Nearly all the interviewees identified discrimination – direct and systemic – as the main reason why the application of discipline in schools has a disproportionate impact on racial minority students and students with disabilities. Some interviewees also pointed out that there are multiple and intersecting grounds of discrimination, including race, disability, poverty and immigrant/refugee status.
A. General Perceptions
1. Black Students
Many Black students who are suspended or expelled believe that it is because of discrimination:
- A community worker at a social service organization that serves Caribbean and Black youth reports that discrimination is “usually the first thing that comes out of the kids’ mouths.”
- A social worker who works with at-risk youth in a high school has observed: “The students who I talk to feel it is discriminatory... The students who are from the groups that are being disproportionately impacted know what is happening.”
- A counsellor at a youth employment program states: “[The Black students] compare themselves to White students. A White student does the exact same thing and remains in school. But a Black student is either expelled or suspended for thirty to forty days.... If they get into an argument or something with a White student, the Black student is expelled, but the White student gets to stay in school.”
- A family services worker at a social service organization that serves the Caribbean and Black community notes that “Black children who are being picked on are being suspended after a fight, but the White children who did the picking on are not. Black children are being suspended for things that White children are not being suspended for. Black children feel that White children are not being disciplined in the same way.”
These comments are consistent with the study on the racial minority students’ perception of school disciplinary practices in Toronto, which was discussed earlier in this report.
Many Black parents also believe that discrimination plays a role, not only in the way Black children are treated, but also the way Black parents are treated. A specialist on race and ethnic relations at a school board in the GTA notes: “Some parents perceive outcomes as discriminatory since they have articulated that a two-tiered system exists whereby visible minority students are not treated in the same manner as students from the dominant culture when it comes to consequences for the same offense.” The chair of an organization of parents of Black children notes:
In many of these cases, the parents... will say it is racism. Most often, they will identify the problem behind it as racism. There are fights in school that some students claim originated in racial taunting.... There have been cases where the parents have complained that the White student had started it, but that student was not suspended. Or the parent might say, if the White student started it, why is my child suspended for the same length of time as the student who started it. They believe there is something behind the way their child is treated.
A counsellor at a youth employment program has noticed: “Sometimes the parents are treated in the same manner as the students. I have had parents tell me that they have gone down to the school to try to sort things out and are asked to leave in a rude manner.” A lawyer, who represents Black students, shares that observation:
[T]he parents are absolutely targetted. The kids will get slapped with a suspension, but the parents will get do-not-trespass notices and be themselves subject to fairly aggressive measures.... [The] underlying racist stereotyping by principals and teachers... crystallizes with the Black mother. All we have is someone trying to talk about what is happening. But it is immediately interpreted as violent, hysterical and threatening versus if [a White mother] came in and sounded like me – there would be room for dialogue.”
A lawyer at a legal clinic that serves the Black community has also observed that some parents have been given trespass orders when they try to advocate for their children and sometimes the school will even notify the Children’s Aid Society:
Another huge problem is that, if parents fight back by being assertive or non-cooperative, schools sometimes call the Children’s Aid Society. The school blames the parents for not disciplining the child properly. In four out of my six current files, CAS has been called. In all those cases, the CAS investigated, found no basis and the file was closed. In one case, the school wanted to have the child labelled as having attention deficit disorder, and put on medication, but the parent refused to cooperate, and CAS was called.
2. Tamil Students
The coordinator of a Tamil youth centre has observed that at certain schools in the GTA, if Tamil students get into a fight with another group, they will be suspended and the other group will not. He has noticed that this has happened at one school four or five times and it does not happen at all schools, only specific ones.
