Blue LLP Final Report (Redacted)

Privileged and Confidential
TABLE OF CONTENTS
I. EXECUTIVE SUMMARY ......................................................................................... 1
II. INVESTIGATIVE PLAN .......................................................................................... 3
A. Define Scope of Investigation ...................................................................... 3
B. Identify Applicable Law ................................................................................. 3
C. Preliminary Steps to Begin Investigation .................................................... 9
D. Witness Interviews .......................................................................................... 9
III. FINDINGS OF FACT ..............................................................................................11
A. Principal Caroline Godwin Wrote “Niggers” in the

Margin of Her Notes in October 2018. .....................................................11
B. Karen McGowen Said “Nigger” or “Nigga” on Two

Separate Occasions – Once in a Classroom Full of Students
and the Other in the Presence of a Student .............................................13
C. Rayford Hankins Posted Two Images of Documents

that Contain the Word, “Nigger,” on Social Media Websites. ...............17
IV. CONCLUSIONS ........................................................................................................18
A. Ms. Godwin Did Not Violate the Standards of Professional

Conduct or Any Board Policy in Writing Her Notes. .............................18
B. PCS’s Investigation of the Circumstances Concerning

Ms. Godwin’s Notes Was Sufficient. .........................................................18
C. Ms. McGowen Violated the Standards of Professional

Conduct and Board Policy 1710-4021-7230 .............................................19
D. The Administration’s Investigation of the Complaint Against

Ms. McGowen Was Not Fully Compliant With Board
Policy 1720-4015-7225 .................................................................................20
E. Mr. Hankins’ Posting Did Not Violate Board Policy 7335 ....................21
ii
IV. WITNESS ACCOUNT SUMMARIES ..................................................................22
A. Dr. Alfreida Moore – Appendix A ............................................................22
B. Ms. Shanika Mack – Appendix B ...............................................................22
C. Ms. Caroline Godwin – Appendix C .........................................................22
D. Mr. Jack Poulos – Appendix D ...................................................................22
E. Ms. Karen McGowan – Appendix E .........................................................22
F. Dr. Steven Hill – Appendix F .....................................................................22
G. Mr. Rayford Hankins – Appendix G .........................................................22
H. Mr. Alex Riley – Appendix H .....................................................................22
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I. EXECUTIVE SUMMARY
On June 12, 2020, the Pender County Board of Education (the “Board”) engaged our
law firm to conduct an independent investigation of certain allegations posted on social
media by a current staff member at Pender High School (“PHS”) concerning comments
regarding race allegedly made by staff at PHS. The Board asked us to determine whether the
comments were made, all circumstances involving these or any other related racial
comments, and whether they were directed towards students or staff. In so doing, the Board
also tasked us with advising whether there have been violations of Board policy, law, or
professional standards, and also to evaluate whether steps taken by the administration to
address the issues that are the subject of the investigation were sufficient. Our mandate has
been to “conduct, as quickly as possible, a thorough, efficient, and complete investigation
without compromising the integrity of the investigation for any reason.” We have worked in
pursuit of these objectives, and this report contains our findings and analysis to date.
In conducting this investigation, we have surveyed myriad laws, regulations, and

Board policies; reviewed several documents; conducted comprehensive witness interviews
(while also attempting unsuccessfully to interview other witnesses); and attempted to
organize and present facts in a manner that will allow the Board to more fully evaluate what
has occurred. In light of the foregoing, we can report the following undisputed facts.
In October 2018, on the first day students returned to PHS in the aftermath of
Hurricane Florence, several PHS students were involved in a large, chaotic fight. In the
course of investigating the fight, PHS’s then-new principal, Caroline Godwin, interviewed
some of the students who had participated in the fight. She was unfamiliar with some of
them because she had just started working at the school. She used a notepad to document
the students who were involved, and wrote the phrase, “‘my’ niggers[,]” in the left margin of
the page. Ms. Godwin does not dispute writing the phrase in her notes, but maintains that
she used it to document how at least one student repeatedly referred to friends who had
been attacked. Assistant Principal Jack Poulos corroborated Ms. Godwin’s description of the
student’s language. Ms. Godwin kept the notes in her files in her office. This investigation
has not yielded any evidence that the notes were provided to or shared with any student. We
also have not been made aware of any evidence that Ms. Godwin ever verbalized the term
privately or in the presence of students.
In a separate incident, on October 10, 2019, Karen McGowen, a PHS English teacher
of approximately twenty years, said “nigger” or “nigga” in comments directed toward a
student. 1 Ms. McGowen claims that the student had been using the word when speaking
with other students after class had started. Evidence obtained supports a finding that Ms.
1For purposes of this investigation, whether she said the word ending in “a” or “er”
is immaterial.
1
II. INVESTIGATIVE PLAN
We developed our plan for this investigation in a manner that is consistent with how
we routinely engage in fact development for internal corporate or nonprofit investigations,
potential litigation, and ongoing litigation. For this engagement, our primary focus – and
challenge – has been to expedite completion in light of intense public interest and the
looming academic year without sacrificing thoroughness. Our process has been as follows.
A. Define Scope of Investigation
Our first task was to define the scope of the investigation. As noted above, and in
fairly broad terms, we have been tasked with investigating certain allegations posted on social
media by a current staff member at PHS concerning comments regarding race allegedly
made by staff at PHS, determining whether the comments were made, investigating all
circumstances involving these or any other related racial comments, and determining
whether the comments were directed towards staff or students.
We understood this to involve determining whether any PCS employees at PHS have
used the racial slurs alleged and the context in which the offensive language was used. In
determining whether any event in the series of occurrences preceding our engagement
violated any law, regulation, or board policy, we considered the instances of the alleged use
of the terms themselves, and whether and how the alleged uses were addressed.
We acknowledge that an investigation such as this one easily can lend itself toward
being unreasonably prolonged or open-ended, particularly where we have been tasked with
determining “all circumstances involving these or other related racial comments[.]” As
explained below, some questions remain unanswered. However, prolonging the investigation
to obtain information that is not directly related to specific individuals’ use of racial slurs
would yield marginal benefits in the context of our broader tasks. Thus, while we present
these findings and acknowledge that some additional information would be helpful, we have
obtained enough information to fulfil our primary investigative goals – to determine who
used racial slurs and in what context, and how those incidents were addressed.
B. Identify Applicable Law
Our next step was to identify the most applicable laws, regulations, and/or Board
Policies that might inform our investigation. We identified the following.2
2 Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq., prohibits
intentional discrimination “on the ground or race, color, or national origin” Alexander v.
Sandoval, 532 U.S. 275. Administrative investigation and enforcement of Title VI in public
school settings generally is conducted by the U.S. Department of Education’s Office of Civil
Rights. In our view, a complete and thorough Title VI investigation involves the assembly of
3
1. Standards of Professional Conduct, 16 NCAC 06C .0602
The Standards of Professional Conduct state, in relevant part:
(a) The standards listed in this Section shall be generally accepted for
the education profession and shall be the basis for State Board
review of performance of professional educators. These standards
shall establish mandatory prohibitions and requirements for
educators. Violation of these standards shall subject an educator to
investigation and disciplinary action by the SBE or LEA.
(b) Professional educators shall adhere to the standards of professional

conduct contained in this Rule. Any intentional act or omission that
violates these standards is prohibited.
(1) Generally recognized professional standards. The educator shall

practice the professional standards of federal, state, and local
governing bodies.
(2) Personal conduct. The educator shall serve as a positive role

model for students, parents, and the community. Because the
educator is entrusted with the care and education of small children
and adolescents, the educator shall demonstrate a high standard of
personal character and conduct.
(3) Honesty. The educator shall not engage in conduct involving

dishonesty, fraud, deceit, or misrepresentation in the performance
of professional duties including the following: . . .
(G) submission of information in the course of an official

inquiry by the employing LEA or the SBE related to facts of
unprofessional conduct, provided, however, that an
educator shall be given adequate notice of the allegations
and may be represented by legal counsel;
* * *
far more data and information than what is required here. Thus, we have not undertaken
such a review.
4
(5) Conduct with students. The educator shall treat all students with respect.
The educator shall not commit any abusive act . . . in the presence of a student
. . . as defined below: (A) any use of language that is considered profane,
vulgar, or demeaning[.] . . .
(6) Confidential information. The educator shall keep in confidence

personally identifiable information regarding students or their family members
that has been obtained in the course of professional service, unless disclosure
is required or permitted by law or professional standards, or is necessary for
the personal safety of the student or others.
2. Prohibition Against Discrimination, Harassment, and Bullying,

Board Policy 1710-4021-7230
The Prohibition Against Discrimination, Harassment, and Bullying states, in relevant

part:
The board acknowledges the dignity and worth of all students and
employees and strives to create a safe, orderly, caring and inviting
school environment to facilitate student learning and achievement. The
board prohibits discrimination on the basis of race, color, national
origin, sex, disability or age and will provide equal access to the Boy
Scouts and other designated youth groups as required by law. The
board will not tolerate any form of unlawful discrimination, harassment
or bullying in any of its educational or employment activities or
programs.
In proscribing discrimination, harassment, and bullying, the Prohibition states that

school system employees “are expected to behave in a civil and respectful manner. The
board expressly prohibits unlawful discrimination, harassment and bullying. . . . Employees
are expected to comply with board policy and school system regulations.” Further, “[a]ny
violation of this policy is serious, and school officials shall promptly take appropriate
action.” “Employees who violate this policy will be subject to disciplinary action, up to, and
including, dismissal.”
When considering if a response beyond the individual level is

appropriate, school administrators should consider the nature and
severity of the misconduct to determine whether a classroom, school-
wide or school system-wide response is necessary. Such classroom,
school-wide or school system-wide responses may include staff
training, harassment and bullying prevention programs and other
measures deemed appropriate by the superintendent to address the
behavior.
5
Under the policy, discrimination “means any act or failure to act that unreasonably
and unfavorably differentiates treatment of others based solely on their membership in a
socially distinct group or category, such as race . . . . Discrimination may be intentional or
unintentional.” “Harassment or bullying behavior is any pattern of gestures or written,
electronic or verbal communications . . . that . . . creates or is certain to create a hostile
environment by substantially interfering with or impairing a student’s educational
performance, opportunities or benefits.” Additionally,
“Hostile environment” means that the victim subjectively views the

conduct as harassment or bullying and that the conduct is objectively
severe or pervasive enough that a reasonable person would agree that it
is harassment or bullying. A hostile environment may be created
through pervasive or persistent misbehavior or a single incident, if
sufficiently severe.
“Examples of behavior that may constitute bullying or harassment include, but are not
limited to, verbal taunts, name calling and put-downs, epithets, [or] derogatory comments or
slurs[.]”
School employees “are required to report any actual or suspected violations of this
policy[,]” and all reports “should be made in accordance with policy 1720/4015/7225,” the
Discrimination, Harassment and Bullying Complaint Procedure.
3. Discrimination, Harassment and Bullying Complaint Procedure,

Board Policy 1720-4015-7225
Board Policy 1720-4015-7225 outlines the procedure for reporting and investigating
allegations that an employee has violated Board Policy 1710-4021-7230. While any report
made through the process set forth in the policy may be anonymous, mandatory employee
reports cannot. To that end, “[a]ny employee who witnessed or who has reliable information
or reason to believe that an individual may have been discriminated against, harassed or
bullied in violation of [Board Policy 1710-4021-7230] must report the offense immediately to
an appropriate individual designated in subsection C.1.” “An employee who does not
promptly report possible discrimination, harassment or bullying shall be subject to
disciplinary action.” Subsection C.1.a. designates the principal or assistant principal of the
school as the appropriate recipient of a complaint if the alleged perpetrator is an employee
of that school. “School officials shall sufficiently investigate all reports of discrimination,
harassment, or bullying, even if the alleged victim does not file a complaint or seek action by
school officials, to understand what occurred and to determine whether further action under
this policy or otherwise is necessary. School officials shall take such action as appropriate
under the circumstances, regardless of the alleged victim’s willingness to cooperate.”
6
4. Staff Responsibilities, Board Policy 7300
Board Policy 7300 states, in relevant part, that all school employees shall: “1. be
familiar with, support, comply with and, when appropriate, enforce board policies,
administrative procedures, school rules and applicable laws; . . . 3. demonstrate integrity,
respect and commitment to the truth through attitudes, behavior and communications with
others; 4. address or appropriately direct any complaints concerning school employees, the
school program or school operations; and 5. support and encourage good school-community
relations in all interactions with students, parents and members of the community.”
5. Code of Ethics for Educators, Board Policies 7305 and 7305-R
Board Policy 7305 provides:
Employee conduct should reflect positively on the integrity and

reputation of the employee and the school system. Each employee shall
demonstrate the highest standards of honesty, integrity, and fairness
when engaging in any activity concerning the school system, including
in relationships with vendors, suppliers, students, parents, the public,
and other employees. The Board will not tolerate deceit or
insubordination. The Board does, however, understand that
inadvertent errors may occur and that honest differences of opinion
will exist.
Employees shall perform their jobs in a competent and ethical manner

