Free Expression 101: Know Your Rights!
Will Creeley, Vice President of Legal and Public Advocacy Foundation for Individual Rights in Education Orange Coast College March 17, 2015
What is FIRE?
¡ non-partisan, non-profit 501(c)(3) educational foundation founded in 1999
¡ dedicated to defending and sustaining core civil liberties at our nation’s colleges and universities
¡ freedom of speech, freedom of the press, freedom of conscience, legal equality, and due process
¡ won 245 public cases affecting more than 2.1 million students Who am I?
¡ Will Creeley, Vice President of Legal & Public Advocacy
¡ 2006 graduate of the New York University School of Law; member of the New York State Bar and the First Amendment Lawyers Association
¡ coauthored amicus curiae briefs submitted to a number of courts, including the Supreme Court of the United States and the United States Courts of Appeals for the Third, Eighth, Ninth and Eleventh Circuits
¡ appeared on national television and radio on behalf of FIRE
¡ edited second editions of FIRE’s Guide to Free Speech on Campus and Guide to Due Process and Campus Justice Today’s Talk: Overview
¡ Explore recent FIRE cases involving student and faculty rights
¡ Discuss importance of protecting student and faculty rights
¡ Introduce First Amendment case law in the collegiate setting
¡ Take a closer look at campus policies concerning civility & bullying ¡ Questions & Answers!
Disclaimer
Jasper Quinn Creeley, 5 months old! Censorship of Students: SUNY Oswego Student Journalist’s Email to Opposing Hockey Coaches
My name is Alex Myers, I work for the Office of Public Affairs at SUNY Oswego. I am currently writing a profile on Oswego State Hockey head coach Ed Gosek and was hoping to get a rival coaches view on Mr. Gosek.
If you have time would you mind answering the following questions. 1. How do you find Mr. Gosek to coach against? 2. Have you had any interactions with Mr. Gosek off the ice? If so how did you find him? 3. What is your rivalry like between your school and Oswego State? Be as forthcoming as you like, what you say about Mr. Gosek does not have to be positive.
One Coach’s Angry Response
Coach’s Response: "[Gosek] is one of the best guys in college hockey. Your last line of saying your comments don't need to be positive is offensive." Student’s Reply: "simply letting you know that this piece I am writing is not a 'puff' piece about Mr. Gosek."
Student Charged, Placed on Interim Suspension “Disruptive Behavior”
1) harassment or creating a hostile environment through discrimination, intimidation, ridicule, or insult toward any person; 2) acts of prejudice or bias targeted toward a person or group; 3) physical abuse, assault and/or battery; 4) threats toward or intimidation of any person, or intentionally or recklessly causing harm or reasonable apprehension of harm; 5) creation of a condition or situation that endangers mental or physical health; 6) conduct which inhibits the peace or safety of members of the College community; 7) conduct related to the use, possession, or distribution of alcohol or other drugs are unacceptable and subject to disciplinary action.
Defamation? Threat? Harassment? Intimidation? No, no, no, and no. ¡ Defamation requires that the speaker make a knowingly false statement that is published and results in harm to its victim. When the victim is a public figure, plaintiff must prove publication with actual malice (i.e., reckless disregard to falsity). ¡ Harassment: discriminatory conduct that is "so severe, pervasive, and objectively offensive that it effectively bars the victim's access to an educational opportunity or benefit." Davis v. Monroe County Board of Education, 526 U.S. 629, 633 (1999). ¡ “True threats”: "those statements where the speaker means to communicate a serious expression of an intent to commit an act of unlawful violence to a particular individual or group of individuals." ¡ Intimidation: “a type of true threat, where a speaker directs a threat to a person or group of persons with the intent of placing the victim in fear of bodily harm or death." Virginia v. Black, 538 U.S. 343, 359-60 (2003).
Charge Dropped
¡ FIRE wrote letter on October 26
¡ Charge dropped October 29
¡ Student forced to write apology
¡ Oswego takes negative media hit: 50,000 page views on Gawker, 1.6k likes on Facebook
¡ President “heartsick”
Censorship of Students: University of Alaska – Fairbanks ¡ Student newspaper The Sun Star subjected to multiple investigations for publishing two articles
¡ Charges of “sexual harassment” and creating a “hostile environment”
¡ Both charges filed by offended professor UAF Sun Star Picture Harassment
¡ What’s the legal definition for peer-on- peer harassment in the educational context? ¡ Discriminatory conduct that is "so severe, pervasive, and objectively offensive that it effectively bars the victim's access to an educational opportunity or benefit."
