I. The Federal Law That Colleges Ignore

The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act is a federal mandate passed in 1990 requiring every college and university that receives federal financial aid to collect and publicly report statistics for certain crimes, including sexual offenses, to the United States Department of Education.

The reporting obligation is triggered when a crime is “reported” to a campus security authority or local law enforcement. Under federal regulations, a crime is considered “reported” the moment it is brought to the attention of someone with significant responsibility for student activities, not when someone files a formal complaint or presses charges.

The law explicitly states that each reported crime must be disclosed “for the calendar year in which the crime was reported to a campus security authority,” not the year in which the crime allegedly occurred. This means a student who reports an assault from three years ago triggers a current-year reporting obligation.

Thomas Galvin knew this. He had served as Roxbury Community College’s primary campus security authority and chief compliance officer for the Clery Act since April 2007. His job was to ensure the college followed the law.

The college did not follow the law. When Galvin tried to force compliance, the institution turned its enforcement mechanisms against him.

II. The Timeline Of Institutional Silence

August 26, 2010: The Complaints Surface

Preston Paul Alexander, then the college’s Director of Human Resources and Affirmative Action, received two written complaints from a student alleging she had been sexually assaulted by two different college professors. One assault allegedly occurred in 2003 or 2004 by a professor who had been fired in 2006. The other occurred on an unspecified date by an unnamed professor.

The student met with Alexander several weeks later. She told him she had previously reported at least one of the assaults to three separate college employees in 2003, to the Director of Financial Aid Raymond O’Rourke in 2006 and 2008, to Vice President of Administration and Finance Dr. Alane Shanks in 2008, and to Galvin himself in 2009.

The student also told Alexander she did not want the human resources office to take any action.

September 1, 2010: Galvin Asks The Wrong Question

Galvin sent an email to Alexander asking whether the human resources office had information about campus crimes that needed to be included in the college’s upcoming 2010 Clery Act report due to the Department of Education on October 1.

Alexander responded by email, copying Vice President Shanks, and stated: “there were no reported crimes on record in Human Resources for the past year.”

This was false. Alexander had received the student’s written sexual assault complaints five days earlier.

November 30, 2010: The Documents Under The Door

Galvin found copies of the student’s two sexual assault complaints slid under his office door. He immediately sent an email to his direct supervisor, Vice President Shanks, asking whether the allegations had previously been reported as required by the Clery Act.

According to Galvin, Shanks told him “there is nothing to report.” According to Shanks, she told him he should report the assaults if he believed they should be reported.

Shanks then forwarded Galvin’s email to Alexander, who responded to Galvin confirming that the human resources office had received the student’s complaints and taken no action on them. Galvin did not reply to this message and did not have any further discussions with Alexander about reporting the allegations.

The same day as Galvin’s inquiry, Shanks directed the college comptroller, Chuks Okoli, to provide the student with a presidential scholarship for her remaining balance for the fall 2010 semester and to send the student a bill with a zero balance. Okoli’s office confirmed the following day that the scholarship had been added to the student’s account and her balance was zero.

January-February 2011: Galvin Goes To The Feds

Galvin met with employees of the United States Department of Education, showed them the student’s complaints, and asked for guidance on how to report the allegations pursuant to the Clery Act. The DOE employees were not sure how to report the allegations and said they would get back to Galvin.

July 13, 2011: Galvin Goes To The State

Galvin met with staff from the Massachusetts State Auditor’s office and told them about the student’s allegations. He told them the student had been given a scholarship shortly after senior management learned of her allegations, and that he was told by Shanks and the human resources office that there was nothing to report.

At the end of the meeting, Galvin was told that the State Auditor’s office would notify the college’s chair of the board of trustees, Michele Courton Brown, about the allegations.

Around this time, Vice President Shanks left the college. Comptroller Okoli replaced her as Vice President of Administration and Finance, becoming Galvin’s new direct supervisor.

September 9-16, 2011: The Board Demands Answers

Board Chair Courton Brown delivered a letter to Galvin requesting information about the concerns he expressed to the State Auditor’s office.

On September 16, 2011, Galvin responded in writing with a detailed summary:

“[The college] has failed to report a campus crime referencing [the student], a former student. This alleged sexual assault is required reporting under the Clery Act. You will [receive] materials that demonstrate that Vice President Shanks and other College officials were aware of this and did not act upon it, as required. Please note that the dismissed student was given College funds: a Presidential Scholarship as directed by V.P. Alane K. Shanks to cover her Fall 2010 bill.”

