Keywords: Bullying, Consequences, Responsibilities, State intervention, Indifference

This memoire raises the issue of bullying behaviors in American schools. It highlights the typical profiles, the types of bullying and the consequences of this social phenomenon. The indifference faced by all victims increase the risk that bullying might continue. Adults and school's intervention are central in the fight against bullying.

I would like to thank Professor Pascale SMORAG for her constructive guidance, advice and ideas that helped me carry out this project and whose knowledge was generously shared. Her kindness and implication over the last two years were really essential. I learned a lot. I want to thank her for believing in my work, for her patience and for believing in me.

I would also like to thank Mrs AMBANI Claire for her help, kindness and guidance that have been highly appreciated on this pedagogical project in this research paper. Her devotion and passion for teaching are truly inspiring.

I would also like to thank my teachers who help me to grow, personally and intellectually.

I want to thank my mom. Her dedication for children has highly inspired me. She is the one who taught me to never stay indifferent to someone's pain.

And I want to thank the 2018-2020 English Master class promotion, some of whom have become true friends. I am very grateful for their empowering friendships, presence and support during good and bad times over the last two years. I do have the best team.

INTRODUCTION

Education in the United States is provided in public, private and home schools.

Educational standards are set by State governments and education is compulsory between the age of five and sixteen, depending on the State. During the twelve years that precede higher education, American students attend primary schools, which are called "elementary schools", and then secondary schools which consists of middle schools and high schools. After their graduations, students may go on with their studies, some of whom will even be admitted in internationally reputed universities.

Education in the United States is compulsory since "by the law of American state, knowledge is a must for the students so that the growing children can be educated."

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Considering these standards, one may expect that all U.S students will benefit from high educational expectations and the best school environment that may be. Yet, major issues are reported such as a lack of funding and legal protection, gender and racial discrimination, harassment, bullying and more. I became interested in the subjects of gender and color discrimination, harassment and bullying in general as I was myself getting into higher education. Personally, facing these problems in the French educational system as a student as a girl by my peers and witnessing it later as an educator made me wonder if this was happening elsewhere. I chose to focus on the American System for this study. This study allowed me to investigate the problem regarding bullying in schools, from its historical background of bullying to the way in which it is tackled.

Over the years, bullying in schools has become a systemic problem worldwide, especially in America, and is considered one of the most common antisocial and aggressive behaviors among adolescents and children, involving either a real or a perceived power imbalance. The term "bullying" usually refers to "an individual or a group of people with more power who repeatedly and intentionally harass, intimidate and cause harm to another individual."2 Bullying behavior can range from verbal insults, the most common form, to physical altercations and violence. The three more common types of bullying are verbal bullying including teasing, name-calling, inappropriate sexual comments, taunting and threatening to cause harm; social bullying, which involves hurting someone's reputation by leaving someone out, telling a group not to be friends with someone in particular, spreading rumors about someone, and embarrassing in public; and physical bullying, which causes harm to a person's body or possessions like hitting, pinching, spitting, pushing, breaking things, and rude gestures done by the harassers. [START_REF]Complete the definition Cyberbullying is when someone ………………… 4[END_REF] Whereas the two first are not as easily physically perceived as the last one, all types of bullying are aggressive and need to be taken seriously.

According to the US National Center of Education, more than twenty percent of students in grades six to ten are reported being bullied. Bullying affects nearly one in three American school children while six out of ten teenagers say they witness bullying in school once a day. 4 Bullying is a serious public health concern. 5 Children cannot get away from it, which has led to an increasing amount of suicides and attempts of suicide over the past decades and has disastrous effects not only on America's youth but also on society itself. According to a report of ten years bullying data collated by the Child Helpline International, the average of students bullied went from 70,360 in 2003 to 134,673 in 2012. 6 It points out the increasing raise of the worldwide systemic problem of bullying. Why cannot American schools stop this trend? The evolution of social media and mobile communication has really increased a favorable bullying environment, but this evolution could also be used to stop this hostile environment. Why stay quiet when it is rather easy to be heard nowadays? Targeted children often suffer and this situation generates poor performance in school, experiencing anxiety and depression among other issues. Loneliness is often associated with, and a consequence of, bullying, a circumstance that is reinforced with the lack of response to this problem. In the fight against bullying in schools, everyone must take a more active role. The role of schools is to ensure safety, health and an effective learning environment, and despite the media fire about bullying in schools over the past years, teachers, educators, adolescents and even children tend to stay quiet and show some indifference in the face of these situations. Indeed, 58% of middle and 66% of high school students believe adults at school are not doing enough to stop or prevent bullying. 7 Numerous preventive measures have been announced by States and local lawmakers in order to prevent and tackle bullying such as hotline numbers, passing laws and anti-bullying legislation. [START_REF] Willard | Deliberate Indifference to a Hostile Environment[END_REF] Each jurisdiction and each U.S State provide different bullying definitions. Some of them such as New York, Ohio and others, established laws, policies and regulations, while the states of Nebraska and Colorado provided definitions but failed to establish a prohibiting statement. Many states such as Alabama and California also include bullying prevention programs and staff training. However, these state laws do not include consequences for the individual who commits those bullying actions and despite these legislative actions, the indifference, deliberate or not, remains present with the staggering facts that 64% of children who were bullied did not report it and nearly 70% of students think schools respond poorly to bullying. [START_REF] Foshee | Examining Explanations for the Link Between Bullying Perpetration and Physical Dating Violence Perpetration: Do They Vary by Bullying Victimization?[END_REF] This indifference is a failure to act in order to protect students from what is considered child abuse. Schools have come under fire these past years for not insufficiently protecting students and preventing bullying in school. 7 Bradshaw, Catherine P., et al. "Bullying and Peer Victimization at School: Perceptual Differences between Students and School Staff." School Psychology Review, vol. 36, no. 3, National Association of School Psychologists, 2007, pp. 361 My main objective here is to analyze the social problem of bullying and its roots.

It is interesting to consider the reasons behind this issue. Who are the main actors? Do the school boards, students and teachers, separately or together, face responsibilities? Why do they stay silent in the face of these acts of violence? Do American schools show a deliberate indifference? Several Federal Cases Law such as Davis v. Monroe County Board of Education demonstrated on May 24, 1999 that school boards had been informed of acts of bullying multiple times and the Court decided that knowledge was a factor that makes schools liable for a non-response to the bullying problem. 10

It has become common for adolescents to stay quiet, whereas they are victims, witnesses or tormentors. Nancy Willard, who is a practicing attorney in Oregon, wrote in Deliberate Indifference to a Hostile Environment published in 2007 that "a critical question arises regarding how students who are being bullied or harassed by their peers, and sometimes by school staff, can effectively protect their interests in situations when school leadership and staff are not effectively responding to prevent these known and well-documented harms." 11 Do American students, victims, teachers, and parents stay quiet because they know they will be ignored? This deliberate indifference makes us wonder if schools are effective in term of protection and prevention.

"Deliberate indifference is a fact of sensitive inquiry. Deliberate indifference must, at a minimum, cause students to undergo harassment or make them liable or vulnerable to it. Although courts have indicated that continuing to utilize the same response after it has been shown to be ineffective, or not responding at all, or utilizing a minimalist response may demonstrate deliberate indifference, a school is not deliberately indifferent simply because the response did not 10 In Davis v. Monroe County Board of Education on May 24, 1999 stated that school boards are liable for failing to stop student-on-student sexual harassment under certain circumstances. 11 Willard, Nancy. Deliberate Indifference to a Hostile Environment. 2007, p. 30. remedy the harassment or because the school did not utilize a particular discipline." 12 We can therefore question the responsibilities of the schools, including their lack of actions. How is it possible to prove that a school deliberately stays indifferent to harassment? How can the indifference of schools be linked to the indifference of students?

The subject I chose does not come with a large choice of sources. I found it difficult to find dependable sources. Most of my research led to interviews, articles on website and testimonies. I discovered several federal cases that are going to be very useful in my study along with an article examining the very specific subject of Deliberate Indifference. 13 I likewise came across some bullying cases on a state and sometimes national levels that profoundly shocked the American people. This dissertation will examine the bully and the bullied, as well as describe the response to this phenomenon. The purpose of this dissertation is to take a look into popular culture along with the many forms and consequences of bullying. This study will discuss the implications for educational leadership. It was interesting for me as a student who majors in Education and as an educator in a middle school to bring up the subject of bullying and to observe the children's behavior while they grow up. This is the reason why my thesis will focus on this question: how are American schools reacting to bullying in schools? Are they falling or succeeding? It will allow me to discuss the different reasons behind their responses and the fact that indifference has become a common habit regarding the bullying issue.

12 Words adopted by the Justice Ishii of the United States District Court in a harassment case against a school Deliberate Indifference Definition. http://www.duhaime.org/LegalDictionary/D/DeliberateIndifference.aspx. Accessed 1 Apr. 2020.

13 "Deliberate indifference is the conscious or reckless disregard of the consequences of one's acts or omissions knowing the harm that will result." "Deliberate Indifference Law and Legal Definition," USLegal, Inc. https://definitions.uslegal.com/d/deliberate-indifference/. Accessed 1 Apr. 2020.

