PLS NOTESFebruary 2011Published by Prisoners’ Legal Services, Eight Phone: (617) 482-2773 |
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News About Parole
In the wake of the killing of a Woburn police officer by a parolee in December 2010, on January 13, 2011, Governor Patrick announced the “resignations” of five of the seven members of the Parole Board and that of DOC Deputy Commissioner Don Giocioppo, who had been the Executive Director of the Parole Board in 2008 when the parolee was released. Three other Parole Board employees were suspended. The governor also named Suffolk homicide ADA Josh Wall as the new acting Executive Director of the Board and nominated Mr. Wall to the Board stating that if confirmed, Mr. Wall would become the Board’s new chair. The governor announced that the moratorium on lifer hearings would remain in place until the new “management team” completes its review of ‘the process.” He also said that while parole hearings will continue, the Board will not “release any prisoner on parole for a violent crime involving firearms or other dangerous weapons until the management team is confident that Field Services is capable of properly supervising these parolees”. Six lifers, some with days left until their release were pulled from pre-releases and returned to medium security prisons “administratively”. PLS is advocating for their return to pre-release.
On February 16, 2011, Mr. Wall was confirmed by the Governor’s Council by a vote of 5-3.
In the past two months, hearings in the houses of correction which only require one Board member have continued but at a very slow pace. The two remaining parole Board members have been conducting upwards of 60 hearings per day but for over two weeks, no one was paroled from the houses of correction. The remaining two members have conducted some of the non-lifer felony hearings in the state prisons. There have not been any lifer hearings since December 2010 and the Parole Board website reports that they are “postponed” and will be rescheduled “at a later date.” Since lifer hearings require five Board members and it took one month for the governor’s first nominee to be confirmed, it is difficult to imagine how the Board would have the requisite number for lifer hearings anytime before April or May 2011. PLS is drafting litigation on behalf of those who are being deprived of their hearings. Potential plaintiffs should contact PLS expressing their interest in joining this litigation. While freedom of information requests regarding the parole voting rates for January and February have been requested, no information has been produced as of this writing. Prisoners report, however, that the parole rate is very low, even at the pre-releases.
PLS has been working with attorney Patty Garin, who co-directs the parole project at Northeastern Law School, and with Lyn Levy at Span, Inc., the Boston based re-entry program. A large group of stakeholders including the Criminal Justice Policy Coalition, the ACLU of MA, Partakers Inc., City of Boston employees and several other interested citizens including some people on, or who have successfully completed, parole have met bi-weekly to discuss strategies to insure, among other matters, the confirmation of Parole Board nominees with a wide variety of backgrounds. The Parole Board’s governing statute states that nominees must have a college degree and 5 years of experience in the following areas: parole, probation, corrections, law, law enforcement, psychology, psychiatry, sociology and social work. On Friday, February 18, 2011, the stakeholders dubbed our organization the Coalition for Effective Public Safety (CEPS). Next steps include enlisting other entities and individuals across the state that care about parole as a key aspect to public safety. The Coalition is committed to meeting with and educating legislators about the positive aspects of parole and urging them to vote against the unnecessary and (to date) two ill-advised “three – strikes” bills that have been filed in the wake of the officer’s death (one bill was filed by the governor and a second by a small group of legislators). Coalition members will also be organizing a speakers’ bureau which will be charged with asking church and other groups for time to educate their membership about parole and the necessity of a fair Board. Coalition members will also be lobbying the governor requesting that he nominate fair- minded Board members from the disciplines described in the statute and will be lobbying the Governor’s Councilors asking that they vote in favor of qualified candidates and against nominees who appear to be limited in their qualifications, including other nominees from law enforcement (In addition to Mr. Wall, one of the two current Board members, Cesar Achilla is a former district attorney).
PLS and Patty Garin distributed a call to action to defense attorneys asking them to lobby the governor’s office regarding nominees. Well over 200 people have already called the governor and/or his chief of staff. PLS urges Notes readers to do the same. Please ask family members to call the governor at 617-725-4005 and ask that he nominate a wide variety of potential Board members, especially those in the fields of psychology, psychiatry and social work. You can also write the governor: Deval Patrick, Governor, State House, Boston, MA 02133. We will be keeping you up to date about other parole developments. Thanks for your help!