September 26, 2011: The Private Investigation Begins

Based on the information Galvin provided, the board of trustees notified Galvin that the college’s private audit firm, O’Connor & Drew, would investigate his allegations and prepare a report.

October 1, 2011: The Report Without The Crimes

Galvin submitted the college’s 2011 Clery Act report to the Department of Education. He did not include the student’s sexual assault claims.

He later testified that he omitted the claims because the DOE had told him they were not reportable due to the fact that one of the underlying incidents occurred in 2003, outside the three-year reporting window.

This reasoning was incorrect under federal regulations, which require reporting based on the year the crime was reported to a campus security authority, not the year the crime occurred. The student reported the assaults to multiple campus officials in 2008, 2009, and 2010, all within the three-year window for the 2011 report.

III. The Audit Reports The College Wishes Didn’t Exist

May 29, 2012: The O’Connor Report

The private audit firm O’Connor & Drew issued its final report. The findings were unambiguous:

The college did not report the student’s claims “in 2003, the year in which [one] incident is first alleged to have been reported, in 2006, the year in which a faculty member was dismissed in connection with a separate sexually related allegation, or in 2008 and 2010, years in which the incident was reported to various [college] officials.”

The O’Connor report further concluded that one of the alleged offenses “met the reporting requirements of the Clery Act based on the definition of the term ‘reportable offenses’ listed in the [Clery Act handbook].”

The report also addressed the 2006 dismissal of the faculty member accused by the student. That dismissal was precipitated by a separate sexual misconduct allegation from another complainant. The O’Connor report concluded that this other complaint “arguably also should have been disclosed to the DOE during the relevant years and was not.”

March 4, 2013: The Goodwin Report (After Galvin Was Already Fired)

On August 21, 2012, eight days after Galvin’s termination, the executive committee of the board of trustees engaged independent counsel, the law firm Goodwin Procter LLP, to conduct a complete investigation of the student’s allegations.

Goodwin issued its final report on March 4, 2013. The conclusions mirrored O’Connor’s findings:

The student “repeatedly made [one] allegation to [the college’s] senior administrators and staff between 2008 (at the latest) and 2011,” and the college “repeatedly failed to comply with its obligation under the Clery Act to disclose the fact of [the student’s] alleged sexual assault in its annual reports to the DOE for, at least, the years 2009 and 2010.”

The Goodwin report also discussed several other allegations of sexual misconduct perpetrated by the same professor that were likewise not disclosed to the DOE pursuant to the Clery Act.

The college does not dispute the findings of either the O’Connor or Goodwin reports.

IV. The Termination

July 9, 2012: The Performance Review

Galvin’s new supervisor, Vice President Okoli, completed a performance review covering the period from July 1, 2011, through June 30, 2012. Okoli’s evaluation stated that Galvin:

“failed to comply with critical public safety compliance requirements”; that “[t]he institution’s failure to comply with all higher education critical regulatory requirements on public safety clearly attest[ed] to the lack of both responsiveness and accountability by [Galvin], in his primary role as the lead Public Safety Officer”; and that Galvin’s noncompliance “placed the [c]ollege in harm’s way both financially and academically.”

The evaluation also stated that other aspects of Galvin’s job performance were deficient, including his maintenance of the college’s grounds and facilities, procurement of goods and services, and supervisory skills.

August 13, 2012: The Letter

Galvin received a termination letter from Linda Turner, then the interim president of the college. The letter stated that the decision was based on Okoli’s “2011-2012 Performance Evaluation, which specifie[d] numerous deficiencies with [Galvin’s] performance, and the findings presented in the recently completed [O’Connor report].”

The college fired the man who exposed their decade-long failure to report sexual assaults by citing his failure to report sexual assaults.

V. The Non-Financial Ledger

Thomas Galvin worked in public safety for a Massachusetts community college. His annual salary in 2012 was approximately $89,000. He had a mortgage, a family, and a job he believed served the public interest. He was responsible for keeping students safe and ensuring the institution complied with federal crime reporting laws designed to inform prospective students and their families about campus safety.

When he discovered his employer had been concealing reports of sexual violence for years, he faced a choice. He could ignore the violations and keep his job, or he could report the violations and risk retaliation. He knew the college had already silenced the survivor with scholarship money. He knew his direct supervisor had explicitly told him there was nothing to report. He knew the human resources director had lied to him in writing about whether any crimes had been reported.

He went to the federal Department of Education first. They couldn’t tell him what to do. He went to the state auditor’s office. They forwarded his concerns to the board of trustees. He provided a written summary of the violations to the board chair. The board hired a private auditor. The auditor confirmed everything Galvin said. The college fired him anyway.