In order to answer this question, I will firstly analyze the basic term of bullying, including its characteristics and risks. Then I will study how American schools protect their students and how they respond to the problem, as well as the lack of intervention depicted and witnessed all over the country. Finally, I will discuss the responses and guidance needed to correct this hostile environment in school.

BULLYING IN SCHOOLS

Bullying -long tolerated as just a part of growing up -finally has been recognized as a substantial and preventable health problem. Bullying is associated with anxiety, depression, poor school performance, and future delinquent behavior among its targets.1

A Bullying Environment

Bullying is a specific problem. It is part of the American school system 2 , but it is just one of the symptoms of American society. The school environment is the main factor leading to bullying. Bullying over the years has created a poor school environment for students but the impact on the school staff cannot be denied either. The easiest targets are the passive and weak children. These acts happen most of the time within the school buildings but also on their way home or to school, and even online. There is not a single profile of a young person involved in bullying. Children who harass others can be either very strong physically or well-known at school, act in a group, or may even be bullied by others as well. It is surprising that those who are bullied sometimes bully others. They are considered the most at risk to experiment subsequent behavioral, mental health, and academic problems. [START_REF]Complete the definition Cyberbullying is when someone ………………… 4[END_REF] Bullying is actually considered a group phenomenon. 4 It cannot be defined by a simple interaction between two students because it often involves groups of students supporting in each other in the act of bullying others.

The bullying statistics5 give an inside look at the places where these acts of bullying happen. It is shown that the most common places are the classroom, the hallways or the lockers. 23.4% of bullying also happens at the cafeteria, in the bathroom (12.2%) or during the gym class (19.5%). All these places share a common factor: these acts happen within the school premises. But it is not only happening in America. In France too, bullying happens within the school. I have seen children being body shamed in hallways, children being insulted on the school playground. School is conducive to bullying.

Bullying is also likely to happen on the way to school, on the way home after class. Bullying can come in various forms, such as physical bullying which refers to kicking, tripping, punching or hitting; any form of unwanted touching can be defined as bullying and possible sexual assault. Bullying also comes in the form of verbal bullying, which involves name-calling or teasing someone; social-bullying is gossiping or excluding someone from the others in order to make them feel alone. Over the past years, cyberbullying has increased with the emergence of new technologies. Bullies use the Internet and social media to harass their peers. They post insults, they send mean texts, and make rude comments on the social media's posts in order to hurt or embarrass a peer.

Types of Bullying

Bullies often mock appearances, behaviors, race or religion, social status and sexual identities (like being gay, lesbian, or transgender). 6 The most common types of bullying are verbal, social and cyberbullying. Cyberbullying is more difficult to track because it does not occur on the school premises but online. Physical bullying is common but less observed or non-reported.7

Bullying in schools also implies drug issues. According to the American Counseling Association8 "Many school shooters who were taking psychiatric drugs for their disorder experienced side effects of the drugs prior to carrying out a violent act. There have been 22 drug regulatory warnings on psychiatric drugs citing effects of mania, hostility, violence, and even homicidal ideations." [START_REF] Foshee | Examining Explanations for the Link Between Bullying Perpetration and Physical Dating Violence Perpetration: Do They Vary by Bullying Victimization?[END_REF] The use of drugs correlates with the violence that is happening in schools. Teenagers who are experimenting the effects of the drugs are more likely able to carry out violent acts and possibly hurt people.

Bullying has become a form of youth violence and has been related to gangs' activities.

Today, almost 33, 000 violent street gangs, motorcycle gangs and prison gangs are criminally active in the U.S.10 All use violence to control people and increase their activities. According to some research, some bullies and their victims are looking at some serious forms of violence in order to face their problems. By joining a gang, a bullied may have the opportunity to gain some power and to become the bully to those who have hurt them.

Indeed, violence is prominent in schools and take the form of rackets, sexual harassment and body shaming. All this violence is a part of bullying. Racket is a dishonest or illegal activity that generates money 11 and happens in schools: on February 18, 1952, at Proviso Township High School, in western Cook County, Illinois, three students were "Racket." Cambridge Dictionary. https://dictionary.cambridge.org/fr/dictionnaire/anglais/racket. Accessed 2 Jan. 2020. charged with extorsion and assault. They were accused of obtaining pocket money by bullying little boys. They offered to protect them in exchange of a weekly fee, and pupils who did not pay got some arm twisting and some punching. 12 Things have not changed some 70 years later. As being part of educator team, it is obvious that stronger children often use their power and strength to get what they want. Violence usually starts by just stealing food, clothes and even money.

Body shaming and sexual harassment have been two rising concerns of the past years. It has always existed but only recently got the attention it deserves.

"Sexual harassment in schools is unwanted and unwelcome behavior of a sexual nature that interferes with the right to receive an equal educational opportunity.

It is a form of sex discrimination that is prohibited by Title IX, a Federal law establishing civil rights in education that addresses issues of sex discrimination and, by judicial precedent, sexual harassment." 13 According to a survey 14 carried out by the American Association of University Women Educational Foundation, there is "a universal culture of sexual harassment with no significant racial distinction flourishing in America's secondary schools." 15 Out of 828 boys and 779 girls selected for the survey, 83% of the girls and 60% of the boys reported being sexually harassed in school. This survey demonstrates how common sexual harassment is. The results of the survey show the locations of the harassment that we discussed earlier on. Body shaming is criticizing someone "based on the shape, size or appearance of their body". 16 It can be defined as a form of sexual harassment since 67% of girls and 12 Provis, Steven Arthur. Bullying (1950[START_REF] Provis | The Bully and the Bullied[END_REF] 26% of boys on the survey reported experienced sexual comments about parts of their body, clothing and looks as a form of sexual harassment. 17

Typical Profiles : the Actors

Everyone plays a role in bullying. It is important to define those directly involved in bullying along those who take part in this offense.

A bully is "someone who hurts or frightens someone else, often over a period of time, and often forcing them to do something that they do not want to do." 18 There are approximately 30% of surveyed young people who admit bullying others in surveys. This percentage only shows it is only representative of those who answer the surveys and are honest doing so. 19 There is not a typical profile of a bully, but many share characteristics and show similar behaviors. We can distinguish being victimized by an individual and being victimized by a group: bullies sometimes act alone, but more commonly in groups.

They are impulsive, they show anger management problems, they are aggressive and frustrated, they have a poor opinion of the others, they are disobedient and most of them see violence in a positive way. 20 Children who are more likely to bully others are those whose feel powerful at school, who have great connections, self-esteem and like to be in charge. But isolated children with low self-esteem, less involved in school with a lack of connections are also reported to be more likely to bully their peers on their own. Studies showed that "school, neighborhood https://mainwebv.musc.edu/vawprevention/research/sexharass.shtml. Accessed 3 Jan. 2020.

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"Bully." Cambridge Dictionary, https://dictionary.cambridge.org/fr/dictionnaire/anglais/bully. Accessed 5 Jan. 2020. 19 Bradshaw, Catherine P., et al. "Bullying and Peer Victimization at School: Perceptual Differences between Students and School Staff." School Psychology Review, vol. 36, no. 3, National Association of School Psychologists, 2007, pp. 361-82. 20 This research on bullying supported by The Jacobs Foundation, the British Academy and the Nuffield Foundation shows that personal factors are deeply connected to the behaviors of the children becoming involved in bullying. In fact, family related factor is definitely associated with bullying and with victimization depending on conflicting parents or punitive parenting. 23 These children bullies engage in bullying behavior towards their peers. Despite the involvement of these children in bullying, it is important to help them change and to raise awareness.

A bullied is an individual who is bullied by someone else. Students get often bullied because of their race, ethnicity, national origin, their gender and/or non normative sexual orientation. These factors put children more at risk of bullying behavior, but not every child with these characteristics will be bullied. The National Center for Education Statistics and Bureau of Justice declared that 20% of students ages 12-18 experienced bullying during their time at school. 24 There is no single factor that defines a child at risk of being bullied. But generally, children who are bullied present some risks factors, which include the way they are perceived from their peers, their being overweight or underweight, wearing glasses, being the new student in school, and possible depression associated with low self-esteem. 25 It does not mean they are going to be bullied, but there is more chance that it will happen. These children definitely need help in order to learn how to respond to these bullying behaviors. Some children are not directly involved in bullying, but they definitely play a role in the circle of bullying and might even be contributing to that offensive behavior. Children might witness bullying happening. They are considering as children who passively witness and assist bullying. These children can be put in four different categories.

"Kids who Assist: These children may not start the bullying or lead in the bullying behavior, but serve as an "assistant" to children who are bullying.

These children may encourage the bullying behavior and occasionally join in.

Kids who Reinforce: These children are not directly involved in the bullying behavior but they give the bullying an audience. They will often laugh or provide support for the children who are engaging in bullying. This may encourage the bullying to continue.

Outsiders: These children remain separate from the bullying situation. They neither reinforce the bullying behavior nor defend the child being bullied. Some may watch what is going on but do not provide feedback about the situation to show they are on anyone's side. Even so, providing an audience may encourage the bullying behavior.