3. Aboriginal Students
There appears to be a perception that Aboriginal students are treated differently than other students in the application of discipline. A lawyer at a legal clinic that serves the Aboriginal community states that if an Aboriginal student gets into a fight with another student, “unless both students are Aboriginal, our experience is that the student who gets kicked out is the Aboriginal student.” An education policy analyst at First Nations organization in Northern Ontario reports that they see cases where students from different racial backgrounds commit the same offence, but the Aboriginal students are more harshly treated. For example:
Five students – two Aboriginal and three White students – were caught getting high on drugs together. Under the policy, they all should have been punished equally. But what happened was the two Aboriginal students were suspended for five days, one of the White students was suspended for three days and the other two students weren’t suspended at all. The school told the parents of the Aboriginal students that the two White students were not suspended because they came forward first.
4. Latino Students
A community worker at a legal clinic that serves the Latino community states that Latino parents believe that racism is causing their children to be disciplined because school administrators always take the word of a White student over a Latino student or a White student is shown more leniency for committing the same offence as a Latino student. For example:
In one case, a White student had attacked a Latino student. The Latino student’s parents wanted the White student to be suspended, but the school just said that everyone should calm down and things could be sorted out without a suspension. I never get calls from parents because the school wants to sort things out when a Latino student has done something wrong.
5. Students with Disabilities
Several interviewees believe that the Safe Schools Act facilitates discrimination against students with disabilities. A behaviour consultant for a school board in Northern Ontario reports that the Act has shifted protection away from the rights of special education students, who are a minority, to the rights of the majority of students:
A number of years ago, special education was geared towards the needs of the special education student. You now find that school administrators are saying that they have to think about the others. So the attention has shifted from the needs of the student to the needs of the larger group. So decisions, in order to meet the expectations of the Safe School Act, are geared to protect the majority rather than the individual needs of children.
He has also observed that the Act “really targets” students with emotional/behavioural disorders and “effectively excludes them from mainstream programs.” The executive director of a children’s mental health centre shares the view that the Act itself is discriminatory because it specifically targets students with emotional difficulties and learning disabilities. The coordinator of an advocacy group for students with disabilities also believes that students with disabilities, whether because they look differently or behave differently, attract attention and are treated differently under the Act.
B. Direct Discrimination
1. Black Students
Very few interviewees believe that intentional, direct discrimination against Black students is widespread, but some believe that it does occur. The executive director of legal clinic that serves children and youth states that there is some “genuine” racism around. A school board trustee states that “some teachers and educators are racist.” A lawyer, who represents students, believes that “by and large the racism is unconscious but for some it is a deliberate act.” A social worker who works with at-risk youth in a high school has the sense that there is both conscious and unconscious discrimination:
I have heard comments made about certain groups that sound discriminatory. When there is a policy like Safe Schools, I get worried about how the discretion is used. I don’t mean to sound totally negative. Generally, I think people are pretty caring and wanting students to do well. But certainly there are some decisions that are made that I have concerns about because it looks discriminatory to me.
A lawyer at a legal clinic that serves the Black community takes the position that even if the discrimination is unconscious, it is still direct discrimination: “It normally starts with a particular teacher. What we see is that Black children are not given a margin of error. There are teachers and principals who hold assumptions and stereotypes about Black children. It may be unconscious, but it operates at the level of expectation they have about Black boys. I see that as direct discrimination.”
Some interviewees point out that there are disciplinary rules on hair and clothing that are seen as specifically target Black students. A community worker at a social service organization that serves Caribbean and Black youth reports:
[Black students] feel that they are being singled out. They feel that some of the rules are being geared towards them. For example, there is a rule in [one high school’s] rulebook that says something like it is prohibited to put a comb or pick in your hair, or something like that. The students felt that it was definitely a Black thing, that they were being targetted as Black students because students of other races don’t put those things in their hair. Some of them were called on to follow this rule and felt it was so discriminatory against them.
