e____----.~-1.~~=..J'4
Complainant notified the vice pres.ide
...
I I I
Page 7 -Diane Y. Bower, Esq. I " , ; I
~-----,------, ~~~rullllf:nlJ~~l.e.d.....b·Lll:~~'~~'" ai~.~o the admiSSioL office thaI the
, to be read'nitted t the Uniy.;rsit '.
Nonresponsive
L-__-.J (emphasis added)
I
INonresponsive ,Itold OCR that, after the e-mail exchalll!e
with the. vice president, i~ was her understanding that the University requlred the ~
Complamant to INonresponslve Iill order to be readmitted. Sh'~ said sh1conveyed that
requirement to the Complainant by hone on seyeral occasions 3 .. d in the
phone log the University provided. Nonresponsh'e told
OCR that she had never before been told to Nonresponsive I' readmission applicants.
The vice presidenL NonresponsiYe .all continued tJlat the
CO)T1 lainant's a) lication for readmission was never considered becaus~ he did not
Nonresponsive I
The vice president explained to OCR that she did no~!requi~e the Complalnant to
necessarily INonresponsi\'e Ibut she did require. S!:lIDe·ey~dence or other documentation
that the Complainant had a disability, and tha't his p7o~le~'~~ere being treated, before
she made a decision about his readmission. Specifically: the vice pre!'idepl wanted
documentation and information from the Com lainam that dem0nstrated that he would be
able handle a full-time course load, Nonresponsive and b! successful at the
University ifhc were readmit ed. She said she thought Nonr.sponsive mig~l also provide
information about what academic adjustments the Complainant might ne~d also. The
vice president told OCR that she told tbe Admissions Office that 'the Complainant needed
to providel~.onresponsi Ibecause she did not want to reveal that he had a ps)~chiatJic
disability.
The vice president acknowledged that the University had only r~qui[ed fltudents to,
provide documentation regarding their medical hi¥tory'in two in,':ances that she could
think of, each time WhCll the stucents posed a threat to themselws or others. She said she
has never reques:ed such documentation from st:.ldcr.ts with non-psychiatric impairments
or disabilities who had withdrawn from the University for medic:; I reasons. She
explained that she has req1!csted documentation from student,,' therapists '~:ujng tha1 the
stl1denis were ready to return and had been seeking treatoent dur~ng thej~ absence from
Lhe University when it was deemed that the students were a threat to themselves or others,
Howe\'er, the Universi1y provided OCR 'v1iith dOC).lInentation of only one ~thcr instance in
which the University required ~e1ical records ~r j,~tbFna!t~~ as a conclitipn for u.
student's reenrollment. In thatlnstance, the UOlv~rS-l-lY reQUlted a student,to provlde
docwnentation of a psychiatric evaluation a~d a ret:Ori16e~datioll from the provider that
the student was able to return to the Uniyersity before the srndcnt could reenroll.
Page 8 -Diane Y. Bower, Esq.
'. ::', { .., ..
! .~ ...
. '.....
i I
I
I
The Univc,sity never detcnl1ined that the Complainant was a thr~[lt to otl1ers. The vicc
president told OCR that the Com Jaincmt had de onstrated he was a lhr~at to himself
because he was ~onresponsive two days after the CoIhplainant
s~bmitted .~s app c~tion 10r readmission) the vice president and INonrespo~sive
discussed "not alloWIng" the Complainant's admissbn in an e-ma'--.i1'e-x-'c'hh',n-g-e-;"b-e-ca-u-s-e.---'
the Nonresponsive noted. the C . n
stated that the Univer ity could assert
the. osi~on that the CoL.m-p'-a-'-in-a-n7"t-w-a-s-a-;d--an-g-e-r-to~himselr and di3ruptive1to others. The
NonresponsIve raised the University's coneem that the CQmplairh could possibly
hurt someone else for the first time in an affidavit dated \Nonre!J>onsive ~uhmitted to
OCR as part of its investigation. I
The University has .: '. ._~; ..,:!'::-..... j. ' .' J
Nonresponsive .,.'.; ,l i'~ . Aoplicable Legal Standards
I
The regulation implementing Section 504, at 34 C.F.R. § 104.3G){ l), dcfirles an individual
with a disability as any person who has a physical or mcntal impairment that substantially
limits one or more major life activities, has a record ofsucb impairment, br is regarded as
having such an imp:tinnent. Section 504~ at 34 C.F.R. § J04. 30)(2)(i\'), further provides
that a p~on is regarded as having an impainnem when the person: has ~physjcal or
mental impairment that does not substantially limit major life activities bht \,.ho is tn.!Jted
by a recipicn1 as constituting sueh a limitation; has a physical or mental 4npairment that
substantially limits major life activities only as a,n~st\lt of the atti tudes onothers toward
such impaimlcnr; or has none of the impainnent~ 9~nneo,by the.l'egulaticfn, but is treated
by arecipiem as having such an impairment. As ofJanuafy 1, 2009, the date the
Americans with Disabilities Amendments Act of2008 took effect, a perspn is regarded as
having a disability if he or she has been subjected to an actklO p;,ohibited i\mder Section
504 because of lln actual or perceived physical or mental impairment whether or not the
impainnent limits or is perceived to limit a major life activity. Accordingly, OCR's
analysis focuses on whether a recipient of FederaHinancial assi51ance perceives that an
individual has a physical or a mental imp~rip~L \\itl,ioui consid~riIlg wi ether the
rcdpicnt perceives "that individual to be limited inca rn.ujor lifc 8cijvity.
