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Journal of Child Sexual Abuse
ISSN: 1053-8712 (Print) 1547-0679 (Online) Journal homepage: http://www.tandfonline.com/loi/wcsa20
Passing the Trash: Absence of State Laws Allows
for Continued Sexual Abuse of K–12 Students by
Billie-Jo Grant, Stephanie Wilkerson & Molly Henschel
To cite this article: Billie-Jo Grant, Stephanie Wilkerson & Molly Henschel (2018): Passing the
Trash: Absence of State Laws Allows for Continued Sexual Abuse of K–12 Students by School
Employees, Journal of Child Sexual Abuse, DOI: 10.1080/10538712.2018.1483460
To link to this article: https://doi.org/10.1080/10538712.2018.1483460
Published online: 12 Jun 2018.
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Passing the Trash: Absence of State Laws Allows for
Continued Sexual Abuse of K–12 Students by School
, Stephanie Wilkerson
, and Molly Henschel
Department of Statistics, California Polytechnic State University, San Luis Obispo, CA, USA;
Consulting, LLC, Charlottesville, VA, USA
“Passing the trash,”enabling teachers who sexually abuse
students to pursue another job with no record of their sexual
misconduct, is common practice for K–12 school district
administrators who fear legal liability and tarnished reputa-
tions. The “Prohibition on Aiding and Abetting Sexual Abuse”
provision in the United States Every Student Succeeds Act
(ESSA) of 2015 aims to eliminate passing the trash. This study
explores states’progress toward developing and implementing
relevant law and policy to comply with the provision.
Researchers collected data from representatives of state
departments of education, asking whether representatives
were aware of the provision and what progress their state
had made toward complying with it. Overall, researchers
found that just four states had fully complied; several others
were in the process of creating relevant policy and legislation
and a few began the process in response to researchers’
queries. However, the overwhelming majority of states—39—
had no plans to create relevant legislation or policy, either
because they were unaware of the provision or because they
believed, erroneously, that existing laws fulfilled the ESSA
mandate. Passing the trash is clearly an unacceptable practice,
yet research suggests it still occurs, and state-level laws and
policies to prevent it are slow to emerge. The lack of knowl-
edge or awareness exhibited by many state representatives
suggests a need to educate policymakers and education lea-
ders about what aiding and abetting sexual offenders consists
of, what consequences it can have for vulnerable students, and
what provisions states can enact to prohibit it.
Received 16 November 2017
Revised 30 March 2018
Accepted 5 May 2018
Sexual misconduct; sexual
abuse; school personnel;
student safety; education
In the United States, 1 in 10 K–12 students (approximately 4.8 million) will
experience sexual abuse or misconduct by school personnel before they
graduate from high school (US DOE, 2004). In 2015, the media, which tracks
only the cases reported to criminal authorities, reported 498 teachers arrested
for sex crimes against children (Google Alerts, 2015)—almost three cases
CONTACT Billie-Jo Grant firstname.lastname@example.org Department of Statistics, College of Science and
Mathematics, California Polytechnic State University, San Luis Obispo, CA 93407
Color versions of one or more of the figures in the article can be found online at www.tandfonline.com/wcsa.
JOURNAL OF CHILD SEXUAL ABUSE
© 2018 Taylor & Francis
each day of the school year. This number is up from 459 cases reported in
2014 (Google Alerts, 2014). Due to a lack of funding for research, as well as
methodological barriers to studying school employee sexual abuse and mis-
conduct, it is unknown how many of those cases resulted in convictions and
how many additional incidents go unreported. There also is a shortage of
research evidence regarding what states and school districts are doing to
implement laws and policies aimed at preventing and responding to cases of
sexual abuse and misconduct among school employees. Internationally,
research studies and reports from news agencies are also limited, but do
show that sexual misconduct by school employees is widespread (i.e., Canada
(Moulden, Firestone, Kingstone, & Wexler, 2010), Europe (Gallagher, 2000;
May-Chanal & Cawson, 2005; Timmerman, 2003), Israel (Khoury-Kassabri,
2006), Australia (Knowles & Branley, 2014), South Africa (Madu, 2001;
Shumba, 2001), and Hong Kong (Tang, 2002)).
