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Penn State University Scandal - Detailed Analysis Paper



EssayChat / Nov 7, 2019

Abstract

The Jerry Sandusky sex scandal completely tore apart Penn State University and ultimately led to the dismissal of several key figures at the university, including legendary coach Joe Paterno. Sandusky' abuse of young boys started several years before the allegations ever came to light and the university had several warning signs to indicate there was a problem. The men in charge of the university consistently made poor decisions regarding the response to information they received about Sandusky's actions, whether on purpose or through incompetence. Ultimately Sandusky was convicted and several people associated with the case lost their positions at the school. The university should have been more forthcoming with its information from the beginning and it was the failure to do so that ultimately led to criminal charges against the former president, vice-president, and athletic director of the school. A combination of geographic and social isolation created an environment where Paterno and the athletic department had more power than they should have and the focus on college athletics further contributed to this. By the time the university commissioned the Freeh report, the damage to the school's reputation had already been cemented. While they have made great strides in the interim, there is still much that can be done to endure that such a situation never occurs again.

Introduction

University ScandalOn June 22, 2012 Jerry Sandusky, the former defensive coordinator of Penn State football, was convicted on 45 of 48 counts related to the sexual abuse of young men over the course of several decades ("The Penn State Scandal," 2012). This conviction was the culmination of a criminal and internal investigation within the university that also resulted in the dismissal of head football coach and icon Joe Paterno, university president Graham Spanier, and several others. The school officials were accused of covering up the years of abuse rather than reporting them to authorities immediately in an effort to protect the reputation of both the university and its football program. The alleged cover-up was just as scandalous and damaging as the actual abuse since it gave the impression of a university that cared more about its reputation than it did about children. The school made several mistakes dealing with this crisis and missed several opportunities to restore their image. Proper handling of the crisis from the first instance of any inappropriate behavior may have saved the school from negative publicity and damaging lawsuits and, more importantly, may have saved several children from being abused.

The First Signs of Abuse



Although Sandusky's conviction stemmed from an investigation that was undertaken in 2009, the abuse had started much earlier than that and Penn State University had been informed of improper behavior involving Jerry Sandusky dating back to at least 1998 ("The Penn State Scandal," 2012). Almost all of the allegations involved boys Sandusky met through the charity he founded, The Second Mile, which began as a foster home but grew into a charity dedicated to helping children with absent or dysfunctional families ("The Penn State Scandal," 2012). Over the course of several years, Sandusky used this charity to meet troubled young boys that he then molested.

In 1998 things were going quite well for Jerry Sandusky. He had been on the staff of the legendary Joe Paterno's football program for nearly three decades and was considered the heir apparent to Paterno's football legacy. That year Sandusky took an eleven-year-old boy to the gym with him and persuaded him to take a shower with him. While in the shower Sandusky hugged the boy. When the boy's mother learned of this incident she contacted Penn State University police who then launched an investigation into the incident ("The Penn State Scandal," 2012).

In Finks four-stage model of crisis management, during the prodromal stage the crisis management professional employs a proactive approach, rather than a reactive one in order to identify an impending crisis (Nazari & Farahani, 2008, p. 532). It should be clear to most people that a case like this one could have explosive consequences for the university. In fact, Senior Vice President for Finance and Business Gary Schultz, who was notified of the investigation, noted as much in confidential notes he took at the time, wondering "Is this opening of Pandora's box? Other children?" ("The Penn State Scandal," 2012).

During an impending investigation and interview Sandusky admitted to showering naked with the boy and hugging him, while admitting that it was wrong and promising to never shower with boys again. However, in tape recorded conversations with the mother of the boy, Sandusky admitted what he did was wrong, but refused to promise to never shower with another boy again. Meanwhile Penn State athletic director Tim Curley notified Schultz and Penn State President Graham Spanier that he had talked with Paterno about the incident and "Coach is anxious to know where it stands" ("The Penn State Scandal," 2012).

Ultimately, citing a lack of evidence of specific wrongdoing the University Park Police Department declined to make any crime log entry and Centre County DA Ray Gricar decided there would be no criminal charges ("The Penn State Scandal," 2012). Though he was not formally charged, Sandusky retired in 1999 to focus more fully on his charity. However, he continued to hold emeritus status, meaning he was free to come and go on campus as he wished, which he did quite often ("The Penn State Scandal," 2012).