Davis v. Monroe County Board of Education, 526 U.S. 629, 633 (1999).
Investigating The Sun Star
¡ Multiple rounds of review
¡ Outside attorney retained
¡ Months-long investigation: April 2013 to February 2014
¡ Chilling effect on student speech
¡ After FIRE letter, investigations finally concluded — paper exonerated
Former Sun Star Editor-in-Chief Lakeidra Chavis Censorship of Faculty: UW – Stout • University of Wisconsin Stout's police chief removed this poster with a picture of Firefly actor Nathan Fillion and a quotation from the show from outside the office door of Professor James
Miller
• Police officer stated that the poster was unacceptable because it “refer[red] to killing” and “can be interpreted as a threat by others”
• Days later, the same officer
removed another posting
outside Miller's door
Miller’s Rejoinder Censorship of Faculty: UW – Stout
¡ The university's threat assessment team was activated, and Miller's academic dean called him in to discuss the threat assessment team's "concerns”
¡ Firefly fans deluge administration with protest letters
¡ Chancellor Charles W. Sorensen and other administrators at first issued a statement defending its censorship…
¡ … but finally folded and announced that Stout would no longer censor the posters. Censorship of Faculty: Bergen Community College
• Professor Francis Schmidt punished for posting picture of daughter wearing “Game of Thrones” shirt on his Google+ account • Summoned to a meeting to discuss “threatening” email
• Head of security told Schmidt “fire” could be “a kind of proxy for AK-47s”
• Suspended without pay pending a psychiatric evaluation
• After he was reinstated, still had formal warning placed in his file
• Threatened with termination if he made “disparaging” comments or acted in any way the college deemed “unbecoming”
Censorship of Faculty: Bergen Community College
¡ After FIRE Legal Network members intervened, college settled case in late September 2014
¡ College erased record of incident, acknowledged that its actions “may have lacked basis” and “potentially violated” Schmidt’s First Amendment rights.
Cost of Silencing Speech
¡ Betrays ideals of higher education ¡ Teaches wrong lessons about life in democracy ¡ Negative reaction from students, faculty, alumni, donors, press ¡ Waste of time, energy, resources Why is free speech important?
“[T]he opinion which it is attempted to suppress by authority may possibly be true. Those who desire to suppress it, of course deny its truth; but they are not infallible. They have no authority to decide the question for all mankind, and exclude every other person from the means of judging. To refuse a hearing to an opinion, because they are sure that it is false, is to assume that their certainty is the same thing as absolute certainty. All silencing of discussion is an assumption of infallibility.”
John Stuart Mill, On Liberty, 1859. Speech at Public Colleges The First Amendment applies in full on public college campuses.
Supreme Court of the United States
Sweezy v. New Hampshire 354 U.S. 234 (1957)
¡ May the Attorney General of New Hampshire prosecute a lecturer for refusal to answer questions about a lecture delivered at the state university?
¡ “The essentiality of freedom in the community of American universities is almost self-evident. No one should underestimate the vital role in a democracy that is played by those who guide and train our youth. To impose any strait jacket upon the intellectual leaders in our colleges and universities would imperil the future of our Nation…”
Paul Sweezy Keyishian v. Board of Regents, State Univ. of N.Y. 385 U.S. 589 (1967)
¡ New York statutes and administrative rules designed to prevent employment of “subversive” teachers and professors in state educational institutions and to dismiss them if found guilty of “treasonable or seditious” acts
¡ Unconstitutional for vagueness.
¡ “Our Nation is deeply committed to safeguarding academic freedom, which is of transcendent value to all of us and not merely to the teachers concerned. That freedom is therefore a special concern of the First Amendment, which does not tolerate laws that cast a pall of orthodoxy over the classroom.” Healy v. James 408 U.S. 169 (1972) ¡ Central Connecticut State College’s president had denied official status to a left-wing student group associated with violence on other campuses
¡ “[T]he precedents of this Court leave no room for the view that, because of the acknowledged need for order, First Amendment protections should apply with less force on college campuses than in the community at large. Quite to the contrary, ‘the vigilant protection of constitutional freedoms is nowhere more vital than in the community of American schools.’” Papish v. Board of Curators of University of Missouri 410 U.S. 667 (1973) ¡ “the mere dissemination of ideas—no matter how offensive to good taste—on a state university campus may not be shut off in the name alone of ‘conventions of decency.’” Speech at Private Colleges
¡ Private universities have a First Amendment freedom of assembly right to determine their own rules
¡ Most private universities promise their students extensive speech rights in school materials such as student handbooks, recruiting brochures, and codes of conduct.