BRISTOL SHERIFF TO REFUND OVER $800,000 IN UNLAWFUL “PAY FOR STAY” FEES
The Bristol Superior Court has approved a settlement agreement in Souza, et al. v. Hodgson, BRCV 2002-00870, obligating Sheriff Hodgson to pay $827,500 to compensate approximately 4,500 people who were held at the Ash Street Jail and the North Dartmouth House of Correction, between July 1, 2002 and July 28, 2004 who were charged $5.00 per day under the sheriff’s unauthorized “cost of care” program. Other unauthorized charges, such as fees for medical co-payments and for GED examinations, are also included in the settlement amount. The settlement includes ten percent interest from July 28, 2004.
PLS filed the Souza case on July 18, 2002. Sheriff Hodgson argued that he had inherent authority to impose the fees as part of his general authority to operate the jail and the house of correction. The plaintiffs’ position was that Massachusetts sheriffs are authorized to charge specific fees by statute, and that because each such fee is explicitly authorized by law, they cannot charge fees that have not been authorized in that way. On July 28, 2004, the superior court granted plaintiffs’ motion for summary judgment, ruling that the fees were unlawful, and directed the sheriff to stop collecting them. The Appeals Court denied the sheriff’s application for relief pending appeal the following month. The plaintiff class was certified at the end of March, 2005. In June of 2008, the court entered partial judgment for plaintiffs, declaring that the fees were unlawful and directing the sheriff to repay them with interest. The sheriff appealed, and on January 6, 2010, the Supreme Judicial Court affirmed the judgment. The settlement resolves issues of the interest rate to be paid on the returned funds, plaintiffs’ attorneys’ fees, and the mechanics of determining the amounts due to plaintiff class members.
The settlement agreement provides that the costs of administration of the settlement and the fees of the plaintiffs’ lawyers will be deducted from the total settlement amount, and that the remaining funds will be divided among those members of the plaintiff class who submit claims that can be verified by reference to the sheriff’s computer records of monies collected.
Notice of their right to make a claim will be mailed to those class members who appear from records to be owed more than $20, as well as to those owed less than $20 who have provided addresses to PLS. (Claims for less than $20 will also be processed if the proper forms are submitted.) Notice of the settlement and the right to make claims will also be published in the New Bedford Standard Times, the Fall River Herald News, and the Taunton Gasette. Notice will also be posted on the PLS web site at www.plsma.org, as well as at community centers, churches, shelters and treatment programs around Bristol County.
Administration of individual claims, including determination of the amount and whether a particularly claim is timely and otherwise supported by records, will be handled by a claims administrator, Analytics, Inc. Claims for settlement funds must be in writing and must be mailed to: Bristol County Jail Class Action, P.O. Box 2007, Chanhassen, MN 55317-2007, by April 7, 2011. Claim forms are available either from that address or from Prisoners’ Legal Services, 8 Winter St., Boston, MA 02108.
The settlement agreement also provides that in the event that the claims paid out do not use up the settlement fund, the balance will be donated to Bristol County charities.
PLS FIGHTS TERMINATION OF KOP POLICY FOR HIV MEDICATIONS
Nunes v. UMass Correctional Health, et al.
This federal court action, filed in November 2010, challenges the decision of the DOC and UMass Medical to require that all antiretroviral medications prescribed to treat HIV be dispensed only at medication lines. Prior to February of 2009, these medications were given to HIV patients as “keep-on-person” (“KOP”) medications, like the majority of medications dispensed within Department of Correction facilities. This lawsuit alleges that UMass and DOC implemented the new policy to cut costs by discouraging prisoners from taking expensive HIV medication.
The complaint seeks class action certification for all DOC prisoners who are HIV positive. There are five individual plaintiffs, four of whom are anonymous. The complaint details the loss of privacy, increased frequency of side effects, and deterioration in medical condition of the five plaintiffs since they began to be forced to get all HIV meds at the med line twice each day. All of the problems of med lines are made worse for HIV positive prisoners. Their status is broadcast to staff and other prisoners by their constant presence at med line, by medical staff who make comments that are heard by correctional staff and other prisoners. Their health is compromised because HIV positive prisoners, who are unusually susceptible to getting almost any contagious illness because HIV is a disease of the immune system, must wait in med line with other prisoners who have all kinds of contagious conditions or wait outside in cold and wet weather where med lines extend outside. They risk deterioration of their medical condition because of all the routine disruptions that affect med lines such as lockdowns, medical emergencies, and conflicts with schedules of work, classes, court or outside medical trips. Even short interruptions in HIV medication schedules can cause the virus to develop immunity which makes it even harder to treat.