The actions of those who were aware of the situation hardly seemed as though they were trying to defuse a potentially devastating crisis. They did not investigate whether any other children had ever showered or been involved in inappropriate contact with Sandusky and they even allowed him to continue to use university facilities whenever he wanted, though he was no longer employed there. Since he was in line to be the next head coach at the university, it is possible that he did not choose to retire and that he was forced to do so, making that his only punishment for this incident. While it is understandable that these men would refrain from rushing to judgment and condemning Sandusky, they seem all too willing to brush this incident under the rug and hope that nothing else surfaces in the future. Their failure to act in the prodromal stage will cost them dearly later.

More Showering Incidents



No longer encumbered by his obligations to the football team and given free rein to use the same facilities in which he had been caught earlier, Sandusky apparently intensified his questionable behavior with several other young boys, in spite of his earlier promises. In 2000 a janitor named James Calhoun saw Sandusky in the locker room showers with a boy, who Sandusky had pinned up against the wall as he performed oral sex on the boy. A deeply disturbed Calhoun reported the incident to his immediate supervisor but, fearing reprisal against the entire janitorial staff, he decided not to make a formal report ("The Penn State Scandal," 2012). The incident would only come to light many years later after the scandal had already erupted.

The following year, in February 2001, Sandusky was again seen in the shower with a young boy. This time it would be grad assistant Mike McQueary who saw a naked boy being subjected to anal intercourse by a naked Sandusky. McQueary notified Paterno who then relayed the story to AD Tim Curley. On February 12, after consulting with university counsel, Spanier, Schultz, and Curley met to discuss the accusations and agreed that Curley would contact Paterno and meet with Sandusky and that they would call child welfare unless he confessed to having a problem ("The Penn State Scandal," 2012).

While that would have been a prudent course of action, it was not the way things unfolded from there. Several weeks later, Curley sent an email to Schultz and Spanier saying that "after giving it more thought and talking it over with Joe yesterday" he had decided they should offer Sandusky "professional help" ("The Penn State Scandal," 2012). Spanier agreed and stated that "the only downside for us" would be if Sandusky continued to act in similar fashion and "we then become vulnerable for not having reported it" ("The Penn State Scandal," 2012). As a result of all this, Sandusky was prohibited from bringing any children into the football building, an essentially unenforceable ban.

While the reaction to the initial report in 1998 could be understood at the time to be a rational response to a potential problem, the four men notified of the subsequent allegations could no longer feign ignorance regarding Sandusky's behavior. They had been notified of at least two similar and serious incidents and may have had some knowledge of others. Their statements at the time appear to indicate that at least one or two of them recognized that they were in a pre-crisis situation. Yet their only response was to bury the information and keep it from public scrutiny while basically telling Sandusky to behave himself. Their failure during the prodromal stage would come back to haunt them several years later when the authorities at Central Valley High School in Clinton County would handle the matter far more appropriately.

The Investigation



In 2008 one of Sandusky's victims, who would later be identified only as Victim 1, entered Central Valley High School and told his mother about the assaults. She promptly notified the school who barred Sandusky from the district and reported the matter to authorities as mandated by law ("The Penn State Scandal," 2012). Once the police were involved, the Pennsylvania Attorney General launched an investigation that would ultimately affect everyone associated with the case and lead to Sandusky's arrest on November 5, 2011 ("The Penn State Scandal," 2012).

Though on November 4 Schultz told university counsel that he "was never aware that Penn State police investigated inappropriate touching in a shower in 1998," by November 7 he and Curley had resigned and surrendered to police on charges that they failed to alert police that to complaints against Sandusky ("The Penn State Scandal," 2012). On November 9 the Penn State Board of Trustees fired both Paterno and Spanier ("The Penn State Scandal," 2012). By November 18, the NCAA was investigating the university and the Second Mile Charity had decided to dissolve. Eventually ten victims come forward to testify that Jerry Sandusky molested them. Eventually Sandusky would be found guilty and sent to jail. Paterno died before Sandusky's trial even started and Curley, Schultz, and Spanier are still awaiting trial.

Fink argues that the severity of the crisis and damage are influenced by the success of the prodromal stage and that successful proactive identification of a crisis can reduce the impact of the crisis during the acute stage. Because the school administrators and Paterno failed to be proactive in dealing with this situation when it was first reported, the acute stage became completely uncontrollable and they were unable to contain the damage. The school, the football program, and the individuals who were involved in this scandal were irrevocably changed by it, few for the better.