¡ Contract theory of student rights. Overview of Private College Contract Cases
¡ Havlik v. Johnson & Wales University, 509 F.3d 25, 34 (1st Cir. 2007): “The relevant terms of the contractual relationship between a student and a university typically include language found in the university’s student handbook….We interpret such contractual terms in accordance with the parties’ reasonable expectations, giving those terms the meaning that the university reasonably should expect the student to take from them.”
¡ Ross v. Creighton University, 957 F.2d 410, 416 (7th Cir. 1992): “It is held generally in the United States that the ‘basic legal relation between a student and private university or college is contractual in nature. The catalogues, bulletins, circulars, and regulations of the institution made available to the matriculant become a part of the contract.’”
¡ Corso v. Creighton University, 731 F.2d 529, 531 (8th Cir. 1984): “The relationship between a university and a student is contractual in nature.”);
¡ Schaer v. Brandeis University, 735 N.E.2d 373 (Mass. 2000): recognizing contractual relationship between student and university, and employing “‘the standard of reasonable expectation -- what meaning the party making the manifestation, the university, should reasonably expect the other party to give it.’”
¡ Tedeschi v. Wagner College, 49 N.Y.2d 652 (Ct. App. 1980): holding that “when a university has adopted a rule or guideline establishing the procedure to be followed in relation to suspension or expulsion that procedure must be substantially observed.” However, Not All Courts Agree…
¡ Pacella v. Tufts University School of Dental Medicine, 66 F. Supp. 2d 234 (D. Mass. 1999) (ruling that the provisions of the student handbook were not contractually binding on the university in part because the university could unilaterally modify them without notice)
¡ Love v. Duke University, 776 F. Supp. 1070 (M.D.N.C. 1991), aff’d, 959 F.2d 231 (4th Cir. 1992) (holding that Duke University’s academic bulletin was not a binding contract)
¡ Romeo v. Seton Hall University, 378 N.J. Super. 384, 395 (App. Div. 2005) (“A contractual relationship cannot be based on isolated provisions in a student manual….[A] private religious university’s values and mission must be left to the discretion of the university.”). However, the weight of the precedent is favored toward recognizing university-student relationships as contractual in nature and holding universities accountable for the promises they make to students in handbooks and other related materials.
For more on this point, see Kelly Sarabyn, Free Speech at Private Universities, 39 J.L. & Educ. 145 (2010). … and Not All Colleges Promise Free Speech.
Speech Codes: What are They?
¡ FIRE defines speech codes as any campus regulation that punishes, forbids, heavily regulates, or restricts a substantial amount of protected speech, or what would be protected speech in society at large.
¡ Wide variety of restrictions ¡ Free speech zones, civility policies, posting policies, IT policies…
¡ Most common type? Harassment policies.
Speech Codes: Examples
¡ Syracuse University’s Computing and Electronic Communications Policy prohibits using its computer systems to send “offensive messages,” including “sexually, ethnically, racially, or religiously offensive messages.”
¡ The University of South Carolina prohibits “teasing,” “ridiculing,” and “insulting.”
¡ The University of Connecticut requires that “[e]very member of the University shall refrain from actions that intimidate, humiliate, or demean persons or groups, or that undermine their security or self-esteem.”
¡ Florida State University bans any “unwanted, unwelcome, inappropriate, or irrelevant sexual or gender-based behaviors, actions or comments.”
