









































“As non-White people, they are perceived as inherently violent; as nonwealthy youth, they are viewed as in need of 
discipline and control; and as girls of color, they are believed to be lacking morals and values. Thus, the body of a 
Black or Brown girl is seen as simultaneously an inherent threat to school officials and other students as well as a 
threat to her own safety and well-being” (Bae-Dimitriadis & Evans-Winters, 2017, p. 418).

Aisthesis      Volume 9,  20181

Criminalization and Discrimination in Schools: The Effects 
of Zero Tolerance Policies on the School-to-Prison Pipeline 
for Black Girls

by Sarah Aldridge

Criminalization and Discrimination: The School-
to-Prison Pipeline 

On March 28, 2007, two police officers were 
brought to Avon Elementary School in Avon Park, 
Florida, to control a student who was reportedly 
“violently” disrupting class and posing a danger to 
those around her (Herbert, 2007). The student in 
question, a kindergartener named Desre’e Watson, 
was handcuffed, taken into custody, fingerprinted, 
and had her mugshot taken. The six-year-old was 
subsequently charged with a felony, battery on 
a school official, and two misdemeanors for the 
disruption of a school function and resisting a law 
enforcement officer—all the result of a young Black 
girl’s tantrum (Herbert, 2007). 

This story is not unique. As early as preschool 
and kindergarten, students of color and particularly 
Black girls across the United States are subjected to 
disproportionate punishment and discipline for their 
behavior in school settings, leading to their exclusion 
from the classroom and their incorporation into the 
school-to-prison pipeline. The school-to-prison 
pipeline is a phenomenon which criminalizes 
student misbehaviors and increases a student’s 
likelihood of involvement in the criminal justice 
system. In 2015, approximately 48,000 youth were 
confined in residential placement facilities on any 
given day (Office of Juvenile Justice and Delinquency 
Prevention, 2017). Furthermore, African Americans, 
Hispanics, Asian Americans and Pacific Islanders, 
and Native Americans account for over two-thirds 
of the youth in juvenile correctional facilities, despite 
only making up a combined 33% of the nation’s 
youth population (Armour & Hammond, 2009). 
The disproportionate incarceration of youth of color 

has been expanded by the school-to-prison pipeline, 
primarily through the amplification of punitive 
discipline and zero tolerance policies in American 
classrooms and the growing influence of law 
enforcement in public schools. As a result of these 
combined practices, the school-to-prison pipeline 
effectively ushers poor students and students of color 
out of their classrooms and into the criminal justice 
system (Crenshaw, Ocen, & Nanda, 2015; Morris, 
2012; McNeal, 2016; Rodriguez Ruiz, 2017). Social 
justice scholar Monique W. Morris (2012) elaborates 
that while school-related arrests are the most direct 
route into the school-to-prison pipeline, suspensions, 
expulsions, and referrals to alternative schools also 
“push students out of school and closer to a future in 
the juvenile and criminal justice systems” (p. 2). 

Criticism of the school-to-prison pipeline has 
often focused primarily on the disproportionate 
punishment of young men of color. However, this 
paper focuses specifically on Black girls’ experiences 
with criminalization and punitive discipline in 
schools. Nationally, Black girls face increasing levels 
of disciplinary actions at the hands of teachers, school 
administrators, and school-based law enforcement. 
While Black girls make up only 16% of the female 
population nation-wide, Black girls without a 
disability constitute over half of all girls in schools 
with more than one out-of-school suspension, and 
over 33% of all school-related arrests of girls across 
the nation. Lastly, Black girls have been shown to 
receive harsher sentences than girls of any other 
racial or ethnic group once they have entered the 
juvenile justice system and are the fastest growing 
demographic group in the juvenile justice system 
(Bae-Dimitriadis & Evans-Winters, 2017; Sherman, 
2012). 