The Aftermath



In the wake of the scandal, the Penn State Board of Trustees hired former FBI Director Louis Freeh to investigate the scandal and the school's handling of it. Freeh released a report that roundly condemned university leadership for "the total disregard for the safety and welfare" of Sandusky's victims ("The Penn State Scandal," 2012). He specifically cited Paterno, Schultz, Curley, and Spanier for their failure to notify law enforcement and pointed out that they never even tried to determine the identity of the boy McQueary saw in the shower with Sandusky in 2001 ("The Penn State Scandal," 2012). Citing Freeh's report, the NCAA handed down historic sanctions against the school and football program, including a reduction in scholarships for the football program, a ban from postseason play, and hefty fines. They also erased the wins the football team had earned from 1998 until the investigation began, knocking Paterno from atop the list of most wins by a college football coach.

Penn State was in serious crisis mode by this point. Their image as a squeaky clean program that played by the rules was in tatters. Benoit's Image Restoration Theory provides three possible responses in such a circumstance. They could deny everything, evade responsibility, or reduce the offensiveness of the act (Coombs, 2012, p. 32). Freeh's report left them little choice other than to take the final option. They expressed mortification by accepting the report, admitting guilt as an institution, and promising to take some corrective action to prevent a repeat of the event. They also offered compensation to the victims by making a fund available to pay any damages they would incur in the courts.

Many questions remained, however, about how such a massive scandal could have unfolded without anyone revealing or discovering it for such a long time. Many people wondered why more information had not been forthcoming and out in the public since Penn State is, as its name implies, a state funded university. But Pennsylvania law says that a "state-related institution," a description that applies to Penn State and three other universities, has no legal obligation to respond to open records requests (You-Jin, 2012, p. 15). This meant that, even if reporters sought information about the incidents on campus, the university did not have to respond to them at all.

Reporters also had other issues to deal with in reporting the story. State College, the town that is home to the university, is in a remote location. It would not have been cost effective for many news outlets in faraway cities to send reporters for what amounted to rumors at first, especially at a time of severe cutbacks in staff and funds. They are also wary of incurring libel suits should they report erroneous information (Steiner, 2012, p. 2). Ultimately most of the reporting on the grand jury investigation was done by Sara Ganim of the Harrisburg Patriot-News, a paper with a circulation of only 71,000 (Solomon, 2011, p. 29). Eventually, Ganim's reporting would bring other news outlets to the scene and unleash a tidal wave that swept all of Penn State up in its path, including its venerable coach, Joe Paterno.

Penn State's "Closed Culture"



When the Freeh report was released, it singled out the athletic department as having been "permitted to become a closed culture" for several decades (Schmitz et al., 2012). However, any independent outside observer could conclude that the same could be said of the entire university. The town of State College, Pennsylvania is nestled in the center of the state, more than a three hour drive away from either Pittsburgh or Philadelphia. It is nearly 90 miles away from the state capital of Harrisburg. It is situated in bucolic surroundings, with several state forests in the area. There is no doubt that a large part of the university's charm rests in the fact that it is so remote and relatively difficult to get to.

This remoteness has become a source of great pride for many alumni and fans of the teams, who feel that this allows Penn State to remain above the fray when it comes to the situations dealt with by other colleges. The remote location builds a sense of community and isolation from the outside world. In essence, being a student at Penn State can seem like being granted access to an elite society that is unknown by people who have not been to "Happy Valley," as it is called. For many students and even administrators, much emphasis is placed on doing things the "Penn State Way," implying that Penn State is superior to other institutions in many ways and that outside influences should be resisted (Schmitz et al., 2012).

This focus on the "Penn State Way" exclusively in almost all decision making has been taken to extremes at the school. In fact, an argument could be made that there exists a nearly obsessive tendency to isolate the school completely from the influence of any external thought and that it has had a damaging effect on the university as a whole. Most schools, especially those that are funded in some way by the state, are subjected to the oversight of external bodies or individuals that monitor the actions and policies of the administration and faculty. Penn State, by contrast, went out of its way to foster a communal feel among its loyal followers while actively ignoring and dismissing input from outside sources, taking its own isolation to an extreme.