With regard to postsecondary students, a "qualified" ilidividual "'16 a disa1:lility is one who
meets the institu!ion' s academic nnd technical stand<1rds for admission or p~rticipatjon in the
academic program. See 34 C.F.R. § 104.3(1)(3). .
The regulation implemcnting Section 504, at 34 C.F .R. § 104.4(a), also prJvides that no
qualified persoll with a disability shall, on the basi~ of a dis~bility, be :xcl~d~ ~om
participalion in, be denied the benefits of, or oilienVlse be subjected to dlSCAmtnatlOn Ul~der
any recipient's program or activity. The regulation implementing Section 5D4, at 34 C.P,R.
Page 9 -Diane Y. Bowcr. Esq.
§ ) 04.42(a), funher provides that a qualified person wiih a disabili'.y may qat, on the basis of
disability, be denied admission or be subjected to discrimination in. admission by a
postsecondary inSl i u:idn that is a recipient of Feded financia1assistance. 1
1
To de-tennine whether an individual has been subjected to disab1ity-basd,d discrimination
in admission, OCR generally considers whether the individual 15 a qualifled person with a
disability, whe1her the individual was subjected to an adverse admission Ia~tion. and
whether the adverse action was based on the individual's disability. OCR examines the
recipient's standards for readmission and how they w~re applied t~ the cbmplainant.
Absent overtly discrirn.inntory poliCies, OCR consi(l'ers whether there ar~other
circumstances that may raise an inference of diScri\nli1ation. OCR may ~xnmine whether
the instiMion failt~ to follow established procedures'or irrac1ice~, whelher the institution
treated the applicant with a disability differently than similarly-situated non-disabled
applicnn s, or whether there is other evidence of discrimination. If differbnt treatment
can be infclTcd from any such circumstances, OCR considers whether the institution has
provided a legitimate, non-discriminatory reason for it<; action. If such a reason is
presented, OCR considers whether tbe reason is merely a pretext for discrimination.
Under Section 504, the "direct threat" standard applies to situations wherc a university
proposes to take adverse action agamst a student ,yhose disability poses ~ significant risk
to the health or safety of othcrs. A significant risk constitutes a high prolbabililY of
substantial harm and not just a slightly increased1 spe~lllatiye. or remote risk. In
. ,.. " t detennining whether a student poses a direct threat, tl\e unlversit)' must m:1ke an
individualized assessment, based on a reasonable judgment that relics on!current medical
knowled!!e or on the best available objective evidence, to ascer\3in: the nature, duration,
and seve;ity of the risk; the probability that the potential injury tl.iJl actucllly occur; and
whether reasonable modifications of policies, practices, or proc('..duTCS wi~1 sufficiently
mitigate the risk. The student must notbe subject to adverse action on the basis of
unfounded fear, prejudice and stereotypes. ',.. ',t' '.' :
( . ~'I .:l :;:)!;..I \i ,.'~ ;
. Under OCR policy, nothing in Section 504 pr~ve;n~,~ducil1i0na1 institutiOns from
addressing the dangers posed by an individ.ua) wno'(gpreF-~nts a "direct tHreat" to the
health and safety of others, even if such an iildf,:iqual is a person with a disability, as that
individual may no longer be qualified for a particular educational program or activity
under 34 C.r-.R. § 104.3(k)(3). Following a proper detennintltiGrt that a $tudent poses a
direct threa~ an educational institution may require as a precondi lion to ar student's return
that the student provide docwncntation that the student has taken steps t~reduce the
previous threat (e.g., follo\lv'ed a treatment plan, submitted periodic reports, granted
permission for the institution {O talk to the treating professional). Ho"veYfr, educational
institutions cannot require that a student's disability-related behavior no ~onger occur,
unless that behavior creates a direct threat that cannot be elimina;'cd through reasonable
modifications.
