THE EQUAL PROTECTION PROJECT

A Project of the Legal Insurrection Foundation

18 MAPLE AVE. #280
BARRINGTON, RI 02806
www.EqualProtect.org

August 19, 2024

BY EMAIL (OCR.Chicago@ed.gov)

Adele Rapport
Regional Director
U. S. Department of Education
Office for Civil Rights – Region V
230 S. Dearborn Street, 37th Floor
Chicago, IL 60604

Re: Civil Rights Complaint Against University of Illinois Urbana-Champaign

Regarding 42 Discriminatory Scholarships

Dear Ms. Rapport:

This is a federal civil rights complaint submitted pursuant to the U.S. Department of
Education’s Office for Civil Rights (“OCR”) discrimination complaint resolution procedures. 1 We
write on behalf of the Equal Protection Project of the Legal Insurrection Foundation, a non-profit
entity that, among other things, seeks to ensure equal protection under the law and non-
discrimination by the government and by recipients of government funds, and that opposes racial
and unlawful sex discrimination in any form.

1
See 42 U.S.C. § 2000d-1; 34 C.F.R. §§ 100.7, 100.8, and 100.9.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-Champaign)
August 19, 2024
Page 2 of 16

We write in connection with the University of Illinois Urbana-Champaign (UIUC) for

illegal sex-based and race-based discrimination in violation of Title IX and Title VI, respectively.
Specifically, UIUC offers, administers, and promotes 42 scholarships that discriminate based on
race, sex, or both. Details of UIUC’s discrimination are provided below in three sections that
include links to the relevant websites for each scholarship.

I. Title IX Violations (19) – Eight scholarships are offered exclusively to female students,
eight state a preference for female students, two are offered exclusively to male students,
and one states a preference for male students.

II. Title VI Violations (19) – These 19 scholarships are all offered exclusively or with a
stated preference for various groups based on race, color, or national origin including
students from underrepresented populations, students who are historically
underrepresented, students from minority groups, and students from various ethnic groups
or national origins including Czech, Lithuanian, Japanese, Latina/Latino, Iranian.

III. Title IX and Title VI (4) – These four scholarships discriminate based on both sex and
race either exclusively, e.g., eligibility is restricted to a male minority freshman, or with a
stated race/sex preference, e.g., minorities or women preferred.

In violation of Title XI and/or Title VI, each of UIUC’s 42 scholarships below illegally
discriminates based on sex, race, or both. Given the vast array of discriminatory scholarships, it is
clear that UIUC has a systemic non-compliance with federal civil rights laws. We request that OCR
investigate UIUC for the multiple violations of federal civil rights laws (Title IX and Title VI) as
set out below, and impose remedial and other relief

Legal Provisions
We summarize below the applicable law that governs the discriminatory scholarships
detailed later in this Complaint.
Title VI – Unlawful Racial Discrimination
UIUC violates Title VI by conditioning eligibility for or providing preferential treatment
for the scholarships listed below based on a student’s race,color or national origin. Title VI
prohibits intentional discrimination based on race, color or national origin in any “program or
activity” that receives federal financial assistance. See 42 U.S.C. § 2000d. The term “program or
activity” means “all of the operations . . . of a college, university, or other postsecondary institution,
or a public system of higher education.” See 42 U.S.C. § 2000d-4a(2)(A); Rowles v. Curators of
the Univ. of Mo., 983 F.3d 345, 355 (8th Cir. 2020) (“Title VI prohibits discrimination on the basis
of race in federally funded programs,” and thus applies to universities receiving federal financial
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-Champaign)
August 19, 2024
Page 3 of 16

assistance). UIUC receives and administers federal funds through numerous programs. 2 As UIUC
is a public institution, it is also subject to Title VI. 3
As you know, in Students for Fair Admissions Inc. v. President & Fellows of Harv. Coll.,
600 U.S. 181 (2023), the Supreme Court declared that “[e]liminating racial discrimination means
eliminating all of it …. The guarantee of equal protection cannot mean one thing when applied to
one individual and something else when applied to a person of another color. If both are not
accorded the same protection, then it is not equal.” Id. at 34 (cleaned up). “Distinctions between
citizens solely because of their ancestry [including race] are by their very nature odious to a free
people whose institutions are founded upon the doctrine of equality.” Id. at 35.

