1. EXPOSING WHAT APPEARS TO BE THE
CLAIBORNE COUNTY, MISSISSIPPI
PUBLIC SCHOOL DISTRICT’S

2. Page 1 of 13
FACSIMILE
This document is in follow-up to my visit on yesterday, July 30, 2015, to the
Claiborne County Public School District Office in Port Gibson, Mississippi wherein I
met with Ms. Mary McCay. As she requested, I am submitting my requests and
concerns in WRITING regarding the Claiborne County Schools.
On Wednesday, July 29, 2015, I attended the Claiborne County School District’s
ANNUAL BUDGET HEARING that was held at Port Gibson Middle School.
TO: Dr. Earl Watkins – Conservator For Claiborne County Public
School District (601) 437-3036
FROM: Vogel Denise Newsome – Community/Civil Rights Activist
DATE: July 31, 2015
RE: COMPLAINT AGAINST CONDITION OF CLAIBORNE COUNTY
PUBLIC SCHOOLS – CONCERNS OF UNLAWFUL/ILLEGAL
ATTACKS ON AFRICAN-AMERICAN CHILDREN UNDER
“SCHOOL-TO-PRISON PIPELINE” PRACTICES

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SCHOOL-TO-PRISON PIPELINE:
https://en.wikipedia.org/wiki/School-to-prison_pipeline (As
of 07/30/15 - Graphics added for EMPHASIS)
The term "school-to-prison pipeline" is a phrase that is used by scholars
and education reform activists and organizations . . . the Justice Policy
Center . . . to describe what they view as a widespread pattern in the
United States of pushing students, especially those who are already at a
disadvantage, out of school and into the American criminal justice
system. They argue that this "pipeline"is the result of public institutions
being neglectful or derelict in properly addressing students as
individuals who might need extra educational or social assistance, or
being unable to do so because of staffing shortages or statutory mandates.
The resulting miseducation and mass incarceration are said to create a
vicious circle for individuals and communities.
Advocates claim that the school-to-prison pipeline operates at all levels
of US government (federal, state, county, city and school district) both
directly as a result of zero tolerance policies, and indirectly due to
exclusion from the school system.
ZERO-TOLERANCE POLICIES
Zero-tolerance disciplinary policies are often the first step in a child’s
journey through the pipeline. Such policies impose severe discipline on
students. The American Bar Association has been critical of these policies,
calling them a "one-size-fits-all solution" that "has redefined students as
criminals."

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In 2011, a study by the National Education Policy Center found that zero-
tolerance policies across the nation were increasing suspension rates,
with students being accused of offenses such as attendance violations,
dress code violations, cell phone use, and other minor offenses. They
found that zero-tolerance policies put children, particularly black . . .
children, on a path of truancy and likely incarceration. Black students
are 3.5 times more likely to be suspended than White students and are
held responsible for70% of arrests while attending school. Simultaneously
Latino students are 1.5 times more likely to be suspended than their
White classmates.
HIGH-STAKES TESTING
More and more schools are being sanctioned for poor performance
underthe No Child Left Behind Act; as a result, teachers in these schools
must bend to the standardized tests that are used for evaluations.
Opponents of these tests argue that they undermine teachers and
students, that they take up too much time, and that they promote rote
memorization rather than critical thinking.

5. Page 4 of 13
Minority students are disproportionately subject to exit examinations that
determine whether they can graduate from high school. These same
students are likely to be in schools that have less funding and larger
class sizes. Furthermore, their schools are often suffering—due to being
punished for low test scores.
SYSTEMIC PROBLEM S
Critiques of the school-to-prison pipeline attempt to show how it falls
into larger systems of domination such as racism . . . An unfair
distribution of educational resources make students less likely to learn,
less likely to find good jobs, and more likely to end up in prison. The
more people in disadvantaged communities that go to prison, the more
alienated and economically disadvantaged these communities become.
The pipeline can also be critiqued in terms of neoliberalism, the idea that
market forces can organize every facet of society. Because prisons can
be privatized and run for profit, and traditional public schools cannot,
the market favors sending people to prisons rather than schools—. . .
(As prisoners, people can be compelled to perform labor anyway.) In

