Pushout: The Criminalization of Black Girls in Schools

by Monique W. Morris

Jennifer was a “runner,” which meant that she often ran away from her foster care placements and other locations that she considered threatening. When asked why she was running, she just shrugged and replied that she “didn’t like it.” On the surface, that might look like she was running away out of defiance, but experience had taught me better. For years, I had heard justice system workers describe the conditions that led girls to run from their court-assigned residential placements in detention centers, group homes, shelters, or private homes.* Sometimes these girls were described as “incorrigible,” “manipulative,” or simply drug-addicted, without explanation. Anecdotes from Black girls revealed a different perspective. They had run away from these places because of experiences like being forced to wash their hair every day and/or use hair products that were not designed for Black girls’ natural hair texture. While these conditions may seem minor, especially if brought up in legal proceedings, to the Black girls who told these stories they were “deal breakers,” not only because these hygienic mandates were inconsistent with cultural norms for Black hair care (and certainly off-limits for girls who wore protective hairstyles like braids or artificial hair) but also, and mostly, because it was a trigger for them—a signal that they were not truly welcomed in these alternative living spaces. Some girls ran away from their placement after being triggered by the actions of othe...

“Why’d you run from your foster home?” I asked Jennifer. “Because, like, they wasn’t treating me right . . . I had a foster dad and . . . he knew I was a prostitute . . . and he was like, if he was a pimp, he’d recruit me. If he was a john, he would date me . . . and I don’t know . . . they just didn’t treat me right.”

“No,” she said. “I got into prostitution because the guy that raped me, he forced me on the track. Basically, I didn’t go willingly at first, but ever since he did that to me, my whole life just changed, and that was at twelve years old. Ever since then, my life’s been off-track.” She spoke the words with such direct honesty that I suspected she had told this story before. Her youth was obscured by a very painful and complicated past. Her large wide eyes continued to squint as she discussed her struggle to learn and to acquire skills that could help her earn a living without having sex. “Has anyone worked with you to try to help you get what you need to get back in school or talked to you about how you can make the transition off of the street?” I asked. “No. Nobody really helped me. Honestly, it took me about four years to get back on track. I’m just now getting back on track. So all this stuff I go through, I go through myself. I encourage myself.”

Jennifer sighed as she retold her story of personal pain and struggle for redemption. The persistence of her frown when she spoke was a subtle cue that she did not like what she was saying or that she was at least aware of how it might sound to someone meeting her for the first time. I held no judgment against her, and I let her know that. The safety of our space mattered, and I really wanted to better understand how her story might inform ways to rebuild a path from confinement to school for her and for other girls in similar situations.

“Was there anything about that that kept you out of school, though?” “Yeah . . . money. It’s just great. When I hustle, I ho by myself. Like, it’s . . . better. Like, you know some of these young girls when they hustle, they hustle with they friends or hang out with their friends. Like, I don’t know. I felt like a businesswoman. You know?” When Jennifer detached from the man who raped her, she began working for herself. She needed money not only for herself but also for her child, who was a toddler when I met Jennifer. In fact, she credited pregnancy as her best educational experience.

Parenting teens often face tremendous obstacles to completing a high school education, but more often than not, girls interpret their parental responsibilities as an incentive to perform better. While these girls are plagued by social narratives that warn of an end to their lives if they have a child as a teenager, they also understand their heightened responsibility and make great attempts to rise to the occasion. Notwithstanding their resilient attitudes, earning a diploma can be a difficult process for girls who have become pregnant during their high school years, particularly given the hurdles associated with it. Some schools unlawfully bar pregnant girls from attending school or discriminate against them in other ways, including penalizing their success or ridiculing them.7 When girls are able to attend school, they often face the additional hurdle of finding child care or recuperating credits that were missed.

Contact with the criminal legal system might be the first time a girl has access to medical screening. For some, this experience may reveal a host of health conditions that affect their ability to return to school, including pregnancy. However, being in juvenile hall or other forms of detention is about more than gaining access to health care. Just as there are relationships that make girls vulnerable to contact with the criminal legal system, there are also a number of relationships within the justice system that keep girls from reconnecting with school and performing well when they are there.