without violating the public trust or applicable policies, regulations, or
laws, including NC State Board of Education Policy regarding the
Code of Ethics for NC Educators. (See 7305-R Code of Ethics for
Educators - R&P.) The absence of a specific policy, regulation, or law
covering a particular situation does not relieve an employee from the
responsibility to exercise the highest ethical standards at all times.
Board Policy 7305-R more specifically defines the standards of professional conduct
for PCS educators. Among the obligations it enumerates are to: discipline students justly and
fairly and not deliberately embarrass or humiliate them; participate actively in professional
decision-making processes and support the expression of professional opinions and
judgments by colleagues in decision-making processes or due process proceedings; practice
the generally recognized professional standards of federal, state, and local governing bodies;
and take action to remedy an observed violation of the Code of Ethics for North Carolina
Educators and promote understanding of the principles of professional ethics.
7
6. Employee Use of Social Media, Board Policy 7335
Pursuant to the Board’s social media policy, the Board “acknowledges that school
employees may engage in the use of social media during their personal time. School
employees who use social media for personal purposes must be mindful that they are
responsible for their public conduct even when not acting in their capacities as school
system employees.” Moreover, “[t]he use of electronic media for communicating with
students and parents is an extension of the employee’s workplace responsibilities.
Accordingly, the board expects employees to use professional judgment when using social
media or other electronic communications.”
Significantly, “[t]he [B]oard respects the right of employees to use social media as a
medium of self-expression on their personal time. As role models for the school system’s
students, however, employees are responsible for their public conduct even when they are
not performing their job duties as employees of the school system.” Thus, “[e]mployees will
be held to the same professional standards in their public use of social media and other
electronic communications as they are for any other public conduct.” “Further, school
employees remain subject to applicable state and federal laws, board policies, administrative
regulations and the Code of Ethics for North Carolina Educators, even if communicating
with others concerning personal and private matters.”
Section C of the social media policy specifically addresses content that may or may
not be posted to a social media site. As relevant here:
1. Employees shall not post confidential information about students,

employees or school system business. . . .
5. Employees shall be professional in all Internet postings related to

or referencing the school system, students and other employees.
6. Employees shall not use profane [or] . . . indecent . . . language,

pictures or graphics or other communication that could reasonably
be anticipated to cause a substantial disruption to the school
environment. . . .
9. Employees shall not use Internet postings to libel or defame the

board, individual board members, students or other school
employees. . . .
11. Employees shall not post inappropriate content that negatively

impacts their ability to perform their jobs.
8
“Any employee who has been found by the superintendent to have violated this
policy may be subject to disciplinary action, up to and including dismissal.” Additionally, the
superintendent “shall establish and communicate to employees guidelines that are consistent
with this policy.”
C. Preliminary Steps to Begin Investigation
After defining the scope of our investigation and then determining how best to
contextualize it through the regulation and policies cited above, we reviewed potentially
relevant documents that had been provided to us. We also requested additional documents
during or following interviews that witnesses provided. In very broad terms, the documents
reviewed included: handwritten employee notes, the social media posting, student
statements, employee statements, letters, e-mails, instant messages, personnel documents,
the PHS Staff Handbook, and the PCS Employee Handbook. For document management
and identification purposes, we affixed Bates numbers to each document. All documents
reviewed and/or referenced in this report have been provided.
D. Witness Interviews
After reviewing and organizing the documents we received, we identified potential

witnesses. We interviewed the following3:
• Dr. Alfreida Moore, Chief Officer of Human Resources for PCS

Interviewed at PHS on June 24, 2020.
• Ms. Shanika Mack, Assistant Principal at PHS

• Ms. Caroline Godwin, Principal at PHS

• Mr. Jack Poulos, Assistant Principal at PHS

• Ms. Karen McGowan, Teacher at PHS

Interviewed via videoconference on July 8, 2020.
3 A summary of each witness interview has been included in this report. We note that
the interview summaries are exactly that – summaries. They are not verbatim transcripts of
witness interviews.
9
• Dr. Steven Hill, Superintendent for PCS

• Mr. Rayford Hankins, Teacher at PHS

• Mr. Alex Riley, Communications Coordinator for PCS

We also requested interviews of certain additional fact witnesses by using the contact
information that we received from PCS and/or PHS personnel. The following individuals
either were non-responsive to our requests or could not be reached. They include:
• Ms.
• Mr.
• Ms.
• Mr.
• Ms.
10
III. FINDINGS OF FACT4
A. Principal Caroline Godwin Wrote “Niggers” in the Margin of Her

Notes in October 2018.
1. How the Notes Came to Exist
Caroline Godwin is the Principal of PHS. She has held that position since mid to late
2018. During the fall semester of 2018, PHS was required to close for several days as a result
of Hurricane Florence. On the first day students returned to campus, on or about October
23, 2018, a massive, chaotic fight occurred. Law enforcement was involved and the fight
resulted in the long-term suspension of some students.
After the fight was broken up, students were separated and interviewed. According to
Ms. Godwin, administrators began their investigation by interviewing students who had been
involved. Neither Ms. Godwin nor Assistant Principal Jack Poulos, who also recently had
been hired, were familiar with some of the students involved.
As Ms. Godwin interviewed the students, she took notes on a legal pad. During her
interview, she identified PCS00037 as an image of her original note. The left margin of the
note contains the phrase “My Niggers[.]” She explained the note as follows. As she tried to
identify the fight participants, one student, , repeatedly said that “‘my niggers’
and I were jumped.” She reported that the student was very excited and continued to repeat
himself. Two other students, and , also said that they had been “jumped,” and so
she drew a bracket next to their names. Ms. Godwin stated that she did not repeat the
student’s offensive language while interviewing him or anyone else.
When interviewed, Mr. Poulos said that he is familiar with . He explained

that the two have become close in the past year, and that refers to his close
friends in the manner reported by Ms. Godwin. When asked whether he had any specific
memory of using the phrase on the day of the fight, Mr. Poulos responded that
he “feel[s] comfortable saying yes.” He also said that he has not ever heard Ms. Godwin use
the slur, neither on the day of the fight nor since. He did, however, recall seeing her notes
when they were written, but did not see them again until the social media posting. He saw
the notes while he was in Ms. Godwin’s office. When asked whether Ms. Godwin used the
slur in private to discuss what had been said, Mr. Poulos said, “I don’t think so[,]” and “I
don’t recall her saying that.”
4 Unless otherwise noted, the description of specific events and statements attributed
to particular witnesses are contained in the witness interview summaries attached in the
appendices.
11
After interviewing Ms. Godwin and Mr. Poulos, we sought an interview of

to assess the accuracy of the accounts provided by Ms. Godwin and Mr. Poulos. As
of the date of this report, we have not been successful in obtaining an interview. We also
note that Mr. Hankins helped break up the October 2018 fight. During that time, he did not
hear any teacher or administrator use racial slurs, but declined to answer whether any student
reported to him that a teacher or administrator had used racial slurs during the fight or its
investigation.
2. Investigation of Ms. Godwin’s Notes
On June 8, 2020, Mr. Hankins published a version of Ms. Godwin’s notes on social
media websites. Alex Riley, Communications Coordinator for PCS, called Superintendent
Hill and Ms. Godwin to alert them of the posts. Dr. Hill already had received notice from a
Board member. During his interview, Mr. Poulos recounted being in Ms. Godwin’s office
for a non-specific reason and overhearing a telephone conversation between Ms. Godwin
and Dr. Moore (on speakerphone). While Dr. Moore and Ms. Godwin were talking, Mr.
Poulos says that he saw Ms. Godwin retrieve her notepad with the note from her files. He
observed that the note on the pad and what had been posted on social media were different.
He heard Ms. Godwin express the same to Dr. Moore. In particular, the word “My” appears
above “Niggers” in the note Ms. Godwin claims to be the original. “My” does not appear on
the social media posting. Additionally, the purported original note lists only seven students
involved in the fight. The social media posting lists an eighth individual – [last
name redacted].
Ms. Godwin said during her interview that she took a picture of her original note.5
She said that she did not copy the note in physical or digital form. Dr. Moore told Ms.
Godwin to bring the pad (and papers concerning Ms. McGowen, see infra Section III.B.) to
her office. 6 Mr. Poulos said during his interview that he did not observe Ms. Godwin alter
her notepad in any way. Ms. Godwin also said that she did not alter her notes.
Dr. Hill, Dr. Moore, Mr. Riley, and Ms. Godwin subsequently met in Dr. Moore’s
office. Ms. Godwin recounted how the note came to exist, and provided information
consistent with what she told us during her interview. Ms. Godwin also provided a
handwritten statement describing the events of the day and her collection of relevant
documents. 7 She also gave Dr. Moore what she contended was the original note and
documents concerning Ms. McGowen. Dr. Hill suggested that Dr. Moore and Ms.
McGowen seal the note in a Ziplock bag, which they did. Dr. Moore and Ms. McGowen
also signed a separate document reflecting the chain of custody for the note. Dr. Moore
5See PCS00001.
6Ms. Godwin also said that when she attempted to retrieve Karen McGowen’s
personnel file, it was empty.
7 See PCS00004.
12
signed her name on the seal and dated the same. During Dr. Moore’s interview, she
produced the sealed envelope, which remained sealed.8
B. Karen McGowen Said “Nigger” or “Nigga” on Two Separate

Occasions – Once in a Classroom Full of Students and the Other in the
Presence of a Student
1. Ms. McGowen’s Use of the Word
Karen McGowen is a teacher at PHS, and has taught there for approximately 20
years. She teaches English for grades 9 through 12. In October 2019, her third period
English 12 class ran from approximately 12:00 pm to 1:30 pm or 12:30 pm to 2:00 pm,
depending on the day. The class began immediately after lunch, and typically had anywhere
from 28 to 36 students. Roughly half of the students were black and half were white.
On October 10, 2019, after Ms. McGowan’s class had started, she spent a period of
time attempting to get the class under control. Her co-teacher, Carrie Falcone, had removed
a student from the class for behavioral issues. According to Ms. McGowen, as she was
attempting to gain control of the class a student, , was talking to students
across the classroom, and in so doing, he repeatedly said the word “nigga.” Ms. McGowen
explained during her interview that after attempting unsuccessfully to stop
from repeating the word, she said to him, “just stop saying nigga.” She recalls
responding by saying, “what did you say” and/or “what did you call me?” She
reported that she knew immediately that she should not have used the word and that she
knew was upset because of his reaction. She claims that she responded by
telling him that she did not call him the slur.
Ms. McGowen dismissed from the classroom, although during her

interview she did not recall doing so. Documents we have reviewed, however, and two of
which were authored by Ms. McGowen, confirm that was, in fact, dismissed
from class. 9
8See PCS00037-38.
9See e.g. PCS00016 (e-mail from Ms. McGowen to ( ’s
mother) informing her that she sent to in school suspension); PCS00019
(statement from Sararesa Hudson reporting that McGowen told her that she had sent
“ ” out of class); PCS00035 (instant message from McGowen to Poulos stating she
had dismissed “ ” from class); PCS00008-9 (student statements stating that McGowen
dismissed from class).
13
Shortly thereafter, Sararesa Hudson 10 sent Ms. McGowen an instant message

informing her that one of McGowen’s students, , was in her office.11 Ms.
McGowen went to Ms. Hudson’s office. While there, and in ’s presence, Ms.
McGowen said during a conversation with Ms. Hudson that she did not understand why
kids (or ) use the slur and get upset or angry when it is repeated to them (or
him).12 Ms. McGowen does not dispute that she said “nigga” in Ms. Hudson’s office while a
student was present.
At 1:19 p.m on October 10, Ms. McGowen sent an e-mail to ,

’ mother, recounting McGowen’s version of what had happened in
class. Ms. McGowen did not tell
13 that she had used offensive language.
wrote back, “[h]e actually just sent me a message saying that you called him a nigga.
I told him that I do not believe that and he was probably saying the word and you asked him
to stop using it!” Ms. McGowen responded, “yes, that is exactly what happened.”
After class, Ms. McGowen went to the school’s front office, and reported the
incident to Mr. Poulos. Mr. Poulos recalled skimming a note written by
about the incident that had been left in his office. wrote, in relevant part,
“I’m in class talking to my folks & we talking how we talk not even loud but Ms. McGowen
says out loud Im tired of the word Nigger wit a hard R & I was wrong for how I delt with
but at the same time no white person now ah days should ever come out dey mouth with
that word as a teacher should’ve said I don’t want to hear the N word but she said whole
word and more[.]” also wrote, “It’s not cool or ok in any type of shape or
form. I felt threatened[.]” Mr. Poulos referred the matter to Ms. Mack due to time
14
constraints and other duties. Ms. Mack read the note and determined that administration
needed to address the matter.
10 Ms. Hudson is a Student Support Specialist for Pender High School, and was
employed at the time by Communities in Schools of Cape Fear.
11 During her interview, Ms. McGowen was unsure how she learned that
was in Ms. Hudson’s office. She appears to have learned through instant message. See
PCS00026.
12 During her interview, Ms. McGowen referred to kids generally becoming upset. In
her statement, however, Ms. Hudson wrote that Ms. McGowen was referring specifically to
. See PCS00019.
13 Ms. McGowen said during her interview that she called after class, and
then sent the e-mail to follow-up. The e-mail exchange is at PCS00015-16.
14 See PCS00011.
14
2. Administration’s Response to Ms. McGowen’s Reported Use of the