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keeping with this system, school budgets have shrunk while prison
budgets have expanded massively, while even within schools more funding
goes to police and less to teachers and children. The feedback loop
between standardized testing and school funding is seen by some as
another facet of neoliberalism, creating competition between students and
teachers who need good test scores to keep their jobs.
LITIGATION
In January 2010, the NYCLU, ACLU and the law firm Dorsey & Whitney
LLP filed a federal class action lawsuit challenging the New York City
Police Department’s practice of wrongfully arresting and using excessive
force against children in New York City schools.
In August 2012, the U.S. Department of Justice released a letter of
findings determining that the Lauderdale County Youth Court, the
Meridian Police Department (MPD), and the Mississippi Division of Youth
Services (DYS) are violating the constitutional rights of juveniles in
Meridian, Mississippi. The department’s investigation showed that the
agencies have helped to operate a school-to-prison pipeline whereby
children arrested in local schools become entangled in a cycle of
incarceration without substantive and procedural protections
required by the U.S. Constitution.

7. Page 6 of 13
KU KLUX KLAN ACT OF 1871
(As of 07/31/15: http://education.harpweek.com/KKKHearings/AppendixB.htm )
Dr. Earl Watkins, as you know, during the July 29, 2015 ANNUAL BUDGET
HEARING, I shared my concerns regarding the Law Firm Baker Donelson Bearman
Caldwell & Berkowitz and the ROLE it appears is playing in efforts of closing Port
Gibson High School and CONSOLIDATING with ANOTHER School in Fayette,
Mississippi.
While Ms. Bonnie Granger (State Accountant ?) came to me after the meeting
and advised that she thought it was BUTLER SNOW - - the FACT IS, being AWARE, of
the UNLAWFUL/ILLEGAL and RACIST Acts be it Butler Snow and/or Baker Donelson
to “HIDE-BEHIND-HOODS/THE SCENE” and keep HIDDEN from PUBLIC VIEW the
MAJOR Roles played in the UNDERMINING of the SYSTEM – i.e.
DRAFTING/CREATION of LEGISLATION that is RACIST and ADVERSELY impact
and TARGET AFRICAN-Americans/Blacks for purposes of SETTING them up to be
ENSLAVED through the CRIMINAL SYSTEM/PRISONS through the SCHOOL-TO-
PRISON Pipeline that appears to be the HANDIWORK of the KU KLUX KLAN!
With that being said, PLEASE ADVISE of the RELATIONSHIP (if any) that the
Claiborne County Public School District as well as you have with Baker Donelson
Bearman Caldwell & Berkowitz!

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9. Page 8 of 13
Dr. Earl Watkins, here is some of the information that I pulled from the July 29, 2015
ANNUAL BUDGET HEARING and your KNOWLEDGE of the following; however, NOT limited to
this listing:
1) ASBESTOS issue(s) at Port Gibson Middle School – which is NOT only a HEALTH
threat but can also be LIFE THREATENING!
Nevertheless, Ms. Mary McCay during my meeting with her on yesterday
(07/30, 15) advised that the Gym WILL NOT be used. However, if that is true
(which I do NOT believe it is), the ABESTOS HAZARD is NOT confined ONLY to the
Gym! Nevertheless, it appears that the Claiborne County Public School District
INSIST on educating students as well as subjecting teachers, workers and patrons
to PERSONAL INJURIES and/or HARMS!
2) ZERO monies have been ALLOCATED for Construction and/or repairs the Public
Schools in Claiborne County. This is UNACCEPTABLE; moreover, with the
ASBESTOS issues, the building is NOT SUSTAINABLE for educating and housing
students, teachers as well as other workers and patrons!
Therefore, PLEASE BE ADVISED, of my OBJECTIONS to the Teachers,
Children, Parents, Workers as well as other Patrons of the Public being EXPOSED
to the ASBESTOS issue(s) at Port Gibson Middle School as well as my
OBJECTIONS of the Port Gibson Middle School being USED for the 2015-2016
School Term with the School Board’s KNOWLEDGE of the HAZARDOUS,
DANGEROUS and LIFE THREATENING conditions of the Middle School!
Nevertheless, it appears that the Claiborne County Public School District INSIST on
educating students as well as subjecting teachers, workers and patrons to
PERSONAL INJURIES and/or HARMS!
3) KNOWLEDGE of SNAKES – i.e. such as RATTLESNAKES - issue(s) at Port Gibson
Middle School. More DANGEROUS and HAZARDOUS conditions! Nevertheless, it
appears that the Claiborne County Public School District INSIST on educating
students as well as subjecting teachers, workers and patrons to PERSONAL
INJURIES and/or HARMS!
4) KNOWLEDGE of DEMISED Infrastructure of the School! Moreover, the POOR and
DILAPIDATED conditions of the building – BOARDED Windows/Missing
Glass/Cooling System Defects/Poor Flooring/Busted Paneling, etc. Nevertheless, it
appears that the Claiborne County Public School District INSIST on educating
students as well as subjecting teachers, workers and patrons to PERSONAL
INJURIES and/or HARMS!
5) KNOWLEDGE of ADDITIONAL Conditions as well as LEGAL issues deeming Port
Gibson Middle School as UNINHABITABLE! Nevertheless, it appears that the
Claiborne County Public School District INSIST on educating students as well as
subjecting teachers, workers and patrons to PERSONAL INJURIES and/or HARMS!

