Communications Between Ossining Union Free School District and ICE Regarding Immigration Enforcement Policies

Jordan Lassiter

Independent Investigative Journalist
Transparency Report
Email: Jordan@Lassiter.eu

Date: February 12, 2025

To:
Records Access Officer
Ossining Union Free School District
400 Executive Blvd
Ossining, NY 10562

Subject: FOIL Request – Communications Between Ossining Union Free School District and ICE Regarding Immigration Enforcement Policies

To Whom It May Concern,

Pursuant to the New York State Freedom of Information Law (FOIL), Public Officers Law §§ 84-90, I hereby request access to and copies of all records, communications, and documentation related to interactions, cooperation, or coordination between the Ossining Union Free School District (OUFSD) and Immigration and Customs Enforcement (ICE) regarding immigration enforcement activities under the administration of President Donald J. Trump.

This request seeks to clarify whether and how the school district interacts with ICE and whether students, staff, or families have been subject to inquiries, investigations, or enforcement actions by federal immigration authorities.

Scope of Request: Specific Records Sought

I request copies of all relevant records, including but not limited to:

1. Communications Between Ossining Union Free School District and ICE
• Copies of all emails, letters, faxes, text messages, internal memos, and reports exchanged between OUFSD officials, school administrators, security personnel, school resource officers (SROs), or board members and ICE agents or representatives from January 1, 2025, to the present regarding:
• Requests for student, staff, or family immigration status information.
• Any ICE investigations, detainer requests, or inquiries involving individuals associated with OUFSD.
• ICE agents requesting access to school property or student records.
• The school district’s policies or responses to ICE enforcement actions involving students or their families.

2. School District Policies on ICE and Immigration Enforcement
• Copies of all official policies, directives, or procedures issued by OUFSD regarding:
• How school officials and staff are instructed to respond to ICE agents seeking access to students, school premises, or records.
• Whether parental consent or legal counsel is required before sharing student information with ICE.
• Notification procedures for parents, guardians, or attorneys when a student or family member is targeted by ICE.
• Compliance with New York State’s sanctuary policies restricting local cooperation with federal immigration enforcement.

3. Training Materials and Guidance for Staff
• Copies of any training materials, legal briefings, or memos provided to:
• School administrators, teachers, counselors, and staff regarding their obligations in handling ICE inquiries.
• School resource officers (SROs) or security personnel on interacting with ICE and enforcing federal immigration laws.
• Guidance on FERPA (Family Educational Rights and Privacy Act) and its application to ICE data requests.

4. Agreements, MOUs, and Data Sharing with ICE
• Copies of any Memoranda of Understanding (MOUs), agreements, or contracts between OUFSD and ICE, including:
• Any formal agreements granting ICE access to school records, facilities, or personnel.
• Any federal funding, grants, or financial incentives provided to OUFSD in exchange for cooperation with ICE.

5. Records of ICE Visits or Enforcement Actions in Schools
• Any incident reports, call logs, visitor logs, or law enforcement records documenting:
• ICE agents visiting Ossining schools for questioning, detentions, or surveillance.
• Any students, faculty, or parents detained or questioned on school grounds.

Legal Justification for Disclosure

This FOIL request aligns with Public Officers Law § 87(2), which provides the public with a presumptive right to access government records. Courts have repeatedly ruled in favor of government transparency in matters affecting public institutions, including schools.

Under Buffalo Broadcasting Co. v. New York State Dep’t of Correctional Services, 155 A.D.2d 106 (3d Dep’t 1990), state agencies must disclose non-exempt records and cannot deny access without a valid legal exemption.

Additionally, FERPA (20 U.S.C. § 1232g) protects the privacy of student records and sets strict limits on when and how student information can be shared with federal agencies. This request seeks to clarify whether OUFSD is complying with FERPA while handling ICE inquiries.

Obligation to Preserve and Provide Records

Under Armstrong v. Executive Office of the President, 1 F.3d 1274 (D.C. Cir. 1993), government entities must preserve records subject to public disclosure laws. Accordingly, I request that no responsive records be deleted, altered, or destroyed while this FOIL request is under consideration.

Fee Waiver Request

I request a waiver of all applicable fees for processing this request. Disclosure of these records serves the public interest by promoting transparency and protecting the rights of immigrant students and families and is not for commercial purposes.

Under Matter of New York Times Co. v. City of New York Fire Dep’t, 4 N.Y.3d 477 (2005), fee waivers should be granted when disclosure benefits the general public.

If a fee waiver is denied, I agree to pay up to $100 in processing fees. Please notify me in advance if costs will exceed this amount.

Request for Expedited Processing

Given the heightened public concern regarding immigration enforcement in schools, I request expedited processing of this FOIL request. Under Matter of Westchester Rockland Newspapers v. Kimball, 50 N.Y.2d 575 (1980), courts have recognized the need for timely disclosure of government records in matters affecting public safety and civil liberties.

Response Format and Timeline

Pursuant to Public Officers Law § 89(3)(a), I expect an acknowledgment of receipt within five (5) business days and an estimated timeline for disclosure.

Please provide electronic copies of records whenever possible. If any records are withheld or redacted, I request a written explanation citing specific legal exemptions in accordance with Gould v. New York City Police Dep’t, 89 N.Y.2d 267 (1996).

Contact Information

Should you require any clarification or additional details, please contact me at Jordan@Lassiter.eu.

I appreciate your prompt attention to this matter and your commitment to transparency.

Sincerely,
Jordan Lassiter
Independent Investigative Journalist
Transparency Report