Word
After reviewing ’s note, Ms. Mack immediately reported the matter to

Principal Godwin and inquired about how to proceed with an investigation. During her
interview, Ms. Mack recalled telling Ms. Godwin that the substance of ’s
allegation against Ms. McGowen was highly offensive, and Ms. Godwin responded by also
stating that the matter needed to be investigated. Ms. Godwin directed Ms. Mack to begin
collecting student statements to document what had happened. She also directed her to meet
with Ms. McGowen later in the day.
For her part, Ms. Godwin recalled Ms. Mack stating that the slur that had been used
should never be used. Ms. Godwin also said during her interview that she wanted Ms. Mack
to conduct as much of the investigation as she felt comfortable doing. She recognized that
Ms. Mack was concerned and discontent, but also wanted to make sure that the investigation
was fair and all the information gathered was correct. Ms. Godwin informed Dr. Alfreida
Moore the same day, and told her that Ms. Mack would send her student statements.
Ms. Mack reviewed the roster for Ms. McGowen’s class to determine which students
to interview. She identified students who she thought would be objective, and determined
which of those students were present that day. Ms. Mack interviewed the students
individually to document their view of the events. She asked those students to write down or
let her know about what they had witnessed.15 Ms. Mack also asked Ms. Hudson for a
statement.16 Ms. Hudson provided a statement, and in so doing, also expressed concern to
Ms. Mack about potentially being the subject of retaliation.17
The same day of the incident, Ms. Mack and Mr. Poulos met with Ms. McGowen
about the allegations. Ms. Mack stated during her interview that she asked Ms. McGowen to
recount the incident. Ms. McGowen’s immediate response was something to the effect of, “I
don’t see the point of this; the students were being rowdy,” and she commented that she did
not have anything to say about it. Ms. Mack told her that they would be back in touch
because they were still investigating and collecting statements from students. Later in the
interview, Ms. Mack confirmed that the document stamped PCS00018 is a copy of her notes
from the meeting with Ms. McGowen on October 10, 2019. Ms. Mack also wrote a letter to
Dr. Moore documenting the meeting.18 Ms. Mack faxed the letter and the student statements
that she had obtained to Dr. Moore on October 11. In the letter, Ms. Mack wrote that Ms.
McGowen said the following during her meeting with Ms. Mack and Mr. Poulos: “I . . . told
15 See PCS00005-10.
16 See PCS00019.
17 See PCS00022.
18 See PCS00014.
15
the student, ‘Stop saying the word Nigger,’ It makes me uncomfortable and the students in
this class as well. I figured if he said it, it was ok for me to say it.”
After the meeting, Ms. McGowen sent an e-mail to Ms. Godwin, Ms. Mack, and Mr.
Poulos, forwarding the e-mail that she previously sent to , ’s
mother. She later printed a copy of the e-mail and wrote on it, “I told to stop saying
‘nigga’ in class on 10-10-19.” Ms. McGowen provided the e-mail and the above-referenced
signed statement to administrators.
Administrators next met with Ms. McGowen on October 15, 2020. Ms. Mack lead
the meeting and both read and presented a letter of reprimand to her. Dr. Moore previously
had reviewed the letter. The letter states, in part:
This letter is to address actions that took place last week and were
discussed with administration. On October 10, 2019, there was a
student statement which reported your use of the racial slur, ‘Nigger’ in
your classroom in response to a student’s disruptive behavior. It was
reported that a student was utilizing the slur with other peers and you
requested he stop using it by repeating the phrase. . . . Witness
statements explained how uncomfortable and demeaning the witnesses
felt when you utilized the slur in the classroom and in a private office. .
. . Please be advised that the use of derogatory racial slurs repeated in
front of students in a classroom is not acceptable behavior and will not
be tolerated.
The letter cites the Standards of Professional Conduct as prohibiting the use of any language
that is considered “profane, vulgar or demeaning” in the presence of a student.
Ms. McGowen refused to sign the letter. She explained during her interview that she
wanted the letter to reflect that she said “nigga” and not “nigger.” She considers the former
to be slang and the latter to be a slur. She also did not want the letter to imply that she had
called a slur. Finally, she wanted the full e-mail exchange with to
be considered as part of her statement, not just the handwriting on the e-mail that she had
printed.
At Dr. Moore’s instruction, administrators added an addendum to document Ms.

McGowen’s refusal to sign the letter. The substance of the letter remained unaltered, and the
final version was placed in Ms. McGowen’s personnel file at PHS.19
19 From a legal standpoint, the distinction as to whether the letter of reprimand was
kept in the personnel file or sent to the Central Office is inapposite. Pursuant to N.C. Gen.
Stat § 115C-319, “a personnel file consists of any information gathered by the local board of
education which employs an individual, previously employed an individual, or considered an
16
C. Rayford Hankins Posted Two Images of Documents that Contain the

Word, “Nigger,” on Social Media Websites.
On June 8, 2020, PHS teacher Rayford Hankins posted on social media two images
of documents that contain the word, “nigger.”20 The first is an image of a version of Ms.
Godwin’s note concerning the October 2018 fight. The second is an e-mail that he received
from Sararesa Hudson and which contained an identical copy of the statement that Ms.
Hudson provided to Ms. Mack during the administration’s investigation of Ms. McGowen.21
Mr. Hankins said during his interview that he redacted students’ last names in both
documents. He also said that he posted the documents to “bring light to discrimination” at
PHS. In addition to posting the images on social media, Mr. Hankins wrote, “[i]t always has
been a hush hush environment to work in, not anymore. Who am I to keep quiet? The
people would love to hear your excuses. Pender County Schools[.]”
Mr. Hankins would not disclose how he came to possess a physical or digital copy of
the version of Ms. Godwin’s notes that he posted. He did state, however, that he has not
ever seen any other version of the notes other than what he posted online.22 He also said
that other than redacting student names, he did not alter the documents in any other way.
Lastly, Mr. Hankins said during his interview that he orally reported the use of the slur in
Ms. Godwin’s notes to someone at the county level. When asked to clarify whether he
reported the notes to someone in the Central Office or the Superintendent’s office, his
attorney stated that Mr. Hankins reported the issue to a person who he believed to be the
proper official and that nothing was done in response. Mr. Hankins did not disclose to
whom he made the report. Without that information, we cannot determine whether any
specific person received the report and failed to act because we do not know who that
person is.
individual’s application for employment, and which information relates to the individual’s
application, selection or nonselection, promotion, demotion, transfer, leave, salary,
suspension, performance evaluation, disciplinary action, or termination of employment
wherever located or in whatever form.” (Emphasis added).
20 See PCS00002.
21 Id.
22 Though not the focus of this investigation, how Mr. Hankins received the notes is
relevant to (1) whether any student ever had access to them, and (2) whether the notes (or
what was presented as the original) were altered in any way to minimize or inflame the
significance of the racial slur written in the margin of the notes. These questions remain
unanswered.
17
IV. CONCLUSIONS
As noted in Section II.B above, the series of events preceding this investigation
implicates a number of regulations and Board policies. In light of the facts obtained to date
and applicable regulations and policies, we conclude as follows.
A. Ms. Godwin Did Not Violate the Standards of Professional Conduct or

Any Board Policy in Writing Her Notes.
Ms. Godwin did not violate any regulation or Board policy in writing her notes from
the October 2018 fight. No evidence suggests that she allowed any student to see them.
Likewise, there is no evidence that she repeated the slur while interviewing students.23 This is
significant because the Standards of Professional Conduct for NC Educators, 16 NCAC 06C
.0602(b)(5)(A), prohibits the use of any language that is considered “profane, vulgar, or
demeaning” in the presence of a student. There is no evidence that Ms. Godwin has engaged
in this sort of prohibited conduct. To be clear, we have reached this conclusion based on the
absence of any evidence that Ms. Godwin referred to or characterized any student as a
“nigger.” Had that been the case, whether the notes were private or not is inapposite.
Referring to any student in this manner unquestionably would exhibit racial animus and be
unacceptable.
Additionally, we observe that the slur is contained in several handwritten or typed

documents generated by PHS employees that either are notes, informal communications, or
official communications among adults to document with sufficient particularity actual or
alleged uses of the word.24 As is the case with Ms. Godwin’s notes, no evidence suggests that
any of these documents or communications have been shared with students, and therefore
they do not violate the Standards of Professional Conduct. Ms. Godwin’s notes should be
construed in the same manner.
B. PCS’s Investigation of the Circumstances Concerning Ms. Godwin’s

Notes Was Sufficient.
PCS’s investigation of the circumstances concerning Ms. Godwin’s notes was

sufficient. Board Policy 7300, Staff Responsibilities, is most applicable. It states that all
23 We note, again, that we attempted unsuccessfully to interview the student who

allegedly used the slur that Ms. Godwin wrote to confirm (1) that he said it, and (2) that she
did not repeat it.
24 See e.g. PCS00014 (Mack letter to Dr. Moore); PCS00015 (McGowen statement to
administrators); PCS00017 (Mack handwritten notes describing conversation with

McGowen); PCS00018 (same); PCS00019 (Hudson statement to Mack); PCS00020
(McGowen Letter of Reprimand); PCS00022 (Mack statement); PCS00035 (McGowen
instant message to Poulos).
18
school employees shall “address or appropriately direct any complaints concerning school
employees, the school program or school operations[.]”25
Immediately upon the publication of Ms. Godwin’s notes, PCS officials summoned
her to Dr. Moore’s office, interviewed her, and took her statement. Within days, officials
engaged our firm to investigate the circumstances surrounding the notes. We have presented
our findings in this report.
C. Ms. McGowen Violated the Standards of Professional Conduct and

Board Policy 1710-4021-7230.
We conclude that Ms. McGowen’s use of a racial slur on two separate occasions
violated the Standards of Professional Conduct. Ms. McGowen admits that she said “nigga”
on two separate occasions in the presence of students. The word was not used in any
academic context and was repeated for the sole purpose of complaining about a student’s
use of it. In context, the word’s use was “profane, vulgar, or demeaning[,]” especially where
Ms. McGowen recognizes that she should not have used the word. Additionally, despite
saying during her interview that she immediately knew that she should not have said the
word to , moments after using it in the classroom, she again said the word
while knowingly in the presence of another student. Multiple PCS witnesses agreed that
repeating a slur, or any other inappropriate language, is not proper and is prohibited by the
Standards of Professional Conduct. Thus, Ms. McGowen knew or should have known that
repeating the slur was prohibited.
Ms. McGowen’s use of the slur also violated the Prohibition Against Discrimination,
Harassment, and Bullying. As discussed in Section II.B.2, “[h]arassment or bullying behavior
is any pattern of . . . verbal communications . . . that . . . creates or is certain to create a
hostile environment by substantially interfering with or impairing a student’s educational
performance, opportunities or benefits.” “‘Hostile environment’ means that the victim
subjectively views the conduct as harassment or bullying and that the conduct is objectively
severe or pervasive enough that a reasonable person would agree that it is harassment or
bullying. A hostile environment may be created through pervasive or persistent misbehavior
or a single incident, if sufficiently severe.”
Importantly, explained in his letter that he “felt threatened.”

Additionally, in light of ’s reaction and multiple PCS employees’ agreement
25 Board Policy 1720-4015-7225, the Discrimination, Harassment and Bullying
Complaint Procedure, also is not applicable because no person has alleged or provided any
plausible evidence to suggest that Ms. Godwin used a slur to refer to students. Rather, the
only evidence we have been provided is that her notes document how one particular student
referred to other students involved in a fight.
19
that slur should not have been repeated in any context, it is reasonable to conclude that the
conduct was “objectively severe or pervasive enough that a reasonable person would agree
that it is harassment or bullying.” Further, by dismissing from class because
of his response to what she said, the conduct “interfer[ed] with or impair[ed] a student’s
educational performance, opportunities or benefits.” All employees have received notice that
the use of a racial slur, particularly while addressing a student as Ms. McGowen did,
potentially violates the Prohibition Against Discrimination, Harassment, and Bullying. The
policy specifically states, “[e]xamples of behavior that may constitute bullying or harassment
include, but are not limited to, verbal taunts, name calling and put-downs, epithets, [or]
derogatory comments or slurs[.]” Ms. McGowen’s successive recitation of the slur while
knowingly in the presence of students falls within prohibited conduct under Policy 1710-
4021-7230.
D. The Administration’s Investigation of the Complaint Against Ms.