Kids who Defend: These children actively comfort the child being bullied and may come to the child's defense when bullying occurs." 26Children can often play more than one role. Children showing these kinds of behavior need to learn what they should do and how they can help someone who is bullied. It is important for them to learn how to be more than a bystander. The first thing to do, whether children are bullied, or witness bullying happen, is to speak up to a trusted adult. Some children are more at risk of being bullied than others. Children who come from racial, ethnic, and national minority groups get often bullied. They are, still nowadays, perceived as being different. They often grow up in a non-supportive and racist environment, which reinforces the inequalities they are facing. They are considering more at risk of being bullied by their peers. Bullying based on the color of the skin can be severe, pervasive and persistent. Religion and Faith are two factors increasing bullying.

Religious harassment is often based on the false perceptions about religions and their rituals.

Lesbian, gay, bisexual, transgender or questioning teenagers (LGBTQ), among all children corresponding to these typical profiles, are those more at risk of being bullied at school. For adolescents, "coming out" has been associated with school victimization.

According to the Centers for Disease Control and Prevention, students who are part of the LGBTQ community are more frequently bullied than their heterosexual peers (33% and 17,1% respectively). 27 The risk of suffering from bullying behaviors is higher for those perceived to have different sexual orientation.

All Adults play an important role in helping to prevent bullying and raise awareness. Parents, educators and adults in the community28 are here to guarantee a safe environment and make sure that all children are free to learn unhampered and grow up in a peaceful environment. But helping to guarantee the children's safety, they need to be aware of what bullying is and how to recognize it.

Parents play a key role in preventing and responding to the bullying of their own child (en). Understanding what bullying means is the first step to be able to help a child.

They can recognize the warning signs at home, whether their children bullies, is bullied or witnesses bullying. They can talk to their child and make sure they know what is going on at school. Most children are too afraid or too ashamed to talk about it, so it is important for parents to know what to look for and to be able to open the communication by using the right words. Knowing what has happened will help to establish a communication with the school, the teachers. Working with the school or the community is vital to support a child and prevent bullying from happening. 29 Schools are the first place where bullying happens. [START_REF]What Is Bullying? Violence, Harassment and Bullying Fact Sheet | Australian Human Rights Commission[END_REF] Teachers are the first persons that are able to witness bullying's behaviors. They are here to establish a supportive school environment. It is important, for an educator, to picture the students and think what they can do about it. Being aware of what bullying is, to establish a safe school climate, to learn how to talk about bullying with youth, to assess and respond when bullying happens are the only way to prevent it from happening.

Adults who work in the community also play a big role in ensuring all children's safety. Working in law enforcement, mental health services, community or youth organizations place them on the front line when it comes to assess and respond to bullying. They are expected to take action against those behaviors and help all children.

Parents, teachers and community come together to prevent and ensure a safe school climate. In America, parents and teachers can provide some help and work together to make the school a better place for children to learn. They are often part of a schoolbased organization called PTA. PTA stands for Parent Teacher Association. They are very powerful in the United States as they vote for school budget and can decide whether or not to maintain certain classes and programs. voice for all children, a relevant resource for families and communities, and a strong advocate for public education." 31 PTA is the oldest and largest child advocacy association in America. Today's PTA is composed of more than 4 million parents, educators and other caring adults whose mission is to ensure the safety, education and health of all children. 32 Their mission is to bring about "an atmosphere of zero tolerance for bullying behavior, and an attitude that bullying behavior is unacceptable and will not be tolerated in homes, schools, playgrounds, buses, school activities, or any place children congregate". 33

Effects of Bullying

Bullying others has deep consequences. It creates an unsafe school climate where tension, anxiety and fear are omnipresent. Someone less powerful would be more likely hurt and threatened by a bully. According to studies investigating the consequences of involvement in bully-victim problems by The Canadian Journal of Psychiatry, 34 four categories of negative health conditions can be clearly identified.

"1. Low psychological well-being. This includes states of mind that are generally considered unpleasant but not acutely distressing, such as general unhappiness, low self-esteem, and feelings of anger and sadness.

2. Poor social adjustment. This normally includes feelings of aversion toward one's social environment, evident through expressed dislike for school or workplace, manifest loneliness, isolation, and absenteeism.

3. Psychological distress. This is considered more serious than the first 2 categories and includes high levels of anxiety, depression, and suicidal thinking.

31 "History -About PTA." National PTA. https://www.pta.org/home/About-National-Parent-Teacher-Association/Mission-Values/National-PTA-History. Accessed 30 Mar. 2020. 32 The subjects of these studies responded regarding their health conditions. It shows that bullying psychologically and physically affects by creating a desperate and distressing atmosphere.

It can affect everyone, not only the person who is bullied. Bullying is linked to many problems such as mental health, drug issues and suicide. Despite the shared characteristics of numerous children linked to bullying, the consequences and effects are not depicted by the majority of them.

Children who are bullied are more likely to experience deep feelings such as These increased feelings of sadness increase the risk for children to miss, skip or drop out school. This decreased school participation can lead to decreased academic achievement with low test scores. These consequences could in a part be responsible for the victims' tendency to stay silent. When bullying is not stopped or challenged it can create an environment when bullying is tolerated and where everyone feels powerless to stop it. This can also be a way to explain the failure of American schools, including teachers and officials.

Children who bully others engage in violent and risky behaviors, sometimes even into adulthood. Bullying is highly aggressive and damaging to others. They are more likely to present a problem with alcohol and drugs, to get into fights, to engage in sexual activity at a young age and, like those who are bullied, to drop out of school. In adulthood, they are more prone to have criminal convictions and be abusive towards their romantic partners and children. 37 As their victims, they are also reported feeling anxious and sometimes even ashamed.

Bullying behaviors can also affect those who witness acts of bullying. Children who observe such deeds can show an early use of tobacco, alcohol or drug use. This can also affect their mental health and increase risks of depression and anxiety. The results of the fact sheets of The Australian Human Rights match those of The Canadian Journal of Psychiatry. It shows that bullying is a worldwide problem and is not only affecting the United States.

CONSEQUENCES AND REACTIONS TO BULLYING

If there's one goal of this conference, it's to dispel the myth that bullying is just a harmless rite of passage or an inevitable part of growing up. Bullying can have destructive consequences for our young people.1

Legislative framework

"When it's harassment based on sex or race or ability, we can intervene. But on other issues, there actually is no national policy or no national law" 2 the Federal Government stated. Kevin Jennings, The US Department of Education's Safe School Czar, following the death of 17-year-old Tyler Long, reported that "victims of bullying like the Longs -who find no relief on a local level -have few options at the federal level either". Indeed, there is no federal law in the United States that specially applies to bullying. Each state and local lawmakers decide how they want to prevent bullying 3 and how they want to protect children. In 2011, a legislation sponsored by California State PTA was voted in order to help to protect students from bullying and harassment. The bill mentions a training of school site personnel on the prevention of bullying and the new law "gives victims priority for transferring out of a school, if requested." 4 Schools, colleges and universities are obligated to address the harassment on their own. The U.S Department of Education (DE) and the U.S Department of Justice (DOJ) may be able to help the schools if bullying "overlaps with discriminatory harassment which is covered under federal civil rights laws" 5 that they enforce.

According to the Title IX Regulation Fact Sheet of the U.S Department of Education6 , schools are required to respond to the situation and to increase access to response measures. They also held liable "when it is "deliberately indifferent" to known sexual harassment, meaning its response is clearly unreasonable in light of known circumstances."7 Schools administrators are required to propose supportive measures to complainants and to preserve access to education. This Regulation Fact Sheet offers a fair process in case of sexual harassment and more support for plaintiffs by ensuring that their wishes are respected. To summarize the situation, schools are compelled by these laws to address bullying behaviors. They must take immediate and appropriate actions, communicate with students, end and eliminate any hostile environment and ensure that they prevent harassment from happening again. Policies prohibiting harassment, discrimination and bullying can be implemented with inquiries if harassment occurs again. If that is the case, the United States Department of Justice offers resources to assist them in term of mediation, conciliation, technical assistance and training, but schools are in the end on their own to implement the solutions.10

It is not possible to talk about the different anti-bullying groups and organizations without raising the name of the Parent-Teacher Association 11 . Created in 1897, the Parent-Teacher Association are millions of families, students, teachers, administrators and community leaders that are devoted to educational success of children. The association pride itself on being a powerful voice for all children and considers itself a relevant resource for parents. On June 2015, the National PTA adopted these words regarding their resolutions:

"That National PTA and its constituent organizations support policies and programs that address the prevention, intervention, and elimination of bullying;

That National PTA and its constituent organizations endeavor, via educational literature, programs, and projects for parents, students, and school personnel, to bring about an atmosphere of zero tolerance for bullying behavior, and an attitude that bullying behavior is unacceptable and will not be tolerated in homes, schools, playgrounds, buses, school activities, or any place children congregate; and be it further That National PTA and its constituent organizations work with the appropriate agencies and organizations in a national effort to inform the general public about the risks and cost of bullying for both the bully and the target, as well as those who witness bullying, and bring about a change in societal attitudes toward bullying." 12 Parents and caring adults can play a central role in the fight against bullying and in the creation of a safe and healthy school climate. Children may not always recognize what is happening to them and most of them are not even aware of all the resources they can use if someone is bullying them. It is important for them to be able to find responsible adults in time of crisis. Many are the anti-bullying and organizations that do take care, amongst which, 11 Supra page 17.