A former equity advisor to a school board in the GTA states: “I don’t understand why schools focus on hats and what kids wear to school. At a forum on diversity, one person couldn’t keep her mind off baggy pants.... It is an irritant to teachers because it is seen as a form of resistance to school authority. The issue of being appropriately dressed does not come up as much for other [racial] groups.” A school board trustee complains that Black students are suspended for “wearing a bandana, which may be seen as belonging to a gang, without looking at the whole issue of North American pop culture and how kids are caught up in it.” A counsellor at a youth employment program provided a concrete example of a Black student who was suspended because of an amulet he was wearing:
There was an African student who was wearing something that the teacher felt was offensive to him, but the student felt it was his culture.... He was wearing an African outfit but it was the chain around his neck that the teacher found offensive, without understanding what it meant or caring to know what it meant. It was an African amulet and the teacher said that he found the symbol disturbing.
Tellingly, the coordinator of a Tamil youth centre reports that school administrators also complain about the hip hop clothing that Tamil youth wear.
There is also some suggestion that the disproportionate impact on Black students may be the result of being suspended for the more “subjective” offences, where there is greater leeway for racial stereotyping and bias to enter into the decision-making process. There are, in fact, studies in United States which show that the discipline of students of colour peaks in the most subjective categories such as “disturbing school” or “defiance or disrespect of authority”. The situation may be similar in Ontario. While many interviewees reported that Black students are getting suspended for fights or violence, an equally high number reported they are getting suspended for being disrespectful to the teacher or questioning authority, which are more subjective offences.
2. Students with Disabilities
Several interviewees take the position that the Safe Schools Act and Regulations provide principals and school boards with the means to directly discriminate against students with disabilities because they may suspend or expel a student for disability-related behaviour. A lawyer at a legal clinic that serves persons with disabilities puts it this way:
One, with respect to suspension and expulsion, [the Safe Schools Act] does not prohibit schools from suspending and expelling students with disabilities where the behaviour that is being impugned is related to the child’s disability. It does not forbid that. It says explicitly that a principal may suspend and expel in that situation. When the behaviour is directly related to the disability, it should be excusable, but the Safe Schools Act says that, even if it is, the principal may nevertheless proceed to suspend or expel them. That is direct discrimination on the basis of disability.... When somebody’s disability accounts for their behaviour, then suspending or expelling them for that behaviour, is suspending or expelling them because of their disability. The Human Rights Code very clearly says that suspending or expelling someone because of their disability is discriminatory. But the Safe Schools Act purports to legitimize those actions taken by a principal or a school board.
The school should be concerned about behaviours that nevertheless occur when the accommodations are present. It doesn’t make sense to punish a child for disability-related behaviours over which they have no control. There is no rationale that can be put forward for punishing a child in that situation. There is nothing that the child can be taught or learn in that situation. [Emphasis added]
He uses the example of a student with Tourette Syndrome:
I have heard the school board lawyers use the Tourette’s example ad nauseum to say that where a student has Tourette’s, and that explains the swearing, that would be a situation where you would not need to use the Safe Schools Act for a response. Nevertheless, the Safe Schools Act permits a principal to discipline a child with Tourette’s for swearing. There is nothing in the Act which prohibits it, whereas the Human Rights Code surely prohibits disciplining a child for that behaviour.
A lawyer at a community legal clinic northeast of the GTA states that the Ministry of Education and the school boards are “subscribing to the pre-Charter viewpoint that similarly situated people should be treated similarly. In the case of students, all students are similarly situated because they are students, and therefore they should be similarly treated.”
The executive director of a legal clinic that serves children and youth also takes the position that the Safe Schools Act and Regulations allow for direct discrimination:
[The] Regulations do not conform to the Human Rights Code. For example, it is a mandatory offence to swear at a teacher. In my view, under the Code, you cannot suspend a student with Tourette’s unless you have accommodated. The Regulations, however, do not speak about accommodation, they just say suspension is not mandatory. The Regulations are deeply flawed because they do not say that you cannot suspend unless you accommodate as required under the Human Rights Code. There are very few, if any, school principals who would look beyond the Regulations to the Code. It is, in fact, unfair to expect them to look at and figure out the overlay of different legal regimes.
She also believes that the failure to mandate reasonable accommodation inevitably leads to discrimination: “[I]t is discrimination to treat students identically. It is discrimination if you have not attempted to reasonably accommodate a student with a disability to the point of undue hardship.”