In 2015, President Barack Obama signed the Every Student Succeeds Act
(ESSA), which reauthorized the 50-year-old Elementary and Secondary
Education Act (ESEA). A provision of the new law, “Prohibition on Aiding
and Abetting Sexual Abuse,”requires school personnel to report incidences
of school employee sexual misconduct to the proper authorities (8546, ESSA,
2015). It discourages school districts from entering into confidentiality agree-
ments with teachers who engage in sexual misconduct with students, a
practice that allows offenders to pursue positions in other school districts
without any public record of sexual abuse or misconduct. Unfortunately,
federal laws such as ESSA may not be thoroughly implemented because they
include limited plans for evaluation and limited accountability for failure to
comply. In other countries, laws and policies do exist to prevent sexual
harassment in educational institutions, but rarely address school employee
sexual misconduct specifically and have weak enforcement (Kaufman et al,
2016; UNESCO, 2017).
The purpose of this article is to provide an overview of school employee
sexual abuse and misconduct, describe what passing the trash is and why it
occurs, describe U.S. federal and state laws such as the ESSA “Prohibition on
Aiding and Abetting Sexual Abuse”and their requirements, and offer
resources and model language for state legislatures to prohibit passing the
School employee sexual abuse and misconduct
School employee sexual abuse and misconduct occurs when a school
employee (e.g., a teacher, coach, administrator, volunteer, or staff member)
sexually abuses a child (i.e., contact or non-contact) while caring for that
child in a K–12 school setting. Sexual abuse may include any sexual activity
with a child where consent is not or cannot be given and sexual contact that
2B.-J. GRANT ET AL.
occurs through force or threat of force (Sexual Abuse, 18 U.S.C. §2242). It
comprises sexual crimes such as indecent liberties with a child, sexual abuse,
rape, and child pornography, among others. Sexual misconduct is a broader
term that encompasses both sexual abuse and acts that are not criminal but
may violate ethical codes (i.e., misconduct with a student who is over the age
of consent—16 in many states—is not a crime, but is typically prohibited by
school policy). Unfortunately, various factors make students and student-
athletes vulnerable to sexual abuse and misconduct by school employees,
including the offender’s authoritative roles, the age differential between the
school employee and the student, and community trust (Grant, 2011; Shoop,
2004; U.S. Department of Education (DOE), Office of the Under Secretary,
2004). These elements allow school employees to use their power over grades,
discipline, recommendations, or playing time to coerce or cajole students to
engage in sexual activity.
What are the characteristics of a school employee sexual abuse or
Contrary to common conception, sexual abuse and misconduct offenders
typically are popular, and they often have been recognized for excellence.
Offenders include all types of school employees, such as teachers, school
psychologists, coaches, principals, and superintendents (Hendrie, 1998;
Shoop, 2004; U.S. Department of Education (DOE), Office of the Under
Secretary, 2004). Offenders range in age and ethnicity, and they are most
frequently male (U.S. Department of Education (DOE), Office of the
Under Secretary, 2004;Hendrie,1998; Jennings & Tharp, 2003).
Beyond these general statistics, the field knows very little about offen-
ders’characteristics, as they span all ages, ethnicities, and income levels
(U.S. Department of Education (DOE), Office of the Under Secretary,
School employees who engage in sexual abuse or misconduct with children
have many different motives; some are repeat offenders, while others commit
offenses based on convenience (U.S. Department of Education (DOE), Office
of the Under Secretary, 2004; LaFond, 2005; Pryor, 1996). A habitual offen-
der will abuse many different children, engaging in a pattern of abuse or
misconduct; an opportunistic offender, by contrast, may fall into an abusive
role while experiencing stressors such as loss of employment, love, or death,
all events which can lower inhibitions (Finkelhor, 1984; p. 45; Johnson, 2008;
Pryor, 1996). School employees who commit sexual offenses may be sexually
attracted to children (pedophilia), antisocial, or psychopathic. They may
evidence cognitive distortions and deficiencies in information-processing
skills; have impaired adult intimacy skills, unclear social boundaries, or
feelings of inadequacy or loneliness; or feel entitled. Or they may commit
JOURNAL OF CHILD SEXUAL ABUSE 3
offenses for reasons unknown (Hayashino, Wurtele, & Klebe, 1995; Marshall,
2010; Pryor, 1996; Salter, 2003; Shoop, 2004).
Ironically, the characteristics of teacher–student relationships that help
foster a successful educational environment can also create a potentially
exploitative situation. Research has shown that those school employees
whose jobs include individual, isolated, or alone time with students (such
as music teachers, coaches, and counselors) are more likely to commit sexual
abuse or misconduct (U.S. Department of Education (DOE), Office of the
Under Secretary, 2004; Gallagher, 2000; Jennings & Tharp, 2003; Willmsen &
O’Hagen, 2003). Close contact with students, who are often eager to please
their teachers, allows offenders to “groom”
a student for eventual abuse, by
giving special attention and rewards while slowly increasing the amount of
touching or other sexual behaviors (Robins, 2000; Salter, 2003; Shoop, 2004).