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Aisthesis      Volume 9,  20182

Recent studies have shown that “while Black 
girls and boys share a common racialized risk of 
punishment in school, Black girls face a statistically 
greater chance of suspension and expulsion compared 
to other students of the same gender” (Crenshaw et 
al., 2015, p. 23). For example, during the 2011-2012 
school year, Black males were suspended three times 
as often as their White classmates, while Black girls 
were suspended six times as frequently as White girls 
(Bae-Dimitriadis & Evans-Winters, 2017; Crenshaw 
et al., 2015). Furthermore, a case study of public 
schools in New York City during 2011-2012 found 
that Black girls made up 90% of the female student 
population that faced expulsion, while zero White 
girls were expelled from schools (Bae-Dimitriadis 
& Evans-Winters, 2017; Crenshaw et al., 2015). In 
order to further understand the magnitude of this 
disparity, Crenshaw et al. imagined that one White 
girl was expelled from school in NYC during the 
2011-2012 school year and calculated that Black 
girls were expelled at a rate 53 times higher than 
their White female classmates. Meanwhile, Black 
male students were expelled at a rate ten times 
higher than White male classmates in New York City 
(Crenshaw et al., 2015). Therefore, it is probable that 
the intersecting gendered and racialized identities 
of Black girls place them at a higher risk of pushout 
and punitive discipline than young men of color, and 
certainly at a higher risk than White girls. For this 
reason, this paper analyzes the experiences of female 
students of color to center their experiences in the 
discussion regarding the school-to-prison pipeline 
and zero tolerance policies. 
      
Causes of the School-to-Prison Pipeline: The Gun 
Free Schools Act of 1994, Zero Tolerance Policies, 
and the Influence of Law Enforcement in Public 
Schools

One of the primary causes of the school-to-
prison pipeline is the expansion of zero tolerance 
policies in K-12 public schools across the nation. 
Howard (2016) argues that “zero-tolerance criminal 
policies have increasingly ensnared young people as 
the ‘lock ‘em up’ mentality…of the adult criminal 
justice system has also been applied to the juvenile 
justice system” (p. 104). Zero tolerance policies 
in schools have created minimum requirements 
for disciplinary actions to student misbehaviors, 

often without any consideration of the unique 
circumstances of the incident or whether the 
punishment matches the behavior (Rodriguez Ruiz, 
2017). The first comprehensive zero tolerance policy 
implemented in public schools across the United 
States was the Gun Free Schools Act of 1994, which 
required that K-12 schools funded under Title I of 
the Elementary and Secondary Education Act must 
immediately expel any students found in possession 
of a gun within 1,000 feet of the school campus 
(McNeal, 2016; Rodriguez Ruiz, 2017; Wun, 2016). 
The Gun Free Schools Act was introduced as a part 
of the Improving America’s Schools Act in 1994 and 
was signed into law by former President Bill Clinton 
on March 31, 1994. Soon after passage, states and 
local districts expanded the zero tolerance ideology 
of the Gun Free Schools Act to further enhance 
the goal of deterring school crime and creating a 
more efficient disciplinary process. By 1998, 90% of 
schools used zero tolerance policies for possession 
of firearms and weapons, 87% for possession of 
drugs or alcohol, and 79% for violence on school 
campuses (Rodriguez Ruiz, 2017, p. 809). While 
there is a significant dearth of research documenting 
suspension and expulsion rates of African American 
girls over time, numerous studies have demonstrated 
the effect of zero tolerance policies on increasing the 
suspension and expulsion rates of Black students and 
further widening the discipline gap between Black 
and White students (Curran, 2016; González, 2012; 
Hoffman, 2014; Howard, 2016; Losen & Skiba, 2010; 
Raffaele Mendez & Knoff, 2003; U.S. Department 
of Education Office for Civil Rights, 2014; Wallace, 
Goodkind, Wallace, & Bachman, 2008). 

At the same time, zero tolerance policies have 
expanded to include punishment for more non-
violent and subjective transgressions, particularly for 
students of color (Rodriguez Ruiz, 2017). In 2013, 
the Children’s Defense Fund reported that a public 
school student is suspended every second and a 
half; furthermore, Rodriguez Ruiz (2017) found that 
95% of these suspensions are punishment for minor, 
non-violent behaviors, such as violating dress codes, 
tardiness, yelling at teachers, or leaving class without 
permission. Over 48% of all suspensions during the 
2011-2012 school year were for “willful defiance,” 
frequently referring to disobeying a school authority 
figure (McNeal, 2016, p. 293). Hoffman (2014) 



Criminalization and Discrimination in Schools

Aisthesis      Volume 9,  20183

found that the discipline gap widened significantly 
as various states and districts expanded their zero 
tolerance policies.