The executive director of an organization that serves people with Tourette Syndrome confirms that students with Tourette Syndrome who swear are being suspended:
Swearing is one [offence] that is totally misunderstood. I hear from parents about children with coprolalia being suspended for swearing. Coprolalia is the medical term for the utterance of profanity.... Coprolalia... [is] not directed. It comes in the middle of a sentence. It comes totally out of context. We need to get the message across that these utterances and gestures are not directed. It is very difficult for a teacher to have to explain that to the rest of the classroom. It is hard for the parent of a child in that classroom who is hearing about that. The parent would say it is not appropriate for my child to hear that. You have to sit down as reasonable adults and discuss and explain what is going on. Educators have to know what it really is.
A behaviour consultant for a school board in Northern Ontario has also come across such cases and observed that “[t]he principal has discretion so he decides that the swearing has nothing to do with Tourette’s and is willful swearing.”
C. Systemic Discrimination
1. Black Students
Most of the interviewees believe that systemic discrimination is the main factor leading to the disproportionate suspension and expulsion of Black students. There have been studies done in Toronto in the last two decades which show that Black students are disproportionately streamed into basic level and special needs classes and leave school earlier and drop out of school in disproportionate numbers. It is believed that the same systemic factors which lead to a disproportionate impact on Black students in these areas lead to a disproportionate impact on Black students in the area of suspensions and expulsions.
The chair of an organization of parents of Black children believes that there is a clear line between the systemic barriers in the education system and the suspension and expulsion of Black students:
My perception is that we have had to work so hard and lobby and advocate so hard because there are systemic barriers. We have been asking for structural and deep-rooted change so that we will have an education system that is inclusive and based on equity and anti-racism where all of our students will receive fair treatment and sit in school feeling that they are part of the environment. That they will see themselves reflected in the curriculum. We believe that much systemic change is needed. It seems to me that the suspensions and expulsions flow out of the stereotyping and low expectation of our students. It is all connected to racist assumptions. It is connected to how these students are perceived as the troublemakers in the class.
The executive director of a legal clinic that serves children and youth also sees a correlation between systemic discrimination and discipline:
There is systemic discrimination. Immigrant kids and kids with different cultural backgrounds are required, with other kids, to do screening tests in grade three. Those tests are designed for middle class White kids. The test results may not result in them being labelled as having a special education need, but they are perceived to have a lower IQ and there are lower expectations for them... All this leads to lower self esteem which in turn leads to more misbehaviour which in turn leads to suspension and expulsion which in turn leads to dropping out of school.
A lawyer at a legal clinic that serves the Black community has observed that schools never ask whether systemic factors are causing a student to misbehave:
The systemic nature of it is that the majority of teachers and principals are White and the curriculum is not inclusive. That can have an impact in terms of the students’ connection to school and engagement with school. If a Black student is affected by that, and then begins to act out, that is not considered. It is not looked at as an underlying reason for the behaviour. The emphasis is only on the student’s behaviour and there is no look at what is causing it.
The course director in the faculty of education of an Ontario university explains that this is because the Safe Schools Act and zero tolerance policies reflect the archaic notion that equity means treating everyone the same:
I think that systemic issues allow the individual principal and teacher to act on their stereotypes as opposed to confronting their stereotypes. No one would ever say that they suspend because of colour or race, but they don’t spend time consciously thinking about why so many of the students who are getting in trouble and coming to the office are Black. They take the attitude that everyone is treated the same way, so they never ask critical questions. By never looking at why some of those things are happening, you are, in fact, perpetuating the inequality.
2. Aboriginal Students
The interviewees identified systemic factors as the cause of the disproportionate impact on Aboriginal students. A youth court worker at a legal clinic that serves the Aboriginal community states that the Safe Schools Act fails to incorporate an Aboriginal perspective: “[I]t is punitive, while from an Aboriginal perspective, it should be more of a collective decision. The vice-principal or whoever is in charge puts the onus on the young person. It is not collective at all and makes no sense from an Aboriginal perspective. Aboriginal kids are used to a community response.”