! .
-,l'., ~.. ,...I ..,
-'. r--. ~" . '-Il"
,;. tl: :lo.'t.' 1,.,_;.; . . I I ':'; ~. ~:~. ";;:, Page lO -Dj'ane Y. Bower. Esq.
Analvsis and Conclusion
In the instant ease, the evidence established that although the Complainkt never
identified himsclfas a student with a disability with the Vnjversity's disability services
office, the University perceived the Complainant to qe an individual witl~ a mental
impairment. In addition to the notice the University 're~lyed from the Cpmplainant's
mother that he sutTered from Nonresponsive the Com lninant m~de the
Universi r OW:1r\! of his syehiatric histo in his Nonresponsive astki on what the
University descrihed :IS Nonrtsponsive tHe University
created a behavior contract at indicmed its belief that the Complainant had a mental
impainnenL Specifically, the University attempted to require th{' Complainant to seek
counseling from a therapist and to agree to take aJl prescribed mcdicatiorys. The
University ~!~o ~ttempted to T:quire the C.o~piajnant.to· pro:ride:-ccess t~ his therapist so
that the UmvefSlty could stay mformed of hIS care, 1he Umvemty subsequently imposed
the same conditions that were in the Nonresponsive behavior contract on the
Complainant's read ission in Nonresponsive d specifically requeEted Nonresponsiv The vice
president maintained that the Complainant needed to provide h~I with Nonresponsiv or at
least the same information about his medical c-andiTiol1 and treatment that she previousl
sou ht in the behavior contract so that she COUld.determine whether he eQuid
d attend classes u me. Additionally, when the Comp amant
~~~~~~~~.....>..U:\<..L_-'----__-_,--JUescribed'the Complainant as a
OCR has determined ,that the
~~~~~~--------~----~~ riiversity's behavior contract and its conditions for the Complainant's return to the
Uniycr.ity dem('n~truted that the University per£,ci;ye<thim t<;> be an individual with!l
disability. pursuant to 34 C.F,R. § b04.3G)P)Q.ii),\~,· {.:, .~ .i,
I '. " . ~.,.. ~ :. \ I
Moreover, the Complainant established that he w~igHali~'ed: He was accepted into the
program and had successfully com;Jleted onc't,crnfas'a full-time ,-itudent.:There is no
dispute that the Complainant voluntarily withdrew trom the University. the University
acknowledged [hat the Complainant did not have any disciplinary or ac;:dcmic issues
while he was emolled as a student. TIle Unive.rsity also acknowledged that it had no
intention of clismissinCI the Com lainant or disciplining him whe:.1 it presented him with a
behavior contract in Nonresponsive Rather, the University said it draftedihis behavior
contract to help him be sliccessful. Based on OCR's review ofthe cvid£nte proy;ded,
OCR has determi.ned that the Complainant was a qualified individll4l1"'lith ~ disability
because he met the Universitis standards for admission and continued participation in the
program, and his withdrawal was a voluntary \i,~thdra'\\o,l[ unrelatcn to any fpetors that would
have disqualified him, such as academic or discip!iryaI)" issues.
OCR next detcmuned whether the LT iversity impo-;ed a requirenent on the Complainant
for bis readmission that it did not uhpose on students \vho were not coru,itiered \0 have a
disability because he has or was perc~ived to be an individual wi-J! a disability. There is
no dispute thm the University requjred the Complainant to provide doc~entation of his
medical condition and confinnatiQn that he was getting treatment which tould include
INonrtsponsive Ibefore l~C Universit! would c(j~sid~r' his,ap~1jcatinl1 for recnrollment. .
Although the CompJamant also had INo~espon"";e. .: ,'.. ~". Il'Ie Ylce
.. ~', " l I '.
