Policy

It is the policy of St. Louis County to comply with Title VI of the Civil Rights Act of 1964 and subsequent updates to that law. The law requires that no person shall on the grounds of race, color, or national origin, be excluded in, denied benefits of, or be subjected to discrimination in any operation, program, or activity receiving federal funding or other financial assistance from the federal government.

Scope

This policy applies to the availability and delivery of all services and programs made available to County residents by the County.

Definitions

Terms used in this policy are intended to have the meaning set forth in the 1964 Civil Rights Act. In the event of any conflict between provisions of this policy and federal law, the federal law prevails.

• “County” refers to the officers, employees, agencies, and facilities of St. Louis County government.
• “Discrimination” refers to any unfair treatment because of race, color, or national origin.
• “The County Board” refers to the St. Louis County Board of Commissioners.
• “Title VI” refers to Title VI of the Civil Rights Act of 1964, 42 U.S.C. 2000d et seq. (”Title VI”). Title VI prohibits discrimination on the basis of race, color, or national origin in any program or activity that receives Federal funds or other Federal financial assistance.

Legal Authorities

The County is guided by the following federal legal authorities:

• Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.
• 28 C.F.R. Part 42.401 et seq, & § 50.03
• Leadership and Coordination of Nondiscrimination Laws Order (Exec. Order No. 12250, 45 Fed. Reg. 72995 (Nov. 2, 1980).)
• Civil Rights Restoration Act of 1987, Pub. L. No. 100-259, 102 Stat. 28 (1988)

General

The County is committed to ensuring that no person is denied benefits or otherwise is subjected to discrimination in any of its programs or activities within the County on the basis of race, color, or national origin. This policy also serves as a source of information for County staff and the public. The Plan sets out the County’s civil rights administrative policies and procedures, identifying key contacts within the County. In addition, the County will take reasonable steps to provide meaningful access to services for persons with Limited English Proficiency (LEP).

When the County distributes federal aid funds to an outside entity, the County will include Title VI language in its written agreements and will monitor the entity for compliance.

Examples of prohibited types of discrimination, when based on race, color, or national origin, include: denial to an individual of any service, financial aid, or other benefit; distinctions in the quality, quantity, or manner in which a benefit is provided; segregation or separate treatment; restriction in the enjoyment of any advantages, privileges, or other benefits provided; discrimination in any activities related to highway and infrastructure or facility built or repaired; and discrimination in employment.

County departments may have or develop more specific Title VI policies or procedures based on the types of federal funding they receive, if appropriate.

TITLE VI COORDINATOR

The County Administrator is responsible for assuring full compliance with the provisions of Title VI and related statutes, laws, and rules and has directed that non-discrimination is required of all County employees, contractors, and agents pursuant to 23 C.F.R. Part 200 and 49 C.F.R. Part 21. The County has created the position of Accessibility and Engagement Coordinator, to perform the duties of the Title VI coordinator on behalf of the County and ensure implementation of Title VI program activities. The County’s Accessibility and Engagement Coordinator is under County Administration.

The following is contact information for the St. Louis County Title VI Coordinator:

The Title VI Coordinator’s responsibilities include, but are not limited to, the following:

1. Provide guidance and technical assistance on Title VI matters and be responsible for the overall program, review what is required for Title VI compliance, develop procedures, and monitor for:
   • Prompt review, processing and resolution of Title VI complaints.
   • Identification of discrimination.
   • Elimination of discrimination when discrimination is found to exist.
   • Prompt resolution in deficient areas.
2. Regular review of County functions to ensure compliance with Title VI requirements.
3. Ensure Title VI requirements are included in policy directives and that procedures used have built-in safeguards to prevent discrimination.
4. Correct Title VI problems, discriminatory practices, or errant policies found when conducting self- monitoring and compliance review activities.
5. Ensure discrimination complaints are fully investigated and allow for a formal review of the investigation.
6. Assure that Title VI information for public dissemination is developed in languages other than English, where appropriate.
7. Provide information to any complainant about where to file a discrimination complaint and refer discrimination complaints to the Minnesota Human Rights Division, the United States Department of Justice Civil Rights Division, or other applicable entity when appropriate.
   • Provide a telephone number or relay service number if deaf or hard of hearing.
   • Provide an email address if possible.
   • The complaint must state the problem or action alleged and the relief desired. If assistance is needed, the Title VI Coordinator will contact the individual.
   • The County will investigate the complaint if it is submitted within the appropriate time period. The Title VI Coordinator will conduct the investigation; or some other qualified person as designated by the County Administrator.

ST. LOUIS COUNTY’S COMPLAINT PROCESS

Every individual has the right to equal access to services, whether they are an applicant, client, or member of the public. The County has implemented this civil rights complaint procedure to provide prompt and thorough resolution of Title VI complaints.

Title VI complaints allege discrimination based upon an individual’s race, color, or national origin. Individuals have a right to file a Title VI complaint if they believe they, or an individual they care for, has been discriminated against because of their race, color, or national origin.

It is against the law for anyone who works for the County to retaliate against a person who files a complaint or who cooperates in the investigation of a Title VI complaint.

If the complainant believes that the complainant has been discriminated against based on their race, color, or national origin by someone working for the County, then a civil rights complaint form will be provided. The contact information below can be used to file a complaint. Individuals may also contact the Title VI Coordinator’s office at St. Louis County with additional questions.

Title VI complaints must be submitted to the Title VI Coordinator within 180 days of the date the alleged discrimination occurred. A complaint must be in writing and contain the name and address of the person filing it.

1. Use Appendix A – Complaint Form*
2. Provide a telephone number or relay service number if deaf or hard of hearing.
3. Provide an email address if possible.
4. The complaint must state the problem or action alleged and the relief desired. If assistance is needed, the Title VI Coordinator will contact the individual.
5. The County will investigate the complaint if it is submitted within the appropriate time period. The Title VI Coordinator will conduct the investigation; or some other qualified person as designated by the County Administrator.

*Administrative updates to the Complaint Form may be completed to ensure ongoing compliance with Title VI and other applicable federal laws and do not require re-approval of the policy or form by the County Board.

The Complainant will be informed that they can file a discrimination complaint directly with the Federal agency that provides federal financial assistance to the County for the program or service with which the Complainant was interacting. The Title VI Coordinator will provide that information to the Complainant. If that information is not provided, the Complainant may file their complaint with:

US Department of Justice Civil Rights Division
950 Pennsylvania Ave. NW
Washington, D.C. 20530

Filing Complaints with State Agencies: The person filing the complaint may also file a discrimination complaint directly with the Minnesota Department of Human Rights. The Minnesota Department of Human Rights prohibits discrimination in public services programs because of race, color, creed, religion, national origin, disability, sex, sexual orientation, or public assistance status. Contact the Minnesota Department of Human Rights directly:

Minnesota Department of Human Rights Freeman Building
625 N Roberts Street
St. Paul, MN 55155
651-539-1100 (voice)
800-657-3704 (toll free)
711 or 800-627-3529 (MN Relay)

St. Louis County will make appropriate arrangements to ensure that people are provided reasonable modifications or effective communications, if needed, to participate in the complaint process. The Title VI Coordinator or designee is responsible for making these arrangements.