June 13, 2010


Stephen F. Waddell, Ed.D.


6125 East Belknap

Haltom City, TX 76117



            RE: Response, from Stephen Waddell dated May 27, 2010, to Request Appeal the Level

       II Response from Dr. Jay Thompson dated May 10, 2010


In lieu of providing an itemized list, as previously offered, I will attempt to simplify my complaint and resolution by omitting some items which have been ignored.  In my original grievance I requested, in good faith, that disciplinary action (that would be in compliant with BISD’s policy) be taken with the staff and administration I filed complaint against.


Since the filing of my complaint it has become all too evident BISD has no such policy.  It is my conclusion no policy exists for BISD after reading BISD’s Employee Handbook, BISD’s Board Policy and requesting reference to any policy pertaining to protocol of staff/administration in cases of assault and harassment.  If I am missing said policy, please correct me.


In the absence of policy, it is my hope the Board of Trustees reviews the actions (in the events which prompted my grievance) of Susan Taylor, Rod Bailey and Mathew Donnell and takes into account 19 TAC Chapter 247, Educator’s Code of Ethics; standards of expectation set forth by the U.S. Department of Education Office of Civil Rights; and Texas Unified School Safety Standards.


I will reference the Haltom City Police Department Incident Report in this request.  This was introduced (and accepted) into my grievance at Level II as it was not available at the time of the Level I, nor the initial filing of grievance.  Names of all minors involved have been, rightfully, “blacked out” by court officials.  A copy of the report will accompany this request for resolution.


19 TAC Chapter 247, Educator’s Code of Ethics


Standard 3.2 Rod Bailey knowingly treated a student in a manner that adversely affected the student’s learning, physical health, mental health, or safety.


      Rod Bailey ignored prior complaints (specifically naming Christian Castillo) of assault and

      harassment, made by Joseph and myself.  Mr. Bailey treated one complaint as an “isolated”

      incident Level I Transcript, page 42.  I say these complaints are ignored simply because all,

      but one, are unacknowledged by Mr. Bailey. 


Contrary to Rod Bailey’s prior statement of one of our complaints being “isolated”, he goes on to say even Christian admitted to “bullying Joseph during the school year,” Level I Transcript, p. 36 and Mr. Bailey stated Christian had been “urinating on another student,” Level I Transcript, p. 31; Mr. Bailey had “worked quite a lot with” Christian Castillo “over the last two years” and this year “as hard as, I guess, it is, he did do better this year.” Level I Transcript, p. 45 and Christian “does this because he thinks it’s funny.” Haltom City Police Incident Report, p. 2


Although I do not deem it necessary for me to say the following, I will- for clarification.  My son was repeatedly harassed and assaulted by Christian Castillo throughout the school year. 


The incidents were repeatedly reported, by Joseph and me, to Rod Bailey throughout. 


The complaints were repeatedly ignored. 


My son, Joseph Jackson, has been adversely affected physically; emotionally; mentally; educationally and his safety has been affected in the most disgusting manner- repetitively.


Standard 3.2 Susan Taylor knowingly treated a student in a manner that adversely affected the student’s learning, physical health, mental health, or safety.


      Susan Taylor ignored prior complaints (specifically naming Christian Castillo) of assault and

harassment, made by Joseph and myself.  I claim these complaints are ignored because all are unacknowledged.  Mrs. Taylor does proudly profess that after speaking to me one time, she accomplished to arrange a visit with the Guidance Counselor for Joseph.  The Guidance Counselor, ironically, suggested Joseph talk to Mr. Bailey and Mrs. Taylor about what had been happening to him.


Again, Joseph has been affected in all of the before mentioned ways.


Standard 3.2 Matthew Donnell knowingly treated a student in a manner that adversely affected the student’s learning, physical health, mental health, or safety.


Mr. Donnell allowed Christian Castillo to re-enter the showers, prior to Joseph’s declining participation in athletics, the day immediately following his reported assault (made with his genitals) against another student.  Joseph’s learning, physical health, mental health and safety were only the beginning of the effect that morning.  Each child in the shower, that morning, with Christian Castillo was affected in the identical manner.