Spotlight on Speech Codes 2015: The State of Free Speech on Our Nation's Campuses
¡ 55.2 percent of the 437 institutions surveyed still maintain “red light” speech codes, which clearly and substantially restrict protected speech. ¡ The percentage of red light schools has declined by 20 points from seven years ago, while the percentage of green light schools has doubled. Speech Codes in Court
¡ Courts have consistently struck down campus speech codes in cases dating back more than two decades
¡ Codes are usually invalidated for two reasons:
¡ Vagueness: The code insufficiently specifies what kind of speech is prohibited
¡ Overbreadth: The code prohibits constitutionally protected speech Speech Code Defeats McCauley v. University of the Virgin Islands, 618 F.3d 232 (3d Cir. 2010) (invalidating university speech policies, including harassment policy);
DeJohn v. Temple University, 537 F.3d 301 (3d Cir. 2008) (striking down sexual harassment policy);
Dambrot v. Central Michigan University, 55 F.3d 1177 (6th Cir. 1995) (declaring university discriminatory harassment policy facially unconstitutional);
University of Cincinnati Chapter of Young Americans for Liberty v. Williams, No. 1:12-cv-155 (S.D. Ohio Jun. 12, 2012) (invalidating “free speech zone” policy);
Smith v. Tarrant County College District, 694 F. Supp. 2d 610 (N.D. Tex. 2010) (finding university “cosponsorship” policy to be overbroad);
College Republicans at San Francisco State University v. Reed, 523 F. Supp. 2d 1005 (N.D. Cal. 2007) (enjoining enforcement of university civility policy);
Roberts v. Haragan, 346 F. Supp. 2d 853 (N.D. Tex. 2004) (finding university sexual harassment policy unconstitutionally overbroad);
Bair v. Shippensburg University, 280 F. Supp. 2d 357 (M.D. Pa. 2003) (enjoining enforcement of university harassment policy due to overbreadth);
Booher v. Board of Regents, Northern Kentucky University, 1998 U.S. Dist. LEXIS 11404 (E.D. Ky. Jul. 21, 1998) (finding university sexual harassment policy void for vagueness and overbreadth);
The UWM Post, Inc. v. Board of Regents of the University of Wisconsin System, 774 F. Supp. 1163 (E.D. Wis. 1991) (declaring university racial and discriminatory harassment policy facially unconstitutional);
Doe v. University of Michigan, 721 F. Supp. 852 (E.D. Mich. 1989) (enjoining enforcement of university discriminatory harassment policy).
Doe v. University of Michigan 721 F. Supp. 852 (E.D. Mich. 1989)
¡ Code prohibited: “[a]ny behavior, verbal or physical, that stigmatizes or victimizes an individual on the basis of race, ethnicity, religion, sex, sexual orientation, creed… and that… creates an intimidating, hostile, or demeaning environment for educational pursuits, employment or participation in University[-]sponsored extra-curricular activities.” ¡ “The Supreme Court has consistently held that statutes punishing speech or conduct solely on the grounds that they are unseemly or offensive are unconstitutionally overbroad” Corry v. Leland Stanford Junior University No. 740309 (Cal. Super. Ct. Feb. 27, 1995) (slip op.)
¡ First speech code case involving a private university
¡ California’s Leonard Law provides students attending private institutions in CA the same free speech rights as those attending public institutions
¡ speech “intended to insult or stigmatize an individual . . . on the basis of their sex, race, color, handicap, religion, sexual orientation, or national and ethnic origin.”
College Republicans at San Francisco State University v. Reed 523 F. Supp. 2d 1005 (N.D. Cal. 2007)
¡ Students charged with “attempts to incite violence and create a hostile environment” and “actions of incivility”
¡ requirement that students “be civil to one another” and act in accordance with SFSU’s “goals, principles, and policies”
¡ struck down on First Amendment grounds McCauley v. University of the Virgin Islands 618 F.3d 232 (3d Cir. 2010) ¡ Policy prohibiting speech that causes “emotional distress”
¡ Policy forbidding “offensive” or “unauthorized” signs
¡ policy prohibited “any act which causes … mental harm or which … frightens, demeans, degrades or disgraces any person”
¡ Third Circuit: “desire to protect the listener cannot be convincingly trumpeted as a basis for censoring speech for university students” Rodriguez v. Maricopa Community College District 605 F.3d 703 (9th Cir. 2010)
¡ Professor sends emails on “superiority of Western civilization,” immigration to college listserv
¡ President declines to punish ¡ Coworkers file workplace discrimination suit ¡ “Colleges and universities—sheltered from the currents of popular opinion by tradition, geography, tenure and monetary endowments —have historically fostered that exchange. But that role in our society will not survive if certain points of view may be declared beyond the pale. " Litigation Stand Up For Speech Litigation Project
¡ File (and keep filing) First Amendment lawsuits challenging speech codes in every federal circuit
¡ Force schools to abandon unconstitutional policies through settlement or litigation
¡ Change risk management assessment to attach a cost to ignoring the First Amendment
¡ Empower students and faculty Modesto Junior College Modesto Junior College
¡ MJC prevents student Robert Van Tuinen from handing out copies of the Constitution to fellow students – on Constitution Day
¡ Police officer stopped Van Tuinen
¡ Administrator told him that due to “time, place, and manner,” he had to use free speech zone
¡ Required to hand over ID for photocopying, then told because area is booked, he can try again in 10 days or in October Modesto Junior College Free Speech Zone Lawsuit Challenging MJC’s Free Speech Zone
¡ Limited free speech to a 600 square foot area that could only accommodate two students at a time;
¡ Required 5 days notice, a written application, and submission of a copy of the applicants student ID;
¡ Failure to comply would result in “possible punitive action, including, but not limited to, termination of the program in process; denial of further use of Free Speech Areas; Discipline; Probation; Suspension; Expulsion and/or Removal from campus.”