Public education remains one of the nation’s most ripe environments for inequality.

The structure of the learning environment made it difficult to develop innovative approaches for girls in trouble with the law, many of whom are also being trafficked. Indeed, though many of the girls in his school had a history of sex trafficking, he felt that there was little he could do to intervene. He did, however, feel that the school could be an important partner. According to Jennifer, a special education student who was never able to fully develop her relationship with school, educators and other key stakeholders have to take a more proactive role in explaining to girls why education is so important to their development.

In a separate conversation, Diamond agreed. When I asked her what might keep her in school, she replied, “Like, probably, more attention. More attention and providing of what I ask. Like, if I ask that I need something, it’s not that I’m trying to annoy you. I’m trying to ask you for things that I really actually need.” “When you think about the other needs you have in your life,” I said, “how can the school help you so that you don’t have to do anything illegal to get it? What do you need to stay focused in school and doing what you’ve got to do?” “I don’t know about the other girls that’s in the sex industry, but for me, like, I like to talk about it and get it out of my system. . . . I don’t know, cry about it and stuff. I think that would help me better because, I don’t know, I like to share.” Narrative is a powerful tool for learning and for rehabilitation. In Diamond’s response and in Jennifer’s call for a space that would allow her to talk through the importance of education were requests to rebuild a relationship—not just with individuals but with school as an institution.

We talked about the potential for school-to-career programs that might help her understand the connections between her education and work. Like Jennifer, she felt making this connection was necessary, and particularly appealing to girls who have been trafficked. “I think that would help. . . . I can’t speak for nobody else. But like, I think that would help because, for some reason, for some kids, coming [to juvenile hall] won’t help them . . . I probably need counseling. Like, I’m trying to get stronger, but my boyfriend . . . he’s like, I don’t know . . . it takes a while . . . I think I’m processing faster since I been here. I should have never done that. I’m not making that mistake again. That person wasn’t right for me. I’m not taking that chance again. It’s going to hurt me in the long run. It’s not hurting him. He’s free right now . . . while I’m sitting here locked up twenty-four hours.” Then, Diamond started to cry as she came to terms with having been abandoned by a man she depended on to care for her—a man who sold her body and who did not come to visit her while she was in detention.

Regularly available counselors and therapists in school are critical to providing the type of emotional support that formerly trafficked girls need to heal from the pain and trauma that they have experienced. Otherwise, schools risk becoming a location where girls continue to experience harm.

For many of the girls on the margins, their parents are also suffering from debilitating conditions of poverty, addiction, and their own tumultuous relationships with people and with schools. Diamond was calling for a different reality, at least when she walks into school. In other words, for girls who have a history of sexual exploitation and abuse, school cannot ignore them or what they experience outside school walls. Even though institutions are prone to reinforcing or replicating the norms of society, Diamond’s path reveals why schools should actively work to generate a different culture, one that doesn’t prioritize high performers over everyone else. Our public schools—especially for these girls—need to be a place of stability and consistency, a place where new norms can emerge. For too many kids, school is the only place they can learn how not to play the circumscribed role the rest of the world casts them in.

Girls of all backgrounds are up against the sexist and dismissive notions that they are choosing a life of prostitution rather than being trafficked into it, though this characterization is significantly more common when it comes to Black girls.

The myth of the “bad” Black woman is rooted in the historical assumption that Black women possess an elevated level of sexuality beyond other women, that they are eager for sexual exploits, or that they are “loose in their morals.” Therefore they are perceived, as they have been historically, as deserving “none of the considerations and respect granted to White women.”9 The sexual terrorism to which Black women were subjected as enslaved women was justified by casting them as immoral and sexually insatiable.

“There is a feeling of unrest, insecurity, almost panic among the best class of negroes in the South. . . . A colored woman, however respectable, is lower than the white prostitute. . . . We are neither ‘ladies’ nor ‘gents,’ but ‘colored.’”