The Complaint states that the reason the DOC and UMass Medical decided to remove HIV meds from the KOP program is to save money by discouraging HIV positive prisoners from taking HIV meds at all. There are about two to three hundred HIV positive DOC prisoners - about 2 or 3 percent of the state prison population - but those prisoners account for at least twenty percent of DOC medication costs. DOC and UMass Medical have given two unrelated excuses for taking HIV meds off of the KOP policy. When the policy was first changed, DOC issued a memorandum to prisoners claiming that it was being made in order to ensure continuity of medication for HIV prisoners when they are transferred from one prison to another. That memo did not explain how frequent such a problem was, nor did it address the obvious contradiction with the policy that allows KOP medications to go with a prisoner during transfer. Later, after HIV positive prisoners questioned that explanation, DOC changed it. The DOC and UMass now claim that the change was made because some HIV positive prisoners were not adhering to their medication schedules. Again, no estimate of the prevalence of the problem was offered, nor was there any reference to the obvious fact that existing policy provided that individuals on KOP who do not comply with medication requirements already can be terminated from the program, without affecting the great majority on KOP who properly take their meds. These weak and inconsistent rationales fail to mask what amounts to a deliberate decision to sacrifice lives to save money.
The complaint in the Nunes case alleges that the defendants are inflicting cruel and unusual punishment in violation of the 8th and 14th Amendments to the U.S. Constitution, violation of Equal Protection under the 14th Amendment, violation of Section 504 of the Rehabilitation Act of 1973, violation of the Americans With Disabilities Act, and violation of the Right to Privacy under the 14th Amendment.
CPCS IMPLEMENTS A NEW INNOCENCE PROGRAM
If you have been convicted of a crime that you did not commit, the CPCS Innocence Program may be able to help you. The CPCS Innocence Program represents indigent Massachusetts state
defendants who are actually innocent of the crime(s) of which they have been convicted. CPCS has funding to conduct investigations, to hire experts, and to perform forensic testing. This program accepts cases whether or not there is DNA available for testing.
For assistance contact:
Debra S. Krupp, Program Director
CPCS Innocence Program
44 Bromfield Street
Boston, MA 02108
PRISONERS’ RIGHT TO EXAMINE AND COPY MEDICAL RECORDS UNDER STATE AND FEDERAL LAW
By Joel Thompson
In the last issue of PLS Notes, we noted that UMass Correctional Health recently argued in litigation that the federal Health Insurance Portability and Accountability Act, or HIPAA, applied to it. HIPAA’s privacy provisions set rules for when, how, and to whom a patient’s health information may be disclosed, and also control how a patient may access his or her own health information. This article expands on the latter point and also identifies state regulations and policies that govern access to health information independent of HIPAA.
All prisoners: By statute, the Department of Public Health must set standards for keeping prisoners’ medical records. M.G.L. c. 127, § 17. These DPH standards (both for medical records and the conduct of physical exams) are found at 105 CMR 205.000 et seq. Sections 205.500 to 205.701 relate to medical records.
The DPH standards primarily discuss the contents of the records, but Section 205.505, entitled “Inspection of Records,” discusses access. Under this section, a prisoner (or representative) may inspect his or her medical records with a signed release. The prisoner’s signature on the release must be witnessed by “a correctional facility’s staff person,” though see below regarding DOC procedures for witnessing releases.
This regulation does not set specific fees, but it states that fees for copies shall not be larger than those for copying other public documents. (NOTE: this regulation specifically refers to fees for copies; it does not say that fees can or should be charged for inspection of the records.)
Finally, 105 CMR 205.505 also requires that copies of medical records “be furnished within 72 hours of request.” This is an ambitious requirement, and often a prison or jail will not meet it. However, this rule is useful to point out when a prisoner is experiencing a long delay, or has not received any response to his or her request for records.
County prisoners: Each county facility must provide a way for prisoners (or their representatives) to inspect their medical records upon submitting a written release. 103 CMR 932.18. The details are otherwise left to each county, so individual sheriffs will have different policies or practice concerning access to health information in the jails and houses of correction under their jurisdiction.