In this way, offenders exploit students’need to please and take advantage of
the tremendous power they have over students (Van Dam, 2001, p. 106).
What are the characteristics of victims of school employee sexual
Victims of sexual abuse or misconduct by school personnel span most
demographic variables, though students who are low-income and female
are most likely to experience sexual misconduct at the hands of a school
employee (Finkelhor, 1984; Gallagher, 2000; Hendrie, 1998; Henschel &
Grant, in press; U.S. Department of Education (DOE), Office of the Under
Secretary, 2004). Researchers have shown that offenders target victims who
appear needier, may be picked on by others, or do not have a happy home
life because it is easier to gain the friendship of these vulnerable children
(Salter, 2003, p. 66). Similarly, students with disabilities are more likely to
experience school employee sexual abuse or misconduct (Sullivan &
Knutson, 2000; U.S. Department of Education (DOE), Office of the Under
While studies of the effects on victims of school employee sexual abuse
and misconduct are limited, we do know that victims of sexual abuse suffer
serious psychological, physical, academic, and behavioral consequences that
can last a lifetime (Dube et al., 2003; Felitti et al., 1998; AAUW, 2001;
Kendall-Tackett, 2002; Macmillian, 2000; Monnat & Chandler, 2015;US
DOE, 2014). Victims of sexual abuse are more likely to have problems with
drugs, alcohol, or substance abuse (Ford et al., 2011; La Fond, 2005; U.S.
Department of Education (DOE), Office of the Under Secretary, 2004), and
they often struggle with long-term symptoms such as chronic headaches,
fatigue, sleep disturbance, recurrent nausea, decreased appetite, eating dis-
orders, sexual dysfunction, suicide attempts, fear, anxiety, depression, anger,
hostility, and poor self-esteem (Kendall-Tackett, 2002). Sexual abuse also
4B.-J. GRANT ET AL.
impairs the victim’s ability to trust other people, potentially destroying a
victim’s chances to develop close personal relationships and especially
healthy sexual relationships (LaFond, 2005).
How do sexual predators and offenders end up in schools?
Sexual abuse and misconduct of children is an age-old problem; and school
systems are not immune to its pervasiveness. Unfortunately, sexual abuse is a
sensitive topic surrounded by a veil of silence that creates many loopholes
offenders can exploit to continue their behavior. These loopholes, which include
spotty background checks, a lack of information sharing between districts, and a
lack of knowledge among school administrators, allow offenders to enter
schools and get hired multiple times before being identified and convicted.
Background checks are limited, inconsistent, and rely on self-report
All but four states now require background checks for at least some school
employees, but those checks are limited by current capabilities and vary widely
in the level of stringency (GAO, 2014). Background checks may include matching
an applicant’s name, date of birth, social security number, or fingerprints to state
or federal criminal databases or child abuse and neglect registries. A total of 36
states rely on both state and federal sources; 6 states use state law enforcement data
only; 3 states use federal law enforcement data only; and 5 states do not require
background checks for applicants, regardless of position (Government
Accountability Office, 2014). Background check requirements are less stringent
for employees in positions that do not require licensure. Only 17 states require
criminal background checks for volunteers and only 36 states require them for
“contract”employees, meaning janitors, secretaries, transportation personnel, and
maintenance workers (Government Accountability Office, 2014).
Even where requirements are strict, the thoroughness of background
checks is limited by the absence of an aggregated national search engine
for criminal records of sexual abuse and misconduct; search capabilities are
limited to individual state and federal databases (Government Accountability
Office, 2014; U.S. Department of Education (DOE), Office of the Under
Secretary, 2004). Conducting a complete national background check would
require searching each of the 50 state databases and the federal records
separately, a task few if any districts have time for. This makes it easy even
for offenders who have convictions to simply move to another state, where
they evade background checks by lying about the state and county of their
last employment—without knowledge that a potential employee has lived or
worked in a state, the new employer will have no reason to search that state’s
system. Even if the system is searched, some records may be expunged after a
certain amount of time passes, offering another loophole by which offenders
can reenter the school systems.
