Students for Fair Admissions, Inc. v. President and Fellows of Harvard College et al

Filing 455

MOTION for Leave to File to Participate as Amici Curiae by Harvard-Radcliffe Black Students Association, Kuumba Singers of Harvard College, Fuerza Latina of Harvard, Native Americans At Harvard College, Harvard-Radcliffe Asian American Association, Harvard-Radcliffe Asian American Women's Association, Harvard Asian American Brotherhood, Harvard Vietnamese Association, Harvard-Radcliffe Chinese Students Association, Harvard Korean Association, Harvard Japan Society, Harvard South Asian Association, Harvard Islamic Society, Task Force on Asian and Pacific American Studies at Harvard College, Harvard Phillips Brooks House Association, Harvard Minority Association of Pre-Medical Students, Coalition for a Diverse Harvard, First Generation Harvard Alumni, Native American Alumni of Harvard University, Harvard University Muslim Alumni, Harvard Latino Alumni Alliance. (Attachments: # 1 Exhibit Amicus Brief by Harvard Student and Alumni Organizations in Support of Defendants' Motion for Summary Judgment, # 2 Exhibit Declaration, # 3 Exhibit Declaration, # 4 Exhibit Declaration, # 5 Exhibit Declaration, # 6 Exhibit Declaration, # 7 Exhibit Declaration, # 8 Exhibit Declaration, # 9 Exhibit Declaration, # 10 Exhibit Declaration, # 11 Exhibit Declaration, # 12 Exhibit Declaration, # 13 Exhibit Declaration, # 14 Exhibit Declaration, # 15 Exhibit Declaration, # 16 Exhibit Declaration, # 17 Exhibit Declaration)(Thayer, Kenneth)

EXHIBIT 3

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
BOSTON DIVISION

STUDENTS FOR FAIR ADMISSIONS, INC,
Plaintiff,
v.
PRESIDENT AND FELLOWS OF
HARVARD COLLEGE (HARVARD
CORPORATION),

Civil Action No. 1:14-cv-14176-ADB

Defendant.

DECLARATION OF CECILIA NUÑEZ
(FUERZA LATINA)
Cecilia Nuñez, pursuant to 28 U.S.C. Section 1746, declares the following:
1.

My name is Cecilia Nuñez, and I am over 18 years of age and fully competent to

make this Declaration.
2.

I am the Vice-President of Fuerza Latina at Harvard.

3.

Fuerza Latina is Harvard’s undergraduate, pan-Latinx organization that seeks to

expose the diversity of Latinx culture at Harvard and create a support system for Latinxs in their
academic and extracurricular pursuits. We organize and co-sponsor events that promote the Latinx
student’s experience on campus. Through this strong community, we hope to enhance the
experience of both Latinxs and other students at Harvard.
4.

Fuerza Latina was originally founded in 1993 as Fuerza Quisqueyana. The club was

created by ten Dominican undergraduates who envisioned a group that would specifically address
Dominican issues and concerns. At the time, Harvard College had several Latinx groups, including

RAZA, Causa, and a Puerto Rican group called “La O,” but nothing dedicated to Dominican issues
and cultural sharing. As an organization, Fuerza Quisqueyana brought speakers to campus,
engaged in community service in Brighton (an area that housed a large Dominican community),
and founded the now annual tradition of Quisque Jam, a party that features salsa, merengue, and
hip-hop—music that was not heard at Harvard’s parties at that time.
5.

By 1998, the membership of Fuerza was no longer mostly Dominican, as a larger

Latinx community grew on campus. After the board and members began a dialogue on whether
the group’s name should better reflect its membership, the name was changed to Fuerza Latina by
a majority vote. The focus of the organization, however, remained unchanged because, by that
time, Fuerza had taken up a much broader Latinx agenda. Today, Fuerza Latina is Harvard’s PanLatinx umbrella organization and boasts members from numerous Latin American countries, as
well as non-Latinx members who share our interest in Latinx and Latin American culture.
6.