Standard 3.3 Rod Bailey knowingly misrepresented facts regarding a student. 

Standard 1.6 Rod Bailey falsified records or coerced another to do so.


Rod Bailey reported to Brandi Perkins he “feels the incident did not take place.”  Bailey said “Joe does not always tell the truth and had been caught telling his mother things that just weren’t true.”  Haltom City Incident Report, last paragraph, page 2.  Mr. Bailey’s allegations of Joseph’s credibility have no precedence.  Rod Bailey later denied making this statement. 


Mr. Bailey’s statement to the police left Brandi Perkins unable to serve Christian Castillo a citation for his assault against Joseph Jackson.  The case was referred to Haltom City Municipal Court for further consideration.


Upon arrival at court, I learned Mr. Bailey’s statement to the police had a significant impact on the integrity of Joseph Jackson resulting in the prosecutor’s unwillingness to prosecute Christian Castillo.  The prosecutor places full trust in police statements and had taken the report as fact.  Mr. Bailey was kind enough to return my phone call and tell me he had never made the statement documented in the police report.  Mr. Bailey’s return phone call arrived as Joseph and I were in the Haltom City Court House proceeding with civil charges against the assailant.  The call took place on speaker phone, witnesses include the City Prosecutor (I will provide his name upon request).  After Mr. Bailey’s denying his statements, the case was then accepted and date was set for Christian Castillo to appear before the court.


Upon my leaving the court house, I briefly visited Rod Bailey and Susan Taylor to show them the police report.  Again, Rod Bailey denied making the statement.  I encouraged him to contact Haltom City Police Department in regards to their falsifying his words.  To my knowledge, he has not done so.  The record stands as previously stated.


Standard 3.3 Matthew Donnell knowingly misrepresented facts regarding a student.


Matthew Donnell said (three times) he had told Joseph to call me on Friday, March 5, 2010 (using Joseph’s cellular phone).  Dr. Kempe’s Report on Investigation  and Level I Transcript, pages 8 and 9. IF this happened, it was purely coincidental. I instructed Joseph to call me from athletics to get Matthew Donnell on the phone, Joseph did so.


      Twice, Matthew Donnell stated he had told me (on Joseph’s cellular phone) that he “would

be contacting administration” about this incident.  Dr. Kempe’s Report on Investigation  and Level I Transcript, page 8.  Mr. Donnell said no such thing; he did not so much as imply he would contact administration.  He told me he discussed the incident with Christian- Mr. Donnell relayed to me he told the Christian Castillo “If he did this again, he would not be allowed to participate in athletics.”  Mr. Donnell also told me he had talked with the team as a whole regarding the incident.  From speaking to Joseph and others, this did not occur either.          


Department of Education Office of Civil Rights (OCR) states the standards I have listed on page 2 of my correspondence with Dr. Thompson’s office, dated April 16, 2010. I have included a copy for your reference.  These standards are specifically explicit to school staff and administration conduct when it comes to reported sexual harassment. These standards are unquestionably clear.  None, but the first, of these standards were even begun to be met in the incident surrounding my grievance.


Texas Unified School Safety Standards  By definition of the document, violence is inclusive of safety protocol.  Throughout the school year, as my grievance covers, it has not been remotely evident that Haltom Middle School staff and administration practice many of these standards.  Specific to the repetitive and escalating behavior of Christian Castillo and the repetitive recipient of Christian’s behavior, Joseph Jackson- it is alarming that neither BISD, nor Haltom Middle School staff and administration, have practiced Standards 3.3, 3.7 and 4.3.  The named standards are only the most specific to this matter, the rest are equally important. A copy of these standards is included for your review.


I thank you, in advance, for your thorough consideration of my grievance.  As I have stood, prior to this request for relief, it is not possible for Haltom Middle School to move progressively toward a safe learning environment for our students if the existing district stance (on this matter) remains.


With Humble Regard,




Christine Jackson

5005 NE Loraine, #2

Haltom City, TX 76117



Enclosures (4):

Texas Unified School Safety Standards

Letter requesting appeal of Level I Hearing Response dated April 16, 2010 (for OCR reference)

Haltom City Police Incident Report

Birdville Independent School District Complaint/Grievance Forms