3. Students with Disabilities
Several interviewees identified a history of failure to accommodate students with disabilities within the school system in Ontario as the major systemic factor which leads to the disproportionate application of suspensions and expulsions. Furthermore, some believe that the Safe Schools Act entrenches the failure to accommodate because it provides schools and school boards with another means of excluding students.
The coordinator of an advocacy group for students with disabilities has observed that “[student with disabilities] have been forced to be segregated for years because they haven’t been getting... the accommodation they required.” While the legal requirement to accommodate students in regular classes has become stronger over the years, “now [principals] have the Safe Schools Act as another tool... another way of saying your kid can be here, but I can send him out if things go wrong.” A behaviour consultant for a school board in Northern Ontario has also observed that the Act is used as a “veiled threat”: “[M]any principals impose ‘informal’ suspensions, where parents are pressured to keep their child at home. It is a coercive relationship between school officials and the parents.”
A lawyer at a legal clinic that serves persons with disabilities has noticed that schools never see their failure to accommodate as a cause of the behaviour that leads to suspension or expulsion:
The schools never seem to have look at what happened and ask themselves whether their failure to accommodate is actually one of the causative factors related to the impugned behaviour. What they end out doing when they don’t provide the accommodation is they are acting in a way which helps to cause the behaviour which they then use to justify the use of the suspension or expulsion provisions of the Safe Schools Act.
4. Cuts in Resources
Some interviewees believe that the cuts in support for students that have been made concurrently with the implementation of zero tolerance policies for misbehaviour are exacerbating the impact on students at-risk. Since 2001, due to budget constraints, the TDSB has been forced to significantly reduce or eliminate, among others, Safe Schools Advisors, Community Advisors, Youth Counsellors, Attendance Counsellors and Social Workers. Significant cuts were also made between 1998-2001. A school board trustee believes that the confluence of the Safe Schools Act and the cuts have created the following trajectory:
As resources have shrunk, those students who are at-risk become more at-risk. Because when there is less support generally, it is going to be the kids who need that support most who are most at-risk. And then you have a policy which focuses on punishment rather than prevention, which is what the Safe Schools Act does. It doesn’t say to a principal that if a child exhibits these behaviours, then this is the program that the child needs to go into. It says that if the child exhibits these behaviours, you get to boot him or her out.
A social worker who works with at-risk youth in a high school believes that the higher suspension rate can at least partly be explained by the loss of supports in the school system: “It is symptomatic of the cuts to the system. There hasn’t been enough resources in special education departments for quite some time, so I don’t know if it is just the recent cuts. The teachers are feeling quite stressed and the schools don’t know what else to do, so they suspend the students.”
A senior official at a school board in the GTA does not see a direct relationship between the cuts in services and the increase in suspensions and expulsions, but believes that the cuts have diminished the ability of schools to assist students at-risk: “I would certainly make the comment that schools and principals are under stress in order to work with students and families who are in crisis or need supportive intervention. I don’t think some of the cuts are helping that.”
The coordinator of a Tamil youth centre believes that the cuts have clearly exacerbated the impact of suspensions and expulsions on Tamil students:
Three years ago, the Toronto District School Board had at least four or five Tamil staff as support staff, whether as school board counsellors or youth outreach workers. Right now, the number of Tamil support staff doing that kind of work at the Toronto Board is zero. Two of them were guidance counsellors who were brought in to assist in situations involving Tamil students or families because of language barriers and so on. One was a youth outreach worker. To us, that was the biggest loss because that person was directly involved in suspensions and expulsions.... Whenever there was a twenty-day suspension, the youth outreach worker was involved. They helped them get into a new school, worked with the student at the new school and ensured that they finished the year properly. Now, that’s not the way it happens. The Safe Schools protocol transfers them to a new school, but with no support. They are left out to dry.