In an article published by The Independent in 1904, Williams wrote the following: I think it but just to say that we must look to American slavery as the source of every imperfection that mars the character of the colored American. It ought not to be necessary to remind a Southern woman that less than 50 years ago the ill-starred mothers of this ransomed race were not allowed to be modest . . . and there was no living man to whom they could cry for protection against the men who not only owned them, body and soul, but also the souls of their husbands, their brothers, and alas, their sons. Slavery made her the only woman in America for whom virtue was not an ornament and a necessity.

Such long-held, deeply ingrained stereotypes have had a lasting imprint on society’s understanding of Black feminine sexuality.

We see her not only in the presentation of hypersexualized “vixens” in hip-hop videos but also in social discourses that produce public policy responses to child welfare, health, and criminalization or incarceration.

The regulation of this so-called decency often happens through dress codes and other comments and behaviors that sexualize Black girls in schools. But it is most apparent in school responses to girls who have been sexually exploited. Teen girls who wear tight or revealing clothing, who are parenting, who are “slut-shamed” and bullied, who express gender along a continuum, and/or who are sexually assaulted are all living under the cloak of jezebel.

School-to-prison pipeline or school pushouts . . . all these things are real and sex work has a big part to play in it.

In my conversations with other young women who were involved in sex work, many did not identify as “sexually exploited” or “sex-trafficked” girls, nor did they believe themselves to be “prostitutes.” Like Diamond, they might say instead that they have an older “boyfriend” (rather than a pimp) or “bust dates” to indicate a casual participation in the sex trade without fully committing to the idea that they were or are selling sex. These girls are vulnerable—very vulnerable—because they are often clawing their way out of some intense situations, without the supports of advocates or trained professionals who know how to respond to the needs of sexually exploited children.

These girls, who are often in foster care or come from unstable homes, become invisible in efforts to dismantle school-to-confinement pathways.

With little understanding of how they’re being pulled out, we call them dropouts. We—educators, neighbors, and other community members—fail to include their stories and experiences in our understanding of how and why girls may not be attending schoo...

Child exploitation isn’t free, and the girls who survive these experiences pay the highest price. Despite U.S. law that requires courts to order convicted traffickers to pay trafficking victims lost wages, they are much less likely than those who are labor-exploited to receive a monetary award for their suffering.13 This payment, which rarely if ever comes, could never compensate for the deep damage and losses that have little do with finances.

Black girls have been our forgotten daughters in responses to the global convergence of racial and gender inequality. Black girls are fully human—they are more than “hos” or a “thing” to break and/or take.15 For many girls, unwanted sexual attention in their early years sometimes leads to premature sexual behaviors. When a little girl who has been sexually assaulted is told and taught through children’s rhymes passed through generations to “shake it to the East, shake it to the West, shake it to the one that she loves the best” and is routinely singing lyrics from songs that objectify Black girls’ and women’s bodies, her spirit is further fed with ideas that affect her understanding of relationships and her perception of herself. For many girls who have survived sexual victimization, these revelations may not come right away in part because of the ways their social world reinforces the idea that they are their sexuality—rather than the idea that they own and control their sexuality. Their personal acknowledgment of their true potential is further obscured when sexual victimization goes unchallenged, or worse, is embedded in schools.

Wearing short shorts on a hot day almost got Deja sent home. The fear, as suggested by the principal’s comment, was that Deja’s shorts might elicit inappropriate touching and behavior among the boys. Instead of focusing on developing a climate in which boys are taught not to touch girls’ bodies, girls are sent home to change their clothes.

“This is based off of media and how it portrays us as Black young females,” Carla said. “If you see a [Black] girl in a movie even, if you see a girl wearing short shorts, and you see a guy, you automatically know they’re going to hook up. If you see a White girl wearing short shorts, you automatically know she’s going to the beach or something. . . . They have no reason to do it school-wise. You don’t know everybody’s story, everybody’s reason for what they have on.” In the public imagination, assumptions about the sexuality of Black people make clothing style a socially accepted (though unsound) predictor of behavior.