Expanding the punitive effects of zero 
tolerance policies to include subjective, non-violent 
transgressions has been particularly significant for 
young African American women when considered 
in conjunction with the racialized and gendered 
stereotypes of Black girls that teachers and school 
administrators bring to their jobs. White, middle-
class conceptions of femininity have aimed to 
create a gender of “good girls” who are socialized 
to be easily controlled, deferential, and “presenting 
an appearance that does not significantly deviate 
from the standards of [White] mainstream culture” 
(George, 2015, p. 108). However, historic stereotypes 
of Black women have worked to contrast Black 
femininity with White middle-class femininity 
and have resulted in the increased criminalization 
of African American girls. These stereotypes and 
assumptions of Black girls’ “attitude,” anger, sexuality, 
or aggressive nature are used to criminalize Black girls 
for not conforming to the ideals of White middle-
class femininity (George, 2015; Haight, Kayama, 
& Gibson, 2016; Morris, 2012; Morris, 2016). As a 
result of these stereotypes and harmful narratives, 
teachers and school administrators are more likely to 
identify their Black female students as “loud, defiant, 
and precocious,” frequently leading to harsher 
punishments including suspension, expulsion, and 
school-based arrests (George, 2015; Morris, 2016, 
p. 11; Wun, 2016). Haight et al. (2016) explain the 
ways that biases and racialized stereotypes of Black 
girls’ behavior lead to harsher punishments and 
criminalization, stating:

 
The most common behaviors Black girls 
are disciplined for, for example, defiance, 
inappropriate dress, using profane language, 
and physical aggression, not only vary from 
behaviors white girls tend to be disciplined for, 
they parallel stereotypic images of Black women 
as hypersexual, angry, and hostile. (p. 236)

In this way, the use of zero tolerance policies has 
strayed far from the original intention of decreasing 
gun violence on school campuses and has instead 
exacerbated institutional discrimination towards 

African American girls by allowing for harsh, 
subjective punishments based on biases and 
stereotypes. 

The school-to-prison pipeline was similarly 
expanded as a result of the increased influence of 
law enforcement and School Resource Officers 
(SROs) in public schools across the nation, 
particularly in low-income schools with significant 
populations of students of color (Howard, 2016). 
After the Columbine shooting in 1999, the federal 
government provided additional resources for 
schools to strengthen security measures, such 
as metal detectors at school entrances, random 
searches of students’ belongings, and the placement 
of armed police offers on school property. Nearly 
43% of U.S. public schools had police officers on 
their grounds in 2013, resulting in over 40,000 police 
officers spending all or some of their time stationed 
at schools (Howard, 2016). Furthermore, Nance 
(2017) found that the use of school surveillance 
measures, including the placement of School 
Resource Officers and law enforcement personnel 
on school campuses, is significantly higher at schools 
with high concentrations of students of color. Morris 
(2016) argues that the “presence of law enforcement 
in schools has… blurred the lines between education 
and criminal justice” through the increase of 
violent policing and higher arrest rates in schools, 
particularly for African American girls (p. 77). 
SROs are assigned to schools despite a severe lack 
of training in working with children, which leads 
SROs to employ adult policing practices on youth, 
including the excessive use of physical force (McNeal, 
2016; Nance, 2016). Nance (2016) also found that 
schools which have regular contact with School 
Resource Officers are more likely to refer students 
to law enforcement for non-violent offenses, as the 
presence of SROs appears to “facilitate a criminal 
justice orientation to how school officials respond to 
offenses that they once handled internally” (p. 979). 

Academic and Social Consequences of Zero 
Tolerance Policies and the School-to-Prison 
Pipeline

As a result of the recent transformations and 
expansions of zero tolerance policies in U.S. schools, 
students of color, particularly African American girls, 
have suffered from disproportionate punishment 