¡ Each student could only use the Free Speech Zone for 8 hours per semester. Victory: Modesto JC Settles Modesto Junior College settled in February 2014.
Agreed to pay Van Tuinen $50,000 and change its policies. Students may now exercise their First Amendment rights across campus. Burch v. University of Hawaii-Hilo
Student Merritt Burch and another student were stopped from distributing Constitutions in the center of a student organization fair;
Burch was told to protest NSA spying in the Free Speech Zone “because it’s not the 60s anymore.”
Filed suit with fellow student Anthony Vizzone in July 2014.
Burch v. University of Hawaii-Hilo
¡ Settled December 2014
¡ Entire University of Hawaii System has changed policy to eliminate all “free speech zones”
¡ Policy revisions affect 59,000 students
¡ Payment of $50,000 to student plaintiffs Merritt Burch and Anthony Vizzone Sinapi-Riddle v. Citrus College
An administrator threatened Vinny Sinapi- Riddle with removal from campus for seeking a student’s signature on a petition outside the free speech zone.
Suit filed July 2014 hallenged three policies:
¡ Free speech zone that the school agreed to abolish after settling a similar lawsuit in 2003 and reinstituted to comprising 1.2% of campus in 2013
¡ Harassment policy prohibiting “offensive” or “inappropriate” speech
¡ Requirement that student organizations to undergo a two-week approval process for any expressive activity Sinapi-Riddle v. Citrus College
• Settled December 2014
• Free speech zone policy revised to allow expression in open areas of campus • Definition of harassment changed to track Davis • Payment of $110,000 to Vinny Sinapi-Riddle
Smith v. McDavis (Ohio University)
OU administrators told plaintiff Isaac Smith and other student members of group Students Defending Students not to wear an t-shirt with the phrase “We get you off for free” because it “objectified women” and “promoted prostitution.”
OU’s Student Code of Conduct forbids any “act that degrades, demeans, or disgraces” another.
Suit filed July 2014.
Smith v. McDavis (Ohio University)
• Settled February 2015
• Policy revised so harassment tracks Davis
• $32,000 payment to student plaintiff Isaac Smith Gerlich v. Leach (Iowa State University)
Iowa State University not only rescinded approval for the ISU NORML official t-shirt, but it adopted and enforced new regulations specifically designed to restrict NORML ISU’s political advocacy.
In both 2013 and 2014, ISU rejected other t-shirt designs because they allegedly associated the ISU name with promoting “dangerous, illegal or unhealthy products, actions or behaviors.”
Suit filed July 2014.
Gerlich v. Leach (Iowa State University)
“College campuses have and always should be a catalyst to new and progressive ideas. But recently at ISU, we've been made to feel like voicing our opinions and beliefs is wrong when it’s absolutely not. It's definitely been a long road and we look forward to reaching an understanding with those involved.” Paul Gerlich and Erin Furleigh, Plaintiffs. Beverly v. Chicago State University CSU administration determined to to silence faculty members Phillip Beverly and Robert Bionaz for their blog, the CSU Faculty Voice, which provides critical commentary on mismanagement at the university.
After demand to shut down blog for trademark violation failed, the university adopted a broad and poorly defined “Cyberbullying Policy” as a tool of censorship.