State prisoners (DOC): For state prisoners, 103 DOC 607 controls access to health information. A prisoner in DOC custody may obtain access to his or her health information with a signed release. 103 DOC 607.05(7). Under the policy, the prisoner’s signature must be witnessed by a medical staff person. 103 DOC 607.05(7)(b). This requirement is narrower than the DPH standard, but it should have little practical effect on access, because the health services contractors for DOC are aware of their obligation to witness releases. (If you have difficulty obtaining a signature from a medical staff person, try to bring the release form to the health services representative at staff access period. If that fails, contact PLS for assistance.)
For prisoners requesting inspection or copies of medical records, the provider should produce both paper records and any IMS screens that are applicable to the request. § 607.05(9). The production will not include records of outside hospitals or providers, unless the consent procedures for those hospitals or providers have been followed. 103 DOC 607.05(10). That is, if a prisoner is referred to an outside hospital for treatment, he or she will have to get the records from the outside hospital with a release in the form required by that outside hospital.
Certain types of health information are defined as “sensitive,” and a prisoner will need to submit an additional release to have access to that information. 103 DOC sections 607.05(7)(c) and 607.05(12)(a). Sensitive information includes records concerning sexually transmitted diseases, HIV, substance abuse, and mental health. 103 DOC 607.05(7)(c). Even with a release, a prisoner may not be able to inspect all of his or her mental health records. 103 DOC 607.05(12)(e). The mental health provider may deny access to mental health records if it finds that release would not be in the prisoner’s best interest. If access is denied, the mental health provider must provide a summary of the mental health record instead. 103 DOC 607.05(12)(e).
DOC policy also determines the fees for medical records. 103 DOC 607.05(9). A prisoner seeking a copy of his or her medical records may be charged a search fee of $5.00, and copying charges of $.20 per page. 103 DOC 607.05(9). (This section specifically refers to individuals who “receive a copy of the medical record,” not those who request to inspect the record. This language suggests that prisoners may inspect their records without charge.) The fees may be waived if the prisoner is indigent, which is calculated the same way as it is for other purposes in DOC, under 103 CMR 157.06. A prisoner is declared indigent if at the time of the request, in all accounts “to which he or she has access,” the prisoner has a balance of less than or equal to $10 plus the fee or cost to be waived, and has had that amount or less in the accounts for at least sixty days. 103 CMR 157.06. For example, if a fee for medical records is $20, the prisoner must have $30 or less in all of his or her accounts combined, and must not have had more than $30 in the accounts in the last sixty days.
As discussed in the last issue of PLS Notes, HIPAA may afford broader rights of access to health information for state prisoners than DOC regulations and policies. HIPAA’s standards generally preempt state law. 45 CFR 160.203. For example, HIPAA only allows fees to be charged for providing copies of records, not for inspection. 45 CFR 164.524(c)(4). When a patient requests to inspect records, the provider must arrange for a mutually convenient place and time to allow inspection. 45 CFR 164.524(c)(3). To the extent that these requirements conflict with state law, the HIPAA requirements control.
At the same time, HIPAA’s privacy regulations do not preempt state law if state law requirements afford greater access to medical records than HIPAA. 45 CFR 160.203(b). For instance, HIPAA calls for providers to act on a request for record within thirty days. 45 CFR 164.524(b)(2)(i). The DPH standard of 72 hours, discussed above, should still apply. State prisoners should get the benefit of the regulation or policy that provides greater or faster access to their health information.
SUPERIOR COURT STANDING ORDER 1-96 GOVERNS JUDICIAL REVIEW OF DENIAL OF PRISON GRIEVANCES
By Peter Costanza
The Superior Court has established a procedure specifically for handling applications to review agency adjudicative decisions. This procedure is called Superior Court Standing Order 1-96. It controls the procedural details of bringing lawsuits for review of administrative decisions, and it applies to both Administrative Procedure Act complaints and Certiorari complaints. It is so useful and so important to getting your grievance claim properly before the superior court that PLS reprints it here in full.
Superior Court Order 1-96
Standing Order 1-96. Processing and Hearing of Complaints for Judicial Review of Administrative Agency Proceedings
In order to facilitate and clarify the orderly processing and hearing of Complaints for Judicial Review of Administrative Agency Proceedings, it is hereby ORDERED, effective March 18, 2002, that:
1. Claims filed in the Superior Court seeking judicial review of administrative agency proceedings on the administrative record pursuant to the standards set forth in G.L. c. 30A, § 14, G.L. c. 249, § 4, or similar statutes, whether joined with a claim for declaratory relief under G.L. c. 231A, or any other claim, shall be heard in accordance with the following procedures.