Galvin spent the next fourteen years fighting to clear his name. He filed his lawsuit in October 2012, two months after his termination. The college moved for summary judgment, arguing he was not a whistleblower and even if he was, they didn’t fire him for whistleblowing. The motion was filed in February 2017. The judge ruled in Galvin’s favor in stages over the next several years, ultimately allowing the case to proceed to trial on the narrow question of whether the college fired Galvin because of his whistleblowing or because of his own performance failures.

The trial took place more than a decade after Galvin lost his job. The jury heard evidence about the scholarship given to the assault survivor the same day Galvin asked about reporting obligations. They heard about the emails from the human resources director denying any knowledge of reported crimes. They heard about the two independent audit reports confirming the college’s systematic failures. They heard the college’s argument that Galvin was fired for legitimate performance reasons unrelated to his disclosure.

The jury did not believe the college. They awarded Galvin $980,000 in damages.

The college appealed. The case reached the Massachusetts Supreme Judicial Court, which issued its final ruling on January 27, 2026. The court affirmed the verdict and established a legal precedent that will govern whistleblower cases across the state: an employee who objects to illegal activity can be protected under whistleblower law even if that employee was partly responsible for the illegal activity they are reporting.

Galvin won. But he won after fourteen years of litigation, two trials, multiple appeals, and immeasurable personal cost. He won after the college spent hundreds of thousands of dollars in legal fees and hired two separate law firms to investigate him. He won after watching his professional reputation be systematically dismantled by the institution he tried to hold accountable.

The student who reported being sexually assaulted by two college professors never got her day in court. The professors who allegedly committed the assaults faced no criminal charges. The administrators who concealed the reports for years faced no professional consequences. Vice President Shanks left the college and moved on to another position. Human Resources Director Alexander remained employed by the college throughout the litigation. The only person who lost their career was the person who tried to follow the law.

This is what institutional accountability looks like in American higher education. The system does not reward those who expose wrongdoing. It punishes them. And then, if they are lucky and have the resources to survive more than a decade of litigation, it gives them a check and calls it justice.

VI. Legal Receipts

The following passages are taken verbatim from the Massachusetts Supreme Judicial Court’s published opinion in Galvin v. Roxbury Community College, case number SJC-13754, issued January 27, 2026:

“The Clery Act requires colleges and universities that receive Federal financial aid to, among other things, collect and disclose statistics for certain ‘reported’ crimes including sex offenses to the United States Department of Education.”

“Under the Clery Act, ‘a crime is reported when it is brought to the attention of a campus security authority or local law enforcement personnel.'”

“Each reported crime meeting the statutory criteria must be disclosed ‘for the calendar year in which the crime was reported to a campus security authority’ not the calendar year in which the crime allegedly was committed.”

“The O’Connor report concluded that the college did not report the student’s claims ‘in 2003, the year in which [one] incident is first alleged to have been reported, in 2006, the year in which a faculty member was dismissed in connection with a separate sexually related allegation, or in 2008 and 2010, years in which the incident was reported to various [college] officials.'”

“The Goodwin report likewise explained that the student ‘repeatedly made [one] allegation to [the college’s] senior administrators and staff between 2008 (at the latest) and 2011,’ but the college ‘repeatedly failed to comply with its obligation under the Clery Act to disclose the fact of [the student’s] alleged sexual assault in its annual reports to the DOE for, at least, the years 2009 and 2010.'”

“The college does not dispute the findings of the O’Connor or Goodwin reports in this regard.”

“We conclude that the motion judge properly decided that Galvin engaged in protected activity as a matter of law, despite his own involvement in and responsibility for reporting the alleged sex offenses, as it was undisputed that he objected to Clery Act violations and that such violations had occurred.”

“An employee objecting to an activity undisputedly in violation of the law is, as a matter of law, objecting to an activity the employee reasonably believes to be in violation of the law.”

“Excluding employees reporting undisputedly unlawful activity from whistleblower protection when they are implicated in the employer’s wrongdoing would discourage the revelation of such wrongdoing, which is one of the purposes of the MWA.”

“The MWA, and particularly the protected activity defined in G. L. c. 149, § 185 (b) (3), thereby necessarily encompasses ‘misconduct in which the employee is personally involved, or in which the employee is asked to participate.'”