In discrimination cases, it does not matter if a recipient of federal funding discriminates to

advance a benign “intention” or “motivation.” See, Bostock v. Clayton Cty., 590 U.S. 644, 661
(2020) (“Intentionally burning down a neighbor’s house is arson, even if the perpetrator’s ultimate
intention (or motivation) is only to improve the view.”) “Nor does it matter if the recipient
discriminates against an individual member of a protected class with the idea that doing so might
favor the interests of that class as a whole or otherwise promote equality at the group level.”
Students for Fair Admissions, 600 U.S. 289 (Gorsuch, J., concurring). And, irrespective of whether
a program’s classifications based on immutable characteristics further a compelling interest, a race-

2
See, e.g., UIUC website, Office of Student Financial Aid, “Federal Pell Grant,” found at
https://osfa.illinois.edu/types-of-aid/grants/federal-pell-grant.; id., “Federal Supplemental
Educational Opportunity Grant (FSEOG),” found at https://osfa.illinois.edu/types-of-
aid/grants/federal-supplemental-educational-opportunity-grant-fseog/.
3
Although your office does not enforce Title II of the Civil Rights Act of 1964, that statute
makes it unlawful to discriminate based on race or color in a place of “public accommodation”
such as UIUC 42 U.S.C. § 2000(a)(a).
These scholarships also violate the Illinois Human Rights Act, which prohibits the “denial or
refusal of full and equal enjoyment of facilities, goods, or services” in any “secondary,
undergraduate, or postgraduate school, or other place of education.” 775 ILCS 5/5-101 ff.
Finally, these scholarships defy UIUC’s own non-discrimination policy, which states, “The
University of Illinois System will not engage in discrimination or harassment against any person
because of race, color, religion, sex, national origin, ancestry, age, marital status, order of
protection status, genetic information, disability, pregnancy, sexual orientation including gender
identity, unfavorable discharge from the military or status as a protected veteran and will comply
with all federal and state nondiscrimination, equal opportunity and affirmative action laws,
orders and regulations. This nondiscrimination policy applies to admissions, employment, access
to and treatment in the programs and activities of the University of Illinois System.” See,
https://www.bot.uillinois.edu/governance/nondiscrimination; archived at
https://web.archive.org/web/20240816013857/https://www.bot.uillinois.edu/governance/nondiscr
imination.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-Champaign)
August 19, 2024
Page 4 of 16

conscious program must be based on “individualized consideration,” and race must be used in a
“nonmechanical way.” Grutter v. Bollinger, 539 U.S. 306, 334 (2003).

Because UIUC is a public institution, its creation, sponsorship or promotion of

discriminatory scholarships also violates the Equal Protection Clause of the Fourteenth
Amendment. Any exception to the Constitution’s demand for equal protection must survive the
constitutional test of strict scrutiny, and the scholarships at issue here flunk that exacting test.

For these reasons, UIUC’s racial requirements for the scholarships set out below violate
federal and state civil rights statutes and constitutional equal protection guarantees.

Title IX – Unlawful Sex Discrimination

Title IX makes it unlawful to discriminate based on sex in education. That statute provides
that “[n]o person in the United States shall, on the basis of sex, be excluded from participation in,
be denied the benefits of, or be subjected to discrimination under any education program or activity
receiving Federal financial assistance.” 20 U.S.C. §1681(a). For this reason, a school receiving
federal funding may not administer scholarships, fellowships or other forms of financial assistance
that impose a preference or restriction based on sex, with limited exceptions not applicable here.
34 C.F.R. § 106.37(a).

Here, the sex-based eligibility criteria for participation in the discriminatory scholarships
listed below are, by their terms, plain: If applicants do not meet the blunt sex requirements
described in their respective eligibility criteria, they are not eligible for these scholarships. UIUC’s
sex discrimination concerning these programs is unlawful.