2. The administrative agency whose proceedings are to be judicially reviewed shall, by way of answer, file the original or certified copy of the record of the proceeding under review (the record) within ninety (90) days after service upon it of the Complaint. Such record “shall consist of (a) the entire proceedings, or (b) such portions thereof as the agency and the parties may stipulate, or (c) a statement of the case agreed to by the agency and the parties.” G.L. c. 30A, § 14(4). Upon service of a Complaint, the agency shall notify all parties of procedures for acquiring a transcript of the hearing testimony. The agency shall also inform the parties of their obligation to provide a transcript, or portions thereof, to the court if alleging that an agency's decision is not supported by substantial evidence or is arbitrary or capricious, or is an abuse of discretion. A request for a copy of the transcript must be made by a party within thirty (30) days after service of the Complaint, and such transcript or portion thereof shall be made part of the record. Any party seeking to defend the agency's decision as supported by substantial evidence or as not arbitrary or capricious, or is not an abuse of discretion shall have an affirmative obligation to provide the court with a copy of the transcript or portion thereof in support of its position. The court may assess the expense of preparing the record as part of the costs in the case. G.L. c. 30A, § 14(4). Additionally, “the court may, regardless of the outcome of the case, assess any one unreasonably refusing to stipulate to limit the record, for the additional expenses of preparation caused by such refusal.” G.L. c. 30A, § 14(4). The court may require or permit subsequent corrections or additions to the record when deemed desirable. G.L. c. 30A, § 14(4). The time for filing the record may be enlarged, for good cause shown, upon allowance of an appropriate motion.
3. The following motions raising preliminary matters must be served in accordance with Superior Court Rule 9A not later than twenty (20) days after service of the record by the administrative agency.
(a) Motions authorized by Mass.R.Civ.P. 12(b) or 12(e).
(b) Motion for leave to present testimony of alleged irregularities in procedure before the agency, not shown in the record (G.L. c. 30A, § 14(5)).
(c) Motion for leave to present additional evidence (G.L. c. 30A, § 14(6)).
Any party failing to serve such a motion within the prescribed time limit, or within any court-ordered extension, shall be deemed to have waived any such motion (unless relating to jurisdiction) and the case shall proceed solely on the basis of the record. Any such motion shall be promptly resolved in accordance with Superior Court Rule 9A. If the motion specified in (c) is allowed, all further proceedings shall be stayed until the administrative agency has complied with the provisions of G.L. c. 30A, § 14(6).
4. A claim for judicial review shall be resolved through a motion for judgment on the pleadings, Mass.R.Civ.P. 12(c), in accordance with Superior Court Rule 9A except as otherwise provided by this Standing Order, unless the Court's decision on any motion specified in part 3 above has made such a resolution inappropriate. A plaintiff's Rule 12(c) motion and supporting memorandum shall be served within thirty (30) days of the service of the record or of the Court's decision on any motion specified in part 3 above, whichever is later. A defendant's response shall be served within thirty (30) days after service of the plaintiff's motion and memorandum. The plaintiff shall then promptly file the motion materials in accordance with Superior Court Rule 9A. The Court may grant an extension of time to file for good cause shown. Memoranda shall include specific page citations to matters in the record.
5. The Clerk or her/his designee will schedule a hearing date after receiving the motion materials. No pre-trial conference will be held, and no pre-trial memorandum filed, unless specifically ordered by the Court. No testimony or other evidence shall be presented at the hearing, and the review shall be confined to the record. A party may waive oral argument and submit on the brief by filing a written notice. Such waiver by a party shall not affect the right of any other party to appear and present oral argument.
End of Order
Comment: Paragraph 2 of this standing order contains the heart of the procedure. Note that it provides that the entire administrative record, or those parts of the administrative record that the agency thinks are necessary to decide the case, is supposed to be attached by the agency (in prisoner cases here that will be the DOC or a sheriff) that is the defendant to its answer to the complaint. This requirement can be helpful to a prisoner challenging denial of a grievance if his copies of the paperwork are lost or unavailable to him. However, PLS recommends that if you have the administrative record (grievance, denial of grievance, appeal, denial of appeal, and any associated documents (such as a request to view video or for witnesses) you nevertheless attach a copy of all of that material to your complaint. When you get the answer, review it carefully to be sure that all of the grievance documentation that you think is important is attached either to the complaint or the answer, so that the court will have all the documents necessary to get a fair view of your claim.