JOURNAL OF CHILD SEXUAL ABUSE 5
There is no publicly available, national database of disciplinary actions
against licenses and certifications
Sexual offenders do not only incur criminal charges; they may also be subject
to disciplinary actions. However, school districts have no way to access this
information, as there is no national database of disciplinary actions against
teachers. The National Association of State Directors of Teacher Education
and Certification (NASDTEC), an independent nonprofit organization,
attempts to keep records of educators who have had their professional
licenses or certificates annulled, denied, suspended, revoked, or invalidated,
but administrative delays in sexual abuse and misconduct cases interfere with
timely reporting; an educator accused of sexual abuse or misconduct can be
employed at another school before any record appears in the database.
Furthermore, a USA Today report found that the NASDTEC database was
grossly incomplete, with more than 1,400 cases in which a teacher perma-
nently lost his or her license not listed—potentially allowing teachers to flee
accusations of abuse or misconduct by moving to new states (Reilly, 2016).
Finally, the database only tracks licensed employees; infractions committed
by contract or non-contract school staffs such as substitute teachers, bus
drivers, and coaches are not included. Even if a case does appear in the
NASDTEC database, not all school employers have access to it. Although
NASDTEC made read-only access free for education departments and jur-
isdictional agencies responsible for educator certification in 2016, organiza-
tions that do not meet this criteria must pay a fee. Those that do not can still
search state-by-state criminal databases, but those report only convictions
and may not reveal actions taken against certifications.
School staffs lack knowledge and awareness about school employee sexual
Many states have adopted policies that appear on their web sites, in their
handbooks, or in school board policies, but studies have shown that school
staffs remain unaware of what school employee sexual abuse and misconduct is,
what the warning signs are, and how and to whom to report it (Grant, 2011).
Because educational actors lack awareness about school employee sexual abuse,
they fail to recognize it or to properly report it to Child Protective Services (CPS)
and law enforcement personnel (Grant, 2011;Jennings&Tharp,2003;Kenny,
2001; Shakeshaft & Cohan, 1995;Shoop,2004;U.S.DepartmentofEducation
(DOE), Office of the Under Secretary, 2004; Willmsen & O’Hagan, 2003).
Schools fail to report sexual abuse and misconduct
As of 2014, 46 states had mandatoryreporting laws that require school personnel
to report suspicions of child abuse, including sexual abuse by any adult (parents,
family members, and school employees) or other students; 43 of those states
have penalties for not reporting (Government Accountability Office, 2014).
6B.-J. GRANT ET AL.
Despite these required reporting laws, administrators are apprehensive about
reporting school employee sexual abuse or misconduct to authorities because of
the potential stigma and loss of reputation, familial reactions, as well as legal
repercussions and liability for monetary damages, that a report can trigger
(Finkelhor, 1982; Grant, 2011; Hendrie, 1998;Shoop,2004). These fears are
powerful; only an estimated 5% of school employee sexual abuse and miscon-
duct incidents known to school employees are reported to law enforcement or
child welfare personnel despite clear policies and potential legal consequences
for failing to report an incident (Corbett, Gentry, & Pearson, 1993; Finkelhor,
Hoatrling & Yllo, 1988;Kenny,2001). A 1994 study in New York State found
that only 1% of the 225 cases superintendents disclosed to researchers were
reported to law enforcement or child welfare and resulted in license revocation
(Shakeshaft & Cohan, 1995). Some school administrators avoid the conse-
quences of reporting by making confidentiality agreements or negotiating pri-
vate settlements with offenders (Shakeshaft & Cohan, 1995; Shoop, 2004; Stein,
1999). Furthermore, collective bargaining clauses often allow for scrubbing of
personnel files, so no record is left once an offender leaves the system.
This practice, of allowing a known sexual predator to quietly leave the district,
potentially to seek work elsewhere, has become known as “passing the trash,”or
“the lemon dance”(Hobson, 2012). With no criminal conviction or disciplinary
record, the predator can obtain a new job and move onto other victims. On
average, a teacher-offender will be passed to three different districts before being
stopped (GAO, 2010); one offender can have as many as 73 victims in his or her
lifetime (Government Accountability Office, 2010). Table 1 provides examples
of school employee sexual abuse and misconduct cases in which the teacher had
committed offenses in multiple districts before being convicted.
Progress in banning passing the trash
States have a patchwork of laws that address background checks and man-
datory reporting behaviors, but they clearly do not prevent districts from
continuing to pass the trash. The ESSA provision “Prohibition on Aiding and
Abetting Sexual Abuse”(ESSA of 2015, section 8546) defines two critical
components those laws must include to stop this practice:
(1) Ban the aiding and abetting of school employee sexual abuse and
(2) Ban confidentiality agreements between school employees and admin-
istration in cases of sexual abuse and misconduct.