Irrespective of whether the scholarships’ classifications based on immutable characteristics

further a compelling interest, a discriminatory program must be based on “individualized
consideration,” and the criterion must be used in a “nonmechanical way.” Grutter v. Bollinger,
539 U.S. 306, 334 (2003). Concerning Title IX in particular, OCR has stated that a school may not
justify discrimination for purposes of addressing an “imbalance” in participation by relying on
national statistics of limited participation in a discriminatory program. Rather, it “must instead
clearly articulate why the particular sex-based scholarship or program was necessary to overcome
the conditions in its own education program or activity which resulted in limited participation
therein.” 4

Here, the sex-based eligibility criterion is, by its terms, applied mechanically, and without
any statistical justification warranted by any alleged past discrimination by UIUC. Because
UIUC’s gender requirements for these scholarships are presumptively invalid, and because there

4
OCR “Questions and Answers Regarding OCR’s Interpretation of Title IX and Single Sex
Scholarships, Clubs, and other Programs,” January 14, 2021, at 4 (found at https://www2.ed.gov
/about/offices/list/ocr/docs/qa-single-sex-20210114.pdf) (emphasis in original).
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-Champaign)
August 19, 2024
Page 5 of 16

is no legal justification for such invidious discrimination, UIUC’s use of such criteria violates
federal civil rights statutes.

Breakdown of Discriminatory UIUC Scholarships

We list below each of the 42 discriminatory scholarships, with links to information about
the scholarships on UIUC’s own website, and specification of the awarding department and a
description of the scholarship where available.

I. Sex Discrimination - Title IX Violations (19)

1) A.E. Florio Award

Awarding Department: College of Applied Health Sciences
“Awarded to undergraduate community health students studying health education . . . For
2024, one $1,500 award will be given.” 5
Eligibility: “Preference is given to women” 6

2) Allen John Kreitzer Jr Scholarship

Awarding Department: College of Business Administration
Eligibility: Preference to males 7

3) Mary Chow Scholarship

Awarding Department: College of Engineering
“Sophomore, based on freshman year performance; Outstanding female; Renewable
through senior year – must remain in good academic standing” 8

5
See, https://ahs.illinois.edu/kinesiology/awards-and-scholarships; archived at
https://web.archive.org/web/20240816181742/https://ahs.illinois.edu/kinesiology/awards-and-
scholarships.
6
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=322; archived at
https://web.archive.org/web/20240816154054/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=322
7
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=58, archived at
https://web.archive.org/web/20240816153745/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=58.
8
See; https://ise.illinois.edu/undergraduate/resources/scholarships/mary-chow-scholarship,
archived at
https://web.archive.org/web/20240816182032/https://ise.illinois.edu/undergraduate/resources/sch
olarships/mary-chow-scholarship.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 6 of 16

4) Roxanne J. Decyk Fellowship

Awarding Department: College of Liberal Arts and Sciences 9
Eligibility: 1st-year female graduate student 10

5) D.A. Decyk Fellowship

Awarding Department: College of Liberal Arts and Sciences
“1st year female graduate student; good academic.” 11

6) E H Schroeder Graduate Award

Awarding Department: College of Agricultural, Consumer and Environmental Sciences
“Shall be used to provide fellowships to female graduate students enrolled in the
Department of Human and Community Development in ACES. Fellowships shall be
awarded based upon academic merit and professional promise.” 12

7) Patricia C. Hammaker Scholarship

Awarding Department: Office of Student Financial Aid
“This scholarship should be awarded to a female student working her way through
college.” 13

8) Harry Fredrickson Memorial Scholarship

Awarding Department: College of Agricultural, Consumer and Environmental Sciences
“Award for student with a farm background studying in an agricultural curriculum.” 14
Eligibility: First preference is given to female student 15

9
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=979, archived at
https://web.archive.org/web/20240816182226/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=979.
10
Id.
11
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=980, archived at
https://web.archive.org/web/20240816182253/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=980.
12
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=692, archived at
https://web.archive.org/web/20240816182327/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=692.
13
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1425, archived at
https://web.archive.org/web/20240816182426/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1425.
14
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=603, archived at
https://web.archive.org/web/20240816182439/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=603.
15
Id.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 7 of 16

9) M&IE Stoecker Scholarship

Awarding Department: College of Engineering Mechanical and Industrial Engineering”
“Mechanical and Industrial Engineering major is preferred” 16
Eligibility: “Preference for out-of-state female students 17

10) Mary Sparks Alley Scholarship

Awarding Department: College of Business Administration
Eligibility: Preference for Women 18

11) Nadia S. Chowdhury Memorial Scholarship Fund

Awarding Department: Office of Student Financial Aid
“Equal consideration shall be given to students enrolled in the College of Liberal Arts and
Sciences, in the College of Business majoring in accounting and/or a focus on studies for
global economic growth and development, and students enrolled in the College Applied
Health Sciences students majoring in the Community Health field.” 19
Eligibility: “Preference shall be made to female students with a multicultural heritage.. ” 20