Shamika’s critique of media’s representation of Black girls bodies was impressive. Why do they put big Black girls in videos? Good question. The fixation with Black women’s bodies, which have been increasingly used as ornaments for rappers and petite pop singers alike, has become the latest commercial iteration of objectifying Black women’s bodies. Videos tell a story. They also reflect fantasy, which most often reduces Black femininity to the size of her backside—and how fast or forcefully she can make it gyrate. We continued to talk about this objectification in the context of schools’ reactions to Black girls’ bodies, especially their feeling that no matter their size or age they were vulnerable to a particular type of sexualization that rendered Black girls as objects of desire, even without their permission. These girls felt that Black girls were constantly sexualized. This is a profound concept that bears repeating: No matter what a Black girl does, no matter her age, and no matter how small or big she is, a man is going to always look at her sexually. If that doesn’t make you want to holler . . . This issue is anything but new.

But I pressed her a bit to get a more complete sense of how she sees herself. “Do you like that people call you Big Booty Mika at school?” “It depends on the person,” she admitted, looking down at the table in front of us. “I’m so serious. If it’s a girl, then it’s like, she’s just being funny . . . but if it’s like an athlete or a whole football team, like [the] captain of the football team being like ‘Big Booty Mika,’ It’s like, ‘No . . . my name is Shamika . . . just move on.’” “So what makes the difference for you?” I asked. “The difference is the point of respect,” she said. “The football player probably don’t even like me like that. He just sees a big butt. The other people, like, know me inside, but they just want to play around. Like, the football player, he only sees my butt, he doesn’t see my personality.” Shamika described a continuous, incessant state of sexual harassment. She was coping, but the adults in her life owe her a safer environment than that—at school and elsewhere.

“No, they don’t,” she confirmed. “No, and some of them, I tell my age . . . I be like, ‘[I’m] fifteen!’ And they be like, ‘You lying. You look like you’re at least seventeen or eighteen.’ . . . I’m like, ‘I can show you my [high school] ID right now!’” Shamika was fifteen years old at the time of our discussion, and she had just described a snapshot from her life under a constant barrage of sexual harassment. Every day, even after she disclosed her age. Every day. This is the cloud of abuse and harassment under which many girls who look like Shamika live. This is the climate in which girls are trying to negotiate their safety and discover their identity as students.

“I feel like sometimes they don’t care,” said Charisma. “This guy was twenty-four with kids . . . So then, I was looking at him like, ‘Sir, how old are you?’ He was like twenty-four. I asked him, ‘How old do I look?’ He was like, ‘Nineteen or twenty.’ . . . But in the back of my head, I was like, ‘I do not look that age.’ . . . So then I was like, ‘I’m seventeen.’ He was like, ‘We still can’t talk?’ . . . No!” Whether in the community or at school, age compression (discussed in Chapter 1) is a phenomenon that is often thrust upon Black girls. However, these girls are girls, not fully developed women in younger bodies. They are adolescents, and like most in their age group, they may test boundaries—particularly with respect to clothing—that are established by those with authority or by institutional rules. Yet they have seen that doing this, the normal stuff of teenagers, can make them targets for exclusionary discipline or additional surveillance.

From the pullout of girls who are being trafficked to the oppressive school dress codes that irrationally institutionalize adult panic over the morals of girls both cis- and transgender, we see how Black girls continue to live with the burden of underprotection, where a girl’s virtue certainly is “not an ornament and a necessity.”

More than 70 percent of girls in juvenile detention facilities have a history of trauma, and at least 60 percent have experienced rape or the threat of rape—a number that reflects reported incidents and is likely an underestimation.7 Other studies show that up to 90 percent of girls in detention have experienced some form of sexual, emotional, or physical abuse.8 We cannot ignore the very real impact of trauma.

Black girls in trouble with the law have a long history of being assigned to institutions that fail to adequately respond to their marginalization from school. The institution of slavery constructed a social and penal environment that reinforced the idea of Black female inferiority, and this setting primarily allowed for the development of a girl’s domestic skills rather than the development of her intellect. This focus has maintained its imprint on the quality of education that girls receive in confinement—girls who are disproportionately Black.