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6) KNOWLEDGE of the SCHOOL-TO- PRISON Pipeline being
UNLAWFULLY/ILLEGALLY implemented for purposes of ENSLAVING and
TARGETING African-American/Black Children for INCARCERATION purposes –
i.e. CREATING and/or IMPLEMENTING unhealthy/unsafe and deplorable
conditions that ADVERSELY impact the LEARNING/MENTAL/PSYCHOLOGICAL
abilities of students as well as TEACHING abilities of teachers. Moreover,
ALLOWING the CREATION of UNHEALTHY/UNSAFE/HARMFUL conditions and
then using LEGISLATION it appears CREATED/DRAFTED and IMPLEMENTED by
the Law Firm of Baker Donelson Bearman Caldwell & Berkowitz and its COHORTS
under a DESPOTISM-Styled Government Regime which is PROHIBITED by
statutes/laws governing
PORT GIBSON HIGH SCHOOL:
My concerns as it relates to Port Gibson High School are as follows; however, are
NOT limited to this list in that I have NOT done a WALK-THROUGH of the entire
school yet:
a) INADEQUATE Library facility/space – i.e. for this to be the ONLY High School
in Claiborne County it LACKS the PROPER space, computer equipment, library
materials, etc.
b) INADEQUATE space/furniture in classrooms – i.e. for this to be the ONLY
High School in Claiborne County it LACKS the state-of-the-art equipment and
furnishings required for a productive learning environment as that found in
HIGHLY White POPULATED Schools in Mississippi – i.e. LACK OF A CONDUCIVE
environment CREATING and/or IMPLEMENTING unhealthy/unsafe and deplorable
conditions that ADVERSELY impact the LEARNING/MENTAL/PSYCHOLOGICAL
abilities of students as well as TEACHING abilities of teachers. Thus, ALLOWING the
CREATION of DEPLORABLE conditions and then using LEGISLATION it appears
CREATED/DRAFTED and IMPLEMENTED by the Law Firm of Baker Donelson Bearman
Caldwell & Berkowitz and its COHORTS under a DESPOTISM-Styled Government
Regime which is PROHIBITED by statutes/laws governing for purposes of
IMPLEMENTING the School-To-Prison Pipeline!
PLEASE BE ADVISED, it was brought to my attention that there was an
original plan of building a PORT GIBSON HIGH SCHOOL FACILITY
approximately $46,000,000 in value with swimming pool(s), etc.; however,
instead, the present Port Gibson High School is what was built at an
EXTREMELY LOW price. NOT only that, does NOT appear to be maintained in
COMPLIANCE under the MANDATORY Code(s)! - - -Therefore, I am REQUESTING
ACCESS TO VIEW ORIGINAL PLANS of the MULTI-Million Dollar Facility that
was originally on the table!
PLEASE ADVISE whether the MULT-Million project was
REJECTED because of the PLANS to turn Port Gibson High
School INTO a PRISON?