McGowen Was Not Fully Compliant With Board Policy 1720-4015-7225.
Although the administration’s investigation of ’s complaint was

substantial, it did not fully comply with Board Policy 1720-4015-7225, the Discrimination,
Harassment and Bullying Complaint Procedure. The Policy requires the investigator to
“interview all individuals who may have relevant information, including (1) the complainant;
(2) the alleged perpetrator(s); (3) individuals identified as witnesses by the complainant or
alleged perpetrator(s); and (4) any other individuals, including other possible victims, who
may have relevant information. Although the administration responded promptly to
’s complaint and took it seriously, no one interviewed or had a
substantive conversation with him about his allegations. See Board Policy 1720-4015-7225,
Sec. D.2.a.
Additionally, to the extent the administration considered and determined that Board
Policy 1720-4015-7225 was not violated, it did not inform the complainant ]
of the “investigator’s determination and the process for addressing the complaint[.]” See id.,
Sec. D.2.b. Likewise, no information was provided to as to whether the
complaint was substantiated. See id., Sec. D.3.a.
20
E. Mr. Hankins’ Posting Did Not Violate Board Policy 7335
Rayford Hankins’ June 8, 2020, posting of two images that contain the word “nigger”
on social media websites did not violate Board Policy 7335, Employee Use of Social Media.
In consideration of Sections C.1, 5, 6, 9, and 11, we observe the following.
First, with respect to Section C.1, Mr. Hankins redacted students’ last names from the
version of Ms. Godwin’s notes that he published. He also redacted student names from the
e-mail that he received from Ms. Hudson. Additionally, because he published the e-mail that
he received from Ms. Hudson, and not any disciplinary or personnel file, he did not post
confidential information about students, employees or school system business.
Second, with respect to Section C.5, nothing about Mr. Hankins posting can
reasonably be construed as unprofessional. The language that he typed is not unprofessional.
Although one of the images that he published has been altered from its original format, he
states, and there has been no evidence to the contrary, that he has not seen any other version
of the document and did not alter it. Additionally, although the second image references Ms.
McGowen by name, neither Mr. Hankins’ commentary nor the information contained within
the image about Ms. McGowen is unprofessional.
Third, with respect to Section C.6, in posting the two images, Mr. Hankins published
a racial slur that may be considered profane and/or indecent. But, the measure of what
“could reasonably be anticipated to cause a substantial disruption to the school
environment” is fairly vague and subjective.26 More importantly, there appears to be some
tension between this clause and the Policy’s pronouncement that the board “respects the
right of employees to use social media as a medium of self-expression[.]” Mr. Hankins
explained that in publishing both documents, he sought to publicize what he believes to be
discrimination at PHS. Moreover, what Mr. Hankins published ultimately is true – PCS
employees have, in fact, verbalized or written racial slurs under varying circumstances.
Fourth, with respect to Section C.9, Mr. Hankins did not defame the board,
individual board members, students, or other school employees in the social media posting.
Although someone altered Ms. Godwin’s notes, he did not attribute the notes to her.
Additionally, Ms. McGowen has admitted to verbalizing a racial slur on two occasions.
Lastly, we note that enforcement of the social media policy is within the
Superintendent’s discretion. See Policy 7335, Section D (“Any employee who has been found
by the superintendent to have violated this policy may be subject to disciplinary action, up to
and including dismissal.”). During their interviews, both Dr. Hill and Mr. Riley said that
26As a practical matter, we note that school was out on June 8, 2020, and therefore
any disruption to the “school environment” would have been minimal.
21
PCS’ approach to addressing violations of the social media policy has focused on coaching
rather than discipline.27
IV. WITNESS ACCOUNT SUMMARIES
For completeness, we have included the following witness interview summaries as

part of this report.
A. Dr. Alfreida Moore – Appendix A
B. Ms. Shanika Mack – Appendix B
C. Ms. Caroline Godwin – Appendix C
D. Mr. Jack Poulos – Appendix D
E. Ms. Karen McGowan – Appendix E
F. Dr. Steven Hill – Appendix F
G. Mr. Rayford Hankins – Appendix G
H. Mr. Alex Riley – Appendix H.
27 We also have considered whether Mr. Hankins violated Board policies that
mandate the reporting of actual or potential discrimination, harassment, or bullying. Board
Policy 1710-4021 makes clear that all employees have a mandatory obligation to report any
“actual or suspected” violations of the prohibition against discrimination, harassment, and
bullying. Likewise, Policy 1720-4015-7225 states that “[a]ny employee who has witnessed or
who has reliable information or reason to believe that an individual may have been
discriminated against, harassed or bullied in violation of policy 1710/4021/7230 must report
the offense immediately to an appropriate individual designated in subsection C.1[.]” Ms.
Hudson sent Mr. Hankins an e-mail on October 11, 2019 at 9:05 a.m. describing the events
she witnessed in her office, and there is no evidence that Mr. Hankins ever reported the
allegation to an administrator. That same day, however, and potentially within only a few
hours, Ms. Hudson provided the exact same statement to Ms. Mack. And so, while Mr.
Hankins’ failure to report likely is a technical violation of Board policy, what, if any,
additional information he could have reported is unknown (he was neither in class nor Ms.
Hudson’s office when the slur was repeated, but also declined to say during his interview
whether he had discussed the matter with or ). Nonetheless,
Board policies make clear that any suspected discrimination is to be taken seriously and must
be reported.
22
APPENDIX A
Dr. Alfreida Moore Interview Summary

June 24, 2020
Dr. Alfreida Moore is the Chief Officer of Human Resources for Pender County Schools
(PCS), and has held that position since 2016. She previously served as the Director of
Human Resources, from December 2007 until she assumed her current position.
Among her several job duties and responsibilities are to oversee personnel matters and
investigations, ensure that PCS Board policies are being followed, ensure that policies are
revised and updated, and assist with professional development.
Dr. Moore typically gets involved in personnel investigations after the matter is initially
investigated at the school level. If the matter has not been resolved at the school and
warrants additional investigation, she becomes involved. Some investigations are initiated
through her office, for example if an employee has been charged with a crime or the matter
concerns theft, harassment, or bullying. Almost all investigations of school employees are
initiated at the school level. School administrators will then contact her to keep her informed
of the progress of the investigation as well as seek guidance throughout the process.
Investigations of teachers start at the school level. Investigations of principals start at the
district office and involve the superintendent. For example, if an assistant principal has a
complaint about a principal, Dr. Moore would be the first in line to investigate. If an
investigation is assigned to Dr. Moore, she would report her findings to the superintendent.
If a matter involving a principal is reported to her, the investigation would start in her office.
Other than the circumstances at issue in the current investigation, Dr. Moore is not aware of
any teacher or principal using a racial slur at Pender High School. By not being aware, she
means that she has not received any report. She is not aware of any rumors of principals or
staff using racial slurs. Dr. Moore also is not aware of any teachers or administrators using
other inappropriate language in the presence of students.
Dr. Moore learned about the situation with Ms. Godwin through the Facebook post. Ms.
Godwin came to Dr. Moore’s office to meet with her and Dr. Hill on the day the post was
made. Dr. Moore’s knowledge about the notepad is based on information provided by Ms.
Godwin at that meeting. The meeting was attended by Dr. Hill, Alex Riley (communications
coordinator), Ms. Godwin, and Dr. Moore. Ms. Godwin reported the notes were taken as
Ms. Godwin wrote a list of students’ names who were involved in a fight that had occurred
on the first or second day after students returned to school following Hurricane Florence in
October 2018. Ms. Godwin and administrative staff, including a school resource officer
(Stokes), were conducting the investigation to determine who was involved in the fight and
their role. The meeting at Dr. Moore’s office lasted for approximately one hour at the
Pender Resource Center in Burgaw. During the meeting, Ms. Godwin talked about the fight
and explained that it originated from some community rifts that had occurred during the
time students were away as a result of the hurricane.
Ms. Godwin told Dr. Moore, in regards to the notepad, that she wrote the slur in the margin
to document what one of the students was saying. Ms. Godwin told Dr. Moore that the
student said, “they’re my n’s,” and that is what she wrote in quotation marks. Ms. Godwin
admitted writing the slur. Dr. Moore reported that Ms. Godwin was very upset and nervous
during the meeting. Dr. Moore stated during the interview that because the fight was a
student-related incident, she was not involved.
Dr. Moore identified Ms. Godwin’s handwritten statement that Ms. Godwin provided
during the meeting. Dr. Moore clarified Ms. Godwin’s reference to “the student files” in the
statement as referring to statements written by students in connection with the investigation
of Karen McGowen. Ms. Godwin’s statement from that day also mentions a “HR file
belonging to Ms. Mack on Karen McGowen.” Dr. Moore explained that she understood that
Ms. Godwin had to gather Ms. McGowen’s HR file from Ms. Mack because the related HR
file in her own office was empty with the exception of one document. Dr. Moore recalled
later in the interview that the sole document left in the file was a student statement written in
red ink. Ms. Godwin told her that the file had been taken or someone had removed papers
from it.
Dr. Moore acknowledged that PCS00001 is an image of the notepad that Ms. Godwin
brought to her office on June 8. She also noted that on the social media post, the word “my”
is omitted from the margin. Additionally, the name “ ” appears on the social media
post, but is not on the note that she saw in her office. Ms. Godwin relayed to Dr. Moore
that the name “ ” was not written in her handwriting and that what Ms. Godwin
shared with Dr. Moore and Dr. Hill was the original document.
During the interview, Dr. Moore presented a sealed envelope that contained a copy of the
note Ms. Godwin provided to her in her office, as well as a chain of custody log, signed by
both Dr. Moore and Ms. Godwin, noting the transfer of possession of the document.
During the interview, images of the envelope were taken, the envelope remained sealed, and
Dr. Moore maintained possession after the pictures were taken.
Dr. Moore has not had any other meetings with Ms. Godwin about this issue. She told Ms.
Godwin that if she had any additional information she needed to share, then to please
contact her. Dr. Moore has not had any subsequent meetings with Dr. Hill about the
Godwin issue.
Dr. Moore is not aware of any other allegation that Ms. Godwin has used a racial slur. Dr.
Moore also said that there are not any write-ups in Ms. Godwin’s personnel file.
Dr. Moore asked Mr. Hankins to meet with her after the post. She called him and left a
voicemail on June 8 (Monday) asking if he would meet with her. When she checked her e-
mail the next day she saw that he had sent her an e-mail the previous night requesting to use
leave for the remainder of the week due . Dr.
Moore responding by informing him that she would forward the request to the benefits
coordinator. Dr. Moore also informed Mr. Hankins that she had left him a voicemail and to
contact her as soon as possible. Later that Tuesday afternoon, Dr. Moore called Mr. Hankins
and they spoke. She asked him to meet with her, and he asked whether he could follow-up
via e-mail to let her know. The following day, she received an e-mail saying that he did not
feel comfortable meeting with HR without an attorney. Dr. Moore responded by thanking
him for following-up.
Dr. Moore does not have any personal knowledge of who may have removed items from the
files in Ms. Godwin’s office. Dr. Moore asked Ms. Godwin to look at camera footage to see
if surveillance camera footage may show who accessed her office. Dr. Moore does not know
who else has lawful access to Ms. Godwin’s office.
Dr. Moore first learned about the situation involving Karen McGowen from Ms. Godwin.
Ms. Godwin either called her or sent her an e-mail the day the slur was reported, and
informed her that Assistant Principal Shanika Mack would be sending her student statements
taken during the investigation. Ms. Godwin and Dr. Moore had a follow-up conversation
that day or shortly thereafter and Dr. Moore observed that most of the student statements
indicated that Ms. McGowen did not call the student a slur, but she did repeat the slur when
she told the student to stop saying it. Ms. Godwin agreed with the observation. Dr. Moore
asked what the next steps would be and Ms. Godwin relayed that Ms. Mack, Mr. Poulos, and
Ms. Godwin would meet with McGowan. Ms. Godwin reported that Ms. McGowan asked if
she needed a lawyer, and Ms. Godwin’s response was that the matter was something that
needed to be discussed regardless. Dr. Moore told Ms. Godwin to follow-up with her once a
draft of the letter of reprimand was written and to send it to her for review. Dr. Moore
provided feedback on the letter. After administrators met with Ms. McGowan, Ms. Godwin
informed Dr. Moore of the meeting and Ms. McGowen’s refusal to sign the letter. During
the meeting Ms. McGowen maintained that she did not direct the slur at the student, but
repeated what he had said. Dr. Moore told Ms. Godwin to add an addendum to the letter
reflecting that they met and to note that she refused to sign.
Dr. Moore did not have any direct communication with Ms. McGowen on the matter. Dr.
Moore’s involvement was limited to receiving information from administrators and
providing guidance on how to proceed.
Dr. Moore became involved in this investigation because of its sensitive nature due to the
language used. Dr. Moore believes that it was appropriate for administrators to bring the
issue to her. If it had been the case that McGowen had called the student the slur, the
situation would have warranted additional conversation, probably with Dr. Moore or with
Dr. Moore and Ms. Godwin discussing cultural awareness or cultural sensitivity training. Dr.
Moore also said later in the interview that if Ms. McGowen had called the student the slur,
the situation could have led to immediate suspension pending the outcome of an
investigation.
Dr. Moore believes that there is a difference between calling the student a slur and repeating
it, and to have repeated the slur is not appropriate. Dr. Moore agrees that it would not be
appropriate for a teacher to repeat any other profanity after a student uses it. Dr. Moore
cited the Code of Ethics for professional educators as the basis for concluding that it is not
appropriate for a teacher to use a racial slur. She also recognized the Standards of
Professional Conduct as a basis for determining that repeating a slur is inappropriate.
Dr. Moore recalls receiving the letter from Ms. Mack describing the meeting between Ms.
Mack, Mr. Poulos, and Ms. McGowen. Ms. Mack also faxed some of the student statements
on or around October 11 to Dr. Moore. Dr. Moore recalls having a brief conversation with
Ms. Mack about the status of the investigation. Ms. Mack and Ms. Godwin were conducting
the investigation together. Ms. Mack had become frustrated due to the sensitive nature of
the matter.
Dr. Moore’s understanding of the final outcome was that the letter of reprimand was given
to Ms. McGowen, but Ms. McGowen would not sign it. Ms. Godwin indicated to Dr. Moore
that she was choosing to keep the letter in the personnel file at the school because this was
the first incident that she had with Ms. McGowan. Dr. Moore said that the file maintained in
the Central Office is the official personnel file, and that principals typically keep
documentation in their own files at the school if they do not want it to be in the official file.
Dr. Moore is not aware of any other circumstance in which Ms. McGowen has been accused
of using a racial slur.
Dr. Moore believes that the matter was investigated and handled appropriately. Dr. Moore
did not meet with Ms. Godwin about this matter because she was confident that it was
handled appropriately at the school level.
Training on the prohibition against discrimination, harassment, and bullying is mandatory at

the start of each school year. The training recently was made available online via the
ClassLink training module. After the interview, Dr. Moore provided records showing that
Ms. Godwin and Ms. McGowen had completed the online training modules for Board
Policy 1710-4021-7230.
With respect to the second image that was posted by Mr. Hankins on social media, Dr.
Moore said that she requested access to Mr. Hankins’ and Ms. Hudson’s e-mail records
because she wanted to determine when information was shared with Mr. Hankins and
whether the access occurred through school e-mail. Based upon the e-mail records, Dr.
Moore determined that in October 2019 Hudson sent Hankins the same written statement
that she had provided to Ms. Mack.
APPENDIX B
Shanika Mack Interview Summary