Bionaz has been charged under this policy for telling the university spokesman to “shut his yap” in a face-to-face conversation. Beverly v. Chicago State University
“It appears that only a court will be able to protect the rights of my campus community to express themselves without fear of retaliation. It is a tragedy that the valuable time of the federal courts would be consumed answering questions that have long since been answered. My commitment to the First Amendment is too strong to have let the behavior of the Chicago State University administration pass.” Professor Phillip Beverly, Chicago State University. Kalamazoo Peace Center v. Dunn (Western Michigan University)
¡ Western Michigan University denied student group request to host rapper & activist Boots Riley on campus without large security fee for undercover police
¡ Fee based on Riley’s viewpoint; arbitrary unwritten rule
¡ Suit also challenges posting policy that requires preapproval of flyers, which must “conform to generally accepted standards of good taste”
Jergins v. Williams (Dixie State University, Utah)
¡ Dixie State University denied student group permission to post flyers criticizing President Barack Obama, President George W. Bush, and revolutionary Che Guevara
¡ Cited policy does not permit students to “disparage” or “mock[]” individuals
¡ Lawsuit filed March 4 Civility Policies
¡ Recent controversies have renewed push for “civility” policies
¡ Steven Salaita “unhired” at University of Illinois after Twitter posts regarding Israel
¡ Professor David Guth of University of Kansas placed on administrative leave following Twitter posts about National Rifle Association
¡ UC Berkeley Chancellor Nicholas Dirks sparks controversy after emphasizing “civility” in commeroration of 50th anniversary of Free Speech Movement
¡ Harvard University proposed mandatory “Kindness Pledge” for all incoming freshmen Civility Policies
¡ In each instance, calls for civility have prompted concern from free speech advocates, students, faculty members, and professional associations like the AAUP
¡ Why?
¡ At public universities, civility policies violate First Amendment
¡ But at any university, privileging “civility” over value of open discourse stifles dissenting, minority, unpopular, or simply inconvenient speech
¡ Vague, subjective requirement – like adherence to “patriotism,” compliance determined by those in power
¡ Civility may be aspirational value, but may not be mandatory Terminiello v Chicago 337 U.S. 1 (1949)
¡ “[A] function of free speech under our system of government is to invite dispute. It may indeed best serve its high purpose when it induces a condition of unrest, creates dissatisfaction with conditions as they are, or even stirs people to anger. Speech is often provocative and challenging. It may strike at prejudices and preconceptions and have profound unsettling effects as it presses for acceptance of an idea.” Anti-Bullying Policies
¡ In recent years, many campuses have responded to concerns about bullying by hastily adopting “anti-bullying” policies
¡ Problematic because “bullying” has no accepted legal definition; used generally to refer to a vast amount of protected speech
¡ Legislative initiatives, too
Anti-Bullying Policies
¡ No matter how well- intentioned, sacrificing First Amendment rights is unacceptable response
¡ Always redounds to detriment of those without political power
¡ Well-crafted harassment policy that tracks existing legal definitions will prohibit speech and conduct we consider “bullying” 2003 “Dear Colleague” Letter from ED’s Office for Civil Rights
¡ “Harassment, however, to be prohibited by the statutes within OCR"s jurisdiction, must include something beyond the mere expression of views, words, symbols or thoughts that some person finds offensive.”
¡ "OCR’s regulations are not intended to restrict the exercise of any expressive activities protected under the U.S. Constitution”
¡ "[t]here is no conflict between the civil rights laws that this Office enforces and the civil liberties guaranteed by the First Amendment." Harassment Revisited
¡ What’s the legal definition again? ¡ Discriminatory conduct that is "so severe, pervasive, and objectively offensive that it effectively bars the victim's access to an educational opportunity or benefit."
Davis v. Monroe County Board of Education, 526 U.S. 629, 633 (1999).
Harassment
Harassment is not what the University of North Dakota used to define as:
“[U]nacceptable behavior, which can range from violence and bullying to more subtle behavior such as ignoring an individual at work or study. It subjects an individual or a group to unwelcome attention, intimidation, humiliation, ridicule, offense or loss of privacy. It is unwanted by the recipient and continues after an objection is made.”
After being named Speech Code of the Month in December 2012, UND changed its code. Not “Sexual Harassment” Appalachian State University Professor Jammie Price FIRE Resources Online Thanks for attending!
Will Creeley 215-717-3473 [email protected]