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c) LACK OF STUDENT ACTIVITIES – i.e. Organizations, Social Events,
Recreational Activities, etc.
d) Advised that there will be NO GAMES (Home) for Football! Such a decision
which CLEARLY UNDERMINES Funding as Revenue for the City of Port Gibson
but appears to be a part of the Baker Donelson Bearman Caldwell & Berkowitz
PLAN as Legal Counsel for the Governor of the State of Mississippi Phil Bryant –
i.e. the firm it appears BEHIND the scenes ACTUALLY DRAFTING Legislation as
it relates to Education, etc. and is CRAFTLY DRAFTED for purposes of
ADVERSELY IMPACTING School Districts with a HIGH African-American/Black
population! Not only that CRAFTLY using the MARKETING System for purposes
UNDERMINING and INFLUENCING ENROLLMENT for purposes of MASKING
Racists/Ku Klux Klan Acts for purposes of CAUSING REDUCTION in Enrollment
(i.e. EXPERIMENTING and CREATING situations for purposes of ADVERSELY
IMPACTING attendance) and then having FUNDINGS/MONIES WITHHELD
bringing about the DILAPIDATED conditions, BUILDING DECAY, DEMISE of
Infrastructure, etc.
e) Advised the following is needed in PREPARATION for the FIRST Football HOME
Game on AUGUST 21, 2015; however, is NOT limited to this list:
(1) Top Dress
(2) Fertilizer
(3) Water
(4) Filling Holes
(5) Sprinkler System – i.e. which has been BROKEN for
approximately TWO (2) YEARS!
This list appears to be a fairly SIMPLY request. Therefore, PLEASE ADVISE,
WHY these repairs WERE NOT MADE during the Summer Break?
Furthermore, WHY these repairs CANNOT be made PRIOR to the August 21,
2015 Opening Game? What is the CONDITION of the REMAINING Facility(s)
– i.e. Concession Stand, Restrooms, Stadium, etc.?
CAN THESE REPAIRS BE COMPLETED BY AUGUST
14, 2015? If not, WHY?
f) Advised the following is NEEDED IMMEDIATELY in the TRAINING of the Players
on the Football Team in PREPARATION for their games; however, is NOT limited
to this list:
(1) NEW Uniforms
(2) Knee Pads
(3) Thigh Pads

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(4) Gurdles
(5) Chin Straps
(6) Mouth Pieces
(7) Back Attachments & Shoulder Pads
(8) NEW WEIGHT ROOM EQUIPMENT – which can be obtained
(i) Double Half Racks
(ii) Padding For Floor In Weight Room

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This is the ONLY Public High School in Claiborne County.
WHY does it NOT have a STATE-OF-THE-ART Weight
Room/Fitness Room?

14. From my understanding, it takes NO TIME to
order and have the equipment needed delivered. Can the
REQUESTED Weight/Fitness Equipment be ORDERED and
DELIVERED before or by AUGUST 10, 2015?
Dr. Watkins, i n closing, 1 am also concerned that you and/or the
Claiborne County Public School District, your Legal Counsel and cohorts are
PREYING on the LACK of knowledge many Claiborne County Citizens may lack
as i t relates to PROTECTED rights that appear are being VIOLATED i n the
IMPLEMENTATION of the "SCHOOL-TO-PRISON PIPELINE" acts for purposes of
TARGETING and INCARCERATING African-Americans for FREE SLAVE LABOR!
With that being said, I DIRECT your attention to the United States
Department of Justice's August, 2012 Investigation:
JUSTICE XEVS
Department of Justice
Office of Public Affairs
FOR IMMEDIATE RELEASE Fnclijv'. August iO. 20 12
Justice Department Releases Iiivestigati Findings Showing Constitutional
Rights of Children in Mississippi Being Violated
Afrei- C o m p r e h e n s i v e e s t i g n t i o u . L i n i c l e i dnle C o i i n t y Y o u t h C o i i r t . M e r i d i a n Police D e p a r f m e n r
a u d :lississippi D i i s i o n o f Y o u t h Serices i n M e r i d i a n . M i s s i s s i p p i . F o u n d to H a v e d
C o n s t i t u t i o n a l D u e Process R i g h t s o f C h i l d r e n
A copy of which is attached hereto.
PLEASE BE ADVISED, that I reserve the right to amend this Complaint as
well as concerns shared. Should you have any questions or concerns, please do NOT
hesitate to contact me.
Sincerely,
Vogel Denise Newsome
P.O. Box 31265
Jackson, MS 39286
(601) 885-8145
Page 13 of 13