The ban on aiding and abetting school employees’sexual abuse and mis-
conduct includes allowing school employees who have committed abuse or
misconduct to leave a school district with a letter of recommendation and
JOURNAL OF CHILD SEXUAL ABUSE 7
without a record of their abuse or misconduct. The provision specifically
requires administrators to report incidences of sexual abuse or misconduct to
their state’s Department of Education and requires a penalty for those who
do not comply. The optional provisions provide for an exception if the
employee is currently under investigation or charges are acquitted, there is
insufficient information, or the charges have been dropped.
The second component is the ban on confidentiality agreements between
school employees and administrators. Teacher, union, and employee rights
agreements can limit the information a prior employer can share about a
school employee, but such information sharing can be critical to stopping an
offender from being rehired in another district. The ban on confidentiality
agreements is therefore essential to ensure that the school district is able to
disclose information about sexual abuse or misconduct to other employers.
These provisions are a good first step, but they are on their own, ineffec-
tive. ESSA, the law that includes the provision “Prohibition on Aiding and
Abetting Sexual Abuse,”is a federal law that defines what states must do to
receive federal funding for education and provides model language for state
laws and regulations. Figure 1 offers model language compiled from the
original bill proposed by Pennsylvania’s Senator Toomey’s office and bills
in Connecticut, Oregon, and Texas. For these provisions to have real effect,
Table 1. Examples of “Passing the trash”.
Position Case description Outcome
Teacher Neither the teacher nor her previous school district (in
another state) disclosed that she was suspended and
eventually resigned from her position in 2008 after
confessing to inappropriate feelings for a 14-year-old
student. Landing a new position in 2011, she began a
sexual relationship with a 17-year-old student and
eventually became pregnant with his child.
Arrested in 2014 for six counts
of unlawful sex with a minor.
The teacher and coach was formally admonished by a
school in Pennsylvania for groping girls between 1993
and 2000. He was rehired within the same county in
2006; the first complaints were lodged against him
during the 2011–2012 school year. He transferred to
another elementary school in the same district, where
more parents filed complaints that he inappropriately
touched students on multiple occasions in 2013–2014.
Arrested in 2014 and convicted
of sexual assault.
Teacher The teacher sexually abused a 16-year-old student
during the 2013–2014 school year and, in 2013, had sex
with a 15-year-old student from the high school where
he previously taught. The victim from the previous
school filed a lawsuit that alleged the superintendent
knew about the sex crimes and, instead of informing
authorities, gave the teacher a favorable
Convicted in April 2015 of
having sex with two students.
8B.-J. GRANT ET AL.
states must enact their own laws and regulations that comply with the ESSA
Although ESSA mandates that states pass legislation and offers model
language for that legislation, it offers no guarantee that states will be held
accountable for implementation of the provision. If the provision is not
implemented at the state level, children may not be any more protected
from school employee sexual abuse or misconduct than they were before
the law was enacted. The U.S. Department of Education requires each state to
submit an ESSA plan, but that plan focuses on the implementation of
programs outlined under section 8302 of ESEA, as amended by the ESSA
(US DOE, 2017a). Unfortunately, the template for the state plan does not
include a section to address the requirements of the “Prohibition on Aiding
Figure 1. Model legislation to comply with ESSA’s ban on aiding & abetting sexual abuse.
JOURNAL OF CHILD SEXUAL ABUSE 9
and Abetting Sexual Abuse”provision. With no explicit directive to do so,
states are not likely to outline their intentions to address this provision.
This is a critical oversight; the consolidated plans represent an important
step in the process of translating federal provisions into state-level policy.
Without any evident prioritization of the provision by the Department of
Education, it is effectively a symbolic policy—a policy written at any level of
bureaucracy that is not intended to be fully implemented (Blumer, 1986;
Smith, Miller-Kahn, Heinecke, & Jarvis, 2004). And it appears that is what is
happening. As of May 2017, 16 states and the District of Columbia had
submitted state ESSA plans for peer review (US DOE, 2017b).
list does not reflect state plans the U.S. Department of Education deems
complete—the plans could be revised based on peer-review feedback—a
review of the documents indicates that these proposed plans do not include
any language or procedures focused on addressing the “Prohibition on
Aiding and Abetting Sexual Abuse.”