12) Calvin B. M. Niccolls Scholarship

Awarding Department: College of Engineering
“Male; Financial need required; Academic Merit” 21

13) Oakley Scholarship

Awarding Department: College of Engineering - Electrical and Computer Engineering

16
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=463, archived at
https://web.archive.org/web/20240816182801/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=463.
17
Id.
18
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=126, archived at
https://web.archive.org/web/20240816182832/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=126.
19
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1509, archived at
https://web.archive.org/web/20240816182942/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1509.
20
Id.
21
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=450, archived at
https://archive.ph/fsXYz.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 8 of 16

“This scholarship is used to recognize and reward outstanding sophomores in the Electrical
and Computer Engineering Department who have been active in outside activities.” 22
Eligibility: Preference for females 23

14) Juanita D Perel Fellowship

Awarding Department: College of Liberal Arts and Sciences – Chemistry
“[E]ndowed fund” 24
Eligibility: Woman chemistry doctoral student.

15) Mary E Ramier Scholarship

Awarding Department: College of Liberal Arts and Sciences – Women's Studies
“Award used for enhancing education of undergraduate women in terms of research
support, conference travel, etc.” 25

16) Richert Scholarship

Awarding Department: Office of Student Financial Aid
“Eligible undergraduate students shall be enrolled at the University of Illinois Urbana-
Champaign and demonstrate financial need. Preference shall be made to female students
...”

17) ROTC Leadership Scholarship

Awarding Department: Reserve Officers Training Corps
“Interview is required by applicant; Student should be a Woman Cadet”

18) Earl Voodry Scholarship

Awarding Department: Office of Student Financial Aid

22
See, https://ece.illinois.edu/academics/ugrad/scholarships-and-awards/scholarships/oakley,
archived at
https://web.archive.org/web/20240816183535/https://ece.illinois.edu/academics/ugrad/scholarshi
ps-and-awards/scholarships/oakley.
23
See, id,; https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=384, archived at
https://web.archive.org/web/20240816183825/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=384.
24
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1186, archived at
https://web.archive.org/web/20240816183848/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1186.
25
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1205, archived at
https://web.archive.org/web/20240816184019/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1205.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 9 of 16

“Awarded to male students with demonstrated financial need.” 26

19) T A Nicastro Scholarship

Awarding Department: Office of Student Financial Aid
“This fund was created to support undergraduate female students majoring in Economics
who are enrolled at the University of Illinois Urbana-Champaign. Eligible students must
demonstrate financial need.” 27

II. Race, Color, and National Origin Discrimination - Title VI Violations (19)

20) Wanda T. Babcock Scholarship

Awarding Department: College of Education
“Preference is given to College of Education graduate students from unrepresented28
populations pursuing a career in education to promote cultural diversity in the education
profession.” 29

21) W. Campfield Scholarship

Awarding Department: College of Business – Accountancy

26
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1452, archived at
https://web.archive.org/web/20240816184152/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1452.
27
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=6149, archived at
https://web.archive.org/web/20240816184127/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=6149.
28
“Underrepresented includes Black, Hispanic, and American Indian, Native Hawaiian/Other
Pacific Islander, and multi-racial students.” University of Illinois | University Office for Planning
and Budgeting website, “Board Trustees Performance Metrics – Student Recruitment and
Enrollment; Percent of All Students from Underrepresented Groups.” Found at
https://www.pb.uillinois.edu/reports-public/bot-performance-metrics/student-recruit-
enroll.cfm?midbuttonID=midbutton2&metricbuttonID=metricbutton1&submetricbuttonID=sub
metricbutton2. See also, Students for Fair Admissions, supra, 600 U.S. at 223 (rejecting
“underrepresentation” rationale for discrimination because “outright racial balancing is patently
unconstitutional”).
29
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=884, archived at
https://web.archive.org/web/20240816184520/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=884.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 10 of 16

“Preference to minority 30 students; Accountancy major” 31

22) O. Sr. & M Capek Scholarship

Awarding Department: College of Engineering – Industrial & Enterprise Systems
Engineering
“Given equal merit, preference to students of Czech descent; Academic Merit” 32

