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May 2, 2019

To Whom it May Concern:

I am writing to file a complaint against Williams College for discrimination against Jewish students in
violation of Title VI and related Department of Education regulations.

My allegations, supported by an account in the Williams College student newspaper, available here, are as follows:

1. Williams College is an institution of higher education that receives federal funds, and is subject
to Title VI.
2. Williams College has a student government known as the College Council (hereinafter, CC).
3. As an official arm of the college, actions by the CC are covered by Title VI.
4. The CC has an official process by which to recognize new student groups as official registered
student organizations, or RSO.
5. In spring 2019 Jewish students at Williams sought official recognition as an RSO by the CC of a
group called Williams Initiative for Israel. The stated mission of the group “is to support Israel
and the pro-Israel campus community, as well as to educate the College on issues concerning
Israel and the Middle East.” The club also planned to hold events, including Jewish cultural
events and celebrations of Jewish and Israeli holidays.
6. Williams Initiative for Israel complied with all CC bylaws for recognition as an RSO.
7. No student organization that had applied for recognition as an RSO and complied with all CC
bylaws for recognition had failed to gain RSO status in over a decade.
8. The CC recognizes a student group known as Students for Justice in Palestine. The mission of this
group is to advocate for the Palestinian cause. It does so primarily by criticizing Israel. Thus, the
CC has no policy, formal or informal, against recognizing student groups that take positions on
foreign affairs in general, on the Middle East specifically, or on matters related to Israel or the
Israel-Palestinian conflict.
9. In the courses of debate over recognizing Williams Initiative for Israel, opponents of recognition
accused Israel of “genocide,” a charge so facially absurd and contrary to facts that it can only be
explained by antisemitism, and is resonant of historical blood libel. It also constitutes antisemitic
demonization of Israel, within the internationally accepted definition of antisemitism. Students
affiliated with Williams Initiative for Israel suggest an antisemitic undertone other comments
made by students opposed to recognition of their organization.
10. Williams CC voted on April 23, 2019 13-8 with one abstention against recognizing Williams
Initiative for Israel.
11. Contrary to usual practice, CC did not to publish a livestream for the April 23 meeting and
published meeting minutes without any speaker names in a document accessible only to
students and faculty with Williams email.
12. 92% of American Jews support Israel, and support for Israel is a bedrock platform of
mainstream Jewish organizations, including Hillel that serves Jewish students. Discriminating
against a student group organized by Jewish students for the purpose of supporting Israel
constitutes discrimination against Jewish students on the basis of ethnicity or race. The
antisemitic statements made in the course of the debate, as well as the unusual procedures
undertaken, provide evidence of anti-Jewish motive.
13. Refusal to recognize Williams Initiative for Israel as a recognized student organization on the
same terms as the CC has recognized dozens of other student groups constituted discrimination
against Jewish students at Williams on the basis of ethnicity or race. The continued non-
recognition of Williams Initiative for Israel constitutes ongoing discrimination against Jewish
students on the basis of ethnicity or race.
14. I request that the Office of Civil Rights investigate Williams for discrimination against Jewish
students on the basis of the above facts.

David Bernstein
3301 Fairfax Drive
Arlington, VA 22201