Status of states’action
We sought to establish how many states have acted to implement the ESSA
provision and ban passing the trash. In October 2016–January 2017,
researchers called or e-mailed representatives in various state department
of education divisions, including legislative offices, liaison and commissioner
offices, governmental relations offices, ESSA officials, attorney generals, and
public affairs offices, asking to speak with the person who would be aware of
any laws to address compliance with recent ESSA changes and their imple-
mentation. Researchers asked representatives if they were aware of the ESSA
provision and if their state had laws that complied with the provision (ESSA
While some representatives we spoke to referred to state laws
and codes of ethics that included information about banning sexual abuse
and misconduct, only four states reported having laws that directly addressed
the requirements of the “Prohibition on Aiding and Abetting Sexual Abuse.”
As of January 2017, only four states—Connecticut, Oregon, Pennsylvania,
and Texas—have passed laws that meet ESSA’s requirement. Those laws, the
text of which is provided in Table 2, vary in complexity and stringency;
Connecticut does not require private and parochial schools to abide by the
law, leaving a loophole for predators to find employment in private and
parochial schools. An additional seven states are working on draft language.
Thus, 39 states currently lack legislation or prospective legislation focused
designed to protect students from sexual abuse and misconduct by school
10 B.-J. GRANT ET AL.
employees. Figure 2 shows the number of states that currently meet the
requirement, are drafting language, or lack any legislation.
Among the seven states working on plans to address the federal mandate,
legislative language is in various stages of development; these states either
had bills being prepared for General Assembly hearings in 2017 or were
constructing draft bills as a result of researchers contacting them. These
states reviewed existing legislation to respond to researchers’information
request and realized there were no laws regarding the ESSA provision. Five
Table 2. States with laws complying with ESSA “Prohibition of aiding and abetting sexual abuse
State Relevant text from bill or law Effective date
CT HB 5400; Public Act No. 16–67
“No local or regional board of education, council or operator shall enter into a
collective bargaining agreement, an employment contract, an agreement for
resignation or termination, a severance agreement or any other contract or
agreement or take any action that: (1) Has the effect of suppressing information
relating to an investigation of a report of suspected abuse or neglect or sexual
misconduct by a current or former employee; (2) Affects the ability of the local or
regional board of education, council or operator to report suspected abuse or
neglect or sexual misconduct to appropriate authorities; or (3) Requires the local or
regional board of education, council or operator to expunge information about an
allegation or a finding of suspected abuse or neglect or sexual misconduct from
any documents maintained by the board, unless after investigation such allegation
is dismissed or found to be false.”
July 1, 2016
OR HB 2062; Chapter 93, (2009 Laws)
“Prohibits education provider from entering into agreement or contract that
suppresses information related to child abuse or sexual conduct, affects provider’s
duty to report suspected child abuse or sexual conduct or impairs provider’s ability
to discipline employee for child abuse or sexual conduct.”
July 1, 2010
PA HB 2063; 1949 Act 14 Sec. 111.1f
“On or after the effective date of this section, a school entity or independent
contractor may not enter into a collective bargaining agreement, an employment
contract, an agreement for resignation or termination, a severance agreement or
any other contract or agreement or take any action that: (1) has the effect of
suppressing information relating to an investigation related to a report of
suspected abuse or sexual misconduct by a current or former employee; (2) affects
the ability of the school entity or independent contractor to report suspected
abuse or sexual misconduct to the appropriate authorities; or (3) requires the
school entity or independent contractor to expunge information about allegations
or findings of suspected abuse or sexual misconduct from any documents
maintained by the school entity or independent contractor, unless after
investigation the allegations are found to be false.”
June 1, 2014
WA RCW 28A.400.301
“The board or an official of a school district shall not enter into a collective
bargaining agreement, individual employment contract, resignation agreement,
severance agreement, or any other contract or agreement that has the effect of
suppressing information about verbal or physical abuse or sexual misconduct by a
present or former employee or of expunging information about that abuse or
sexual misconduct from any documents in the previous employer’s personnel,
investigative, or other files relating to verbal or physical abuse or sexual
misconduct by the applicant.”
Public Act No. 16-67 (State of Connecticut, 2016);
Chapter 93 (State of Oregon, 2015);
14 (State of Pennsylvania, 2014);
RCW 28A.400.301 (State of Washington, 2004).
Note. As of January 2017
JOURNAL OF CHILD SEXUAL ABUSE 11
states actively began drafting bills; one state representative asked the
researchers for model language to ensure guidelines were met. Another
state representative said the department would start its own research as a
result of this study and would draft a bill to be addressed in the next
Of the states with no legislation, four indicated they were working on
legislation and could not confirm what legislation would be addressed or
when, and an additional four said there were no current laws or pending
legislation to address the provision. A representative from Stop Educator
Sexual Abuse Misconduct and Exploitation (S.E.S.A.M.E.) confirmed that
there was no current law and nothing was being drafted in one state with
which we could not establish contact.