The chair of the board of trustees has been a Penn State student, administrator, or trustee fro over fifty years and over three-quarters of the trustees are alumni of the university (Gruver, 2012). All of the people involved in the scandal have also had extremely long tenures at the school. Paterno spent 62 years as a coach at Penn State and Spanier spent 25 years there, with 16 as president. Curley, Schultz, and McQueary all attended Penn State and then spent their entire professional careers there until the scandal broke, which could mean nearly 40 years for some (Gruver, 2012). This gives the school an intrinsic administration that may have a predisposition towards continuing to do things the same ways they have always been done. It has made the school resistant to change and continued to feed the idea that the school has operated on a completely different level than any other institution for a very long time. Most importantly it puts in place administrators and board members who have cozy relationships with the school and its employees, making it potentially difficult to accomplish any real oversight.

The athletic department was particularly shielded from any outside influence or oversight. The Freeh report noted there was "little personnel turnover or hiring from outside the University and strong internal loyalty" in the department (Schmitz et al., 2012). In fact, athletic director Tim Curley once played for Joe Paterno before getting the AD job. That could make it exceedingly difficult for him to do his job fairly, especially when it came to dealing with Paterno in any potential disciplinary matters as an athletic director may be asked to do. It is difficult to imagine that Curley would have ever overruled Paterno on any matter, since this was a coach and mentor whom he had admired for several decades.

The Sandusky scandal is not the first time that this isolation from the rest of the state and national universities has caused issues at Penn State. A 1982 desegregation order charged the 32 state-owned and state-supported universities in Pennsylvania with raising their black student population to five percent over a period of five years (Morello, 1986). Two years into its plan, Penn State was able to raise the number of black students at its 22 campuses to 2,308, making up 3.7 percent of the student population, an improvement from 2.6 percent of the population in 1983. At the same time black professors made up only 1.7 percent of the total faculty (Morello, 1986). Once again, the issues of isolation and elitism proved difficult to overcome. White students expressed anger and even made racist signs decrying the university's push to increase minority enrollment and minority students felt completely out of place at the predominantly white campuses. While 56% of white freshmen enrolled at Penn State stayed until their junior year, only 34% of black freshmen stayed, a statistic the university blamed on geographic isolation (Morello, 1986). White students are just as geographically isolated and they are able to cope, which would lead one to believe that it is the isolation from outside influence that is more to blame for the discrepancy.

The isolation contributed to an environment that was conducive to corruption and scandal. Without sufficient external oversight, the school was left to its own devices when determining how to handle potentially explosive situations. No situation was more explosive than that posed by Sandusky's behavior. Everyone involved with the school had become conditioned to taking care of things "in house" and not venturing outside for help. As seen with the effort to further integrate the school years earlier, many at the school actively reject the notion that outsiders should be part of the "Penn State Way" and any attempt to allow outside influence is met with heavy resistance. Such resistance is evident in the student riots that followed Paterno's firing. Whether geographic or influential, the isolation created an environment that led directly to the cover-up of Sandusky's actions.

Athletic Programs Influence on College Decision-Making



Many of the circumstances that led to the Sandusky scandal were not unique to Penn State. While acknowledging that outrage over what occurred at the school was justified, Michael D. Giardina, an associate director of the Center for Physical Cultural Studies at Florida State University, also notes that "we shouldn't overlook or forget that the corporate university of today ethically suspect decisions all the time" (Wolverton, 2012). This statement seems to imply that Penn State is not alone in its attempts to cover up and then rationalize poor decisions and behavior. One of the main drivers for such attitudes is the outrageous amounts of money that colleges and universities derive from participation in athletics, especially football and basketball. As the money continues to pour in many college administrators prefer to look the other way regarding improprieties among their athletic departments.

This has led to an increase in the public perception over the influence athletics has on college campuses. In a recent survey, 83 percent of respondents blamed "the culture of big money" in college sports for the failure of Penn State officials to report the suspected child abuse to law enforcement (Pappano, 2012). Most people seem to suspect that administrators acquiesce to powerful football and basketball coaches because of the enormous amount of money their programs generate for the schools. In the case of Penn State this suspicion was probably much stronger due to the fact that Joe Paterno was a longtime face of the institution and was synonymous with the school.