'\.)·j'l '1I: '
" .:
Page J I -Diane Y. Bower. Esq.
president and \Nonresponsive Istated that they would not consider'the
Complainant's application until he submitted.\~.onresponsi lor medical docukncnlation
regarding his mental health. The Complainant'Was denied readmission. therefore.
because he did not provide the University with:.his\~.~:r<spon lor either documentati~n
regarding the status of his mental health. Th.e University's readmission ~Iicy docs not
require an applicant to provide I~.onresponsi lor other medical docur1entatior regarding the
status of a disabili ty. or status of any health condition. The vice president acknowledged
that, in her history in her position, she had only required two sUlcen+s to provide medical
documentation regarding: their condilion and treatment prior to readmissio11, when it was
deemed that those students were a t.hreat to themselves or others. According to the
docwnents provided by the University, the University required only one c!lther student to
provide medical documentation, specifically ev.idence,ofthat student's psychimric
.condition, before the student could.continu.~ enrollment at the University~ This evidence
is sufficient to show d1at the University Unpo~ed an additional requirement for
reenrollmcnt on the Complainant that it does not requi~e of recnrollment applicants who
are not individuals with disabilities, abd are not perceived to be.
The Unive:-sity represented that it conditioned the Complainant"s reen:oHment on his
ahility to demonstrate tbat he could handle a fun-time course 10a(~ILN_ollI_e_sp_on_si",ve--,;,..--__...J
and be successful at the University. The Complainant had not given callS!e for the
University to require a showing that he eould be successful. His vvithdrawal was
voluntary, he had peen in good standing academicaJly, and the Universit~ had never
disciplined him. OCR found, therefore, that this was not.a legitioale, nohdiscriminatory
basis for the additional requirement the University imposed on the Complainant.
The University implied, in its affidavit submitted by tlw INonresponsive Ithat
when the Complainant \..~thdrew, the University consiaered the s'uden! to possibly pose a
directtbreat. The I .. 7I Nonresponsive
OCR found that the University had taken no me.asures to detennbe whether the
Complainant represented a direct threa~ to ot~~r&\,:~p~~<;jf.\~~ly, there is no evidence that
th~ University made ~n indjvidu?:li~d ass~s~~ri~}g:.d,:o,~. *r<~a~~nable~udgment that
relied on CUJTcnt medlcal k.nowledge or ~u ~ebes~,u~ai.T~Wc obJe~t:ve evrdollce, to .
ascertain: the natUre, duration, and seventy of the ns~; theproba'rnhty that the potcntlal
injury would actually occur; and whether reasonable modifications of po~cjes, practices,
or procedur~s would sufftcicntly mitigate the risk. Testimony ftom UiUversity ersonnel
illdica1ed that they believed the Co lainant was
In an e-ma\ exc ange contemporar eous wit t cL-________________~
Complainant's ap )jcation for readmissio~ University personnel described the
Complainant as Nonresponsiv and not as a threat to others. The vice preside~t. who as vice
president of Student Development would make a detennination 33 to thatioffice's
approval of his application for readmission, bad not had any substantial interactions with
the Complainant prior to the\Nonresponsive Imeeting when the'Complainant v-,ithdrew.
Page 12 -Diane Y. Bower, Esq.
.:.~. ;:; ~1.~~.~::,;;~ i'.: :~.: .
There is no evidence that the Unh'crsity believed he,pos~d a sigJificnnt ri!\k or high
probability ofb..:mn to anyone. or made such a de{erti,ination.
Thus, in this instance, OCR finds that the evidence is sufficient -;;0 supuorit a finding that
the University discriminated against the Complainant on the basis of disalbiJit\, in -
violation of 34 C.F.R. § 104.4(a) and 34 C.F.R. §104.42(a) when it condition;d his ability
to.remain enrolled at the University upon.signing the behavior ccmrac:t, and th.en refused
to consider his readmission until he provided medical documentation to dstabUsh his
condition and treatment. Although the matter c.oncerning the behavior contract was
untin:ely ~~~use tbe,complaintwas filed more than 180 days afi:!rtheINonresponsi\'e
mee ng, 1t IS mstmctlve to OCRls conclusions 011 the allegation regarding the
Complainant's application for readmission.
,
I discriminated a 'amst hlm by refusing
~ ~~~
necessary because of'his disabilit . However "the University never considered the
Complalnant's request for Nonresponsive because he was ntver readmitted to the
Uniycrsiy. Theretbre, OCR did no additional investigation oftlris allegation.