15. Justice Department Releases Investigative Findings Showing Constitution... http://www.justice.gov/opa/pr/justice-department-releases-investigative-f...
JUSTICE NEWS
Department of Justice
Office of Public Affairs
FOR IMMEDIATE RELEASE Friday, August 10, 2012
Justice Department Releases Investigative Findings Showing Constitutional
Rights of Children in Mississippi Being Violated
After Comprehensive Investigation, Lauderdale County Youth Court, Meridian Police Department
and Mississippi Division of Youth Services in Meridian, Mississippi, Found to Have Violated
Constitutional Due Process Rights of Children
The Justice Department released a letter of findings today determining that the Lauderdale County Youth Court, the
Meridian Police Department (MPD), and the Mississippi Division of Youth Services (DYS) are violating the
constitutional rights of juveniles in Meridian, Miss. The department's investigation found reasonable cause to believe
that these agencies have violated the constitutional due process rights of children in the city of Meridian and the
county of Lauderdale under the Fourth, Fifth, and Fourteenth Amendments of the U.S. Constitution.
The department initiated a comprehensive investigation in December 2011 under Section 14141 of the Violent Crime
Control and Law Enforcement Act of 1994, which prohibits a pattern or practice of deprivation of civil rights for
juveniles in the administration of juvenile justice, and Title VI of the Civil Rights Act of 1964, which prohibits
discrimination on the basis of race, color or national origin by recipients of federal financial assistance. The Justice
Department continues to investigate whether any of the agencies are violating children's rights under Title VI or the
Equal Protection Clause of the Fourteenth Amendment.
The department's investigation showed that the agencies have helped to operate a school-to-prison pipeline
whereby children arrested in local schools become entangled in a cycle of incarceration without substantive and
procedural protections required by the U.S. Constitution. The department's findings show that children in Lauderdale
County have been routinely and repeatedly incarcerated for allegedly committing school disciplinary infractions and
are punished disproportionately, without constitutionally required procedural safeguards. Children have also been
arrested at school for offenses as minor as defiance. Furthermore, children on probation are routinely arrested and
incarcerated for allegedly violating their probation by committing minor school infractions, such as dress code
violations, which result in suspensions. The department's investigation showed that students most affected by this
system are African-American children and children with disabilities.
"The systematic disregard for children's basic constitutional rights by agencies with a duty to protect and serve these
children betrays the public trust," said Thomas E. Perez, Assistant Attorney General for the Civil Rights Division. "We
hope to resolve the concerns outlined in our findings in a collaborative fashion, but we will not hesitate to take
appropriate legal action if necessary."
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16. Justice Department Releases Investigative Findings Showing Constitution... http://www.justice.gov/opa/pr/justice-department-releases-investigative-f...
In its investigation, the Justice Department found a pattern or practice of unconstitutional conduct in several areas,
including:
• Failure by MPD to adequately assess probable cause that an unlawful offense has been committed prior to
arresting children at local schools;
• Failure by the Lauderdale County Youth Court to provide children with proper procedural due process,
including by making untimely and inadequate probable cause determinations;
• Failure by the Lauderdale County Youth Court and the Mississippi DYS to provide children procedural due
process rights in the probationary process, especially with regard to alleged probation violations; and
• Failure by all entities to ensure substantive due process for children on probation by incarcerating children for
school disciplinary offenses without any procedural safeguards.
"The U.S. Attorney's Office is committed to seeing the rule of law applied to all citizens fairly and equally," said
Gregory Davis, U.S. Attorney for the Southern District of Mississippi. "We hope to be able to resolve the civil rights
violations found by the Justice Department in a way that benefits all the people of Meridian and Lauderdale County,
including those children who are being treated unfairly by the juvenile justice system."
This investigation was conducted by the Civil Rights Division's Special Litigation Section, working in conjunction with
the Educational Opportunities Section, which has a long-standing school desegregation case against the Meridian
Public School District, and the U.S. Attorney's Office for the Southern District of Mississippi. For more information on
the Justice Department's Civil Rights Division, please visit www.iustice.qov/crt.
Related Materials:
Letter of Findings
12-993 Civil Rights Division
Updated October 8, 2014
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