23) Chancellor's Access Grant

Awarding Department: Office of Student Financial Aid
“The Chancellor’s Access Grant is a 4-year renewable scholarship awarded to Illinois
residents from historically under-represented groups. Students must make satisfactory
academic progress, show financial need, maintain Illinois residency, and maintain
continuous full time enrollment for renewal.” 33

24) Dockins-Baxter Scholarship

Awarding Department: College of Business Administration
“Accountancy majors; Prefer diverse 34 students” 35

25) Dr. Kazys Grinius Scholarship

Awarding Department: Office of Student Financial Aid

30
“Minority” is a term with a well-understood meaning in civil rights law. See, e.g., 20
U.S.C.A. § 1067k (“The term ‘minority’ means American Indian, Alaskan Native, Black (not of
Hispanic origin), Hispanic (including persons of Mexican, Puerto Rican, Cuban, and Central or
South American origin), Pacific Islander or other ethnic group underrepresented in science and
engineering”).
31
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=2, archived at
https://web.archive.org/web/20240816184204/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=2.
32
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=443, archived at
https://web.archive.org/web/20240816184403/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=443.
33
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=10501, archived at
https://web.archive.org/web/20240816184546/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=10501.
34
“Diversity” is a term that is universally used to describe a result to be achieved by race-based
and other forms of unlawful discrimination. See, Students for Fair Admissions, 600 U.S. at 143.
35
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=89, archived at
https://web.archive.org/web/20240816184836/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=89.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 11 of 16

“The Dr. Kazys Grinius Endowment Scholarship was recently established to help fund the
education of University of Illinois students ‘of Lithuanian descent as well as to students
who have demonstrated interest in Lithuanian history, culture, and/or language.’ We will
award two $1200 scholarships for the 2013-2014 academic year.” 36,37

26) Earl Neal Scholarship

Awarding Department: Office of Student Financial Aid
“The scholarship was established in 2005 to honor Earl L. Neal. Neal had a prominent legal
career spanning 50 years in the Chicago area. . . . This scholarship is awarded to minority
Juniors or Seniors with preference to those in pre-law with a 3.2 GPA or higher. Need is
preferred.” 38

27) Emmons Scholarship

Awarding Department: Office of Student Financial Aid
“This fund was created to provide scholarships to undergraduate students who are enrolled
at the University of Illinois Urbana-Champaign and are sophomores and above. Preference
shall be made to students of Latino/Latina descent. Recipient(s) shall have obtained a
cumulative GPA of at least a 3.0.” 39

28) F G Erinkitola Memorial Scholarship

Awarding Department: College of Business – MBA
Eligibility: “1st year MBA student, minority” 40

29) Firdawsi Science Award

Awarding Department: Office of Student Financial Aid

36
See, https://publish.illinois.edu/educationadvising/2013/11/08/dr-kazys-grinius-endowment-
scholarship/, archived at
https://web.archive.org/web/20240816184856/https://publish.illinois.edu/educationadvising/2013
/11/08/dr-kazys-grinius-endowment-scholarship/ .
37
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1332, archived at
https://web.archive.org/web/20240816185105/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1332.
38
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1518, archived at
https://web.archive.org/web/20240816185112/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1518.
39
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=6023.
40
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=95, archived at
https://web.archive.org/web/20240816184927/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=95.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 12 of 16

“The Firdawsi Science scholarship is awarded to Iranian students at the graduate level
not currently residing as or intending to become permanent residents of the US. Candidates
are nominated by the Deans of LAS, Agriculture, and Engineering at UIUC and UIC and
chosen by a committee. The award is to be a supplement to an existing fellowship or TA or
other position where the recipient already receives a tuition waiver.” 41

30) Norman and Blanche Good Scholarship

Awarding Department: College of Education
“Provides support for a student who pursues elementary, early childhood or special
education degree. . . First preference to students pursuing a master's degree who are
nontraditional students or racially/ethnically diverse or bilingual students. Second
preference to undergraduate students who are nontraditional students or racially/
ethnically diverse or bilingual students.” 42

31) Hattie Hillard Scholarship

Awarding Department: Student Affairs Advancement
“Student should have strong Community Service record; Renew 3.2 gpa; Preference given
to minority students” 43