StopBullying.gov National Bullying Prevention Center 13

The Trevor Project No. 15-1474 (4th Circuit, April 8, 2016), schools have been proclaimed not liable for failing to stop and redress the hostile environment. Nancy Willard is definitely concerned about the Deliberate Indifference and that "unless and until federal courts hold schools accountable for taking the steps necessary to correct a hostile environment that is supporting students in engaging in harassment, millions of U.S students will face daily torment that is not only interfering with their right to receive and education, but also resulting in significant, long-lasting emotional harm." 19 She added that if schools' districts face no inquiry in failing, there would be vulnerable children that "will continue to suffer harms at the hands of their peers and sometimes school staff." 20 Her approach identifies what school leaders under the laws and regulations should do to correct their mistakes. She tries to demonstrate whether school officials had actual knowledges or not on specific situations and if their responses were adequate. Her research is based on a better understanding of the problem by enumerating scenarios in which everyone can self-identify.

A deliberate indifference to bullying is a non-response to the problem. Bullying behaviors are often considered a normal rite of passage to be left alone and endured. That is why too often schools are not doing enough to help children who need help or worse, are not doing what policies and laws require them to do. Bullying today is no longer acceptable.

"A school that does have a grievance procedure is liable for any conduct of its students that creates a sexually hostile environment where (a) the school knows The principle of liability for deliberate indifference to known harassment is settled high in Davis v. Monroe County Board of Education. 22 The case debated the question if a school board could be held responsible, under Title IX of the Education Amendments of 1972 23 , for student-on student harassment. The judgment of the U.S Supreme Court in which, under Title IX of the Federal Education Amendments, stated that school boards are liable for failing to stop student-on-student sexual harassment under certain circumstances was later reversed during appeal and it now rests on the principle that "recipients of federal funds should be held liable only for their own misconduct and not the misconduct of others." 24 Thus, Title IX makes a school district non-liable for the misconduct of their students, misconducts that they should have known prior to the offense. On the same note, the Supreme Court's decision in Gebser v. Lago Vista Independent School District 25 stated that if sex harassment is "not reported to or observed by an appropriate person, […] then a school district will not be liable." 26 It points out that showing the school's knowledge must be made in order to prove the deliberate indifference and failing. A school district is then not liable for teacher-student sexual harassment unless they had knowledge of it and if they responded with deliberate indifference. The system qualifies an "appropriate person" as "an official of the school district who at a minimum has authority to institute corrective measures on the district's behalf." 27 The degree of importance of knowledge by teachers or counselors has been raised in the case of KB v. Daleville City Board of Education and it has been decided to be determinate on a case by case basis.

The fact that liability lays on the decision that schools should be held responsible only for their own misconduct is a factor that can increase deliberate indifference. In order to avoid 22 Aurelia Davis sued the Monroe County Board of Education on behalf of her daughter, alleging that school officials failed to prevent her daughter's suffering sexual harassment from another student. 23 The Title IX of the EA is meant to secure equal access of students to educational benefits and opportunities.

24 "Davis v. Monroe County Bd. of Ed., 526 U.S. 629 (1999)." Justia Law. supreme.justia.com, https://supreme.justia.com/cases/federal/us/526/629/. Accessed 1 Apr. 2020. 25 Alida Star Gebser, a high school student, had a secret sexual affair with one of her teachers. The teacher was arrested and fired following the discovery. She claimed she was harassed in violation of the Title IX of the EA and asked for sexual harassment damages. Hudson Area Schools (2009) 29 and Zeno v Pine Plains (2012) [START_REF]What Is Bullying? Violence, Harassment and Bullying Fact Sheet | Australian Human Rights Commission[END_REF] . In Paterson, the Court determined that the student-on-student harassment had occurred over years and that over the years the school had used the same ineffective method to address the issue. This statement led the jury to find the school guilty for deliberate indifference. In Vance, the Court stated that "Although no particular response is required, and although the school district is not required to eradicate all sexual harassment, the school district must respond and must do so reasonably in light of the known circumstances. Thus, where a school district has knowledge that its remedial action is inadequate and ineffective, it is required to take reasonable action in light of those circumstances to eliminate the behavior. Where a school district has actual knowledge that its efforts to remediate are ineffective, and it continues to use those same methods to no avail, such district has failed to act reasonably in light of the known circumstances." 31 In Zeno, the case demonstrated that the punitive responses delivered by the school did not prevent further harassment but made things worse for Anthony. It was determined that the school's responses were inadequate and deliberately indifferent and that the School district did not reacted to many signals of Anthony's situation.

28 Steven Vance complained of verbal and physical abuse to school officials, including the principal. She reported numerous incidents but no real punishment followed despite her Title IX complaint. She was diagnosed with depression, left school and filed against the school. 29 Patterson v. Hudson Area Schools, 551 F. 3d 438 (6th Cir. 2009). On November 22, 2005, David and Dena Patterson filed suit under Title IX of the EA claiming that Defendant was liable for its alleged deliberate indifference to others students harassing their child. [START_REF]What Is Bullying? Violence, Harassment and Bullying Fact Sheet | Australian Human Rights Commission[END_REF] Anthony Zeno, a dark-skinned biracial 16-year-old was harassed with explicit and degrading racial slurs and wth violent threats. The award was in response to a suit in which a jury determined the school district was deliberately indifferent to the pervasive harassment the student suffered in violation of Title VI of the Civil Rights Act of 1964.

Bullying and its Consequences

Bullying affects every child, those who are bullied, those who bully others, and even those witnesses of bullying. It can have consequences, on different levels, for everyone. Among the most common consequences of bullying, we can quote suicide, violence (mass shootings) and poor social skills. Bullying can affect the quality of education. As it is shown by Unicef 32 , bullying does interfere with student reading scores 33 . It shows a correlation between bullying and student academic results.

School bullying is a type of school violence. Violence marked by behavioral, emotional and social problems. Social rejection can generate violence, and it can turn deadly if teenagers have access to weapons.

There is no universal definition of mass shootings or central database tracking them, CNN created a list 34 based on media reports of the deadliest mass shootings in modern US history from 1949 onwards. It is hard to properly define what a mass shooting is since everyone defines it differently. In the 1980s, the Federal Bureau of Investigation defined a mass murderer as someone killing four or more people in a single incident in a single location 35 . A mass shooting is considered as three or more victims, not including the shooter. 36 Shooting can be an act of desperation fueled by anger, loneliness, depression, bullying. With the right to carry guns in the US, as defined by the Second Amendment 37 , the use of deadly weapon can be a response to social rejection for some children. Of course, not all mass shooters were bullied as children at schools. Some mass 32 See appendix 4. 33 The reading scores give a picture of how student is doing in school. shooters are the bullies. [START_REF] Khazan | Why Many Mass Shooters Are 'Loners[END_REF] But it cannot be denied that some links exist between loneliness, social exclusion and mass shootings. Mass shooting are the result of a violent environment at school, at home and in the society. Children seek vengeance for what they have endured. There are two leading causes of school shootings according to Allison Paolini, assistant professor of Counselor Education at Kean University: "bullying (87%), as well as both non-compliance and side effects from psychiatric drugs (12%)". Most school shooters were identified as victims of severe and long-term bullying (including feelings of humiliation). These perpetual humiliations resulted in thoughts of suicide or revenge. They are a major factor of school shootings.

Bullying might end up in suicide. Many media stated that bullying can cause suicide and reported tragic stories of young's suicide 39 linked to bullying. Suicide connected to bullying is a more complex phenomenon. Both are closely related but it is not accurate and dangerous to present bullying as the problem that causes suicide. [START_REF]Facts About Bullying[END_REF] Bullying is not a reason for suicide. Suicide is the third leading cause of mortality for adolescents in the U.S. [START_REF] Kim | Bullying and Suicide. A Review[END_REF] It is a serious problem worldwide. According to a large scale of the Youth at Risk Behavior Surveillance in 2002, 19% of U.S high school students had serious suicidal thoughts, 15% planned their suicide, 8.8% attempted to suicide, and 2.6% made a suicide attempt that necessitate medical intervention. [START_REF] Grunbaum | Youth risk behavior surveillance--United States, 2001[END_REF] A bullying environment increases the risks of suicidal behaviors. Some research proved that bullying can "lead to or worsen feelings of isolation, rejection, exclusion, and despair, as well as depression and anxiety, which can contribute to suicidal behavior" 43 but it would be wrong to say that bullying directly causes suicide. The use of words can contribute highlights the fact that suicide is not a natural response to bullying. It is important not to frame the discussion around the fact that bullying is a direct cause of suicide because it could encourage the belief that suicide is a natural response to this problem. It also needs to be reminded that the vast majority of children being bullied do not become suicidal and that people who die by suicide have pre-existing risk factors. For example, young LGBTQ people are more at risk of being suicidal even if they are not bullied at school. The attention of everyone must focus on all risk factors for suicidal behaviors. A young person's suicide is a tragedy and bullying and suicide related behaviors are two very serious public health issues that must be addressed with understanding and precaution.

FINAL OVERVIEW: SCHOOLS' RESPONSIBILITIES AND INTERVENTIONS AT STAKE.