Section 504 Grievance PI'occdurcs .: '. :-~.'< ~ I'
.. !')' ';: '..'! ,:
Summ~·I.I·v oflnvestitmtion . , "" :d 11~~i, j:;' i
Although the Complainant did not raise an j'ssue ~eg~;di~g the l"niversiJ,s Section 504
grievance procedures, OCR learned during the course of its investi ation 'that the
University did not haye Section 504 grievance procedures, On Nonresponsive the
Complainant qUC'stioned the trnnsfcr and readmissions represenbtivc about why he \.....as
required to submitlNonresponsive given that the same requirement W8.S not (nlposed on all
other applicants for readmission. The Complainant told the transfer and readmissions
representative that he believed the University's jmposition o~Nonresponsi\'e . Ion
him was discriminatory because he had a disa~i)ity. The transfer and readmissions
representative did not refer the Complainant to the University's S'ection 504 Coordinator
or its grievance procedure for disability discrimination complai:;ts. Nor ciid the transfer
and readmissions representative report her conVersation with the Complainant about his
claim of disabil1ty discrimination to the vice president I
OCR reviewed the University's ~kc(ion 504 grievance procedure which ~pears to be
published only in a faculty and st..'lffhandbook. The University's Section'S04
Coordinator did not know where students or visitors could find tr.e University's Section
504 grievance procedure. OCR notes that the University's 2010-2.011 Sh;ldcnt Handbook
includes a "Student Complaints" p!ocedur~ thqt,r,.eC!.ui~es students to seek info:-mation
about resolution of complaints with appropriate UniVersity officials, and if necessary
submit complaints to the a TO riate Univer~ity vicc:presiti'ent l11[s complaint procedure
was not included in the Nonresponsiv Student Handbook th~t was j'n effect while the
Complainant was enrolled a1 the University or during the period of time he applied for
readmission..
Page 13 -Diane Y. Bower. Esq.
TIle Section 504 coordinator told OCR that she was not involved in disahility
discrimi ation complaints or grievances. She explained that an\' !ffiev8necs ·related to
disability discrimination were referr(.';d to the University's assistnt vice president for
human resources. OCR found that the UniversilY' s Section 504 grievance procedure
requires the accused individual to-provide the \v!itteti response 10 the grievance to both
the grievant and the assistant vice president for Iruman res-ources. The procedure
provides timelines for completion of each phase of the:iIivestigatlon. The procedure also
provides for notice of the disposition ofthe compJahi.t'to the parties by the assistant vice
president for human resources. The procedure alsb provides that a grievant may apreal
the decision to an appeals committee and subsequently to the prc ;ident. 111e procedure
does not include a process for adequate, reliable, and impartialiflvcstigatlon of
complaints, including the opportunity to present witnec;ses and othcr evidence. Rather,
the assistant vice president for human resources only inyestigates grievru,ces "as
appropriate." The procedure also does not provide contact information, such as a phone
ilumbcr, name or titie, or address, for the assistan vice president ':>"f humdtl resources.
I
Amilicable Re2UlatoD' Standar~
The Section 504 regulation, at 34 C.F.R. § 104.7(b), states, in r:"rt, that a recipient shall
adopt grie\"ance procedures that incorporate appropriate due pro'"!ss standards and that
provide for the prompt and equitable resolution ofcompJaints alleging any action
prohibited by Section 504. \Vhen evaluating a recipient's grlevaJlce procedures under
Section 504, OCR considers a number offactors in evaluating whether a recipient's
grievance procedures meet regulator)' requirements, including: whether the procedures
provide for notice of the procedures, including ,ybcr~,~omplain1S may be filed;
application of the procedure to ~o~plai~~s ~1;l~g~g,ffi~c11}}!Ratio: ,carrie~ Ol~t by. .
e ployees, oth students, or ~partIes; ad~qu,a~'lSfihffll~~ aIle Impartial tnvestlgahon
of complaints, including he opportunity to presen,t~'trie!l$.es and other evidence;
designated and rea<;onably prompt timefram.es ~or ih~.:ma}or stages ofthe-complaint
process~ notice to the pllrtics of the outcome ofthe complaint; and an assurance that the
school will take steps to prevent !:"ccurrence of an)' harassment all i to correct
discriminatory effc ts on the complainant and others, if appropriate.