32) Jose & Kathleen Andrade Scholarship

Awarding Department: College of Media
“[T]he Dr. Juan Andrade Jr. Scholarship for young Hispanic Leaders seeks to recognize
Hispanic students who share Dr. Andrade’s lifelong commitment to servant leadership. . .
. Recipients will receive: A non-renewable academic scholarship ($1,000 for a 4-year
institution or $500 for a 2-year institution) for undergraduate students.” 44

41
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1322, archived at
https://web.archive.org/web/20240816185526/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1322.
42
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=862, archived at
https://web.archive.org/web/20240816185715/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=862 .
43
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=762, archived at
https://web.archive.org/web/20240816185843/http://web.archive.org/screenshot/https://secure.os
fa.illinois.edu/scholarship-database/detail.aspx?id=762.
44
See, id,; https://www.ushli.org/dr-juan-andrade-scholarship-for-young-hispanic-leaders/,
archived at https://web.archive.org/web/20240816185859/https://www.ushli.org/dr-juan-
andrade-scholarship-for-young-hispanic-leaders/ .
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 13 of 16

Eligibility: “Preference given to minority/diverse students” 45

33) Kaiser Aluminum Scholarship

Awarding Department: College of Engineering
Eligibility: “Preference to qualified minorities” 46

34) Latino Latina Alumni Scholarship

Awarding Department: Office of Student Financial Aid
“Eligible undergraduate students shall be enrolled at the University of Illinois Urbana-
Champaign. Recipients shall have a demonstrated financial need and minimum GPA of 3.0
and shall have at least 24 credit hours completed. Preference shall be given to students of
Latino or Latina descent, in accordance with and as appropriate under applicable
University policies, state and/or federal law.” 47

35) Wensel Morava Scholarship

Awarding Department: Office of Student Financial Aid
“The Wensel Morava Scholarship is open to students at the University of Illinois at Urbana-
Champaign. You must have at least a 3.00 GPA to be eligible for this award. Preference
will be given to students of Czech descent and residents of Cook County.” 48

36) Office of Minority Student Affairs Hope Scholarship

Awarding Department: Student Affairs Advancement
“This scholarship is awarded to undergrad Sophomores, Juniors, and Seniors who
participate in OMSA services. Preference is given to a minority student with a GPA of 3.2
or above.” 49

45
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=837, archived at
https://web.archive.org/web/20240816190111/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=837 .
46
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=452, archived at
https://web.archive.org/web/20240816190129/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=452.
47
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=6000, archived at
https://archive.ph/ccu8R.
48
See, https://www.fastweb.com/college-scholarships/scholarships/77806-wensel-morava-
scholarship; https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1443, archived at
https://web.archive.org/web/20240816190432/https://www.fastweb.com/college-
scholarships/scholarships/77806-wensel-morava-scholarship.
49
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1517, archived at
https://web.archive.org/web/20240816190413/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1517.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 14 of 16

37) RL Schmidt Memorial Scholarship

Awarding Department: College of Liberal Arts and Sciences – Chemistry
“Preference to Chicago public high school minority student” 50

38) Tadao Murata Undergraduate Scholarship

Awarding Department: Office of Student Financial Aid
“The Tadao Murata Undergraduate Scholarship was established to provide scholarships to
incoming or current undergraduate students at the University of Illinois at Urbana-
Champaign. Awards shall be made on the basis of academic merit. First preference shall be
given to students of Japanese heritage.” 51

III. Combined Title VI and Title IX Violations (4)

39) Doris I. And James L. Willmer Endowed Scholarship

Awarding Department: College of Engineering - Civil and Environmental Engineering
“[I]ntended to provide financial support for tuition, fees, and for an internship in private
consulting.” 52
Eligibility: “Preference first to first-generation female, then to female students, and finally
to minority students.” 53

40) Philip Morris Scholarship

Awarding Department: College of Business
Eligibility: “Minorities or Women preferred” 54

50
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1231, archived at
https://web.archive.org/web/20240816190540/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1231.
51
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=12313, archived at
https://web.archive.org/web/20240816190552/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=12313 .
52
See, https://cee.dev.engr.illinois.edu/academics/awardlists/doris-i-and-james-l-willmer-
endowed-scholarship, archived at
https://web.archive.org/web/20240816190824/https://cee.dev.engr.illinois.edu/academics/awardli
sts/doris-i-and-james-l-willmer-endowed-scholarship.
53
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=508, archived at
https://archive.ph/2024.08.18-201020/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=508.
54
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=147, archived at
https://web.archive.org/web/20240816190830/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=147.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-
Champaign) August 19, 2024
Page 15 of 16

