INSTITUTE FOR SCIENCE AND HUMAN VALUES, INC

Civil Rights/Civil Liberties

RE: Guidance Regarding Law Enforcement Response to Domestic Violence and Sexual Assault Dear Attorney General Lynch: We write to thank the Department of Justice for its commitment to addressing gender discrimination in policing1 and to urge the Department to issue, without delay, much-needed guidance outlining how flawed law enforcement responses to domestic violence and sexual assault can violate federal law and constitute police misconduct. The undersigned include 88 national groups and 98 state and local organizations that are dedicated to advancing civil and human rights, eliminating gender-based violence, and advocating for survivors. In light of the ongoing attention to policing reform, we believe that issuing guidance that addresses the context of domestic violence and sexual assault- which the Report of the Presidents Task Force on 21st Century Policing identified as necessitating a coordinated community and law enforcement response - will ensure that survivors are more fairly treated by the justice system. Re: Request for Guidance Reminding Schools of Obligations Under Title IX and Title VI to Address Sex- and Race-Based Harassment Occurring on Yik Yak and Other Anonymous Social Media Applications Dear Secretary Duncan and Assistant Secretary Lhamon: As an organization working to advance womens equality and civil rights, we are writing to request that the Office for Civil Rights (OCR) promptly issue guidance to universities and colleges reminding them of their legal obligations under Title IX of the Education Amendments of 1972 and Title VI of the Civil Rights Act of 1964 to protect students from harassment and threats based on sex, race, color, or national origin carried out via Yik Yak and other anonymous social media applications. Center for Faith-Based & Neighborhood Partnerships U.S. Department of Justice Washington, DC 20531 Attn: Eugene Schneeberg Submitted electronically at www.regulations.gov Re: Docket No. OAG 149, Partnerships With Faith-Based and Other Neighborhood Organizations --------------------------------------------- The following comments to the Notice of Proposed Rulemaking (NPRM) Partnerships With Faith-Based and Other Neighborhood Organizations1 are submitted by the undersigned members of the Coalition Against Religious Discrimination (CARD). We are pleased that Department of Justice (DOJ) has published this NPRM, which is an important step toward implementing Executive Order 13559. CARD members welcome these proposed regulations as an advancement that increases beneficiary protections and clarifies the roles and responsibilities of both the faith-based provider and the Agency when they partner to provide vital and necessary social services. Although these proposed regulations are a vast improvement over the current ones, we believe they can be further strengthened in several areas. Below you will find our comments and suggestions in the following areas: Clarifying prohibited uses of direct federal financial assistance; Assuring the religious liberty rights of the clients and beneficiaries of federally funded programs by strengthening appropriate protections; Stating more clearly the distinction between direct and indirect aid; Improving monitoring of constitutional, statutory, and regulatory requirements that accompany federal social service funds; and Ending taxpayer-funded employment discrimination. Director Jocelyn Samuels U.S. Department of Health and Human Services, Office for Civil Rights Re: Comments on Proposed Nondiscrimination in Health Programs and Activities Rule, RIN Number 0945-AA02 The Institute for Science and Human Values thanks you for the opportunity to comment on the proposed rule on Section 1557 (Section 1557) of the Patient Protection and Affordable Care Act (ACA), clarifying prohibited discrimination in health services and activities. As an organization that works to ensure young people have access to a full range of reproductive and sexual health services, we are especially concerned with the impacts of the rule on youth between the ages of 15 and 25. We appreciate the expanded protections for LGBTQ (lesbian, gay, bisexual, transgender, and queer or questioning) people, people who speak English as a second language, and people with disabilities. However, we ask the Department of Health and Human Services (HHS) to prioritize young people and LGBTQ youth in the new anti-discrimination rule. We urge HHS to strengthen language prohibiting discrimination based on sexual orientation, and to include young people in prohibited age discrimination. Furthermore, we ask that HHS recognize that religion should not be a basis to perpetuate discrimination. Director, Regulation Policy and Management (02REG) Department of Veterans Affairs 810 Vermont Ave. NW., Room 1068 Submitted electronically at www.regulations.gov Re: RIN 2900-AP05, Equal Protection of the Laws for Faith-Based and Community Organizations --------------------------------------------- The following comments to the Notice of Proposed Rulemaking (NPRM) Equal Protection of the Laws for Faith-Based and Community Organizations1 are submitted by the undersigned members of the Coalition Against Religious Discrimination (CARD). We are pleased that Department of Veterans Affairs (VA) has published this NPRM, which is an important step toward implementing Executive Order 13559. CARD members welcome these proposed regulations as an advancement that increases beneficiary protections and clarifies the roles and responsibilities of both the faith-based provider and