U.S. Department of Education Investigation Finds UCLA Did Not Violate Civil Rights Laws

The U.S. Department of Education’s Office for Civil Rights (OCR) conducted an investigation into a complaint filed against the University of California, Los Angeles (UCLA). The complainant alleged that UCLA failed to appropriately respond to a student’s complaint of harassment based on shared Jewish ancestry, in violation of Title VI of the Civil Rights Act of 1964.

The complaint stemmed from events surrounding the 2018 National Students for Justice in Palestine (NSJP) conference held on UCLA’s campus. The student alleged that he was subjected to antisemitic harassment during and after the conference and the University did not take adequate steps to address his concerns.

Under Title VI, institutions receiving federal funds must take prompt and effective action to address national origin-based harassment that creates a hostile environment. A violation occurs when: (1) a hostile environment exists based on national origin; (2) the institution has actual or constructive notice of the harassment; and (3) the institution fails to take prompt and effective steps to address the harassment and prevent its recurrence. OCR applies a totality-of-the-circumstances test to determine whether conduct is severe or pervasive enough to create a hostile environment.

UCLA enrolls over 45,000 students and hosts more than 1,200 student organizations, including groups representing both Jewish and Palestinian perspectives. The NSJP conference, held in November 2018, sparked significant controversy, with multiple stakeholders urging UCLA to either cancel or allow the event. In particular, the complainant, a student at UCLA, alleged that:

• While tabling near the conference venue, he and other students from Students Supporting Israel (SSI) were subjected to antisemitic rhetoric, including chants of “from the river to the sea, Palestine will be free,” which he perceived as a call for the eradication of Israel.
• On another occasion, unidentified individuals dressed in “pro-Palestinian garb” shouted phrases like “free Palestine” and “go home” at him while he was walking on campus.
• He felt unsafe walking across campus, even though he did not directly encounter anyone who harassed him.

UCLA responded to the broader controversy surrounding the NSJP conference in multiple ways, including:

• Engaging with student organizations, including SSI, to provide support and coordinate counter-programming.
• Allowing SSI to host an alternative event near the conference venue.
• Ensuring a police presence at the conference.
• Issuing a public statement from the University chancellor addressing concerns about antisemitic rhetoric and reaffirming UCLA’s commitment to free speech.

Despite these actions, the student did not formally report harassment to UCLA administrators or file a complaint through any of the University’s reporting channels. UCLA officials, including the Vice Chancellor for Equity, Diversity, and Inclusion and the Director of Student Organizations, Leadership, and Engagement, stated that no student, including the complainant, reported specific incidents of harassment related to the conference.

OCR determined that there was insufficient evidence to conclude that UCLA violated Title VI. The investigation found that:

• UCLA took proactive steps to address concerns about the conference and maintained neutral policies regarding student events.
• The complainant did not file a formal complaint or report harassment through available University channels.
• University officials were aware of tensions on campus but were not informed of specific incidents of harassment requiring an institutional response.
• UCLA’s response to general concerns about the conference, including outreach efforts, safety measures, and support for counter-programming, was timely and reasonable.

Because UCLA did not have actual or constructive notice of a hostile environment and took reasonable measures to address concerns raised before the conference, OCR concluded that the University did not violate Title VI.

The full resolution letter can be found here .

Note: Recently, there have been very few cases where OCR found that the educational institution took the necessary steps to comply with their legal obligations under Title VI. Although Title VI only applies to schools receiving federal funding, this letter provides helpful guidance to independent schools navigating similar situations.