The remaining 39 states gave various reasons for lacking current or work-
ing legislation to address the ESSA provision. Most—24 representatives—
provided current state laws or ethical codes as confirmation that their state
already adheres to the requirements of the federal provision. In most cases,
those assertions were incorrect. Although some of these laws and codes
discussed preventive procedures or disciplinary actions against sexual abuse
and misconduct by educators, none addressed aiding and abetting or speci-
fically prohibited confidentiality agreements.
Figure 2. Status of “Aiding and abetting”Legislation for school employee sexual abuse and
12 B.-J. GRANT ET AL.
For example, 12 states cited laws referring to state background check
requirements or criminal history reports as sufficient for meeting the condi-
tions of aiding and abetting. One representative told a researcher,
Although they do not contain the specific language referred to in ESSA, we have
laws in place that require criminal history record checks for [State] employees that
will be working in close proximity of children. These laws allow for the termina-
tion of or denial of employment for individuals convicted of a crime.
While background checks are important to limit the hiring of offenders, they
do not prevent schools from aiding and abetting offenders in getting rehired
in other districts.
Eight representatives cited laws or codes mandating that school personnel
report instances of child abuse. One respondent said,
We believe we already have laws in place that accomplish the [aiding and abetting]
items below [ESSA provision]. Specifically, [State Act], includes a list of profes-
sionals/individuals who are designated ‘mandated reporters’who must, by law,
report suspected abuse/neglect of a child to DCFS [Department of Child and
Family Services]. Failure to report makes an individual subject to criminal
Mandatory reporting laws are useful to identify cases of sexual misconduct
and abuse; but again, do not meet the ESSA provision’s standards for
banning passing the trash.
A total of 10 additional states referenced codes requiring license or
certification revocation as well as employment termination and policies
requiring educators to maintain “professional relationships with students
inside and outside of the classroom”and to refrain from unethical conduct,
including any sexual act with a student regardless of age. One state requires a
letter of reprimand, suspension, revocation, or denial of certification to any
person known to have been convicted of a criminal offense involving
immoral conduct, such as sexual misconduct. Some state officials referred
to NASDTEC’s database of disciplinary actions taken against educator certi-
fications or mentioned that states keep a list of teachers whose licenses have
been revoked. One member referenced a bill that requires that, in
scenarios where a school employee is not necessarily convicted of a crime, but is
recommended for termination based on ‘grounds that could form the basis of
criminal charges sufficient to result in the denial or revocation of a certificate’...
the school district must forward a copy of the termination recommendation to the
State Board of Education. . . School districts considering a teacher for employment
may request a copy of any recommendations received by the State Board regarding
While licensing and policies associated with it can help prevent offenders
from getting licensed, they do not meet the ESSA provision’s criteria for
banning aiding and abetting.
JOURNAL OF CHILD SEXUAL ABUSE 13
Finally, four states were still considering ESSA legislation at the state level
and either could not provide any insights into the direction of their plans or
were completely unaware of this particular provision. One state official
We are currently considering the impact of ESSA in our state, including this
provision and how best to move forward.
Another representative said,
I checked with staff and to our knowledge there is no state law regarding this issue
and no proposed legislation.
ESSA encompasses various elements of education, such as student perfor-
mance, and many states were focusing their plans on other elements of the
law, leaving the prohibition on aiding and abetting unaddressed.
States are required to submit their consolidated plans to the U.S. Department
of Education for peer review (Department of Education, 2016a,2016b);
however, as of September 2017, 39 states still have no working draft of
legislation to ban passing the trash and prevent unreported offenders from
gaining access to students. In these states, there is no apparent timeline for
enacting laws and policies to enforce ESSA’s provision, nor are there any
clear repercussions for failing to do so, short of the theoretical loss of federal
funding due to noncompliance. Significantly, the law explicitly prevents the
Secretary of Education from mandating, directing, or controlling specific
measures that states or districts must take to be in compliance with the
law. Thus, states, state educational agencies, and school districts must take
the lead in establishing consequences for assisting a known offender in
obtaining a new job in schools.
