I. INTRODUCTION AND PARTIES PETITIONING
We, the undersigned parents, students, taxpayers, residents, alumni, educators, and
members of the Foundational Black American community of the City of Passaic,
respectfully submit this formal Petition requesting immediate administrative review,
public hearing, and formal Board action to remove the name “Mahatma Gandhi” from
Passaic School No. 25, and to rename the facility in honor of Fannie Lou Hamer, an
American civil-rights leader, voting-rights activist, community organizer, educator, and
recipient of the Presidential Medal of Freedom.
II. JURISDICTION, BOARD AUTHORITY, AND GOVERNING LAW
This Petition is submitted pursuant to the lawful authority vested in the Passaic Board of
Education under N.J.S.A. 18A:11-1, which grants local boards of education authority to
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make, amend, and repeal rules for the government, management, and operation of public
schools; pursuant to Board governance authority reflected in Board Bylaw Series 7000
and 9000, including File Code 9000 governing the role of the Board, File Code 9313
governing administrative procedures, and the district’s established authority to name,
rename, or rescind naming rights when a name no longer reflects the district’s educational
mission, public welfare, or the values of the community.
This Petition is further submitted pursuant to the New Jersey Open Public Meetings
Act, which guarantees the public meaningful participation in matters affecting public
education, and pursuant to the equal educational protections recognized under the
Fourteenth Amendment to the United States Constitution, 42 U.S.C. § 1983, Title VI of
the Civil Rights Act of 1964, 42 U.S.C. § 2000d, and the New Jersey Law Against
Discrimination, which prohibit discriminatory conditions in publicly funded educational
institutions.
III. FACTUAL BACKGROUND AND COMMUNITY IMPACT
The Foundational Black American community of Passaic submits this Petition after
extensive historical research, public record review, and community consultation. The City
of Passaic currently operates under an at-large governance structure for both its City
Council and Board of Education. The Black population of Passaic, once approximately
thirty percent in the mid-1990s, has declined to approximately three percent in recent
years. Despite the continued enrollment of Black students within the district, Black
residents remain materially underrepresented in educational leadership, curriculum
development, faculty hiring, administrative decision-making, and symbolic representation
within the district’s public institutions.
IV. HISTORICAL RECORD CONCERNING MAHATMA GANDHI
School No. 25 currently bears the name of Mahatma Gandhi. While Gandhi is
internationally recognized for his later work involving nonviolent political resistance, the
historical record—including Gandhi’s own writings published in Indian Opinion between
1893 and 1914, his private correspondence, and The Collected Works of Mahatma
Gandhi—contains documented statements in which Gandhi repeatedly referred to Black
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Africans using the racial slur “Kaffir,” advocated racial separation, and described Black
people as “very dirty” and living “almost like animals” in his March 7, 1908 writings.
These statements are not disputed interpretations; they are documented historical records.
V. NATIONAL AND INTERNATIONAL REASSESSMENT OF GANDHI
HONORS
The public reassessment of Gandhi’s documented anti-Black statements is neither
isolated nor novel. Beginning in 2003 in Johannesburg, South Africa, and continuing
through 2026 in universities, municipalities, and public institutions throughout South
Africa, Ghana, Malawi, England, Canada, and Australia, citizens, educators, students,
and governmental institutions have formally petitioned for the removal of Gandhi statues,
memorials, and honorary recognitions after reviewing the same historical record.
Numerous public institutions throughout the United States and abroad have likewise
removed names, statues, and honors associated with individuals whose documented
statements or conduct conflict with modern principles of racial equality, educational
inclusion, and public welfare.
VI. LEGAL AND EDUCATIONAL CONCERNS
The continued honorific placement of Gandhi’s name on a public school in a district
where Black students are materially underrepresented sends an objectively harmful and
racially insensitive message to Black children and families, particularly after the Board
has been placed on actual notice of Gandhi’s documented anti-Black statements.
Once a public educational institution receives notice of conditions that may contribute to
race-based hostility or exclusion, deliberate inaction may give rise to liability under state
and federal law, including L.W. v. Toms River Regional Schools Board of Education,
in which the Supreme Court of New Jersey held that a school district may be liable
when it knew or should have known of race-based hostile conditions and failed to take
effective remedial action, and Monell v. Department of Social Services, which
recognizes municipal liability under 42 U.S.C. § 1983 when official policies or deliberate
inaction cause constitutional injury.
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We therefore respectfully submit that the continued state-sponsored honorific recognition
of Mahatma Gandhi within Passaic School No. 25, after actual notice of documented
anti-Black statements, may create an educational environment inconsistent with the
district’s mission, inconsistent with the standards of equal educational access required
under federal and state law, inconsistent with the district’s own naming criteria requiring
that named individuals reflect positively upon the mission of the schools, and inconsistent
with the public welfare of Black students and families.
VII. PROPOSED HONOREE: FANNIE LOU HAMER
We further submit that Fannie Lou Hamer represents the exact qualities this district
should honor. Born into poverty in Mississippi, Hamer overcame systemic racial
oppression, organized Black voters, co-founded the Mississippi Freedom Democratic
Party, advocated for educational opportunity, economic self-sufficiency, and
constitutional equality, endured imprisonment and physical violence for exercising her
constitutional rights, and was posthumously awarded the Presidential Medal of Freedom
in 2025.
Her life and legacy reflect courage, educational empowerment, civic participation, and
human dignity. Her name would serve as a positive, mission-aligned reflection for all
students in the City of Passaic.
VIII. FORMAL REQUESTS FOR RELIEF
Accordingly, we formally request that the Passaic Board of Education immediately
exercise its lawful authority and take the following actions:
1. Formally accept this Petition into the official record of the Board;
2. Place this matter on the next available public agenda;
3. Appoint a Citizen Advisory Committee to review the historical record and community
input;
4. Schedule and publicly notice a public hearing for parents, students, educators, and
residents;
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5. Direct the Superintendent, pursuant to File Code 9313, to prepare administrative
recommendations regarding the renaming process;
6. Introduce and vote upon a formal Resolution removing the name “Mahatma Gandhi”
from School No. 25; and
7. By majority vote of the full Board, adopt the new name “Fannie Lou Hamer
Academy.”
IX. DEMAND FOR FORMAL RESPONSE AND RECORDED VOTE
Because the Passaic Board of Education acts only through formal session and majority
vote under its governing bylaws, we respectfully request a recorded vote by the full
Board, written findings, and a written response to this Petition within thirty (30) days of
service.
X. RESERVATION OF RIGHTS AND NOTICE OF FURTHER ACTION
Should the Board refuse to place this matter on the agenda, refuse to conduct a public
hearing, depart from its established procedures, or otherwise act arbitrarily after receiving
actual notice of the issues presented herein, Petitioners reserve all rights and remedies
available under 42 U.S.C. § 1983, Title VI, the New Jersey Law Against
Discrimination, the New Jersey Open Public Meetings Act, and an action in lieu of
prerogative writ under New Jersey Court Rule 4:69.
XI. CONCLUSION
Respectfully submitted on behalf of the Foundational Black American community,
parents, students, taxpayers, and residents of the City of Passaic.
Respectfully submitted,
Kassim Mouzone
Pro Se Litigant/Freedom Rights and Community Advocate
Foundational Black American Descendant of Freedmen
City of Passaic, New Jersey
E: Freedom1535k@gmai.com
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Date: May 5, 2026
The undersigned hereby adopt, support, and incorporate this Petition:(Additional
signature pages attached and incorporated herein.)