the Agency when they partner to provide vital and necessary social services. Center for Faith-Based & Neighborhood Partnerships U.S. Department of Justice Washington, DC 20531 Submitted electronically at www.regulations.gov Re: Docket No. OAG 149, Partnerships With Faith-Based and Other Neighborhood Organizations --------------------------------------------- The following comments to the Notice of Proposed Rulemaking (NPRM) Partnerships With Faith-Based and Other Neighborhood Organizations1 are submitted by the undersigned members of the Coalition Against Religious Discrimination (CARD). We are pleased that Department of Justice (DOJ) has published this NPRM, which is an important step toward implementing Executive Order 13559. CARD members welcome these proposed regulations as an advancement that increases beneficiary protections and clarifies the roles and responsibilities of both the faith-based provider and the Agency when they partner to provide vital and necessary social services. U.S. Department of Agriculture 1400 Independence Avenue SW Washington, DC 20250 Attn: Norah Deluhery Submitted electronically at www.regulations.gov Re: RIN 0503-AA55, Equal Opportunity for Religious Organizations in USDA Programs: Implementation of E.O. 13559 --------------------------------------------- The following comments to the Notice of Proposed Rulemaking (NPRM) Equal Opportunity for Religious Organizations in USDA Programs: Implementation of E.O. 135591 are submitted by the undersigned members of the Coalition Against Religious Discrimination (CARD). We are pleased that United States Department of Agriculture (USDA) has published this NPRM, which is an important step toward implementing Executive Order 13559. Office for Civil Rights and Civil Liberties Department of Homeland Security 245 Murray Lane SW. Bldg. 410 Washington, DC 20528-0190 Attn: Scott Shuchart Submitted electronically at www.regulations.gov Re: DHS Docket No. DHS-2006-0065, Nondiscrimination in Matters Pertaining to Faith-Based Organizations --------------------------------------------- The following comments to the Notice of Proposed Rulemaking (NPRM) Nondiscrimination in Matters Pertaining to Faith-Based Organizations1 are submitted by the undersigned members of the Coalition Against Religious Discrimination (CARD). We are pleased that Department of Homeland Security (DHS) has published this NPRM, which is an important step toward implementing Executive Order 13559. CARD members welcome these proposed regulations as an advancement that increases beneficiary protections and clarifies the roles and responsibilities of both the faith-based provider and the Agency when they partner to provide vital and necessary social services. Regulations Division, Office of General Counsel Department of Housing and Urban Development 451 7th Street SW., Room 10276 Washington, DC 20410-0500 Submitted electronically at www.regulations.gov Re: Docket No. FR-5781-P-01, Equal Participation of Religious Organizations in HUD Programs and Activities: Implementation of EO 13559 --------------------------------------------- The following comments to the Notice of Proposed Rulemaking (NPRM) Equal Participation of Faith-Based Organizations in HUD Programs: Implementation of E.O. 135591 are submitted by the undersigned members of the Coalition Against Religious Discrimination (CARD). We are pleased that Department of Housing and Urban Development (HUD) has published this NPRM, which is an important step toward implementing Executive Order 13559. CARD members welcome these proposed regulations as an advancement that increases beneficiary protections and clarifies the roles and responsibilities of both the faith-based provider and the Agency when they partner to provide vital and necessary social services. U.S. Department of Labor Frances Perkins Building, 200 Constitution Ave. NW, Room C-2318 Washington, DC, 20210 Attn: Phil Tom Submitted electronically at www.regulations.gov Re: RIN: 1290-AA29, Equal Treatment in Department of Labor Programs for Faith-Based and Community Organizations; Protection of Religious Liberty of Department of Labor Social Service Providers and Beneficiaries --------------------------------------------- The following comments to the Notice of Proposed Rulemaking (NPRM) Equal Treatment in Department of Labor Programs for Faith-Based and Community Organizations; Protection of Religious Liberty of Department of Labor Social Service Providers and Beneficiaries1 are submitted by the undersigned members of the Coalition Against Religious Discrimination (CARD). U.S. Agency for International Development 1300 Pennsylvania Avenue NW. Washington, DC 20523 Attn: C. Eduardo Vargas Re: RIN: 0412-AA75, Amendment to "Participation by Religious Organizations in USAID Programs" to Implement Executive Order 13559 --------------------------------------------- The following comments to the Notice of Proposed Rulemaking (NPRM) Amendment To Participation by Religious Organizations in USAID Programs To Implement Executive Order 135591 are submitted by the undersigned members of the Coalition Against Religious Discrimination (CARD). We are pleased that the United States Agency for International Development (USAID) has published this NPRM, which is an important step toward implementing Executive Order 13559. CARD members welcome these proposed regulations as an advancement, insofar as they clarify that providers cannot discriminate against beneficiaries and set out the roles and responsibilities of both the faith-based provider and the Agency when they partner to provide vital and necessary social services.