Crisp wrote in an email that he could not respond to the complaint’s allegations until the complaint has been provided to the University by the U.S. Department of Education’s Office for Civil Rights. He said his email response was sent on behalf of Sauls, Leslie Strohm, the University’s general counsel, and Kara Simmons, associate University counsel.

Sauls, Strohm and Simmons did not respond to calls and emails requesting comment.

“I want to assure you that the University takes the issue of sexual assault very seriously, and we are all working together to make sure that our process for handling these cases is fair, effective and supportive,” Crisp wrote.

Threats and retaliation

Manning joined the University, which she attended as an undergraduate and law student, in 2001 as assistant dean of students. Much of her work focused on training programs for those involved with the system used for reporting sexual assault.

Manning declined to comment Thursday on the complaint’s allegations.

According to the complaint, in 2006, the year Sauls was hired as judicial programs officer, all language requiring sexual assault training for judicial boards disappeared.

The complaint states that in 2010, Manning began to encounter a hostile environment within her own office and the University’s upper administration — an environment that only grew increasingly aggressive during the remainder of her time at UNC.

According to the complaint, in 2010, when Crisp was promoted from dean of students to vice chancellor for student affairs, Manning met with Crisp to ask him about applying for the vacant dean of students position.

“Vice Chancellor Crisp told her that he would ‘never hire her because she had a young child at home’ and what that could mean,” according to the complaint, which cites the action as a violation of Title VII of the Civil Rights Act of 1964, which prohibits discrimination on the basis of gender.

Sauls was hired for the position.

For the next two years, the complaint states, Manning endured persistent hostility from Sauls, her direct superior, who lashed out at her with threats, retaliation and silence — a stressful combination that eventually affected her health, according to the complaint. The document claims this hostility violated Title IX’s guarantee to an equal opportunity work environment.

On separate occasions, Sauls reprimanded Manning for reaching out to Chancellor Holden Thorp and the Office for Civil Rights regarding UNC’s handling of sexual assault, the complaint states.

“She was told by Dean Sauls that she should ‘never contact the Office for Civil Rights again,’” the complaint says.

The complaint also states Sauls told Manning she would suffer consequences for writing to Thorp. Though at the time Sauls did not specify what the consequences would be, the complaint says he later rated her as “needs improvement” in her annual review and told her that others had suggested he fire her.

The complaint then details how Manning felt isolated by Sauls. He initiated and then canceled eight separate meetings with Manning and often failed to respond to her emails, according to the complaint.

The document also states that at points, Sauls made Manning uncomfortable and scared.

“Sauls balled one of his hands into a tight fist on the small table that he and Manning were sharing,” according to the document. “This action made Manning feel fearful for her safety, and she therefore decided to end the meeting.”

But Manning’s mistreatment extended beyond Sauls, according to the complaint.

Manning eventually reached out to Crisp to express her concern that she was being retaliated against by Sauls. Crisp told Manning that filing a grievance against him would only “go badly” for her, according to the complaint.

When the retaliation was eventually investigated, Manning was told that the University found no evidence of retaliation or bullying behavior from Sauls, according to the complaint.

After Manning resigned at the end of the fall semester, she learned that Sauls had tried to persuade one person who was interviewed to change her testimony for the investigation, the document states.

‘Too high’

According to the complaint, in 2011, the University Counsel’s office pressured Manning to underreport cases of sexual assault for 2010 to the federal government.

The Clery Act requires campuses to disclose crime statistics to the federal government each year.

“(Manning) was told by a member of University Counsel staff that the ‘number of reports was too high’ and she was asked to ‘look over the numbers again,’” the complaint states. “For two weeks, she received multiple phone calls from various members of University Counsel staff asking her to ‘make sure that her numbers were correct.’”

The number of sexual assaults that appeared in that year’s Clery report was three lower than the number Manning submitted to the Office of University Counsel, the document states.

The University reported six incidents of forcible sex offenses on campus for 2009, 19 for 2010, the year for which Manning was asked to compile statistics, and 12 for 2011.

The maximum fine for violating the act is $35,000 per incident.

Frank LoMonte, executive director of the Student Press Law Center, said the accuracy of numbers reported through the Clery Act is a national issue.

“Nationally, there’s no question that Clery Act crime statistics all across the board look suspiciously low,” he said. “I would say it’s rare that you see direct evidence that people intentionally manipulate the numbers. And these are just accusations, obviously.”

“The fact is there’s enough confusion and misunderstanding about how Clery works that you’re never certain whether the understatement is intentional or accidental,” he added.

“I tend to suspect it’s intentional because it’s not all that confusing.”

LoMonte said one can only remove a case from Clery Act statistics if it is found to be completely unfounded.

“If it’s not entirely unfounded, then you have to count it, even if it doesn’t result in any punishment,” he said.

Jim Bradshaw, spokesman for the Office for Civil Rights, wrote in an email Thursday that the office had received the complaint and was working to determine whether it warranted an investigation.

There’s no established timeline set out for complaint investigations, LoMonte said.

“It’s conceivable that it could hang out there for even a matter of a couple of years.”

Contact the desk editor at university@dailytarheel.com.