Every Monday, Fuerza Latina hosts a dinner of some type to give people a more

casual space to make connections, network, and socialize with other people on campus—
essentially, students talk through their week with people who understand more of what they are
going through. We have a general meeting every week and a board meeting every week. These
meetings and events require a lot of planning and coordination with leaders of other cultural
organizations on campus. Fuerza Latina also has overnight retreats—sometimes to speak to the
Harvard administration about issues of concern to our members and improvements we want to see
on campus.
7.

In addition, Fuerza Latina offers a mix of social, political, and identity-based

programming and discussions on issues pertinent to the Latinx community at Harvard and in the
larger United States. We have sponsored debates and discussions about issues like immigration or

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issues of Latinx representation in the United States. Especially in the current political climate, we
feel a need to create a space for Harvard Latinx students to discuss issues that are affecting them.
We also sponsor a lot of political actions on campus on issues such as affirmative action and
policing of Latinx communities in Boston.
8.

Fuerza Latina and other cultural organizations do a lot to provide academic support

to students who do not come from a college preparatory background. We create databases of study
guides, organize forums for people to talk about issues that they may be having in classes or
generally on campus, and create spaces for people to get advice and receive tutoring from each
other.
9.

As an organization, we also have had to address insensitive incidents that affect

Latinx students. For example, as part of a political protest, one of the clubs on Harvard’s campus
slipped fake deportation notices under doors to try to raise awareness of immigration issues, not
realizing that we have people in our community who are undocumented. That incident was very
scary for some of our members, and they relied on Fuerza Latina for help. Because Fuerza Latina
has such a strong presence, we were able to very quickly communicate to all of our members
explaining that these notices were fake and to alleviate many people’s worries. But if Fuerza
Latina’s membership was reduced, it may not have been as successful at organizing to quickly
notify the Latinx community that the deportation notices were fake, resulting in some individuals
wasting time worrying about whether they or their roommate were actually being deported.
10.

There have also been incidents where people don’t respect the Latinx presence on

campus and it helps to have a support system to respond collectively. For example, on Mexican
Independence Day, a lot of us were out and celebrating at night. Some white students walked by
called us “a bunch of wetbacks.” I think that’s one of those experiences where, because we were

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in a group, we could respond and push back, but I think it would be very threatening to a student
who was alone—especially because it occurred at night.
11.

Our organizations have been able to come together to fight discrimination and

hostility toward Latinx students, but if we didn’t have a critical mass of Latinx students, we
wouldn’t necessarily be able to advocate for ourselves in that way and make people realize why
that’s not okay.
12.

This case could be very damaging for Fuerza Latina in terms of our membership if

there is not a critical mass of Latinx students to run the organization. We are already a small
community, but if admissions for Latinx students dropped by 50%, as estimated by Harvard’s
expert if all considerations of race were eliminated from Harvard’s admissions policy, Fuerza
Latinx could not realistically be able to sustain our club, or at least not in at our current capacity.
We would not be able to offer that same support to our members, leading to more isolation of
Latinx students in the Harvard community.
13.

This is case is particularly troubling for the Latinx community because we are

comprised of diverse nationalities and a drop in admissions increases the likelihood that, for
instance, there may be only one Cuban or El Salvadorian student in the entire Harvard
undergraduate campus. It would be very isolating to basically be the only one. Certain sub-Latinx
organizations cannot sustain themselves when there are not enough students from a particular
background. A lot of Latinx clubs on campus have gone through periods of being defunct since
their founding. In fact, a lot of clubs right now are not recognized as clubs by the Harvard
administration because they have encountered so many difficulties to formally exist due to the
fluctuation of admissions of students of various nationalities.

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14.

Fuerza Latina takes on a lot of responsibilities to support students on campus that

are often handled by the administration at other universities. For example, other universities have
multicultural centers or a dean in charge of inclusion or diversity. At Harvard, the cultural
organizations have to pick up the slack in terms of creating an inclusive environment on campus
for our members because Latinx students cannot assume that we necessarily have a space for
ourselves.
15.

Harvard does not have that much institutional support for diversity once students

are admitted. I think Harvard assumed that by recruiting more people, these issues will take care
of themselves. But this kind of attitude does not reflect the reality that students face—the reality
is that the Harvard administration needs to step up to provide a lot more support so that students
can depend on them when negative incidents happen on campus.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this day, July 28, 2018

/s/ Cecilia Nuñez
Cecilia Nuñez

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