Criminalization and Discrimination in Schools

Aisthesis      Volume 9,  20184

and school pushout. Howard (2016) argues that 
these policies have led to the criminalization of Black 
students in educational settings, and “Black children 
became ‘public enemy number one’ in many schools 
across the nation” (p. 103). Moreover, Black girls 
have experienced disproportionate surveillance, 
punishment, and criminalization in schools, and 
have largely been excluded from their educational 
experiences, in addition to being ushered towards 
the school-to-prison pipeline (Morris, 2016). 12% of 
school-aged Black girls across the United States have 
experienced out-of-school suspensions, 31% of Black 
girls have been referred to law enforcement, and 43% 
have had experience with school-related arrests (Wun, 
2016). In 2006, 18% of African American middle 
school girls faced out-of-school suspension, higher 
than the out-of-school suspension rates of Hispanic, 
Native American, and White male students, and 
female students of all other racial groupings (Losen 
& Skiba, 2014).  Furthermore, experiencing school 
discipline (suspension or expulsion) in middle school 
is the strongest predictor of being arrested later in 
adolescence for young women (Wallace, Goodkind, 
Wallace, & Bachman, 2008). While disproportionate 
disciplining of African American girls has expanded 
through zero tolerance policies and the use of law 
enforcement personnel on school campuses, African 
American girls have become the fastest growing 
demographic in the juvenile justice system (George, 
2015; Sherman, 2012). In 1992, Black girls made 
up 35% of girls detained in juvenile facilities, with 
15,237 Black girls detained. By 2002, that number 
had nearly doubled to 30,009, and despite a decline 
in the rates of girls detained, the proportion of Black 
girls in juvenile detention in 2008 was still 75% 
higher than the 1992 level (Sherman, 2012).

In addition to increasing students’ likelihood 
of participation in the criminal justice system, zero 
tolerance policies significantly harm the educational 
opportunities of the students who are being 
inequitably targeted and punished, particularly 
Black girls. Throughout American history, Black 
women and girls have been denied equal access 
to educational opportunities, yet Black women 
have never lost sight of the “liberative power of 
education” (Morris, 2016, p. 5). Education is viewed 
as an equalizing force within American society and 
a tool for social mobility, yet the school-to-prison 

pipeline disrupts the equal access to these benefits. 
The primary disciplinary technique of zero tolerance 
policies is to remove the child at question from their 
classroom, whether through in-school suspension, 
out-of-school suspension, expulsion, or arrest. By 
excluding students from the classroom, students 
miss necessary material and feel disconnected 
from the social networks in their classes, and 
face exacerbated academic underperformance 
(George, 2015; Morris, 2016; Rodriguez Ruiz, 
2017).  Furthermore, the constant surveillance and 
criminalization of the behaviors, dress, manners 
of walking and talking, and every action of Black 
girls in schools has led to strained student-teacher 
relationships and detachment from the classroom 
(Crenshaw et al., 2015; Morris, 2016). Morris argues 
that Black students’ performance and motivation 
to attend school is particularly influenced by their 
social relationships with their teachers, and that 
when teachers harbor biases and prejudices that lead 
to differential treatment and punitive discipline, it 
decreases the motivation of girls to attend school. 

Students who are subjected to zero tolerance 
policies, excessive discipline, and discriminatory 
treatment in their school are not only more likely 
to be excluded from the classroom, but are also 
more likely to drop out of school as a result of their 
disconnect with their teachers, the material, and 
the idea of education overall (Christle, Jolivette, 
& Nelson, 2005; Curran, 2016; González, 2012; 
Haight et al., 2016; Morris, 2016; Rodriguez Ruiz, 
2017). There are several societal difficulties that 
face individuals who have dropped out of school, 
including difficulty in finding employment, reduced 
political participation, poorer levels of health, 
increased reliance on social services, and the 
reduced ability for intergenerational social mobility 
(Rodriguez Ruiz, 2017). Furthermore, dropouts often 
display increased criminal activity and increased 
participation in the criminal justice system, serving 
as another long arm of the school-to-prison pipeline 
(Curran, 2016). After being excluded and pushed 
out from their classrooms, dropouts are 3.5 times 
more likely to be arrested, and approximately 82% of 
prison inmates are high school dropouts (Rodriguez 
Ruiz, 2017). In this way, the school-to-prison pipeline 
and zero tolerance policies reach beyond the scope 
of a girls’ K-12 education and uphold systems of 



Criminalization and Discrimination in Schools

Aisthesis      Volume 9,  20185

discrimination and criminalization that impact the 
communities surrounding Black girls. 
      