Penn State is hardly the only school that prizes success in athletics. Though the money that comes in through the programs related to marketing and attendance is substantial, there are other reasons that schools support the programs. Each year, the top twenty football schools and top sixteen basketball schools in the nation see increases in the quantity of applications to their schools, ranging 2% to 8% over the previous year (Pope & Pope, 2009, p. 750). Private schools also see an increase in applications after sports success at a rate two to four times higher than in public schools, with the extra applications composed of both low and high scoring SAT scores (Pope & Pope, 2009, p. 750). These increases in applications allow schools to improve both the number and quality of incoming students, which will lead to higher enrollment for the long term and, as a result, greater income for the university.

For these reasons many schools are willing to place both an economic and strategic priority on college athletics. Ohio State chose to spend a large amount to hire Urban Meyer as their head football coach, giving him $4 million per year plus bonuses and use of a private jet. By contrast a physics professor at the school claims that there is not enough money in the department's budget to cover attendance at conferences (Pappano, 2012). This is in spite of the fact that Ohio State is well known for its physics and science departments. The football program, however, brings in far more money and applicants than does the physics department, so that is where the university decided to spend its money. A similar situation existed at Penn State where having Joe Paterno as football coach for decades had become incentive for people to apply to the school. It was a school, most students felt, that prided itself on always doing things the right way and they longed to be a part of that.

Researching Joe Paterno



Paterno is perhaps the biggest reason that the story failed to generate much traction early on. At the age of 84, "JoePa," as he was affectionately called in the college football and Penn State communities, had spent 46 year at Penn State and amassed more wins than any other coach in major college football history with 409 (Solomon, 2011, p. 29). He had been coaching for longer than many of his contemporaries had been alive. During that time there had never been even a whiff of scandal. While other programs repeatedly faced sanctions for recruiting or other violations, Penn State simply kept on running a program that seemed above the fray.

When the Patriot-News ran a front-page, full-page editorial calling for Spanier and Paterno to step down, Paterno attended a rare news conference where he brushed aside a question about the scandal and said he would only talk about his football team (Solomon, 2011, p. 29). That was the end of the story for most everyone who heard him. If Paterno had nothing to say about the matter, it wasn't worth discussing. After 46 years that was the kind of cache that Paterno had managed to amass. Not only had he run a clean program and won games doing it, he had donated money to fund the library, acted as a father to many of his players, and even had a statue of himself on the campus. Paterno was more than a coach, he was a revered figure in the state and beyond.

It was this reverential treatment that allowed people to ignore the story, rationalizing that if anything was wrong, JoePa would surely take care of it. When he was fired Penn States students rioted in the streets of State College, unable to comprehend that he would no longer be at the helm of the football team. Eventually the school took down the statue, a move that caused even more consternation among those who held the coach in such high regard. But looking back, as the Freeh report did, it is evident that things may not have been as they seemed. The Freeh report stated that the athletic department at the university was "perceived by many in the Penn State community as an island where staff members lived by their own rules" (Schmitz et al., 2012). The football program, in particular, opted out of most of the university's Clery Act training, which covered sexual abuse awareness (Schmitz et al., 2012).

Most of this can be traced to Paterno's status within the community. In fact, when Dr. Vicki Triponey, the university's former standards and conduct officer, clashed with Paterno she was forced to resign her post (Albergotti, 2011). Her mistake was complaining that Paterno believed she should have no business "holding out football players accountable to our community standards" and that "he was saying that we should treat football players different from other students in this regard" (Albergotti, 2011). Their biggest battle occurred in 2007, six years after the incident McQueary witnessed.

There is no doubt that, contrary to Paterno's claims, he was fully aware of the situation regarding Sandusky. The fact that he had been able to run his program his way with no outside interference, regardless of the level of the crime, surely led him to believe he would be able to continue to do so. This was as much a failing of the Penn State community as it was a failing of Paterno himself. It was an institution that, as the Freeh report stated, placed an "over-emphasis on 'The Penn State Way'" with a "resistance to outside perspectives" (Schmitz et al., 2012). Paterno was spared from charges due to the fact that he was not in a position that required him to report the allegations of abuse. However, that does not absolve him of guilt. He was certainly free to report them if he so chose and it is evident from the emails and notes that he actively encouraged not reporting Sandusky. Clearly Paterno felt his status would allow him to continue to avoid any blame that might come his way.