As parents and students, as teachers and members of the community, we can take steps -all of us -to help prevent bullying and create a climate in our schools in which all of our children can feel safe.1

Lack of Actions and Bullying Cases.

Many media focus on blame and judicial intervention when it comes to bullying. The media overlook the evidence-based approaches and prevention, which is the most important. It increases the concern that bullying is not treated the way it should be. School failure to address the issue can be explained by the fact that schools are not tackling bullying in the right way. It is clear, from an educator's point of view, that bullying does not stop because adults are aware of the situation. Sometimes educators think it's natural and they should not be worried. Sometimes it gets worse. Children do not seem to be impressed by authority probably because they do not understand the severity of their actions. Sometimes they do not understand the severity because schools' officials, along with teachers and parents, do not address this problem as they should. The emotional and educational damages to victims are enormous and yet, no enormous decision or intervention is taking place. Failure and lack of actions can be partially explained by the misunderstanding of the situation and the responses given.

The direct bullying approach is not the more effective in long term: blaming and seeking for punishment can contribute to a climate that makes it more likely to happen.

Interventions must involve the entire community and not only bullies and victims. The interventions need to be comprehensive and must involve all students, parents and school's officials in order to ensure a safe and learning-supportive environment. The Power of One Foundation 2 points out the tendencies concerning the beliefs regarding bullying. They highlight the fact that parents are often unaware of the bullying problem so they do no talk to their children to the extent they should. They also report the low percentage of students who think that an adult might actually help them. Students do feel that "adult intervention is infrequent and ineffective, and that telling adults will only bring more harassment from bullies […], teachers seldom or never talk to their classes about bullying" 3 and that "school personnel may view bullying as a harmless rite of passage that is best ignored unless verbal and psychological intimidation crosses the line into physical assault or theft." 4

A low percentage of reports can be also explained by the shame that most students can feel regarding what they have endured. Many are ashamed and do not report it. Shame can be a damaging emotion that takes part in bullying. Students can feel ashamed of what happened to them, so they do not want others to know and to officially face it. They may be worried about a reaction from their parents, their peers or, their teachers. They fear that people will think they can not stand up for themselves. They do not want to be seen as failing their own life so they often keep a low profile feeling that they deserve the bullying.

All these wrong perceptions and feelings could be in part responsible for the failure to help more teenagers. Schools' responses can be considered inadequate when actions have little or no effect on the harassment and the harasser. The purpose of the responses should not be making sure that students understand what they have done?

2 The Power of One Foundation in a nonprofit organization which was founded in 1999 by two parents after the death of their high school daughter. She had been victim of severe peer harassment. The parents created the foundation because they think few resources are available. They think all children should feel safe at school and to be treated with respect and dignity. In Stiles v. Grainger County Board of Education5 , schools' officials allegedly failed to recognize and reasonably respond to a pattern of bullying incidents. They took no actions to address concerns related to the school environment6 . Their mistake was to not focus on the hostile atmosphere that was helping the harassment to progress, but no proof was given to show a violation of Stiles' rights under Title IX of EA.

Matthew Shepard was a 22-year-old gay American student at the University of Wyoming. He was beaten, tortured and left to die on October 6, 1998. He died from severe head injuries. Aaron McKinney and Russel Henderson developed a rouse in which they had pretended to be gay in order to get closer from Matthew. With his death came awareness of the dangers, the violence and discrimination that members of the LGBTQ community are facing every day.

Nigel Shelby was a black Alabamian 15-year-old student who died from suicide after suffering from anti-gay bullying. He put an end to his life after years of homophobic bullying. His mom, Camika Shelby, reported after his death that the school ignored clear warning signs and that an administrator told her son that being gay was a choice. She declared that the school never informed her of the discussion about homosexuality between her son and the school administrators and that he was struggling at this point with his sexual identity. The Huntsville City Schools Districts denied all accusations and stated that they worked with Nigel to provide him with a safe environment at school.

According to Nationwide Children's, black children are more at risk of committing suicide than white children.

Megan Meier was a 13-year-old American teenager who committed suicide by hanging herself three weeks before her 14 th birthday. Her suicide was attributed to the cyberbullying she suffered from through the social network MySpace. She was speaking with a 16-year-old boy online. The tone of the messages she received progressively changed until one day, things were posted about her online. She had a fight with her parents, then went upstairs to her bedroom and hanged herself with a belt in her bedroom closet. The boy was later proved to be the mother of one of Megan's former friend. The mother, with her daughter and one of her employees, tried to get information and humiliate Megan online. Megan's story resonates with Marion Fraise's.

Marion Fraise was a 13-year-old French teenager who hang herself after being bullied at school by her classmates. She was threatened and received many text messages and Facebook posts. Her classmates humiliated her in class, threatened her to hurt her after school, calling her bad names. She hung herself in her bedroom. Her phone was at the end of the scarf she used to take her life, like she wanted to explain the reason of her choice. Before taking her life, she wrote that her life got out of control and no one understood. She said that the words using by her classmates were too severe for her.

Marion's case came with a widespread of awareness in the fight against bullying in schools. She inspired a book and a movie, and her mom fights for raising awareness about the serious problem of bullying.

In all these cases, teenagers faced the harsh reality of bullying. All children here suffered from lack of intervention. Failure of schools, parents and students can have disastrous consequences.

What is at stake

Childhood experiences shape the children. Students who are bullied and those who bully others tend to have serious, lasting problems. School climate, pupil engagement, school safety, violence, victimization, the use of drugs and students' mental health are at risk if no solution is found. Problems in high school can turn into problems into adulthood.

U.S Secretary of Education, Anne Duncan, said that "Children cannot get a quality education if they do not first feel safe at school." 7 They need to feel safe in order to respect the law of America, which is to provide an education to each American child. So, is it correct to say that the American Education System is failing its duty to provide the education that children deserve and to ensure their safety? Does it mean that quality education is depreciated because of bullying behaviors? Her words are reinforced by the statement of Nancy Willard who says that, "If school districts are required only to respond to incidents reported by harassed students and face little to no risk of liability for their failure to exercise diligence in correcting a hostile environment that is known to be supporting ongoing acts of harassment, vulnerable children and teens will continue to suffer harms at the hands of their peers and sometimes school staff. The harms caused by this harassment are a recognized public health concern--resulting in long-lasting emotional harm and also interfering with students' right to receive an education." 8Education is then at risk if the schools' hostile environment is not under control. This risk contradicts the Constitution which requires that all children be given opportunity to an education independently of their race, ethnic background, religion, gender or sexual orientation. Many states and locals protect students against discrimination in education.

The right to an equal educational opportunity is one of the most valuable rights someone can have in the U.S, as stated by The Supreme Court in Brown vs The Board of Education of Topeka (1954), and it definitely should not be questioned. Schools need to ensure an equitable learning environment for all students.

Researches also suggest that "Childhood experiences shape the kids. Kids who are bullied and those who bully others tend to have serious, lasting problems." [START_REF] Foshee | Examining Explanations for the Link Between Bullying Perpetration and Physical Dating Violence Perpetration: Do They Vary by Bullying Victimization?[END_REF] It is proved that bullying infers that the perpetuation of violence among adolescent has an incidence on the perpetuation of violence among adult-partners. Bullies, along with their victims, may be at greater risk of abusing dating partners but for different reasons. Bullies use aggression instrumentally. 10 They show self-control problems that can last into adulthood. Whereas bully victims use aggression out of a failure to regulate their emotions. They are at higher risk because of their emotional distress (that can also be found in bullies but not at the same level). Studies show that bullying perpetration is clearly associated and predicts dating violence perpetration. 11 They also found that those who were the most violent as adult were mostly those who were the most violent at school and bullied their peers.

The increase of technologies increases the risk of children being cyberbullied.

With so much at stake, it is beyond important that parents and educators be aware of what bullying is and how it manifests itself.

Bullying affects children and can cause social rejection that leads to social pain.

It can have disastrous consequences on individuals as they socially and professionally assert themselves. Social rejection can be a threat to social ascension in life. The social rejection is based on the culture of no-compassion that takes place. Compassion is being threatened by hostilities and judgements. Everyone has grown less patient and tolerant with one another. Children learn to be less tolerant with other children. Those children are precisely more likely to bully others. People condemn others for being different and bullying has become a culture of condemnation when no one is actually free to be who they are. It appears, from my perspective, that there is a tendency to harshly judge and condemn everyone that does not follow the typical "rules" of society: marriage, children, gender normative sexuality and, social status. Everyone has an opinion and makes sure that the others feel bad from being different. People have created a society in which others 10 Schwartz D, Proctor LJ, Chien DH. The aggressive victim of bullying. In: Juvonen J, Graham S, editors. Peer harassment in school: The plight of the vulnerable and victimized. New York: The Guilford Press; 2001. pp. 147-174. 11 Miller S, Williams J, Cutbush S, Gibbs D, Clinton-Sherrod M, Jones S. Dating violence, bullying, and sexual harassment: Longitudinal profiles and transitions over time. Journal of Youth and Adolescence. 2013;42:607-618. doi: 10.1007/s10964-013-9914-8. might not feel free to be who they are and that they must pay the price for their choices they make and for not being what is expected from them to be. People are paying for their choices their make. A teenager who chooses to be proudly gay is probably going to pay for the "audacity" to be different, as though he had a choice.