Ana\v.;;.is ~md Conclusion
OCR found tha. the University has adopted a Section 504 grievance procedure which is
published in the University's faculty and staffhandbook. The grievance procedure
indicates which office complaints are to be filed with (the Assistant Vice 'President of
Human Resources), provides prompt timeframes for all stages of the inve~tigation of all
complaints, and provides that complainants will be piqvided wi til notice of tite outcome
of the inyestigation. further, complainants have the right to an 'Tpeal. The appeal
process provides complainants an opportunity to identify relevant infonnation and
establishes clear and reasooable 1imeframes for processing the ap::>cal. Finally, the appeal
procedure provides that the complainant wm be provided notice of the appeal decision in
writing.
Page 14 -Diane Y. Bo vcr, Esq.
.,, , "
,.... ::~ I. . . ,; ~"
..' ....
~~ .' t ~ ~;
However, the University's Section 504 Coordinator didnot know how students or visitors
are notified of the grievance procedure, nor could OCR locate a copy ofthe grievance
procedure in the Student Handbook. Additionally, the Universi:y's Section 504
grievance procedure'doe.s not incorporate appropriate due process standards.
Specifically, the grievance procedure does not. indicate how com laints should be filed,
does not provide complainants an opportunity to identify witnesses and other relevant
information during the investigation. does not provide complainc nts with v,'ritten notice
of the outcome of he investigation,. does not explain that complaints to b,e filed pursuant
tothe procedure,include allegations of disability qis~~ination, includin~ disability
harassmf!nt, camed out by cmployec,~, other studeill$,,or third parties, do~s not include
the address, and te-Iephone number of the University employee with ~ho~n complaints
should be filed and provide for an alternate person if the person with whom the co:nplaint
is filed is ailcged to have been rnvohTed in the discriminationlhar:!5sment, and does not
include an assurance thAt, in cases ofdisability harnssmenLr the T.! niversit)' wi II take steps
to pre\'ent recurrence of any harassment and to correct discriminatory effects on the
complainant and otllers, ifappropriate. The Uniycrsity's Section 504 Coordinator also
plays no role in addressir~g complainants of disabi!i~.discrimi alion. Therefore, OCR
found that the Univcrsity's Section'504 g:-ievancc.procedures do not meet all ofthe
requirements oftbe Section 504 regulation, at 34 C:F:R. § l04.7(b).
To resolve tIlis ma,ter, the University submitted. the enclosed Resolution Agreement,
si·ncdDecemberlO 2010. Pursuantt tleA ,ecmenLtheUni"ersi will:
Nonresponsive
(2) reimburse
'-:t-;-he-;:;C:-o-m-p7"'la-;-il-1a-n~t"fo-r--;t""71i -s-co-s""7t-o"'f7:tu"""it:>io-n-:-7jo-r:-c-o":":"ur=-=s-=-e:-c-:re:-:JT;lls~r::-;-t"'-'lr::-no"t-Xtr=a::::n-=1sfer from the
University EO the post-secondary institution he enrolled in immediately after!::-Ionresponsive I
provided that the Complainaot submits documentation to the UnrversilY of such costs;
(3) revise its Section 504 gricvance procedure; and (4) publish the revised Section 504
grievance procedure in 1110 Student Handbook and on the Uruver~ity's website.
The Unjversity should revise its Section 504 gri~v~'ntJ~'procedure as described below and
provide adequate notice of tl e procedures. The revised procedur.~s v.111 include the
following: (I) clarification that the procedure applies to student~ lIld cmployees,
(2) clarification about how complaints can be filed (e.g. in ....11tin:;), (3) clarification that
complaints to be filed pUT:lUan1 to the procedure include allegatio!l.s of di~2bllity
discriminaiion. including disability haras~ment, carried out by clr,ployees, other students,
or third parties, (4) notice of t..f-Jc aqdres$ and ~eJ~hon~c,n~mber of the Universiry ,
employee with whom complaints snrJuld be filed ~~qg~or1~. for ~alte~ate person If
the person with whom tbe complaint is filed i~ aIlegecl'to naVe be~n invol;ved 111 the
discrirninafioniharassment, (5) provision ofadequate, reli~bJe, 01:1 imPaI1ial investigation
ofcomplaints, including the opportunity to present witnesses and other evidence,
(6) inclusion of the University Section 504 Coordinator in 1he Unjversity1~ inv:-stig~tion
of grievances, (7) assurance that., in cases of disability harassrnen!, the UmversLty WlII
Page l5 -Diane Y. Bo'wer. Esq.