June 24, 2020
Ms. Shanika Mack is one of two Assistant Principals at Pender High School. She has held
this position since January 2017.
Her several job duties and responsibilities involve performing tasks at the principal’s
discretion, the testing and evaluation of teachers, and student discipline.
Ms. Mack’s general involvement in investigating matters of student or teacher discipline

depends on the circumstances. If she is responsible for handling the disciplinary matter and
the matter requires a more in-depth investigation, she will be involved in any way that she
can. Ms. Mack clarified that investigations of complaints about teachers are based on which
administrator is assigned to the particular department. She oversees English, Math, Arts, and
Exceptional Children. With respect to the McGowen matter, once she received the
information prompting the investigation, she determined that the issue required an
immediate response.
Other than the specific matters being investigated with respect to Ms. Godwin and Ms.
McGowen, Ms. Mack does not have any personal knowledge of any racial slurs being used
by staff directed toward students or other staff. Likewise, she has not received any reports of
racially charged language being used.
Ms. Mack has heard students on occasion use racial slurs between each other in the hallway.
On those occasions, Ms. Mack generally corrects the student by pulling him or her aside and
discussing the issue. She recounted a specific occasion in which a student was in her office
for an unrelated disciplinary matter and began using the n-word. She asked him to refrain
from using the word and explained why it was not appropriate in school. Ms. Mack did not
repeat the word when she corrected the student. Similarly, when students use profanity, Ms.
Mack corrects them by asking them to refrain from using the offensive language and she
does not repeat the offensive word. Ms. Mack stated that adherence to the Code of Ethics
and her own personal choices would make it inappropriate for her to repeat certain words. If
a teacher has a consistent problem with a student using offensive language, parents would be
contacted and the problem should be documented in the Educators Handbook (a discipline
log).
The Standards of Professional Conduct and Code of Ethics are reviewed at the faculty
meeting at the beginning of the year. Staff are provided an opportunity to ask questions, and
each staff member signs a statement acknowledging receipt and review of the Faculty
Handbook. The Handbook is provided in physical and electronic form.
Ms. Mack does not have any personal knowledge of the handwritten note posted on social
media on June 8, 2020 that had a racial slur written in the margin. She clarified, however,
that Ms. Godwin told her, during a meeting with her and Assistant Principal Jack Poulos,
that the handwritten notes were taken in the aftermath of an October 2018 fight. Ms.
Godwin went on to explain to them that the slur that was written in the margin referred to
what students were saying about each other, particularly with respect to who was on whose
side during the fight. Ms. Mack had not seen the note prior to its posting on social meeting
and she has not had any other discussion about the note other than during the meeting on
June 8. Ms. Mack later stated that Ms. Godwin inquired as to why the note that was posted
on social media differed from the original and why it had been altered. Ms. Mack is not
aware of any other circumstance (other than the letter of reprimand) in which Ms. Godwin
has written or used a racial slur.
Ms. Mack believes that the notepad containing Ms. Godwin’s notes were stored in a
confidential file in a cabinet in Ms. Godwin’s office and the cabinet usually is locked. Ms.
Godwin, , and have keys to Ms. Godwin’s office. Ms. Godwin leaves
her office open on occasion when she is not there so that she does not have to keep locking
and unlocking it. Ms. Mack does not have any evidence or knowledge of who took the
notepad from Ms. Godwin’s office.
With respect to the matter involving Ms. McGowen, Ms. Mack was in an extra office on
October 10, 2019, when she noticed a paper with red writing on it. Upon reading it, she was
made aware of a complaint accusing Ms. McGowen of using a racial slur in class. Ms. Mack
gave her recollection of the contents of the note, and later confirmed the document stamped
PCS00011-12 is a copy of the note she described. Ms. Mack again explained that she found
the note in the spare office in front of the receptionist’s desk, and adjacent to Mr. Poulous’
office. The note was on the desk. Ms. Mack clarified that Mr. Poulos told her that
left the note in the office and that Poulos did not have time to look over it. He
told her that he was dealing with being sent out of class, and she asked him
whether he read the note. He said that he had looked at it, and Ms. Mack responded that the
note was something that they needed to pay attention to.
Ms. Mack then called Ms. Godwin to inform her about the note, and inquire how she should
proceed in investigating the issue. Ms. Godwin directed her to meet with Ms. McGowen
later in the day, after school had ended. Ms. Mack stated to Ms. Godwin that the substance
of ’s allegation against Ms. McGowen was highly offensive, and Ms. Godwin
responded that the matter needed to be investigated. Ms. Godwin directed Ms. Mack to
collect student statements as soon as she could.
To determine which students to interview, Ms. Mack reviewed the roster for Ms.
McGowen’s class, identified which students she thought would be objective, and determined
which of those students were present that day. Ms. Mack interviewed the students
individually. She asked the students to write down or let her know about what they had
witnessed. Ms. Mack reviewed the statements she collected and recalled the following
additional information that is not necessarily reflected in the statements themselves:
• graduated in . Ms. Mack determined that

was not in the classroom for the duration of the period and, based on her interview
of him, did not believe that he was in the classroom when Ms. McGowen used the
slur.
• graduated in . He heard Ms. McGowen use the slur when

she was speaking with Ms. Hudson.
• graduated in , . Ms. Mack trusted her

judgment and described her as trustworthy and honest. In addition to the information
provided in the statement, said that “you are not supposed to say
that word,” and that she was surprised that it was said in the classroom.
• graduated in . Ms. Mack regarded her as a bright

student. said that and Ms. McGowen have frequent
“back and forth” exchanges. said that was talking but
did not use the slur. Ms. McGowen used the slur, became upset, and
walked out of the class.
• graduated in .1 In addition to what was written in the

statement, said that Ms. McGowen is a good teacher and that some
students are always doing things that disrupt the class.
On October 10, 2019, Ms. Mack and Mr. Poulos met with Ms. McGowen about the
allegations accusing her of using the racial slur. Ms. McGowan asked who made the
accusation, and Ms. Mack responded she could not reveal the identity of the student. Ms.
Mack asked Ms. McGowen to recount the incident. Ms. McGowen’s immediate response
was something to the effect of, “I don’t see the point of this; the students were being
rowdy,” and she commented that she did not have anything to say about it. Ms. Mack told
her that they would be back in touch because they were still investigating and collecting
statements from students. Later in the interview, Ms. Mack confirmed that the document
stamped PCS00018 is her notes from the meeting with Ms. McGowen on October 10, 2019.
Ms. Mack recalled communicating with Dr. Moore during the investigative process. She
acknowledged that the letter stamped PCS00014 reflected her effort to document the
meeting with Ms. McGowan on October 10, as recommended by Ms. Godwin. Ms. Mack
faxed that letter to Dr. Moore on October 11. Ms. Mack was asked to explain the school
policy to which she referred in the last sentence of the second paragraph of the letter, which
states, “[t]his action did not follow our school policy of alerting a school administrator if
there is a conflict with a student.” Ms. Mack explained that the school policy to which she
referred was in the behavior plan. She further explained anytime there is a disruption or
1
PHS graduation was June 12, 2020.
conflict with a student that a teacher cannot handle, the teacher should report the issue to
the office. Additionally, any time a student is removed from class, an administrator should be
notified to escort the student out of the class so that the student is not left alone.
Ms. Mack also confirmed that the document stamped PCS00015-16 is what Ms. McGowen
provided to Ms. Mack, Ms. Godwin, and Mr. Poulos as evidence of her notifying
’s mother of her interaction with him.
After Ms. Mack gathered the student statements on October 10 and 11, she attempted to
schedule a meeting with Ms. Godwin, Mr. Poulos, and herself on October 14. Ms.
McGowan said that she was not able to meet because she had classes and did not have time.
She eventually agreed to meet the following day, October 15. At that meeting, attended by
Ms. Godwin, Mr. Poulos, and Ms. Mack, Ms. Mack gave Ms. McGowen the letter of
reprimand that Ms. Mack had written. Ms. McGowen reiterated that she said the slur but did
not call the slur; she said that she had repeated what he said. Later in the
interview, Ms. Mack confirmed that the document stamped PCS00020-21 is a copy of the
final letter of reprimand.
After the meeting on October 15, 2019, Ms. Mack met again with Ms. McGowen to follow-
up with her about signing the letter of reprimand. Ms. Mack confirmed that the document
stamped PCS00017 are her notes from the exchange with her and Ms. McGowen. Ms. Mack
met with Ms. McGowen from 8:55 am to 9:01 am. Ms. McGowen told Ms. Mack that she
did not like the way the situation was handled because the letter of reprimand implied that
she called a racial slur. Ms. McGowen also stated that another student,
used the n-word in class on a different occasion, but that she did not
report him to the administration. The notation “teacher repeated again” refers to Ms.
McGowen’s use of the slur in Ms. Mack’s presence. During the meeting, Ms. Mack also
counseled Ms. McGowen on student behavioral issues that could be handled by teachers
inside of the classroom versus matters that require administrative intervention. In that
regard, Ms. Mack explained during the interview that administrators have communicated to
teachers that student use of profanity in the classroom is a major offense and inappropriate.
Prior to October 10, 2019, Ms. McGowen had informed administration of student use of
profanity in the classroom, but not racial slurs.
Ms. Mack confirmed that the document stamped PCS00019 is a copy of the statement that
she asked Sararesa Hudson to prepare concerning Ms. McGowen’s use of a racial slur in Ms.
Hudson’s office on October 10, 2019. Based on Ms. Hudson’s account, Ms. Hudson
messaged Ms. McGowen to let her know that was in her office. Ms. McGowen
went to Ms. Hudson’s office to find out why did not report to class. It was not
unusual for students to be in Ms. Hudson’s office during the day. Ms. Mack authenticated
PCS00022, and stated that she prepared the statement at the direction of Dr. Alfreida
Moore, who wanted her to explain how she retrieved PCS00019. Ms. Mack received Ms.
Hudson’s statement in physical form.
With respect to the letter of reprimand being kept in Ms. McGowen’s school personnel file,
Ms. Mack said that Ms. Godwin explained to her that because Ms. McGowen had not been
accused of using a slur in the past, the letter would remain in the school file. If it occurred
again, the letter would be sent to the Central Office.
Ms. Mack believes that Human Resources and Ms. Godwin determined what would be
appropriate discipline for Ms. McGowen. Ms. Mack wanted to include a recommendation
for professional development in the letter of reprimand, but was told by Ms. Godwin that it
was not available to be provided because it was not offered by the district. Ms. Mack does
not have any other issue with how the situation with Ms. McGowen was resolved.
Ms. Mack is not aware of any other official allegation concerning the use of a racial slur by
Ms. McGowen.
Ms. Mack is aware of at least one other circumstance in which a teacher has been disciplined
for using inappropriate language in front of students. She recalled meeting with a teacher
who had been accused of discussing inappropriate topics and cursing in the classroom. That
teacher resigned. She did not address any other incidents.
When asked if the outcome of the initial investigation of Ms. McGowen should have been
different if the slur had been directed toward , Ms. Mack stated that how the
word was used did not matter and that use of the slur is inappropriate regardless of the
context.
APPENDIX C
Caroline Godwin Interview Summary