D. Multiple and Intersecting Grounds of Discrimination
As has been discussed elsewhere in this paper, there are studies which show that Black students are disproportionately represented in special needs classes. It would therefore be a logical inference that suspensions and expulsions would impact even more heavily on Black students in special needs classes. Moreover, other factors such as poverty and immigrant/refugee status may further compound the impact.
A significant number of interviewees do, in fact, believe that other factors, such as being poor or an immigrant or refugee, are significant causative factors, which at the very least exacerbate the impact on racial minority students. A policy analyst at a legal clinic that serves the Black community believes that, while other factors are important, for Black students, race is the overriding factor:
The impact is very layered. It is tempered by accent, nationality, class and gender. All those things come into play, but the underlying issue is what it means to be Black. For example, Somali kids may have a rough time because of their accent, but kids whose family has been here for generations also have a rough time. Racism is filtered through all these experiences. I work both with kids who were born here and are immigrants. It seems to cut across the board. All Black kids experience racism in schools. It cuts across class lines. I have been to private schools. The Act doesn’t extend to private schools, but Black kids still face these problems. We still see a lot of the same stereotypes and problems. Class may provide some cushion but it doesn’t protect you from racism.
There are, in fact, multivariate studies in the United States which show that, even after controlling for socio-economic background, there continues to be an overrepresentation of Black students in suspensions.
Other interviewees, however, believe that other factors such as poverty or immigration status are as important causative factors as race. A school board trustee states: “I think other factors, such as being poor or an immigrant, are huge... There are multiple biases in the system.” A family services worker at a social service organization that serves the Caribbean and Black community has observed:
I find that when children come to Canada, they are having difficulties because the issue of reunification with the culture and adjustment is not being addressed. What I see is that a child may go to school with several different problems – economic and social – and when a behavioural issue comes up, it is seen as strange, and time is not taken out to understand what is going on.... My perception is that there are racial biases. It is worse if you are in the social welfare system. A child who is known to be from a poor, Black, immigrant background is more targetted because of socio-economic status.
The chair of a Muslim social service organization, which is located in a multiracial, low-income community, believes that immigrant parents, especially if they are poor, are often less successful in advocating for their children, which compounds the disproportionate impact on a Black student:
In one case that was reported to me by a parent, a Black kid and a White kid were in a fight, but the White kid was allowed back in school before the Black kid, even though the White kid initiated the fight. I would speculate that the White parent is much more articulate than the immigrant parent who doesn’t understand the system. The more you know the system, the better they treat you. The vast majority of kids who are suspended have parents who don’t know the system. That is a major reason why there is this disparity. The inability of immigrant parents to advocate for their children.
The executive director of a Somali social service organization has found that school administrators often fail to take the refugee background of Somali students into account when applying discipline for misbehaviour:
The teachers follow policies which are supposed to apply to kids in normal situations. We have situations where a Somali kid is not acting normally because the kid has come through refugee camps.... We tell the educators that the kids are not acting in a normal way because of the situation they have been in. I show them photographs from Somalia of a child running in the same direction as American soldiers who are firing guns, a child holding a gun and children looking at dead bodies. I try to tell the educators that when they apply the policies they should remember that this is where Somali kids are coming from.
He has also observed that some Somali parents believe that there is a triple impact on them: “A lot of the parents are telling us that it has to do with colour and background. Some parents were telling us that we are Black, we are immigrants and Muslims, which means we have three strikes against us.”
 Supra note 160 at 1.
 Supra note 167 at 3.
 Supra note 11 at 1.
 Supra note 127 at 2.
 Supra note 116.
 Supra note 128 at 1.
 Supra note 30 at 3.
 Supra note 11 at 1.
 Supra note 151, 11 April 2003, at 1-2.
 Supra note 13 at 2.
 Supra note 17 at 2.
 Supra note 132 at 1.
 Supra note 15 at 1.
 Supra note 133 at 1-2.
 Supra note 19, 13 May 2003, at 2.
 Ibid. at 1.
 Supra note 29 at 2.
 Supra note 142 at 4.