Recommendations and Conclusion 

In order to end the disproportionate 
criminalization, punishment, and pushout of 
African American girls in K-12 school settings, 
Morris (2016) argues that future reforms must 
“revisit ‘education as usual’ and the relationships 
that are facilitated, nurtured, and/or damaged in 
educational institutions” (p. 176). This includes four 
main reforms that must be implemented to create an 
educational institution which not only counters the 
incessant criminalization of Black girls in society, but 
creates an environment which allows Black girls to 
learn, grow and thrive: (1) responsive and de-biased 
learning in the classroom, (2) healing-informed 
responses to “problematic” student behavior, (3) 
healing-informed classrooms and schools, and 
(4) college and career pathways (Morris, 2016, p. 
193). These broad categories include smaller, easily 
implementable school reforms, such as providing 
emotional counseling and mental health services 
for students, recess and breaks from the classroom, 
school-wide trainings on reducing implicit bias, and 
allowing students to participate in the administration 
of the school, such as the construction of disciplinary 
and dress code policies (George, 2015; Morris, 
2016). Simply expanding opportunities for the 
inclusion of Black girls in policymaking decisions 
and advocacy not only increases their own agency 
in their education, but helps to build a system that 
doesn’t inherently discriminate against Black girls on 
the basis of stereotypes and internalized prejudices 
(Crenshaw et al., 2015; Morris, 2016). 

Lastly, schools must work to abolish the 
disciplinary policies which allow for discrimination 
towards students of color, particularly African 
American girls, and those which funnel students into 
the criminal justice system (Crenshaw et al., 2015; 
George, 2015; Morris, 2016, Rodriguez Ruiz, 2017). In 
order to end racialized and gendered discrimination 
against Black girls, schools and disciplinary policies 
must undergo an extensive reorganization to ensure 
that students are still protected from violence, and 
truly have a safe, caring, and loving educational 
setting to learn in. One method which has gained 
significant traction over the past decade in the U.S. is 

the implementation of restorative justice programs. 
Simson (2014) notes that such programs focus on 
“accountability, reintegration and inclusion (instead 
of exclusion and exiling), community building, and…
the development of a safe, collaborative, and positive 
environment in which students are more likely to 
succeed” (p. 554). Furthermore, restorative justice 
policies seek to create a safe school environment by 
building a school community, as opposed to the use 
of punitive responses.  Restorative justice programs 
can look different depending on the school context 
and policies, but can include practices such as 
peer meditation, discussion circles, whole-school 
involvement, or conferences between victims and 
offenders (George, 2015; González, 2012; Simson, 
2014). Simson emphasizes the use of restorative 
justice policies to reduce racial disproportionality 
in school punishment, as a focus on dialogue and 
building community works to counter implicit bias, 
provides students of color with the opportunity to 
share their experiences, and negates the stigmas 
and long-lasting effects of disproportionate 
criminalization and school punishment. This is 
particularly meaningful in aiding African American 
girls to voice their viewpoints and address the 
stereotypes and narratives that have been assigned to 
their actions and behaviors (George, 2015). Through 
the reformation of school discipline policies, such as 
the implementation of Restorative Justice practices 
in the classroom, Morris (2016) argues that

As a locus of learning, our schools can serve a 
greater purpose than just indoctrinating our 
girls with the politics of surviving racial, class, 
and gender bias. These institutions can be 
bastions of community building, where healing 
is at the center of their pedagogy and where our 
girls learn more than just how to behave in the 
presence of adults to be considered ‘acceptable’ 
in the school environment. (p. 194)

All students deserve the opportunity to 
learn and grow in a safe, nurturing, and loving 
educational environment. However, many of the 
policies that have sought to increase the safety of 
schools, particularly zero tolerance policies and the 
placement of law enforcement personnel on school 
campuses, have instead contributed to the pushout 



Criminalization and Discrimination in Schools

Aisthesis      Volume 9,  20186

and criminalization of students of color. African 
American girls have been particularly impacted by the 
expansion of zero tolerance policies and the school-
to-prison pipeline, and in recent years have become 
the fastest growing demographic in the juvenile 
justice system (Sherman, 2012). Furthermore, by 
disrupting Black girls’ access to education and 
instead pushing them towards the school-to-prison 
pipeline, zero tolerance policies work to further 
exclude African American girls from schools and to 
increase social inequality and discrimination facing 
Black girls. In order to create a school environment 
where all students have equitable opportunities to 
learn in a safe and nurturing community, school 
districts and states across the nation need to take 
tangible action to move away from discriminatory, 
punitive disciplinary practices and to embrace the 
experiences and needs of marginalized students, 
including African American girls. 

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