While many states referenced mandatory reporting requirements as
sufficient to respond to ESSA’s criteria, these laws do not fulfill the
requirements outlined in the provision. Mandatory reporting laws require
persons in positions of authority to report abuse to CPS or law enforce-
entering into confidentiality agreements and writing letters of recommen-
dation for school employees known to have committed sexual misconduct
with students—there is nothing to stop school leaders from reporting
abuse and then allowing the employee involved to resign, failing to
disclose information to other schools where the employee seeks employ-
ment, or in the worst case, even recommending the employee for another
14 B.-J. GRANT ET AL.
This research has some limitations that might have affected the results of
this study. While we contacted each state department of education for direct
information, it is difficult to know if the person who provided the answers to
our questions was informed of all efforts to address ESSA. There may be
other staff members working on legislation to address the provision. To
address this limitation, research into the status of state-level aiding and
abetting legislation will be ongoing and reported annually.
No one can argue that passing the trash is acceptable, yet research suggests
it still occurs and state-level laws and policies to prevent it are slow to
emerge. The ESSA provision lays out criteria for effective laws and provides
states with model language, but some state representatives remain unaware of
the provision and many believe that it is covered by extant child abuse
legislation; in most cases, this is not true. This lack of knowledge or aware-
ness suggests a need to educate state policymakers and education leaders
about what aiding and abetting sexual offenders consists of, what conse-
quences it could have for vulnerable students, and what provisions states
could enact to prohibit it.
Including the “Prohibition on Aiding and Abetting Sexual Abuse”provi-
sion in the ESSA law was an important first step in stopping sexual abuse and
misconduct by school employees. However, unless states incorporate the
elements of the provision into their legislation and enforce aiding and
abetting bans through explicit laws and policies, schools will continue to
pass the trash. Without some accountability for this behavior, students will
continue to be exposed to sexual predators, with serious, long-term
1. Grooming involves activities intended to establish an emotional connection with a
student and normalize sexual behavior.
2. (Arizona Department of Education, 2017;Colorado Department of Education, 2017;
Connecticut Department of Education, 2017; Delaware Department of Education,
2017; ; District of Columbia Department of Education, 2017; Illinois Department of
Education, 2017; Louisiana Department of Education, 2017; Maine Department of
Education, 2017; Massachusetts Department of Education, 2017; Michigan
Department of Education, 2017; Nevada Department of Education, 2017; New Jersey
Department of Education, 2017; New Mexico Department of Education, 2017; North
Dakota Department of Education, 2017; Oregon Department of Education, 2015;
Tennessee Department of Education, 2017; Vermont Department of Education, 2017).
3. Researchers tracked responses in an Excel spreadsheet that captured the state, depart-
ment of education office contacted, contact name, e-mail, phone number, status of
state-level law or bill addressing the ESSA provision, and notes. Follow-up commu-
nication was made with states that did not reply after the initial round of communica-
tion. A total of 17 states provided a response to our request for information by phone,
and 18 states by e-mail. Information for nine states was provided by S.E.S.A.M.E., a
JOURNAL OF CHILD SEXUAL ABUSE 15
nonprofit organization dedicated to the prevention of school employee sexual abuse
and misconduct, and 6 states either did not reply or pointed us to information on their
web sites that did not meet the requirements. Results were corroborated with Terri
Miller, President of S.E.S.A.M.E. Ms. Miller is an active supporter of the ESSA provi-
sion and is often the first person contacted by state representatives seeking model
language to comply with ESSA.
The opinions, findings, and conclusions, or recommendations expressed in this publication
are those of the authors and do not necessarily reflect those of the Department of Justice.
This project is supported by Award No. [2015-CK-BX-0009] awarded by the National
Institute of Justice, Office of Justice Programs, U.S. Department of Justice.
Notes on contributors
Billie-Jo Grant has a Ph.D. in Educational Research, Statistics and Evaluation from the Curry
School at the University of Virginia and is an experienced quantitative and qualitative
methodologist, researcher, and evaluator as well as an expert on school employee sexual
misconduct. She has led multiple national efficacy studies and was the principal investigator
on a 2015 –2017 Department of Justice funded study, School Employee Sexual Misconduct,
Policy Implementation and Effectiveness, examining school employee sexual misconduct
policy implementation nationwide.
Stephanie Wilkerson has a Ph.D. in Education Research, Statistics, and Evaluation from the
Curry School at the University of Virginia, is the President of Magnolia Consulting, and has
extensive experience in designing and implementing national studies.
Molly Henschel has a Ph.D. in Educational Evaluation and Research from Virginia
Commonwealth University. She is a researcher and evaluator with Magnolia Consulting
and supports quantitative, qualitative, and mixed-methods studies.
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