VII. Societal Impact Mapping

Environmental Degradation

While this case does not directly involve environmental harm, it illustrates the institutional practice of concealing regulatory violations to protect reputation and avoid federal penalties. The same structural incentives that led Roxbury Community College to hide sexual assault reports for a decade operate in every sector where external oversight depends on self-reporting. When institutions can punish internal disclosure and face minimal consequences for substantive violations, compliance becomes optional. The environmental parallel is industries that under-report emissions, contamination, and safety incidents because the cost of revelation exceeds the cost of concealment. The degradation is systemic: regulatory frameworks designed to protect the public become performative exercises that reward institutional opacity.

Public Health

The failure to report campus sexual assaults under the Clery Act is a public health crisis. Prospective students and their families rely on federally mandated crime statistics to make informed decisions about campus safety. When colleges systematically conceal sexual violence data, they deny the public the information necessary to assess risk. The student who reported assaults to Roxbury Community College administrators beginning in 2003 was not the only victim. Every student who enrolled at the college between 2003 and 2012 made their enrollment decision based on incomplete and deliberately falsified safety data. The college reported zero sexual offenses during years when multiple incidents had been reported to campus authorities. This is not a paperwork error. This is the institutional manufacturing of a false safety record that directly endangered subsequent students by concealing patterns of violence and institutional inaction.

Economic Inequality

Thomas Galvin’s wrongful termination lawsuit took fourteen years to resolve. He filed in October 2012 and did not receive a jury verdict until 2023. The Massachusetts Supreme Judicial Court did not issue its final ruling until January 2026. This timeline is not an anomaly. It is the standard cost of challenging institutional misconduct through the legal system. Galvin had to survive fourteen years without the income, benefits, and professional standing he lost when he was fired. He had to fund legal representation for over a decade. The college, a publicly funded institution, paid its legal fees with taxpayer money and faced no budget constraints in its efforts to outlast him. The verdict of $980,000, while substantial, does not account for fourteen years of lost wages, lost retirement contributions, lost career advancement, or the personal and familial cost of being unemployed and publicly branded as incompetent by a former employer. The message is clear: if you report institutional wrongdoing, you must be wealthy enough to survive more than a decade of litigation, or you will be ground down by the process itself. This is not justice. This is attrition as enforcement.

VIII. What Now?

The Massachusetts Supreme Judicial Court opinion does not name every individual responsible for the systematic concealment of sexual assault reports at Roxbury Community College, but the court record identifies the following institutional actors:

• Dr. Alane Shanks, Vice President of Administration and Finance, who allegedly told Galvin “there is nothing to report” and directed that the assault survivor be given a presidential scholarship the same day Galvin inquired about reporting obligations.
• Preston Paul Alexander, Director of Human Resources and Affirmative Action, who falsely told Galvin in writing that there were “no reported crimes on record in Human Resources.”
• Chuks Okoli, who replaced Shanks as Vice President of Administration and Finance and authored the performance review used to justify Galvin’s termination.
• Linda Turner, Interim President, who signed Galvin’s termination letter in August 2012.
• Michele Courton Brown, Chair of the Board of Trustees, who received Galvin’s written disclosure in September 2011 and oversaw the subsequent internal investigations.

The applicable regulatory watchlist for this matter includes:

• U.S. Department of Education, Office of Federal Student Aid, Clery Act Compliance Division
• Massachusetts Department of Higher Education
• Massachusetts Attorney General’s Office, Public Protection and Advocacy Bureau
• Massachusetts State Auditor
• New England Commission of Higher Education (NECHE), regional accreditation body

If you are a current or prospective student at Roxbury Community College, you have the right to request the institution’s current Clery Act annual security report. You have the right to compare current reported crime statistics against historical data. You have the right to ask administrators how reporting procedures have changed since 2012. You have the right to demand accountability for the individuals who concealed sexual violence reports for a decade.

If you are a college employee who becomes aware of Clery Act violations or other federal reporting failures, document everything in writing. Send emails that create a paper trail. Request written responses from supervisors. If you are told verbally not to report something that federal law requires you to report, send a follow-up email summarizing the conversation and asking for written confirmation of the directive. If your institution retaliates against you, you will need evidence.

If you are a survivor of campus sexual violence, know that your decision to report or not report is yours alone. The failure of institutions to comply with federal reporting requirements is not your responsibility. The law does not require your consent to include your report in federally mandated crime statistics. The law requires the institution to report what was reported to them.

The most important action you can take is to stop trusting institutional self-regulation. Colleges and universities do not voluntarily disclose their failures. They conceal them until external pressure forces revelation. That external pressure comes from students, employees, journalists, auditors, and attorneys who refuse to accept institutional narratives at face value. Trust documents, not assurances. Trust patterns, not explanations. Trust the people who lost their jobs for telling the truth, not the people who kept their jobs by hiding it.