The enormous damages that bullying can do is immense, but collateral damages can be worse. Everyone has a stake and can do something to guide those who are in need.

Guidance and Actions to be Taken.

In order to tackle bullying, comprehensive interventions must involve students, parents, teachers and schools' officials in order to ensure a safe and free-fear environment at school. It has to be everyone's commitment to create a safe environment where children can thrive academically and socially. The first step is to recognize and learn what bullying is, then to prevent it.

Educators can have a huge impact in the process. The American Psychological Association wrote that teachers and school administrators should "be knowledgeable and observant, involve students and parents, and set positive expectations about behavior for students and adults." 12 On the same note, The Lesley University, a private University in Cambridge, UK, wrote an article about "Six Ways Educators Can Prevent Bullying in Schools" 13 . Educators came up with six strategies to ensure a safe environment and guarantee that all students know they can come and talk to them. Children need to know they can ask for help. Here are the 6 pieces of advice they give: The program prevents bullying and tackles the cases of bullying in more effective way.

One of the specific aspects of KiVa is the monitoring of the situation thanks to online tools included in the program. It offers universal (for all students) and indicated (when bullying cases emerge) actions to address bullying cases.

Schools can help students to feel connected with everyone at school. They can teach students life skills that will socially help them. Providing a more effective training for staff is a way for teachers to provide support for young people and their families.

Encouraging and empowering youth with positive ways to improve social norms are the key to neutralize the culture of condemnation that every day they face on an every day basis.

Children who are the most at risk of bullying behaviors need specific attention.

LGBTQ youths and those perceived to have different sexual orientations are the targets 14 "Preventing Bullying Through Science, Policy, and Practice." NAP. Edu. www.nap.edu, doi:10.17226/23482. Accessed 3 Apr. 2020. 15 Ibid. of severe bullying because of their non-conformity to gender norms. It is on the duty of Schools and Community to help these children. The StopBullying website16 posted six suggestions17 to tackle bullying and create a safe school climate. According to them, they clear policies should be developed on bullying adding sexual orientation and gender identity to their bullying policies, train staff and volunteers in prevention and intervention regarding these specific young people, create safe environment by reducing stress for

LGBT youth, discuss bullying openly and raise the issue of LBGT youths: avoiding the subject of their sexuality may increase a sort of acceptance of what is happening to these teenagers, provide additional supports that LGBTQ youth may need in order to inform and support them, and the most important thing is to raise community awareness with community leaders to provide facts and develop real support groups for everyone.

Prevention has to be adopted in order to prevent suicide, violence and mental health problems from developing. With a strong guidance, all students might be able to get through bullying. They can learn safe habits that they can use throughout their life.

Fiche élève SURVEY (Annexe 2)

A rendre pour la prochaine fois, sans nom, sans signe, je ne souhaite pas savoir à qui c'est, anonyme, pliée en 4.

EE CE EOI

Adverbes de fréquence (rebrassage) Ensuite, 3 définitions seront proposées aux élèves. Le but pour les élèves sera de déterminer quelle définition correspond à quelle image.

Match the following words with the corresponding pictures.

Le deuxième document iconographique va permettre d'introduire le lexique des sentiments ainsi que de mettre en lumière les différents points de vues dans le harcèlement (bystander, bullied, bully)

Consigne : Circle the right answer for each question. Be honest. No one will know your answer.

Il serait également intéressant de s'intéresser à leur propre situation personnelle concernant le harcèlement scolaire. Ce questionnaire sera anonyme, ce qui leur permettra d'être libre de répondre sans aucun jugement de la part de leur camarade. Le questionnaire permettra également de revoir les adverbes de fréquence, et si nécessaire, de faire point de grammaire sur l'utilisation des adverbes si des lacunes sont présentes. L'objectif de ce questionnaire est de faire ressortir l'existence du harcèlement à l'école, faire un point avec eux sur ce qui est acceptable, et de voir si la majorité des élèves sont conscients du harcèlement à l'école.

• Verbal bullying

• Physical Bullying

• Social Bullying

• Psychological Bullying

• Picture 1

• Picture 2

• Picture 3

  Traditional media and social networks amplify Bullying somehow victimizing children: social networks have become a huge part of today's society. Popular culture influences bullies and their victims. A lot of bullying (like cyberbullying) happens on the social media. Children make no difference between what they see and what they do: much violence is happening online while they are too young to judge what is good and what is wrong.

  and family factors are independently associated with children's involvement in bullying". 21 "Multinomial logistic regressions showed that over and above other socioenvironmental factors and children's behavior problems, school size was associated with an increased risk for being a victim of bullying, problems with neighbors was associated with an increased risk for being a bully-victim, and family factors (e.g., child maltreatment, domestic violence) were associated with all groups of children involved in bullying."22

"

  For more than 120 years, National Parent Teacher Association (National PTA®) has worked toward bettering the lives of every child in education, health and safety. Founded in 1897 as the National Congress of Mothers by Alice McLellan Birney and Phoebe Apperson Hearst, National PTA is a powerful 29 Infra page 23. 30 Supra page 8.

  8 A school failing to respond to harassment of students might face problems with Justice, since the DE and DOJ enforce civil rights laws including Title IV and Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972 (recognized forms of sex discrimination and protect all students, including LGBTQ students, from sex-based harassment), Section, Section 504 of the Rehabilitation Act of 1973, Titles II and III of the Americans with Disabilities Act and the Individuals with Disabilities Education Act (IDEA).9

(

  or should have known) of the harassment, and (b) the school fails to take immediate and appropriate steps to remedy it." 21 19 Willard, Nancy. Deliberate Indifference to a Hostile Environment. 2007, p. 1. 20 Ibid. 21 « Sexual Harassment in Schools ». Accessed on 2 Jan. 2020. https://mainwebv.musc.edu/vawprevention/research/sexharass.shtml.

  the liability for deliberate indifference, schools should expel the harassers, engage in actions and remedy any potentially hostile environment.Only three federal cases have declared that schools were found guilty of deliberate indifference: Vance v. Spencer County Public School District (2000) 28 , Patterson v.

  -82.[START_REF] Willard | Deliberate Indifference to a Hostile Environment[END_REF] "Laws, Policies & Regulations" StopBullying.Gov. https://www.stopbullying.gov/resources/laws. Accessed 1 Apr. 2020.

	9	"Staggering	Facts	About	Bullying	In	America."	Business	Insider.

https://www.businessinsider.com/staggering-facts-about-bullying-in-america-2013-10?IR=T. Accessed 14 May. 2019.

  : The Bully and theBullied. p. 192.

	13	"Sexual	Harassment	in	Schools"	Vaw	Prevention.	https://mainweb-
	v.musc.edu/vawprevention/research/sexharass.shtml. Accessed 3 Jan. 2020.
	14 See Appendix 2.
	15 Ibid.
	16 "Body shaming." Cambridge Dictionary, https://dictionary.cambridge.org/fr/dictionnaire/anglais/body-
	shaming. Accessed 5 Jan. 2020.

  The Canadian Journal ofPsychiatry, vol. 48, no. 9, SAGE Publications Inc, Oct. 2003, pp. 583-90. SAGE Journals, doi:10.1177/070674370304800904. 4. Physical unwellness. Here, there are clear signs of physical disorder, evident in medically diagnosed illness. Psychosomatic symptoms can be included in this category." 35

Ibid.

33 "Resolution on Bullying." National PTA.

https://www.pta.org/home/advocacy/ptaspositions/Individual-PTA-Resolutions/Resolution-Against-Bullying. Accessed 2 Jan. 2020.

34

Rigby, Ken. "Consequences of Bullying in Schools."

  "Feeling guilty like it is your fault Feeling hopeless and stuck like you can't get out of the situation Feeling alone, like there is no one to help you

	Feeling like you don't fit in with the cool group
	Feeling depressed and rejected by your friends and other groups of people
	Feeling unsafe and afraid
	Feeling confused and stressed out wondering what to do and why this is
	happening to you
	Feeling ashamed that this is happening to you." 36

  "What Is Bullying? Violence, Harassment and Bullying Fact Sheet. Australian Human Rights Commission." https://www.humanrights.gov.au/our-work/commission-general/what-bullying-violenceharassment-and-bullying-fact-sheet. Accessed 16 May. 2019.

35 Ibid page 20.

36

2.2. Deliberate Indifference to Bullying Bullying

  Today, every State has either a law or a policy that applies for bullying offenses. They address bullying in different ways. Some States apply laws while others apply policies.15 Policies are only documents, they are not laws, but they can lead to new laws. Laws are standards and procedures that must be followed in society. Violation of anti-bullying policies could result in expulsion, and, suspension whereas violations of anti-bullying laws could end up with civil and judicial penalties. On 51 States, 44 States apply both laws and policies, 7 States rely on laws solely and 1 Commonwealth territory applies policies only. 16 has increased over the years 17 and is now a recognized public health problem. Yet, Nancy Willard 18 , in Deliberate Indifference to a Hostile Environment, points out the fact that in recent federal court cases such as Stiles v. Grainger County, Nancy Willard is a former attorney in Oregon, a specialist on digital safety, bullying and harassment and a bullying prevention expert. She has presented at multiple conferences as a bullying and legal expert.