Interview Date: June 25, 2020
Caroline Godwin is the Principal of Pender High School. She has held that position since
2018. She previously was the principal of Burgaw Middle School.
In general terms, Ms. Godwin sees her job duties and responsibilities as providing a safe
environment for students to learn, ensuring that they receive an appropriate education, and
identifying areas of growth for the school.
Ms. Godwin normally gets involved in an investigation when a matter is reported to

someone, whether that person might be a teacher, administrator or some sort of stakeholder.
Who conducts an investigation can depend on the relationship a particular student might
have with the administration. Sometimes students may report something directly to an
assistant principal, and if the assistant is comfortable handling it then he or she can proceed.
Ms. Godwin will become involved if the assistant is not comfortable with the situation, the
issue is what she describes as major, the assistant requests guidance, or the issue was brought
to Ms. Godwin’s immediate attention. For example, if there’s a simple issue that arises in a
hallway or the cafeteria and she is present, she will handle it. Normally, an assistant will
approach her to say whether he or she needs assistance in an investigation, but her
involvement is situational.
The Code of Ethics, Board Policies, and the school handbook are among the resources that
Ms. Godwin looks to for guidance in investigating matters. The handbook is provided in the
form of a physical copy. At the beginning of the school year, prior to student arrival on
campus, the faculty holds a meeting where some board policies are discussed to set
expectations for staff. The Code of Ethics, which is part of the handbook, is addressed
during the meeting.
Other than Ms. Godwin’s handwritten note that contains a racial slur and Ms. McGowen’s
use of a racial slur in the classroom as well as Sararesa Hudson’s office, Ms. Godwin is not
aware of the use of any racial slur by any teacher at Pender High School. Ms. Godwin did
recall an occasion on which a parent complained about a health science’s teacher’s
explanation that sickle cell anemia is more common in the African American population, but
the discussion did not involve any slur or language that is derogatory.
Ms. Godwin was not aware of any teacher’s use of profanity in the presence of students, but
agreed that any such occurrence would be inappropriate due to the Code of Ethics. Ms.
Godwin stated that faculty serve as role models and therefore should model what is expected
of students.
Ms. Godwin stated that student use of profanity is not prevalent in a classroom setting when
instruction is occurring, but is prevalent in other contexts when students are on their free
time. Those situations are addressed when faculty hears it, but if it becomes prevalent as to a
particular student, faculty will have a conversation with that student’s parent(s) and follow
the student Code of Conduct and other appropriate measures. For example, if a student uses
profanity in the hallway, Godwin will address the situation by informing the student that the
language is inappropriate and explaining why. She explained that a proper way of correcting
the student “absolutely” does not involve repeating the profanity. Ms. Godwin agreed that
using profanity in the presence of a student would violate the Code of Ethics.
If Ms. Godwin learned that a teacher used profanity in the presence of a student, a meeting
reviewing the Code of Ethics and documenting the incident would be warranted so that if it
occurred again there would be a record of the matter. Any such documentation would be
placed in a file in her office. If she determined that Human Resources should be involved or
if HR deemed it necessary, a copy of the record would be kept at the Central Office as well.
Ms. Godwin was referring specifically to a situation in which a teacher would be
reprimanded for misconduct for not following the Code of Ethics or Board Policy.
In regards to when documentation of teacher incidents is stored at HR, Ms. Godwin

explained the following: In an incident where an employee had habitual occurrences of not
following Board policy or the Code of Ethics or if the situation involved an issue, that if not
corrected, could lead to dismissal HR would receive a copy. Under those circumstances, HR
would inform Ms. Godwin that the report should go to the HR file. For example, if a
teacher does not report to work on time, that is not something that would be sent to HR,
however, if it is a more regular occurrence and the teacher neglects other duties, HR would
be alerted. In sum, HR would be alerted if a problem is persistent or significant on its own.
Normally, Ms. Godwin makes the decision whether to contact HR.
Ms. Godwin is familiar with Board Policy 1710-4021-7230 (Prohibition Against

Discrimination / Harassment / Bullying). This board policy is reviewed with teachers at the
faculty meeting at the beginning of the year. She is familiar with Board Policy 1720-4015-
7225 (Discrimination / Harassment / Bullying Procedure). That policy also is reviewed with
faculty at the meeting at the beginning of the academic year. She noted that some of the
review of the policy is completed in the online training module. The deadline to complete
the modules is normally by mid-September.
Board Policy 7335 (Employee Use of Social Media) is reviewed consistently with teachers
and staff. It is included with the materials provided at the beginning of the year, and also is
addressed throughout the year through reminders at staff meetings, e-mails, meetings of the
professional learning committees, and occasionally when staff have questions about it.
In October 2018, there was a significant fight at the school. Ms. Godwin had been in school
for 10 days before Hurricane Florence caused the school to close. The first day that students
returned to school was October 23, 2018. Shortly after busses started arriving, Ms. Godwin’s
radio alerted her about a fight.
Once the disruption was contained, students were brought into the school office, where the
brawl resumed. With the assistance of law enforcement, the fight was contained and
administration began gathering information. Dr. Hill arrived shortly thereafter. Ms. Godwin
used a legal pad to record who was involved in the incident and how. She proceeded through
the school and interviewed students who had been involved in the fight once they had been
separated. The assistant principals participated in the effort. Ms. Godwin noted that Ms.
Mack had been at the school longer and was more familiar with the students than her or Mr.
Poulos, who were both new.
Ms. Godwin authenticated PCS00001 as her note from the interview. She also authenticated
No. 37 and 38 as the same documents from her legal pad. PCS00003 was the back of the
page. The signature on page PCS00038, she confirmed also was hers. The notes were kept
in a credenza to the right of her desk in the bottom drawer and it contained personnel files
and individual student files. The drawer was not locked. Her office door had a lock on it. It
was not always closed, but locked automatically when closed.
PCS00001 was the legal pad Ms. Godwin used while trying to determine who the students
were involved in the fight. The student listed at the top of her legal pad reported to her that
he had been attacked (jumped). This student ( ) repeatedly said, that “‘my
niggers’ and I were jumped. Ms. Godwin said during the interview that was very
excited and continued to repeat the language. She asked who he was referring to and she
began writing down names. and also said that they had been “jumped,” and she
determined that was referring to them, and therefore she placed the bracket
around their names. Ms. Godwin said that she did not repeat the offensive language. The
word “Started” on the legal pad underlined twice means that she started her interview with
. Ms. Godwin stated the purpose of writing that was to remind herself that is
where she started gathering her information. “Started” did not refer to who started the fight.
She also says that she asked to stop repeating the slur.
, who was not listed in her original note, also was involved in the fight.
Mr. Poulous was with Ms. Godwin during her investigation of the fight.
Ms. Godwin does not know how Rayford Hankins got access to the document that he
posted on social media. The legal pad on which the note was written had been in her office.
She acknowledged to Dr. Moore that the note had been distorted and immediately retrieved
it upon being questioned by Dr. Moore. Ms. Godwin took a picture of the note and had
physical possession of the original note that she subsequently took to Dr. Moore’s office.
Ms. Godwin later sent to our firm a copy of the picture that she sent to Dr. Moore. Ms.
Godwin denied altering her original note in any way. On the day of the posting, Dr. Moore
asked her to gather any documentation she had pertaining to the social media post and to
bring it to the HR office. She was also asked to bring Karen McGowen’s file. Ms. Godwin
attempted to retrieve the file and noticed the folder was empty. Ms. Godwin did not share
her pad with any student or staff member or show to any one it at any time. The purpose of
her notes was to help her identify who was involved in the fight and to assist in the
investigation.
Godwin identified the differences between her note and the note that was published on
social media. The “my” was removed from above the slur in the margin and the name
“ ” had been added with a checkmark beside it. Ms. Godwin did not copy the note,
and there was not a copy of the note in the file, physical or digital. She does not have any
information about who altered the note or why it had been changed. Ms. Godwin,
, and have keys to Ms. Godwin’s office. No one else is
authorized to be in her office when she is not there.
In regards to Ms. McGowen’s personnel file at school, Ms. Godwin reported it was empty
on the date of the social media posting when she pulled it at Dr. Moore’s request. Missing
from the file was documentation of Ms. McGowen using a racial slur as well as
documentation of an unrelated incident in the spring when a student reported McGowen
telling him to “shutup.” The letter of reprimand as to the second incident did not go to the
Central Office.
Shortly after the social media posting, Ms. Godwin went to Dr. Moore’s office.
Superintendent Steven Hill and Alex Riley were present when she arrived. Ms. Godwin gave
them all of the documents underlying both social media posts that she had, explained the
situation, provided the written statement, and left. She estimated that the meeting lasted 45
minutes to an hour. Ms. Godwin identified PCS00004 as the handwritten statement that she
drafted and submitted at that meeting. She noted that the reference to a fight in October
2019 should have been October 2018, and attributed the oversight to being in a hurry.
Ms. Godwin learned about Ms. McGowen’s use of a racial slur from Ms. Mack. Ms. Mack
informed Ms. Godwin that a student reported that a teacher used a racial slur. She could not
recall whether the conversation was via telephone or in her office. During the conversation,
Ms. Mack expressed the slur that had been used should never be used. Ms. Godwin said that
she agreed and the matter needed to be investigated. Ms. Godwin wanted Ms. Mack to
conduct as much of the investigation as she felt comfortable doing. She recognized that Ms.
Mack was greatly concerned and discontent, but also wanted to make sure that the
investigation was fair and that all the information gathered was correct. Ms. Godwin took
the nature of the allegations seriously, which is why she contacted Dr. Moore immediately.
Ms. Godwin was familiar with the letter written by [PCS00011].
Early in the investigation, Ms. Mack said that she would be meeting with students to gather
information. Once the information was compiled, Ms. Godwin worked more closely with
Ms. Mack by providing a sample letter of reprimand, reviewing the Code of Ethics together,
and discussing aspects of the investigation. During the investigation, Ms. Mack told her that
Ms. McGowen was not interested in discussing the issue. Ms. Godwin also confirmed that
PCS00013 is her handwritten note, but could not recall whether she personally heard Ms.
McGowan said “that’s a crock . . .” as indicated in the note or whether that information was
conveyed to her by Ms. Mack.
Ms. Godwin identified PCS00015 as an e-mail that Ms. McGowen sent to administration
about the matter. Ms. Mack told her that the document was the only statement that Ms.
McGowen was willing to provide.
Ms. Godwin’s interaction with Ms. McGowen concerning the matter was mostly limited to
the October 15, 2019 meeting between Ms. McGowen and administrators. The only other
interaction she recalled was a brief mention to Ms. McGowen that Ms. Mack wanted to meet
with her.
Sararesa Hudson was a program director for Communities in Schools (CIS). She was
responsible for PHS’ afterschool program. She also was present in the school to help tutor
and support students. Ms. Mack told Ms. Godwin that Ms. Hudson had contacted her and
wanted to speak with her about a situation that had occurred in her office. Ms. Godwin does
not question Ms. Hudson’s credibility or honesty.
One of the purposes of the letter of reprimand was to make clear that use of a racial slur is
inappropriate under any circumstance. Normally, to determine the type of discipline that is
appropriate for any particular situation administration confers with Human Resources. Ms.
Godwin believes that the McGowen matter required documentation. Dr. Moore reviewed
the letter of reprimand prior to sharing it with Ms. McGowen. After Ms. McGowen refused
to sign the letter at the October 15 meeting, Dr. Moore instructed administrators to
document her refusal to sign.
With respect to the October 15 meeting, Ms. Godwin recalls Ms. McGowen wanting
documentation that she did not intend to use the word as a racial slur and was repeating
what the student said. Ms. Godwin attempted to state Ms. McGowen’s position in the
addendum. Nonetheless, Ms. Godwin wanted to make sure Ms. McGowen knew that use of
the word was unprofessional and should not have been used at all. Additionally, Ms. Godwin
wanted the letter to address the administration’s role in addressing student behavior.
Human Resources did not ask for a copy of the letter of reprimand, and said that the letter
should be kept in Ms. Godwin’s file at school. When referring to Human Resources, Ms.
Godwin stated that she was specifically referring to Dr. Moore because she was her point of
contact.
Ms. Godwin did not recall discussing training or professional development for Ms.
McGowen with other administrators at the time but recalls having those discussions more
broadly about staff in general since the events occurred. Ms. Godwin believes that
administrators followed the protocol that they were told would be appropriate for this
particular incident.
Any time a teacher intends to dismiss a student from class for behavioral reasons, the
teacher should contact administration.
Ms. Godwin is not aware of any other circumstance in which Ms. McGowen has been
accused of using a racial slur or racially charged language against a student or staff member
at Pender High School.
When asked about any other occasions on which a teacher may have been disciplined for
using inappropriate language, at the conclusion of the interview, Ms. Godwin explained a
circumstance in which a teacher was disciplined for using profanity in front of students. The
teacher had been reported by another teacher for swearing in the presence of students and
behaving in an unprofessional manner. The accused teacher did not deny using profanity and
received a letter of reprimand. The letter is kept in the teacher’s personnel file at the school
and did not go to the Central Office.
APPENDIX D
Jack Poulos Interview Summary