Since the eighteenth century, girls who were in trouble with the law, even as part of the enslaved population, were confined in semi-penal institutions: asylums, jails, reformatories, and other homes. Between 1825 and 1828, the United States opened its first juvenile reformatories in New York, Boston, and Philadelphia, for the purpose of providing “food, shelter and education to the homeless and destitute youth and to remove juvenile offenders from the prison company of adult convicts.”9 Children in these facilities participated in activities that were deemed appropriate for their moral rehabilitation at the time, meaning many children were assigned domestic chores, and some even attended school four hours each day.10 However, because Black children, including Black girls, were not deemed suitable for such facilities, their alternative reality often involved mob lynchings or placement into punitive adult correctional facilities. It was not until 1835, following an intense, racially charged debate between reformists and racial justice advocates about the rehabilitative promise of troubled Black youth, that the New York House of Refuge, in Hudson, became the first juvenile reformatory to accept Black children. However, in these early days, the blueprint for “reform,” as reflected in the practice of reformatories across the nation, included plans to prepare Black girls for lives as “cooks, maids, and seamstresses,” and to provide them with religious (Christian) instruction, w...

Little has changed over a hundred years later. Girls dismissed as “delinquents” struggled to be included in discourses on correctional education and its role in returning them to their home communities and rebuilding their lives. Black girls were denied opportunity or granted only a limited form of access to private institutions that were designed to “reform” children. But once Black girls were accepted into these institutions, access to services remained unequal. Black girls tended to stay in juvenile justice facilities longer, and experience fewer positive outcomes, than their White counterparts.

This is a trend that was exacerbated by formal segregation throughout the Jim Crow era. Classrooms in correctional facilities mirrored the intense segregation of school classrooms in surrounding communities—a trend that continues to this day.

For Black girls who were placed into public reformatories, the rehabilitative emphasis was not on making them more productive students, but rather on forming them into better servants for social elites. This was largely in response to the prevailing early twentieth-century practice of institutionalizing Black girls f...

As Khalil Muhammad notes in The Condemnation of Blackness, “Black women’s perceived moral shortcomings or racial ‘defects’ disqualified them from the protective status of the law . . . the problem was ‘located in Black women themselves.’”17 Never mind that many Black women, including educators and political activists such as Fannie Barrier Williams, Nannie Helen Burroughs, and Mary McLeod Bethune, were calling for an elevation of Black girls’ dignity not through the policing of their sexuality (and incarceration) but rather through the implementation of equal rights and economic or educational opportunity. To say these women were facing an uphill battle understates the case.

In 1933, there were 1,803 Black girls whose delinquency cases were disposed in sixty-seven courts and eight Black girls whose cases were “handled by federal authorities.”21 However, these girls were still expected to rehabilitate in separate and inferior environments that failed to support their educational development. For example, in 1936, at the New York Training School for Girls in Hudson, New York, Black girls—who were 19 percent of the girls in the facility at the time—were segregated from White female residents and forced to reside in two of the most “crowded and dilapidated of the reformatory’s ‘cottages.’”22 Jazz legend Ella Fitzgerald was once assigned to this facility for being an “ungovernable” teen.23 Here she was quarantined, tortured, and excluded from participating in the choir, as it was reserved for White girls only.

Essentially, the criminal legal system never developed clear educational pathways to success for Black girls in confinement—and this has now come back to threaten the legitimacy of a juvenile justice system that is supposed to prevent future involvement with the criminal legal system. Black girls are confronted with the usual hurdles to educational success in a correctional setting: the highly punitive nature of the facility and trouble reconciling school credits. Yet their Black girl identities subject them to a brand of systemic discipline and victimization that mirrors, and in some cases surpasses, the mundane and everyday ways that the full humanity and potential of Black girls is confined.

The racial disparities described here are a function of multiple factors: socioeconomic (unemployment, poverty), educational (poor performance, truancy), juvenile justice (differential handling, lack of gender-responsive treatment and alternatives to detention), and family and community (an incarcerated parent, living in high-crime areas), among others.