		It Gets Better Project
		Kind Campaign
		Stomp Out Bullying
		Born This Way Foundation 14
	Tenn. MiLW, No. 01-91360 (6th Circuit, March 25, 2016) and S.B. v. Harford County,
	13 "Anti-Bullying Programs & Organizations." Study.Com, https://study.com/academy/popular/anti-
	bullying-programs-organizations.html. Accessed 2 Jan. 2020.
	14	Denton, Elizabeth. "Best Anti-Bullying Orgs." Seventeen, 13 Nov. 2017,
	https://www.seventeen.com/health/tips/anti-bullying-organizations.
	15 See appendix 3.

16

Ibid. 17 Supra page 4.

18

  26 "Gebser v. Lago Vista Independent School Dist., 524 U.S. 274 (1998)." Justia Law. supreme.justia.com, https://supreme.justia.com/cases/federal/us/524/274/. Accessed 1 Apr. 2020.

27

Gebser, 524 U.S. at 277.

  34 "Mass Shootings in the US Fast Facts." CNN. https://edition.cnn.com/2019/08/19/us/mass-shootingsfast-facts/index.html. Accessed 2 Jan. 2020. 35 "Mass Shootings: Definitions and Trends." Rand Corporation. https://www.rand.org/research/gunpolicy/analysis/essays/mass-shootings.html. Accessed 2 Jan. 2020.

  Dorlen, Special thanks to Rosalind, et al. "How Parents, Teachers and Kids Can Take Action to Prevent Bullying." Https://Www.Apa.Org. www.apa.org, https://www.apa.org/helpcenter/bullying. Accessed 3 Apr. 2020. 13 "Six Ways Educators Can Prevent Bullying in Schools." Lesley University. https://lesley.edu/article/6ways-educators-can-prevent-bullying-in-schools. Accessed 3 Apr. 2020. Bullying must be prevented with policies and practice. That is why numerous Anti-Bullying Programs exist. Implementing programs give schools the guidance they need to address and respond to the problem. The Olweus Bullying Prevention Program (2005) is the most studied bullying prevention program in the U.S. Its aim is to reduce bullying thanks to multiple components (schoolwide components, activities and meetings in classrooms, interventions with those identified as bully or victim, activities with parents and mental health workers). Several studies have reported declines in bullying behaviors and improvements in school climate. 14 The Positive Behavioral Interventions and Supports (PBIS) is another American prevention program which "prevent disruptive behaviors and promote positive school climate […] in order to prevent student behavior problems systematically and consistently" 15 . The KiVa Antibullying Program is a Finnish research-based anti-bullying program developed at the University of Turku in Finland.

	4. Use the arts to create context
	5. Minimize "concentric circles" in schools
	6. Participate in simulations
	1. Teach Kindness and Sympathy
	2. Create opportunities for connection
	3. Identify "gateways behaviors"

12

Document iconographique (ANNEXE 3) http://learningapps.org/watch?v=pvaeo n60t17 https://www.michellehenry.fr

  Brainstorming de la dernière séance : L'objectif pour cette séquence est également de procéder à des brainstormings sous forme de Mindmap. L'objectif est de réactiver ce qui a été fait en amont (remontrer les images, ou juste écrire certains mots au tableau) L'objectif est de sensibiliser les élèves à toutes les formes de harcèlement, et de savoir les reconnaître. La mise en commun fera alors office de trace écrite pour cette séance. Insults è "You are ugly. You look so bad. You are fat." • PHYSICAL BULLYING: to use physical action to gain power and control. è kicking, hitting, punching, slapping… • CYBERBULLYING: to hurt someone online. è Being mean on Snapchat or Instagram. è Posting images or videos, rumors, mean texts. • SOCIAL BULLYING: to embarrass or humiliate someone in Il serait attendu des élèves de repérer les différents mots inscrits sur l'image, et d'introduire quelques mots de vocabulaire. L'étape suivante sera de se concentrer sur le personnage au centre de l'image. Il sera attendu des réponses telles que : This is an article from the CBC NEWS website, written and posted/uploaded on October 9 th , 2014. It talks about an anti-bullying campaign in Canada. It was created by Caitlin Prater-Haacke who had been bullied by other students. Her mother was shocked. Caitlin decided to fight back by posting nice messages on every locker in her school.Grâce à cet exercice, les élèves s'entrainent à la voix passive : She was called a loser. She was called names. She was bullied by other people. Rumors were spread about her. She was threatened. She was sent mean messages. She was laughed at.Les élèves débutent la séance par un test de vocabulaire sous la forme d'un crossword. La correction se fait directement après le test en inter-correction. L'inter-correction fera alors office de brainstorming pour cette séance.Le texte CBC News est une compréhension écrite abordée dans le but de montrer aux élèves les bienfaits des campagnes anti-harcèlement.

	2/	Test de vocabulaire à l'aide d'un			• PSYCHOLOGICAL BULLYING
	4/	Crossword (15 min) (Annexe 6)			è Stalking someone
					è Intimidating someone
					è Make fun of someone's religion, race, sexual orientation
		CBC NEWS (ANNEXE 7)	CE	Lexique de l'opinion	Exemple de Brainstorming attendu:
			CE EE EE	Lexique de l'opinion	Bullying -> how? -physically, verbally 1. Describe the picture.
				Lexique du harcèlement	Where ? -at home, at school
					Reaction ? -sad, stressed, depressed
					Exemple de trace écrite:	• Picture 4
					VERBAL BULLYING, PHYSICAL BULLYING, SOCIAL BULLYING • Picture 5 AND CYBERBULLYING.
					public.
					è Lying, humiliation
					è Give someone a bad reputation
					è Rumors
					è Gossiping
				57

• VERBAL BULLYING: to say mean things to someone è 2. Match the following words with the right definition.

http://learningapps.org/watch?v=pvaeon60t17

3. Make hypothesizes about her feelings.

1.

Read and Underline what you understand (characters, date, place and action):

  This is an article from CBC NEWS on October 9 th , 2014. It talks about an anti-bullying campaign in Canada. It was created by Caitlin Prater-Haacke who has been bullied by other students. Her mother was shocked. Caitlin decided to fight back and posted nice messages on every locker in her school. 2.

Circle the personal pronoun. Who does it refer to? 3. Give your opinion on this initiative

  : I think this is a great idea. In my opinion, this is a good way to respond to bullying. I like the idea. I don't like the idea. Se placer du côté des « bullies » pour expliquer et mieux comprendre comment ils peuvent devenir violents et méchants.

	5/			Brainstorming des séances précédentes.
				Bullying -> how? -physically, verbally
				Where ? -at home, at school
				Reaction ? -sad, stressed, depressed
				How? -Verbal, Social, Psychological, Physical, Cyberbullying
	Bullying Serie Part 2 (Annexe 8)	CE	Voix passive	BULLYING PERPRETATOR -WORKSHEET ANNEXE 8
		EE	Nom verbal	è

"American High School System, Age, Grades, Education In USA." LearnTech IT, 1 Jan.

2020, https://learntechit.com/american-high-school-system/.

"Definition Of Bullying." National Centre Against Bullying. https://www.ncab.org.au/bullyingadvice/bullying-for-parents/definition-of-bullying/. Accessed 2 Jan. 2020.

3 "Awareness." Red Card KC, http://redcardkc.com/awareness/. Accessed 16 May

2019. 4 Affairs (ASPA), Assistant Secretary for Public. "Facts About Bullying." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/resources/

facts. 5 "Ten Years of Bullying Data: What Does It Tell Us?" News, The Guardian. https://www.theguardian.com/news/datablog/2013/may/23/10-years-bullying-data. Accessed 1

Apr. 2020. 6 "Child Helpline International." Child Helpline International. www.childhelplineinternational.org, https://www.childhelplineinternational.org/. Accessed 1 Apr. 2020.

Olsen, Steve, et al., editors. Building Capacity to Reduce Bullying: Workshop Summary. The National Academies Press,

 2 The U.S is ranked 4 th regarding the relationship between students poor scores and schools with more bullying according to Unicef. 3 Affairs (ASPA), Assistant Secretary for Public. "Facts About Bullying." StopBullying.Gov, 24 Affairs (ASPA), Assistant Secretary for Public. "Facts About Bullying." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/resources/facts. 4 Ibid.

See Appendix 1.

"Dealing With Bullying (for Teens)" Nemours KidsHealth. https://kidshealth.org/en/teens/bullies.html. Accessed 24 Mar. 2020.

Affairs (ASPA), Assistant Secretary for Public. "Facts About Bullying." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/resources/facts.

Paolini, Allison. School Shootings and Student Mental Health: Role of the School Counselor in Mitigating Violence. 2015, p. 17.

Ibid page 12.

"Gangs." Federal Bureau of Investigation, https://www.fbi.gov/investigate/violent-crime/gangs. Accessed 2 Jan. 2020.

Bowes, Lucy, et al. "School, Neighborhood, and Family Factors Are Associated With Children's Bullying Involvement: A Nationally Representative Longitudinal Study." Journal of the American Academy ofChild & Adolescent Psychiatry, vol. 48, no. 5, May 2009, pp. 545-53. ScienceDirect, doi:10.1097/CHI.0b013e31819cb017.