June 25, 2020
Mr. Jack Poulos is an Assistant Principal at Pender High School. He has served in this
position since October 2018. He previously served as a teacher for 21 years in various school
districts in Eastern North Carolina.
His several job duties and responsibilities include school bus monitoring, hall monitoring
during class transitions, lunch supervision, tenth and twelfth grade discipline, classroom
observations, supervising beginning teachers, field trip transportation, and various other
tasks.
Mr. Poulos generally gets involved in teacher investigations when a complaint is brought to
his attention. Usually if there is a complaint about a teacher’s interaction with a student in
the classroom, administrators will observe the teacher in the classroom and proceed from
there, depending on the situation. Investigative responsibility is shared, for example, each
administrator may observe the same teacher during different periods of the same day.
Investigations also involve speaking with students to understand the circumstances.
At the beginning of each academic year, faculty attends a meeting during which the faculty
handbook is reviewed. The review includes a discussion of the Code of Ethics, but Mr.
Poulos could not recall specifically whether discussion includes the prohibition of the use of
any language considered profane, vulgar, or demeaning. He noted, however, that discussions
during the faculty meeting occurred in four different groups, and that other groups may have
discussed things of which he is not aware.
The School Board policy against discrimination, harassment, and bullying was addressed
during the faculty meeting, and Mr. Poulos is familiar with the policy. Mr. Poulos did not
know whether the discrimination, harassment, and bullying complaint procedure was
discussed. Nonetheless, he noted that the Code of Ethics, the prohibition against
discrimination, harassment and bullying, and the complaint procedure all are in the faculty
handbook.
In his time at Pender High School, Mr. Poulos has not had a student or parent complain that
a teacher used profanity in a student’s presence. He also was not aware of any such
complaint. Likewise, and other than specific matters being investigated, Mr. Poulos was not
aware of any circumstance in which any PHS staff member has used any racial slur or racially
charged language directed toward any student or staff member. When a student uses
offensive language, Mr. Poulos stated that it is not appropriate to repeat the language.
Turning to the events of October 2018, Mr. Poulos recalled a large fight that occurred on
the first day students returned to campus after Hurricane Florence. After the fight, students
were separated as administrators and law enforcement officers were identifying the
participants. Neither Mr. Poulos nor Ms. Godwin were familiar with some of the students.
Mr. Poulos is familiar with one of the students in the fight, . Mr. refers
to his close friends by using the slur at issue in this matter. Mr. Poulos recalled that Mr.
called him that during the most recent year due to their closeness (Mr. Poulos told
Mr. that he could not call him that). Mr. ’s use of the term is consistent with
Mr. Poulos’ experiences with him, and when asked whether Mr. Poulos had any specific
memory of Mr. using the term on the day of the fight as Ms. Godwin was taking
notes, Mr. Poulos responded that he “feel[s] comfortable saying yes.” Mr. Poulos has not
ever heard Ms. Godwin use the slur, neither on the day of the fight nor since. He did,
however, recall seeing her notes [PCS00001] when they were written, but did not see them
again until the social media posting. He saw the notes while in her office, and the only other
person present may have been Ms. Mack, but he was not sure. He does not recall Ms.
Godwin putting her pad down or leaving it anywhere, and therefore does not believe any
student saw the notes. Mr. Poulos recalled Ms. Godwin describing what students had told
her about the fight and referring to her notes to convey what she had been told. When asked
whether Ms. Godwin used the slur in private to discuss what had been said, Mr. Poulos said,
“I don’t think so[,]” and “I don’t recall her saying that.”
Mr. Poulos recalled the events of June 8, 2020. He went to Ms. Godwin’s office for a non-
specific reason, and she asked whether he had seen what had been posted on Facebook. She
was on the phone with Dr. Moore discussing the matter. He saw her retrieve her notepad
from her files. He looked at the notepad and looked at the posting as Ms. Godwin and Dr.
Moore were talking, and observed that the two documents were different. Ms. Godwin
expressed the same to Dr. Moore. Dr. Moore told Ms. Godwin to bring the pad and papers
concerning Ms. McGowan to the Central Office. Dr. Moore was on speakerphone during
the conversation.
When Ms. Godwin went to retrieve Ms. McGowan’s file, she said that the papers were
missing. Ms. Godwin retrieved papers concerning Ms. McGowan from Ms. Mack because
she lead that investigation. Mr. Poulos did not observe Ms. Godwin alter her pad in any way.
He does not know why “my” is not present in the margin of the version of the notes that
were posted on social media. Likewise, he does not know why the name “ ”
appears on the notes posted on social media. Mr. Poulos does not have any information
about who accessed Ms. Godwin’s notes.
Turning to the matters regarding Ms. McGowan, Mr. Poulos recalled her coming to his
office and saying that there was an incident in her class that he probably would hear about
and that she already had communicated with the parent. Mr. Poulos later received
’s note. Ms. Mack was present. He began reading the note and asked her to take
care of the situation because the bell just had rung and he had to be on duty. Mr. Poulos
recognized PCS00011 as a copy of the note. Later, asked Mr. Poulos whether
he received the note.
Mr. Poulos did not recall receiving PCS00035, an instant message purportedly sent to him
from Ms. McGowan. He noted, however, that he did not frequently use instant messaging.
Mr. Poulos did recall, however, that the protocol for removing a student from the classroom
had been communicated to teachers multiple times. That is, if a student needed to be
removed, the teacher should call and an administrator will report to the classroom to escort
the student out. Students should not be allowed to just leave the classroom. This policy is
communicated at the faculty meeting at the beginning of the year and in teacher meetings.
Mr. Poulos recalled meeting with Ms. McGowan on the day of the incident. He recalled her
not wanting to come in for the meeting, noting that she was always busy. He remembered
Ms. Mack trying to talk to her and had the impression that Ms. McGowan did not think that
the issue was serious.
At the next and final meeting with Ms. McGowan, Mr. Poulos, Ms. Mack, Ms. Godwin, and
Ms. McGowan were present. Ms. Mack essentially read the letter of reprimand verbatim. At
the end of the meeting, Ms. McGowan was asked to sign the letter and said either that she
was not going to sign it or would sign it later. When Ms. McGowan left, Ms. Godwin
advised that if a teacher will not sign a letter, an addendum must be added stating that the
teacher refused to sign. Mr. Poulos recalled signing the revised letter.
Mr. Poulos did not recall any discussion about any additional training or professional
development for Ms. McGowan.
When asked, Mr. Poulos recalled an instance in which another teacher was disciplined for
allegedly using profanity in the presence of students. The situation was addressed by meeting
with the teacher, and giving the teacher a letter of reprimand.
APPENDIX E
Karen McGowen Interview Summary

July 8, 2020
Ms. Karen McGowen is a teacher at Pender High School and has been there since 1999 or
2000. She teaches English for grades 9 through 12. English 12, the class at issue, follows
lunch and runs from 12pm to 1:30pm or 12:30pm to 2pm, depending on the day and the
schedule. The class had anywhere from 28 to 36 students, and approximately half of the
students were black and half were white.
School policies were usually communicated in a handbook or at the faculty meeting at the
beginning of the school year. Different administrators and staff lead instruction on various
aspects of the handbook, and some sections, such as those dealing with dress code, were
reviewed by faculty on their own. After the faculty handbook is reviewed, staff acknowledges
reviewing it by signing a statement. The meeting lasts roughly half a day and occurs before
students report to campus.
Ms. McGowen identified PCS00072 as the staff handbook that was reviewed during the
faculty meeting prior to the 2019-2020 academic year. The Code of Ethics is discussed every
year and is addressed throughout the year in various contexts. Ms. McGowen also was
familiar with the specific provision in the Standards of Professional Conduct, 16 NCAC 6C
.0602, that prohibits the use of language that is considered profane, vulgar, or demeaning.
When dealing with a disruptive student in the classroom, Ms. McGowen tries to redirect or
refocus the student. Sometimes that involves conferencing with the student outside of the
classroom, giving the student space, and depending on what has happened, following up
with a parent or having a conversation with administration. Ms. McGowen interprets the
school disciplinary policy stated on PCS00098 to mean that once a referral is made in the
Educator’s Handbook, an administrator will handle any disciplinary consequences.
Ms. McGowen also is familiar with the Pender County Schools Employee Handbook
[PCS00152] but said that she had not seen a copy recently. She has some recollection of the
handbook being mentioned at the faculty meeting and the beginning of the year, but is not
certain. She did not remember anyone going through the handbook with faculty. After
reviewing PCS00041, Ms. McGowen recalled completing an online training module on the
Board policy against discrimination, harassment, and bullying.
Ms. McGowen does not have personal knowledge of the use of racial slurs by any faculty or
administrator at Pender High School. Other than the incident concerning ,
Ms. McGowen denied using any racial slur in the presence of a student at Pender High
School. She could not recall any instance in which a faculty member or administrator used
profanity or vulgar language in the presence of students.
When a student uses profanity, vulgar language, or a racial slur, Ms. McGowen’s typical
response is to ask the student not to use the offensive language. She could not recall any
other circumstance in which she repeated the offensive language.
With respect to the events on October 10, 2019, Ms. McGowan said that
would not stop repeating a racial slur. A co-teacher (Ms. Falcone) already had taken another
student ( ) out of the class because of behavioral issues. As Ms. McGowen
was attempting to get the class under control, was talking to students across
the classroom, and prefacing each statement or question with “that word.” After attempting
unsuccessfully to stop from repeating the word, Ms. McGowen said, “just
stop saying” the word. responded by asking, “what did you say?” Ms.
McGowen replied, “just please stop saying it.” He asked the student sitting beside him,
, “what did she say to me?” chastised him by telling
him to stop using the term and the exchange ended.
Ms. McGowen said that when she used the word, she was directing her language toward
but was not calling him the slur. She explained that she was repeating what he
said. Class went on as normal for the rest of the day. Ms. McGowen first denied and later
said that she did not recall dismissing from the classroom. PCS00035 and
PCS00015 did not refresh her recollection.
Ms. McGowen knew immediately that she should not have used the word. She also knew
that was upset because his first reaction was, “what did you call me.” She
responded by telling him that she did not call him the slur.
After class, Ms. McGowen called ’s mother to explain what had happened
and left a voicemail message. She followed-up with the e-mail on PCS00015. After reviewing
PCS00016, Ms. McGowen still did not recall sending out of class but said
that if she typed it (referring to the e-mail) that is what happened.
Ms. McGowen recalled discussing the matter with Sararesa Hudson. When Ms.
Falcone returned to the classroom, Ms. McGowen became aware that another student was
missing from class. She either had received a message from Ms. Hudson or the student told
her that he was going to Ms. Hudson’s office. She left to try to get him to come back to
class. When she went to Ms. Hudson’s office, he was there and appeared bothered by
something. Ms. McGowen began what she described as a casual conversation with Ms.
Hudson, and told her that she did not understand why kids say certain words and when the
word is repeated when telling them to stop using it, they get angry. Ms. Hudson shrugged
her shoulders and Ms. McGowen returned her attention to the student who was present.
She said that she used the slur during the conversation with Ms. Hudson while the student
was present.
After class ended, Ms. McGowen went to the front office to follow-up with Mr. Poulos and
tell him what she had said. He shook his head and said okay. She also told him that she had
followed-up with ’s mother.
Ms. McGowen said that she repeated what said because she was frustrated
with the circumstances in the classroom. Her intention was to get him to stop using the
word.
Her next interaction with administrators involved an e-mail or instant message stating that
they needed to speak with her after school. When she followed-up to meet with them she
became frustrated because she had to wait until all three administrators were available to
meet with her. Ms. McGowen thought that the events concerning the use of offensive
language had been settled and had not considered that to be the purpose of the meeting.
Ms. McGowen does not have a clear recollection of the meeting. She remembers Ms. Mack
leading the meeting in Ms. Godwin’s office and informing her that there had been a
complaint that she had used a racial slur. She explained during the meeting that she already
told Mr. Poulos what happened and had been in contact with the student’s parent. She was
frustrated and asked why she had to stay after school. She does not remember whether she
sat down for the meeting or stood in the doorway for the duration. The meeting was later
than she wanted it to be because she had to pick her son up from school by 4:00 p.m. Ms.
Mack told her that administrators would need a statement from her and that they were
conducting an investigation into the incident. After the meeting, Ms. McGowen returned to
her classroom and forwarded the e-mail exchange between her and ’s mother
[PCS00015] to administrators. Ms. Mack was not satisfied with the email, and Ms. McGowan
eventually printed it, wrote a note at the top and signed the statement appearing on the e-
mail. She believed the e-mail explained what had happened and was sufficient for a
statement.
Ms. McGowen’s next interaction with administration following the initial meeting was to
discuss the letter of reprimand. They again met in Ms. Godwin’s office with Ms. Mack
leading the meeting by reading the letter of reprimand. Ms. McGowen expressed her
disagreement with it. Ms. Mack took notes and told her that she would edit the letter. The
meeting also included a discussion of behavior in school, student-teacher interaction, and a
general conversation about how to best handle disciplinary matters. Administrators told her
to seek help when she needed it and not to allow herself to get frustrated again.
When asked to explain the portion of the letter that she did not agree with, Ms. McGowen
explained that she wanted the letter to reflect that she repeated the slang version of the term
– niggaa versus nigger. She considers the former to be slang and the latter to be a slur. She
did not want the letter to imply that she had called the student a slur. She also wanted the
full e-mail exchange with to be considered as part of her statement, not just the
handwriting on the e-mail that she had printed. Ms. McGowan does not recall having any
conversations with administrators about whether the letter would remain in her personnel
file at the school or the Central Office.
With respect to Ms. Hudson’s letter posted on social media, Ms. McGowan disputes saying
“nigger,” but rather says that she said “niggaa.” She does not recall other immaterial aspects
of the letter.
APPENDIX F
Dr. Steven Hill Interview Summary