 Supra note 129 at 3.
 Supra note 12 at 2.
 Supra note 151, 11 April 2003, at 3.
 Supra note 167 at 3.
 Supra note 13 at 2.
 Supra note 160 at 1.
 Interview, 17 April 2003, 2.
 Supra note 12 at 3.
 Supra note 11 at 2.
 Supra note 17 at 3.
 Opportunities Suspended, supra note 90 at 7-8; K. Carrillo, “Suspend Negative Behaviours, not Students who Perform Them,” Albuquerque Journal, 20 December 2001. See Appendix I, Tab 33. Online at: http://www.abqjournal.com/opinion/guest_columns/guest12-20-01.htm.
 Education Act, supra note 42 at ss. 306(5) and 309(3); Ontario Regulation 106/01, s. 1; Ontario Regulation 37/01, s. 2.
 Interview, 10 April 2003, 2.
 Ibid. at 5.
 Supra note 18 at 6.
 Supra note 129 at 5.
 Ibid. at 3.
 Supra note 19, 14 May 2003, at 2.
 Ibid., 13 May 2003, at 2.
 See e.g. S. Larter, S., Draffin, S., Power, M., & M. Cheng, Identification, placement and review process: Parent's/Guardian's opinions (Report # 179) (Toronto: The Board of Education for the City of Toronto, Information Services Division, 1986); M. Cheng Tsuji, G., Yau, M., & S. Ziegler, The every secondary student survey, Fall 1987 (Report # 191) (Toronto: Research Section, Toronto Board of Education, 1989); M. Cheng, Yau, M., & S. Ziegler, The 1991 every secondary student survey, part II: Detailed profiles of Toronto’s secondary school students (Report #204) (Toronto: Research Services, Toronto Board of Education, 1993); G. Dei,., Mazzuca, J., McIsaac E., & R. Campbell, Drop-Out or Push Out? The Dynamics of Black Students Disengagement from School (Toronto: University of Toronto Press, 1995); K. Braithwaite, & C. James (eds.), Educating African Canadians (Toronto: James Lorimer, 1996); Dei, G., Mazzuca J., McIsaac, E., & J. Zine, Reconstructing “Drop-Out”: A Critical Ethnography of the Dynamics of Black Students Disengagement from School (Toronto: University of Toronto Press, 1997).
 For example, a lawyer who represents students states: “[I]n the same way that Black kids have been streamed historically into technical schools because of the belief that that is where they properly belong, those same attitudes affect disciplinary issues.” Supra note 151, 24 April 2003, at 2.
 Supra note 30 at 3.
 Supra note 129 at 3.
 Supra note 13 at 2.
 Supra note 130 at 2-3.
 Interview, 3 April 2003, 2.
 Supra note 142 at 3.
 Supra note 19, 13 May 2003, at 2.
 Supra note 208 at p. 5.
 Under the provincial government’s education funding formula, the Toronto District School Board has been forced to make $418 million in cuts since 1998. TDSB, The Real Costs of Public Education (Toronto: TDSB, 2001-2002), 1; TDSB, Minutes, Committee of the Whole (Private Session), Report No. 14, 4 May 2001, 454; TDSB Supervisor, Highlights of Cost Saving Management Plan, (Toronto: TDSB, 2002-2003).
 Supra note 146 at 2.
 Supra note 167 at 2-3.
 Supra note 2, 14 May 2003, at 7.
 Supra note 17 at 2, 4.
 Supra note 215.
 Interview, 3 March 2003, 2.
 R.J. Skiba, & R. Peterson, “The Dark Side of Zero Tolerance: Can Punishment Lead to Safe Schools?” (1999) 80(5) Phi Delta Kappan, 80(5), 372-382. See Appendix I, Tab 32. Online at: http://www.pdkintl.org/kappan/kski9901.htm.
 Supra note 146 at 2.
 Supra note 127 at 1-2.
 Supra note 14 at 3.
 Supra note 126 at 1.
 Ibid. at 1.