Black girls experienced assignment to residential placement at a rate of 123 per 100,000 youth, one of the highest in the nation. This racial isolation, coupled with an increase in the number of girls being placed into these facilities, has had a tremendous impact on the development of an effective, culturally competent learning continuum for these girls—and the way they enhance their own self-esteem and academic performance.

“What has gotten you kicked out of class in here?” I asked. “One time I was in class . . . I was telling her that I was done, because I get done with my work fast if I know how to do it. So I was like, I’m done. She was like, ‘Okay, you’re always done before the class, what does that mean?’ So, I’m like, ‘Well, I have an hour to go before I go back to the unit.’ So I’m telling her like, ‘What, you want me to just sit here for an hour?’ She was like, ‘Yes, put your head down.’ So I’m just like, ‘All right.’ So I just sit there, you know, like . . . then I’m like, ‘Can I write or draw? Something? I mean, it’s a whole hour to go.’ She was like, ‘No, you can’t do anything. You’re always getting done before the whole class. You know what, get out. Give me your pencil and get out.’ I’m like, ‘Because I do my work, I’m actually trying to do my work now, and now you want me to get out?’ Hella shit. She blame hella shit on us, like . . . some of the class is badder than the others. So like, some of the class will take off the erasers and throw it at her, and the whole class gets in trouble because of it. ‘Oh, I’m going to let your staff know that you guys have been taking off the erasers, and whoop-tee-whoop.’ She act like we want to steal a fucking eraser. What’s an eraser?” When girls were “kicked out” of class, they were relegated to sitting out in the hallway until they were invited back to the classroom or the class period was over. “And sometimes she gives us suspension for t...

Teachers in juvenile hall face the tall order of managing girls with significant histories of school absence and failure, which are compounded by their histories of trauma and abuse. I have never met a teacher who actually “didn’t care” about the education of girls in juvenile hall, but many teachers that I have encountered over the years have admitted to feeling overwhelmed and often emotionally unprepared or insufficiently trained to deal with the myriad issues that prevent them from forming meaningful relationships—even if temporary—with the girls they educate in juvenile hall.

I asked a school district official about the credit alignment process and how to facilitate a more seamless process for children in detention. I was specifically interested in how system leaders might better respond to the nature of educating youth in detention—the short stays versus the long stays, reconciling the student’s ability versus the design of the curriculum, and other considerations. Other professionals in the department had observed the problem and devised unofficial strategies, such as using smaller increments for the credit accrual process that prevent youth from losing credits if they stayed less than a week in custody. I offered these suggestions and other ideas to engage school board members in a conversation on this topic. After listening to me talk for several moments, the administrator smugly looked at me and said, “If you can figure that out, then you’ll get a major award.” I’m certain he meant it as a joke, but credit recovery is a serious concern for girls who have a history of particularly contentious relationships with school. The uncertainty with which a number of the young women I spoke to approached the topic of credit accrual and recovery left little question that the inconsistent manner for earning and tracking student credits undermines their trust in the juvenile court educational system.

In my experience, children in carceral settings will create family structures in order to normalize what can be an otherwise dehumanizing experience.

When teachers are not aware of these relationships, or when they respond to them with discipline, they undermine these relationships and instead perpetrate a hyperpunitive learning environment. A more productive and effective approach might be to facilitate collaborative learning spaces where girls are encouraged to explore their relationships with each other along with why they reenact “arguments” as a way to demonstrate familial bonds. Like Black girls who are high achievers, many of those in trouble with the law understand the value of a quality education, even if it has never been offered to them. In my conversations with detained Black girls, they understood that education was an important part of their time in juvenile hall. However, most did not consider their juvenile court school to be a model learning environment. In general, they agreed with youth nationwide who view the quality of correctional education as “poor,” inadequate by state standards.

For girls who live in poverty and who have a history of contact with the criminal legal system, schools reproduce dominant ideas of power and privilege in ways that push them away from school and toward other environments that increase their risk of confinement. Historically, this vulnerability is further increased when teachers, administrators, and institutional policies project low expectations onto Black girls who have been labeled as delinquent.