July 8, 2020
Dr. Steven Hill is the Superintendent of Pender County Schools. He has served in this
capacity since September 2017.
Dr. Hill explained his general understanding of the investigative process for school teachers
and principals and how he typically becomes involved. At the county level, investigations
begin with Human Resources and Dr. Hill is the next level of engagement. For matters at
the school level, a school administrator typically addresses the issue directly. Dr. Hill’s office
encourages principals to conduct their own investigations while keeping the Central Office
informed of the progress, normally by working through Human Resources. Every Tuesday,
Dr. Hill receives a briefing from the chief Human Resources Officer to stay informed of any
investigations that are ongoing.
Dr. Hill first learned about the handwritten note the same day it was posted on social media,
June 8, 2020. A board member had sent him a text message with a screen shot of the social
media posting. Within a few minutes, Dr. Hill was in touch with Alex Riley, the
Communications Coordinator. Dr. Hill met with Mr. Riley and Dr. Moore at the Human
Resources office. Dr. Hill asked Dr. Moore for any files regarding what had been posted. Dr.
Moore was aware of the circumstances involving Ms. McGowen in the second post, but she
had no knowledge of the notes pertaining to the 2018 fight reflected in the first post. They
then called Ms. Godwin and asked for all documents concerning both matters.
Ms. Godwin came to the office at approximately 3:00 pm the day of the posting and
delivered all documents she had access to as requested. Dr. Hill became aware of the
circumstances surrounding the documents and the social media posting as he reviewed the
items Ms. Godwin brought in. Although Dr. Hill was present during part of the investigation
immediately following the 2018 fight at PHS and he was aware that Ms. Godwin had been
taking notes that day, he never held the notepad or read the notes. Ms. Godwin informed
him that the notes posted on social media were different that the original document. Dr. Hill
advised putting what Ms. Godwin represented to be the original note in a plastic bag, sealing
it, and signing a statement showing the chain of custody. Dr. Hill was physically present
when the chain of custody document was signed.
Dr. Hill was not aware of the matter concerning Ms. McGowen until June 8, 2020. Dr. Hill
could not recall Dr. Moore briefing him on the matter when it had occurred. Other than the
matters being investigated, Dr. Hill cannot recall any other instance in which a teacher or
administrator has used a racial slur at Pender High School.
Dr. Hill believes that the matter concerning Ms. McGowen was investigated and addressed
appropriately, but also believes that professional development would have been appropriate
for her.
Dr. Hill said that the social media policy is mostly enforced through coaching and not
reprimand. He could not recall any circumstance in which a teacher has been disciplined for
violating the social media policy, but added the caveat that he would need to review
personnel records. He reiterated that violations of the policy generally are addressed through
coaching.
Dr. Hill concluded the interview by saying that there is no excuse for a teacher to use the
slur at issue in this matter in the presence of a student.
APPENDIX G
Rayford Hankins Interview Summary1

July 30, 2020
Mr. Hankins is a teacher at Pender High School, and has been there since August 2016. He
also is the head coach of the Men’s Basketball team, and has held that position since 2018.
Mr. Hankins graduated from Pender High School in 2008.
Other than the circumstances surrounding the June 8, 2020 social media postings, since the
time he has been a teacher, Mr. Hankins has not been made aware of any staff member or
administrator at Pender High School using racial slurs. Mr. Hankins recalled that when he
was a student, teachers made jokes about turning off the lights and not being able to see
certain students. Those teachers are still on the faculty. Mr. Hankins was not comfortable
identifying them. He said that the use of racially charged language by teachers has been
persistent. When asked to clarify whether the incident that he described involved more than
one teacher, he declined to answer.
Mr. Hankins confirmed that a faculty meeting occurs at the beginning of every academic
year. He is not sure whether the meeting involves discussion of the policy against
discrimination, harassment, and bullying. He does not recall whether the meeting addresses
the complaint procedure for discrimination, harassment, and bullying.
Mr. Hankins confirmed that he posted the June 8, 2020 social media posting. Mr. Hankins
described his knowledge of the first image on the posting. He understood that a fight had
occurred and the notes were located in what he called an “investigation room.” When asked
to clarify what he meant by “investigation room,” he said that investigations usually take
place in the principal’s office. The list of names represent the people involved in the fight in
October 2018.
Mr. Hankins does not have personal knowledge of who wrote the notes. He does not have
any information about how the racial slur came to appear in the margin. Mr. Hankins has
not ever seen any other version of the document than the one that he posted on social
media. He declined to answer: whether the person who provided the document to him gave
him any information about it; whether he was provided the document in physical or digital
form; and when he received the document. Mr. Hankins redacted the student last names in
both documents that he posted on social media. He did not alter the documents in any other
way.
Mr. Hankins assisted in breaking up the October 2018 fight. During that time, he did not
hear any teacher or administrator use racial slurs. He declined to answer whether any student
reported to him that a teacher or administrator had used racial slurs during the fight or its
1At various times during the interview, Mr. Hankins’ lawyer, James Lea, interjected to
express Mr. Hankins’ desire to cooperate fully in the investigation, while also being
concerned that the information provided may be used against him.
investigation. His attorney explained that Mr. Hankins would not answer the question
because he did not want to identify anyone.
Mr. Hankins reported to an unidentified person the use of the slur in the notes prior to him
posting the notes on social media. He declined to provide the person’s response. He said
that he reported it above the school level and at the county level. Mr. Hankins was
uncomfortable answering whether he reported it to anyone in the Central Office. Mr. Lea
stated that Mr. Hankins reported the issue to who he believed to be the proper official, he
thought that the report would go to the Superintendent (he does not know if it did or if it
did not), and nothing was done in response. Mr. Hankins affirmed his attorney’s statement.
Mr. Lea added that the complaint was made orally.
Mr. Hankins said that the second e-mail was sent to him by a colleague explaining what she
had observed. He declined to answer whether he reported the contents of the e-mail to
anyone after receiving it and before he posted it on social media. He later confirmed that the
e-mail was sent by Sararesa Hudson. Mr. Hankins declined to provide any information about
what Ms. Hudson told him beyond what is stated in her e-mail. He also declined to answer:
whether he had any discussion with the student who was involved in the incident with Ms.
McGowan or with the student’s mother. He also declined to answer whether Ms. McGowan
has used racial slurs or racially charged language on any other occasions.
Since the events of October 2019, there has not been any additional training concerning race
and discrimination at the school.
Mr. Hankins’ purpose and intent in posting both documents to social media was “to bring
light to discrimination.” He reported that 50 percent of teachers at Pender High School
reported in a recent survey that students are not treated equitably.
Mr. Hankins does not recall receiving any training or guidance provided by the school or
county on the board’s social medial policy. Mr. Hankins said that he has not been provided
examples of what is inappropriate for posting on social media, and that the social media
policy is not addressed at the faculty meeting at the beginning of the year.
APPENDIX H
Alex Riley Interview Summary

July 30, 2020
Mr. Riley is the Communications Coordinator for Pender County Schools (PCS), and has
held that position since February 2019.
His job includes managing social media, sending out press releases, dealing with the press,
managing the district website, and working with all of the departments within the district in
communicating information to staff, the community, and others.
Mr. Riley learned about the June 8, 2020 social media postings when he received a
notification from Twitter that PCS had been tagged in a post. He confirmed that the post
was what appears at PCS00002. He then went to Facebook and also saw that PCS had been
tagged there. Mr. Riley called Superintendent Steven Hill and then Principal Caroline
Godwin to alert them of the posts. Dr. Hill told him to meet at the Central Office, and Mr.
Riley went there to begin working on the matter.
Mr. Riley went to Dr. Alfreida Moore’s office, sat down and looked at what was posted. Dr.
Moore reflected on what she remembered about the incidents. Ms. Godwin arrived and
presented documents she had kept from both incidents and they all reviewed them as a
group.
Ms. Godwin explained the handwritten note. She described the large fight that had occurred
the on the first day that class had resumed after the hurricane. She said that she took the
notes in documenting the fight and who was involved. She said that some of the students
were using the n-word to identify each other in discussing the fight. Mr. Riley said that the
note depicted at PCS00001 and PCS00037 were images of the note that he saw.
After Ms. Godwin explained the note, Dr. Hill asked Dr. Moore if she had a ziplock bag to
seal the note. Dr. Hill sealed the note in the bag and wrote across the seal the time and date
in the event the seal was broken. During the meeting, Ms. Godwin noted that the word
“my” does not appear on what had been posted on social media and that the document that
she had presented was in the file and had been there since the fight happened. Mr. Riley
does not remember discussing any other differences between the documents.
With respect to the second image on PCS00002, Mr. Riley recounted that Ms. Godwin
explained the matter concerning Ms. McGowen and showed them the letter of reprimand in
Ms. Godwin’s file. Mr. Riley was in the meeting for approximately 35 to 40 minutes until he
left for work-related errands.
Mr. Riley recounted reviewing social media comments since June 8, 2020 generally
suggesting that racial problems have been occurring for a long time at Pender High School,
but the comments were not specific to any teacher or administrator.
Mr. Riley is not aware of any specific teacher being disciplined for violating the Board’s
social media policy. He agreed that violations of the policy or questionable postings are dealt
with through coaching rather than discipline, and potentially letters of reprimand if the
posting is “really bad.”

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I. EXECUTIVE SUMMARY ......................................................................................... 1

II. INVESTIGATIVE PLAN .......................................................................................... 3

A. Define Scope of Investigation ...................................................................... 3

B. Identify Applicable Law ................................................................................. 3

C. Preliminary Steps to Begin Investigation .................................................... 9

D. Witness Interviews .......................................................................................... 9

III. FINDINGS OF FACT ..............................................................................................11

A. Principal Caroline Godwin Wrote “Niggers” in the

B. Karen McGowen Said “Nigger” or “Nigga” on Two

C. Rayford Hankins Posted Two Images of Documents

IV. CONCLUSIONS ........................................................................................................18

A. Ms. Godwin Did Not Violate the Standards of Professional

B. PCS’s Investigation of the Circumstances Concerning

C. Ms. McGowen Violated the Standards of Professional

D. The Administration’s Investigation of the Complaint Against

IV. WITNESS ACCOUNT SUMMARIES ..................................................................22

A. Dr. Alfreida Moore – Appendix A ............................................................22

B. Ms. Shanika Mack – Appendix B ...............................................................22

C. Ms. Caroline Godwin – Appendix C .........................................................22

D. Mr. Jack Poulos – Appendix D ...................................................................22

E. Ms. Karen McGowan – Appendix E .........................................................22

F. Dr. Steven Hill – Appendix F .....................................................................22

G. Mr. Rayford Hankins – Appendix G .........................................................22

H. Mr. Alex Riley – Appendix H .....................................................................22

In conducting this investigation, we have surveyed myriad laws, regulations, and

II. INVESTIGATIVE PLAN

A. Define Scope of Investigation

B. Identify Applicable Law

1. Standards of Professional Conduct, 16 NCAC 06C .0602

The Standards of Professional Conduct state, in relevant part:

(b) Professional educators shall adhere to the standards of professional

(1) Generally recognized professional standards. The educator shall

(2) Personal conduct. The educator shall serve as a positive role

(3) Honesty. The educator shall not engage in conduct involving

(G) submission of information in the course of an official

(6) Confidential information. The educator shall keep in confidence

2. Prohibition Against Discrimination, Harassment, and Bullying,

The Prohibition Against Discrimination, Harassment, and Bullying states, in relevant

In proscribing discrimination, harassment, and bullying, the Prohibition states that

When considering if a response beyond the individual level is

“Hostile environment” means that the victim subjectively views the

3. Discrimination, Harassment and Bullying Complaint Procedure,

4. Staff Responsibilities, Board Policy 7300

5. Code of Ethics for Educators, Board Policies 7305 and 7305-R

Board Policy 7305 provides:

Employee conduct should reflect positively on the integrity and

Employees shall perform their jobs in a competent and ethical manner

6. Employee Use of Social Media, Board Policy 7335

1. Employees shall not post confidential information about students,

5. Employees shall be professional in all Internet postings related to

6. Employees shall not use profane [or] . . . indecent . . . language,

9. Employees shall not use Internet postings to libel or defame the

11. Employees shall not post inappropriate content that negatively

C. Preliminary Steps to Begin Investigation

After reviewing and organizing the documents we received, we identified potential

• Dr. Alfreida Moore, Chief Officer of Human Resources for PCS

• Ms. Shanika Mack, Assistant Principal at PHS

• Ms. Caroline Godwin, Principal at PHS