A note about transcripts. A transcript is an audio or written record of a hearing. Although disciplinary proceedings often involve hearings, grievances almost always do not. If there was no hearing, there is no transcript. The paperwork associated with a typical claim of lost property is minimal – grievance, receipts to show the value of the property, perhaps a written statement in support of your grievance from a witness or two, or a request to review a tier video, etc.
If you think that important evidence necessary to proper decision of your grievance was not presented during the grievance process, you can move within 20 days of service of the defendants’ Answer and record, for leave to present additional evidence pursuant to G.L. c. 30A, § 14(6), which reads:
If application is made to the court for leave to present additional evidence, and it is shown to the satisfaction of the court that the additional evidence is material to the issues in the case, and that there was good reason for failure to present it in the proceeding before the agency, the court may order that the additional evidence be taken before the agency upon such conditions as the court deems proper. The agency may modify its findings and decision by reason of such additional evidence and shall file with the reviewing court, to become part of the record, the additional evidence, together with any modified or new findings or decision.
The administrative record for grievance proceedings will generally be less than ten pages, and should be very easy for a court to digest and decide. In APA or certiorari cases challenging denial of a lost property grievance, the superior court often can decide the matter “on the papers,” without oral argument (referred to in the Standing Order 1-96 as “judgment on the pleadings”). You can ask the court for oral argument if you wish. Do not ask for oral argument unless you think it is important for the judge to hear from you directly. If you do argue the matter, you cannot introduce any new evidence (information not in the written record attached to the answer and the complaint) at the hearing, and must limit your argument strictly to what is in the grievance and the grievance appeal.
Remedies
There is a real question about what the court can do if it decides that you are right and that your grievance was not handled properly. The most likely outcome in such a case is that the court will simply order the DOC to rehear the grievance. The DOC might in such a situation decide to settle your claim rather than go through the grievance procedure (and probable appeal) twice. Another possibility is that the court will make a declaratory judgment that says that the grievance procedure was not followed properly, or that certain evidence should have been considered that was not considered, etc.
What the court will not do is order the DOC to pay you for your lost property. That is because it has already been decided by the Appeals Court that because the DOC is a state agency, it is immune from paying for prisoner property that is lost or damaged by guard negligence. To put it another way, you cannot get an order for damages against the DOC by using the APA or certiorari that you cannot get through the Tort Claims Act. This may lead to some very frustrating situations. For example, you could “win” the APA review case and get an order for the DOC to rehear the grievance. The DOC might rehear the grievance and deny it again. Even if you win the grievance on rehearing the DOC does not have to pay you the value of the property lost or destroyed . In such a situation the remedy is unclear, and you should consult with PLS or another attorney before proceeding further.
INVESTOR GROUPS SUPPORT CORI REFORM IN BUSINESS HIRING BY MAJOR EMPLOYERS
In mid-December, 23 institutional investors jointly sent a letter to more than 100 publicly-traded companies with operations in Massachusetts asking them to stop denying employment to qualified job-seekers based on the presence of criminal record in background checks.
The CORI reform legislation passed at the end of 2010 prohibits employers generally from asking about CORI on initial employment application forms. Employers are still allowed to ask for CORI information, but only after they have decided to offer the individual a job. That is, the CORI check gets moved to the end of the process. This is designed to discourage unthinking automatic rejection of job seekers at the start of the application process. Unfortunately there are still many unemployed individuals who will likely get rejected – sometimes even after they have started work – when routine background checks disclose even old and minor CORI. In addition, the new legislation does not apply to state or federal jobs where there is a mandatory or presumptive disqualification for a conviction, or where state or federal law prohibits hiring a person with a conviction.
The investors signing the letter are concerned that employers with zero-tolerance policies regarding CORI will deprive themselves in many cases of qualified employees, and that such policies will cause the recent CORI reform to have no meaningful effect on the present CORI-based exclusion of hundreds of thousands of Massachusetts citizens from the workforce.
The investors signing the letter include Zevin Asset Management, Friends Fiduciary Corporation, Catholic Coalition for Responsible Investing, Haymarket People’s Fund, Fresh Pond Capital, Trillium Asset Management Corporation, and over a dozen other funds and organizations with a commitment to socially-responsible investing.