41) Roy Mercer Young Scholarship

Awarding Department: Office of Student Financial Aid
“Eligible undergraduate students shall new male minority freshmen, be enrolled at the
University of Illinois Urbana-Champaign in the College of Liberal Arts and Sciences.
Recipient(s) shall be selected based on financial need, personal and academic
accomplishments, outstanding leadership, impact on the quality of life at the University,
and demonstrated personal growth and integrity.” 55

42) Myron & Jewel Ash Scholarship

Awarding Department: College of Education
“Preference to provide support for an African American man pursuing a career in
elementary and middle school planning a teaching career in an inner city school a the
kindergarten through eighth grade level.” 56

OCR Has Jurisdiction

OCR has jurisdiction over this complaint. OCR enforces Title VI of the Civil Rights Act of
1964 and its implementing regulation, 58 which prohibit discrimination on the basis of race, color,
57

or national origin in programs and activities receiving federal financial assistance. As a recipient
of federal financial assistance from the Department of Education, UIUC is also subject to Title VI.
Discrimination based on sex in “education program[s] or activit[ies]” that receive federal financial
assistance transgresses Title IX. See 20 U.S.C. §1681(a). “Title IX reaches institutions and
programs that receive federal funds,” 20 U.S.C. § 1681(a), including nonpublic institutions.
Fitzgerald v. Barnstable Sch. Comm., 555 U.S. 246, 257 (2009). UIUC receives federal funding
and administers funds from federal Pell grants, CARES Act funding, and other federal grants and
contracts, as set out above and in Footnote 2. Accordingly, UIUC is subject to Titles VI and IX.

The Complaint is Timely

This complaint is timely brought because it includes allegations of discrimination based on

race, color or national origin that appear to be ongoing.

55
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=1520, archived at
https://web.archive.org/web/20240816191033/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=1520.
56
See, https://secure.osfa.illinois.edu/scholarship-database/detail.aspx?id=855, archived at
https://web.archive.org/web/20240816191058/https://secure.osfa.illinois.edu/scholarship-
database/detail.aspx?id=855.
57
42 U.S.C. §§ 2000d-2000d-7.
58
34 C.F.R. Part 100.
U.S. Dept. of Education, Office for Civil Rights
Civil Rights Complaint –University of Illinois (Urbana-Champaign)
August 19, 2024
Page 16 of 16

Request for Investigation and Enforcement

In Richmond v. J. A. Croson Co., Justice Scalia aptly noted that “discrimination on the basis
of race is illegal, immoral, unconstitutional, inherently wrong and destructive of a democratic
society.” 488 U.S. at 505. This is true regardless of which race suffers discrimination. Racial
preferences “fly in the face of our colorblind Constitution and our Nation’s equality ideal” and
“are plainly—and boldly—unconstitutional.” Students for Fair Admissions, 600 U.S. at 287
(Thomas, J., concurring). The same reasoning applies to sex-based discrimination.

“The way to stop discrimination,” the Supreme Court has taught, “is to stop
discriminating.” Parents Involved in Cmty. Sch., 551 U.S. at 748. The Office for Civil Rights has
the power and obligation to investigate UIUC’s role in creating, supporting and promoting the
discriminatory scholarships above and to impose whatever remedial relief is necessary to hold it
accountable for that unlawful conduct. This includes, if necessary, imposing fines, initiating
administrative proceedings to suspend or terminate federal financial assistance and referring the
case to the Department of Justice for judicial proceedings to enforce the rights of the United States
under federal law.

As set forth above, the number and scope of discriminatory scholarships is extensive,
reflecting a systemic disregard for the civil rights laws. In light of this systemic problem, we ask
that OCR promptly open a formal investigation not only as to these scholarships, but also as the
UIUC system.

We further request that OCR impose such remedial relief as the law permits for the benefit
of anyone who may have been illegally excluded from UIUC’s scholarship offerings based on
discriminatory criteria, and ensure that all ongoing and future programming through UIUC
comports with the Constitution and federal civil rights laws.

Very truly yours,

Ronald D. Coleman
Director of Litigation
The Equal Protection Project
ron.coleman@legalinsurrection.com

William A. Jacobson
President
Legal Insurrection Foundation
contact@legalinsurrection.com