:. f I~'-:'j,,;. . take steps 10 prevent rec\l!Tcnce.dr any har~~riV~Il! fiPdto-,yo!Teu discriminatory efrects
on the complainant and others, if~PTlropriiite1 ~9-(;g) o9ticethu', retaliation agai nst
individuals \\ ho file disability ruscnmination complaiIilts or participate in the grievance
process is prohibited.
This GOllcludes our in"estigation of this matter. We wiII contint:e to monitor the
University's iniplementation of the agreement. Ifthe University does D(}t implement the
acti-ons outlined in the ugreemcnt. OCR v"ill un.rnediately reSlU11e our eff{)tts to secure the
University's compliance \vith applicable Federal laws. Also, please be aware that a
complainant may file a private suit in Federal court \"'hether or not OCR'finds a violation.
This letter is a let cr of findings issued by OCR to address an individual OCR case.
Letters of findings contain fact·speciftc investigative findiugs acd dispositions of
individual ctlses. Letters offindings arc not fom).al ~tatcmcnts of OCR policy and they
should not be relied upon, cited, or c,onstrued as such. OCR's r~nnal policy statements
are appro 'ed by a duly authorized OCR official and made available to the public,
We a preciate the courtesy shown by and your staff during the investigation of this
complaint. We look forward to receiving your first monitoring report, which is due on
January 21,2011. If yOIl have any questiops or concerns about tbe resolution of this
complaint, please contact Mr. D?Bald S. Yata?~/Tfi~~n\~~~9.er, at (216) 522-7634.
tIll,.. ;'_J'''~l~' i~!t·· \ .;;1i\.
~~~
Catherine D. Criswell ~ Director
Enclosure
" \
; ,,~.~ <\:;,.,
Resolution Agreement
Spring Arbor Univet:Sity
OCR Docket No. 15-10-1098
I
Spring Arbor University (the University) submit's the following agreemcnHo the U.S.
Department ofEd0 c:.ati'On, Office for Civil'Rights (ocr). ~o enSUl'C the University's
compliance with Section 504 of the Rehabilitation Act of 1973 (Sec 'on 504),29 U.S.C. §
794, and its impleme:ltiug regulation at 34 C.F.;R.:?art·l04. Accordingly, the University
agrees to take the following actions to resolve the abo-v..e-referen·ced complaint:
. ",
L L'1dividuai Remedies
A. By Janua.ry 7 2011 the UnIversity will)
Nonresponsi\'e
8. By January 7, 2011, the University will notify the Student tHat it has taken
the actions set forth in item l.A.
REPORTING REQUJREMENT: 8y Jannary2t 2011, the University will provide
OCR with documentation to verify that ithas irnplemented item LA'and E,
ioc\udin documentation showin that the Uuivcrsi
Nonresponsive
C. By J~tU~7,2011: the'University wiQ1~ffer, in vrriting. to reimburse the
Studen.t for ?is c,ost 9ftuition ,f9t,FO;:/~f ~~?,its that did not .~sfer f~orn
the Umverslt to the post-secondary tn·!\~i'tunbn he (: 11'olled m unme~hately
REPORTING REQUIREMENT: By January 21,2011, the Un.iversity will provide
OCR with documentation to verify that it has notified the ~)'lldent as required in
item IC, including a copy ofthe written offer.
D. Within two weeks of the Student's submission ofdC'cumentation to
establish the specific dollar amount of such costs, b11t by ITO later than May
13, 20l1, the Univer,;ity will reimburse the Student for the e~penses
described in item I.e.
REPORTING REQUIRElViENT: By May 27, 20r 1, the University will provide
OCR with documentation to \'crify that it h!lS re.im~~'rsed to'! Studel1~ by certified
check for his ccsts, ifany. as required irii:em'lD. " -
Page 2 -Resolution Agreement-Spring Arbor University -OC~ Docket #15-10-2098
n. Revisions to Section 504 Grie...."nce Procedures A. By January 14,2011, the University witl revise its grievance procedures to
ensure that they provide, at a min imum : ! 1. notice to students and employees ofthe procedure, including \"('here
complaints may be filed and how they maybe filed (in writing, e.g.); 2. clarification that complaints of disability discrimination, includi ng
disability baras~ent7 canied ,ou,t by employee:;, other students, or third
partles may be filed under the Uriiversity's Section 504 grievance procedure; .
