Charles County Public Schools

Statement in response to civil rights complaint

Charles County Public Schools (CCPS) is aware of the complaint filed on Jan. 3 with the U.S.
Department of Justice by the parents of three female students who attend Gale-Bailey Elementary
School. CCPS filed an initial response to the complaint on Jan. 6 that explained that the factual
allegations set forth in the parents’ complaint are in dispute. The teachers who were supervising
recess on the day in question vehemently deny observing or being made aware of any sexual assault
while on the playground. According to the teacher who primarily interacted with the female
students that day, the girls did not report any inappropriate conduct of a sexual or violent nature
until one of the girls was accused by another student of using sexually vulgar language. Only then
did one of the girls accuse one of the boys of making a sexually aggressive/violent statement. The
teacher encouraged the girls to report the matter immediately to the school’s vice principal.

An investigation was initiated which, among other things, resulted in CCPS imposing discipline
on several students and making efforts to separate the students involved. Despite these efforts, the
parents of the female students were not satisfied, removed their children from school and have
demanded that the male students be removed from the school. CCPS, however, is bound by the
student discipline regulations promulgated by the Maryland State Department of Education, and it
has a legal obligation to educate all of its students, even those who may engage in conduct which
may warrant student discipline.

Among other things, CCPS has offered to put specific measures in place that would ensure the
boys and girls would be separated and have no contact with each other at school or on the bus to
and from school. Additionally, the school system has offered counseling for the girls as well as
mediation between the families of the boys and girls that would be provided contingent on the
parents’ agreement to participate. . CCPS further expressed its willingness to reevaluate the
proposed plan should it prove unsuccessful. Instead of responding to CCPS’ offer, the parents of
the female students filed their complaint with the Department of Justice.

CCPS has offered the female students appropriate educational services since their parents removed
them from school. Despite disagreeing with the parents of the female students about the
underlying facts of this matter, CCPS shares the parents’ goal of the girls returning to school, and
it has made repeated good faith efforts of making it possible. CCPS stands ready to work
cooperatively with the parents of the female students to achieve a mutually satisfactory resolution
to this matter, and it will cooperate fully with the Department of Justice to accomplish this goal.