Ibid.

Baldry, Anna C., and David P. Farrington. "Protective Factors as Moderators of Risk Factors in Adolescence Bullying." Social Psychology ofEducation, vol. 8, no. 3, Sept. 2005, pp. 263-84. Springer Link, doi:10.1007/s11218-005-5866-5.

"Indicator 10: Bullying at School and Electronic Bullying." National Center for Education Statistics https://nces.ed.gov/programs/crimeindicators/ind_10.asp. Accessed

Mar. 2020.

Affairs (ASPA), Assistant Secretary for Public. "Who Is at Risk." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/bullying/at-risk.

Affairs (ASPA), Assistant Secretary for Public. "The Roles Kids Play in Bullying." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/bullying/roles-kids-play.

"YRBSS." Youth Risk Behavior Surveillance System. Data. Adolescent and School Health. CDC. 13 Mar. 2019, https://www.cdc.gov/healthyyouth/data/yrbs/index.htm.

Affairs (ASPA), Assistant Secretary for Public. "What You Can Do." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/resources/what-you-can-do.

Affairs (ASPA), Assistant Secretary for Public. "Effects of Bullying." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/bullying/effects.

Words from former U.S. President Barack Obama at the Conference on Bullying Prevention at the White House in Washington, March 10,

2 Kevin Jennings, the U.S. Department of Education's Safe School Czar. 3 See Appendix 3. 4 « Bullying Prevention." California State PTA. Accessed 2 Jan. 2020. https://capta.org/focusareas/community-concerns/bullying-prevention/. 5 Affairs (ASPA), Assistant Secretary for Public. "Federal Laws." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/resources/laws/federal.

Bull, Brittany. « Title IX Regulation Fact Sheet », s. d., 1.

Ibid.

The purpose of this proposed Title IX Regulation Fact Sheet is to increase control for complainants in case of bullying. Its purpose is to ensure that complainants, and respondents, understand their options and rights and that schools will be able to honor complainant's wishes about how they want to respond to the situation (supportive measures) It is supposed to encourage students to turn to their school for help.

Affairs (ASPA), Assistant Secretary for Public. "Federal Laws." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/resources/laws/federal.

"Stopping School Bullying." www.justice.gov,

May 2018. https://www.justice.gov/usao-sc/civilrights/stopping-school-bullying.

"Resolution on Bullying." National PTA.https://www.pta.org/home/advocacy/ptaspositions/Individual-PTA-Resolutions/Resolution-Against-Bullying. Accessed 2 Jan. 2020.

"VANCE v. SPENCER COUNTY P | 231 F.3d 253 (2000) | 1f3d2531458 | Leagle.Com." Leagle. www.leagle.com, https://www.leagle.com/decision/2000484231f3d2531458. Accessed 2 Apr. 2020.

University,© Stanford, et al. "Mass Shootings in America." Stanford Libraries, https://library.stanford.edu/projects/mass-shootings-america. Accessed 2 Jan. 2020.37 The Second Amendment of the United States Constitution reads: "A well-regulated Militia, being necessary to the security of a free State, the right of the people to keep and bear Arms, shall not be infringed."

Words from former U.S. President Barack Obama at the Conference on Bullying Prevention at the White House in Washington, March 10,

DS's case in 2016 revolves around these school officials' alleged failure to recognize and reasonably respond to a pattern of bullying incidents he suffered while attending Rutledge Middle School. They sued the school for alleging violation of Title IX of the Education Amendments of 1972 and deprivation of DS's constitutional rights to equal protection and substantive due process.

"FindLaw's United States Sixth Circuit Case and Opinions." Findlaw. caselaw.findlaw.com, https://caselaw.findlaw.com/us-6th-circuit/1730197.html. Accessed 2 Apr. 2020.

The website is federal government website managed by the U.S department of Health and Human Services.

Affairs (ASPA), Assistant Secretary for Public. "LGBTQ Youth." StopBullying.Gov, 24 Sept. 2019. www.stopbullying.gov, https://www.stopbullying.gov/bullying/lgbtq.

ACKNOWLEDGMENTS

CONCLUSION

Bullying is a serious health problem that dramatically affects the life of many students. It affects students' ability to have access to an enriching and safe education.

Victimization is a factor that deteriorates the health and the well-being of those who find themselves in such a position. It increases the risk of damaging their academic and social evolution. Bullying has become a problem that we can no longer leave aside. It can cause self-esteem issues and lead to depression. It is not a rite of passage. It does not only concern one typical profile. All children can be at risk, LGBTQ and people of color even more.

The culture of difference that has taken place over the last decades on discrimination and assault deserves to be understand. It is important to grasp that being indifferent means acknowledging harassment. The reason I chose to tackle the indifference is not about declaring who is liable for someone's misconduct. The first person guilty is the person who harasses. But we are all liable for what is happening to students. The concern is that unless the federal government, schools' officials, educators, parents and students really do something, bullying will keep perpetrating and harm millions of students around the world, resulting in long lasting emotional problems.

Sometimes the problem is reported to teachers, but they are unable to help. Bullying can be the cause of many problems at school. Providing examples of bullying cases has personally broadened my understanding and helped me to represent in a more realistic way what bullying can cause. The facts are not numbers anymore, but for each number there are students who feel desperate and who lose control on their emotions. To stop bullying, we need to understand its origin and the way it is developing. We need to understand these children who were bullied and who thought they were alone experiencing it.

Bullying represents the situation of numerous students worldwide. The culture of condemnation that we face every day, not only in schools, needs to stop. Schools' staff can help by establishing a set of rules and policies that will help students to know how they should treat and respect others. Many schools are not aware of the assistance programs they can use as help, and many know of them but do not use them.

Helping students from the beginning can make a huge difference for their life. As we saw, bullying also indicates tendencies to intimidate others later in life. Stopping bullying is not only stopping children from being deprived of their education's rights. It's about giving them all the tools they need to be able to properly build their own life as responsible adults.

Schools have substantial control over the context in which the harassment occurs. There is a duty to ensure safety, health and an effective learning environment. Prevention has to be made. Increasing awareness about bullying, what we should do, what we should not is the right and most helpful answer to prevent any student of being harmed or to harm others. It is important to make sure bullying will not represent their future.

Appendix 1

Bullying Statistics in the USA. Malini Saba. 6 Oct. 2018.

CO EOI Anticiper un thème à partir d'une image Émission d'hypothèses

There is/There are L'objectif pour cette première séance est de dégager le thème général, d'introduire le vocabulaire de l'opinion ainsi que des sentiments.

L'ouverture sur la séquence se fera à l'aide d'images qui joueront le rôle d'anticipation. Le but pour eux est de décrire un thème, et me permettra de prendre connaissance de leur vocabulaire, et les connaissances qu'ils possèdent. Des documents iconographiques en tant que rituels d'entrée sont à mon sens, un bon moyen pour les élèves de prendre la parole, de revoir le vocabulaire de description sur une base régulière et d'ainsi faire à chaque séance une piqure de rappel.

Pour introduire le thème de la séquence, l'idée est tout simplement de projeter une image au tableau. La consigne serait alors :

1. Observe and React.

Describe the five pictures.

Les images qui entourent BULLYING peuvent permettre aux élèves d'inférer le sens du mot, s'il leur est inconnu. La numération des imas permettra aux élèves de mieux s'y retrouver et de savoir de quelle image untel est en train de parler. Il est attendu des réponses telles que:

This is a poster with 5 pictures of children in different situations. The word

Bullying is written in bold capital letters encircled in a STOP sign. There is written "Don't be a bully, be a friend"

On picture 1 at the top left, there is a big boy harassing a younger one because he's holding him by the collar. Picture 2: There is a girl throwing a ball at a boy. The boy looks sad. Picture 3: A bigger child is taunting or mocking a younger one. Picture 4: There are three girls deliberately excluding/ignoring another one because they are laughing at her. She looks lonely and left out. Picture 5: There are two big boys harassing a younger one. One of the big boys is going to punch him on the face. L'activité pourrait se dérouler en salle multimédia, afin que les élèves regardent la vidéo à leur rythme. L'objectif est qu'ils arrivent à remplir entièrement le tableau pour la fin de la séance. Au cours de la mise en commun, nous aurons constitué un corpus pour que les élèves se rendent compte de la voix passive. Je leur préciserais que la passivation est synonyme de victimisation. Les sujets ici subissent l'action.

Les élèves sont prévenus d'un test de vocabulaire en début de prochaine séance. Ils devront dire pourquoi il est important de parler du harcèlement scolaire, les enjeux, ce qu'il peut être mis en place pour protéger les élèves, et prendre conscience des dangers.

6/

Les élèves seront ainsi évalués sur leur niveau de langue, sur la prononciation des mots qui aura été vu tout au long de la séquence, sur la qualité́ de leur poster, ainsi que sur la précision et les détails des commentaires qu'ils vont apporter. Le barème est un moyen pour eux de savoir sur quoi je les évaluerai.

La note sera en deux parties. Une partie évaluer par les élèves eux-mêmes (/10). Les 10 autres points par moi-même.