3. notice of the address and telephone number of~he University employee
with whom c.omplaints should be filed and no:ice ofan"alternate person
ifthe person with whom the complaint is filed is alleged to have been
involved in the discrimination/barassment; 4. adequate, reliable, and impartial investigation elf complaints, including
the oppommtty to prescnt witnesses and other evidence; 5. involvement oftie University's Section 504 Coordinator in the
University's investigation of ~evances, to ens-uI'C the l1niversity's
adherence to the requircmen~ gf S'y~tion 504 n.:1d its implementing regulation; .' '.
6. assurance ili;~ 'in 'c~esOtdiSabi-lityhlrassmeri'~ the Uni,'erni1y will
take steps to prevent recurrence of any har8s:;nent and to correct
discriminetory effects on the compla1nant andotilCrs. if'appropriarc:
and ... '.'- '.
7. notice that retaiJatron a~~i~tlfv!duaj.s·who D.te disability
discrimination complamts 'or pdrticrpate 'in'the firievance process is
prohibited. RFPORTlNG REQUTREMENT: By January 28. 201 t, tile University will provide
OCR \\;th a draft of its revised Sec,tion 504 grievance procedure, and within
calendar 30 days after roceiving writ1rn notification from OCR that the grievance
procedure, as revised in accordance with Item ILA.I-7 above, is consistent with the
.reqlliremeots of Section 504, the University wili submit documentation to OCR to
verlfy that it bas implemented Item It.A.l-7, including adoption ofthe gri~vance
procedure_
, ""
, '
'. ~. ~ ... ' .... .
Pa{!c 3 -Resolution Agreement -Spring Arbor Uuiversfty -OCR Docket #15-1 0-2098
A. Within c.alendar 60 days after adopting the revised grievance procedure, the
University win publish its revised grievance procc·:iure in itS Srudent
Handbook. Employee Handbook, B11d on the Uni'Vc 'Sity website.
B. Within c.'tlendar 90 days after adopting the: revised grievance procedure, the
University will effect'ivC!ly publish a notice to all sl11denl~·a:nd employees
that the University's procedures forrcpomng disabiliry discrimination have
b~en revised and where copies ma), be obtaihed; and provide training to ns
Section 504 Coordinator, all University administrat'JTS, and any staff who
will be involVed in responding to reports of disabili:y dis:rimination
regarding the University's obl.igation t() promptly respond to Section 504
grievances,'as well as the: University's revised 'pro\;edures for how such
complaints should be reported and how they will be investigated.
REPORTING REQUIREMENT: Within 90 valendar day. after the University has
adopted rhe revised grievance procedure, drafted pursuant 10 item lLA, 1-7, the
University will submit to OCR documentation to verify that it implemented hems
IILA and B a ove, including but not limited to a copy of lh ~ notice sent to students
and fa<..'Ulty, a copy of the revised Student Handbook and Employee Handbook, the
link to the grie\'allce procedure on the University's websiu, and any agendas,
outlinr.s., handouts, and sign-in sheets from the training(s) provided to faculty and
st~ff.
The University understands that OCR will not close the monitoring of the
Agrceme .t until OCR determines that tile reQipient has fulfilled the tenm of the
Agreemer.t and is in compliance witll the n:gulation implementing Section 504, at
34 C.F.R. §§ 104.4, 104.7, and 104.42, which were at issue in this case.
The University understands that by signing the Agreemcn\ it agrees to provide data
and other infcnnation in a timely manner in accordance with the TCyorting
requirt:ments ofthe Agreement. Further, the University understands that during the
monitoring of the Agreement, if necess?I)', OCR may visit the University,
interview staff and students, and reque;;,t ~~Gh additional reports or data as aTe
necessary for OCR to detennine whether theqntyersity ras fulfilled the temlS of
the Agreement and is in co·ir.pliance with 'th~ r'o'guUition implementing Section 504,
at 34 C.F.R. §§ 104.4, 104.7, and 104.42, w.hich were at ;s5ue in this case.
Spring Ar~; University
"7j'. -r-/I ,7 ~'.,/"", / ...../)'/::;'".. ?<~ ~.V;~V(/~tiLM#6
President or authoTizcd designee
Charles H. Hebb, .President
Date
"',.
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