Future Crisis Management Plan



There are many things that Penn State could have done better at the time of the crisis and in the years leading up to it that would have gone a long way towards minimizing the damage that Jerry Sandusky's actions caused to the university. A primary concern for the school must be the lack of oversight that existed, especially in regards to the athletic department and the football program. Though it can be argued that in the wake of Paterno's firing and subsequent death there will no longer be a person in such a unique position of authority there anymore, there is always the chance that such a scenario could repeat itself in the distant future. It is imperative, therefore, that the university establishes some guidelines for dealing with any future situations.

Though a future scandal could involve any area of the university, it is useful in this instance to focus on the way crises in sports are handled. The first and most obvious step is to place the athletic department under direct authority of the board of trustees. This means that all decisions passing through the athletic director's office must be reported to the board so that it can be reviewed for proper procedures. Any failure in this instance would result in the immediate removal of the athletic director and any other offending parties. Responsibility and accountability are the most important aspects of this approach.

Regardless of the oversight steps that may be undertaken, certain crises may still arise. It is important that the school understand how to properly deal with them. In a case such as the Sandusky scandal and many other sports-related crises, apologia, or the "public speech of self-defense," is a useful and often applied tool (Jordan and Smith, 2013, p. 28). This can involve either denial of intent or denial of the act itself, differentiation to distance the institution from the act, or transcendence to reframe the action from a different perspective (Jordan and Smith, 2013, p. 28). Of these, only differentiation would have been useful in the Sandusky scandal. However, there are instances where apologia can be applied to team sports. These include threats to team harmony, failure to give a best effort, or misdeeds that violate society's ethical standards (Jordan and Smith, 2013, p. 28). Such misdeeds would include Sandusky's behavior. In such a case, mortification is often the only strategy available and it involves admitting wrongdoing and begging forgiveness (Jung, Graeff, and Shim, 2011, p. 26). That is, in essence, what Penn State did, only it came much too late in the process.

There are also several avenues available for restoring image after such a crisis. In order to reduce the offensiveness of an act, Benoit suggests six possible practices. In a case similar to the Sandusky situation, bolstering would be useful as a tool to remind people of past positive actions or good character overall (Jordan and Smith, 2013, p. 29). The only other available option in such a case was to provide compensation, which the university ultimately did, both of its own accord and at the behest of the NCAA and Big Ten Conference. In other situations, minimization, differentiation, transcendence, and attacking the accuser are potentially useful approaches to restoring image (Jordan and Smith, 2013, p. 29).

Conclusion

There were many failings in the entire Sandusky affair at Penn State. This crisis could have been averted if the principals involved had been more proactive when they were first informed of any wrongdoing. By acting during the prodromal stage, they could have completely defused the situation and potentially saved many victims of sexual abuse. However, the combination of a remote school with little oversight from outside entities and a revered figure who was constantly allowed to handle things at the university in his own way proved a recipe for disaster and led to the university having to perform extensive image restoration. Though the university may eventually put the entire episode behind them, it will have done so at great cost to many people both inside and out of the institution.

REFERENCES

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Gruver, W.R. (2012). PSU needs an outside influence. Penn Live

Jordan, T. & Smith, D. (2013). Crisis communication in sport management: Research aides crisis response selection. KAHPERD Journal, 51(1), 26-33.

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Pappano, L. (2012). How big-time sports ate college life. The New York Times.

Pope, D.G. & Pope, J.C. The impact of college sports success on the quantity and quality of student applications. Southern Economic Journal, 75(3), 750-780.

Schmitz, J., Eyring, D., Fittipaldo, R., Chute, E., McCollough, J.B., & Niederberger, M. (2012). 'Closed culture' of Penn State contributed to scandal, Freeh report finds. Pittsburgh Post-Gazette.

Solomon, G. (2011). Slow to react. American Journalism Review, 33(3), 28-51.

Steiner, L. (2012). Why was the Penn State scandal ignored for so long? AEJMC News, 45(2), 2-3.

The Penn State scandal, piece by piece. (2012). Pittsburgh Post-Gazette.

Wolverton, B. (2012). Penn State's culture of reverence led to 'total disregard' for children's safety. The Chronicle of Higher Education.

You-Jin, H. (2012). Shut out at Penn State. News Media & The Law, 36(1), 15-17.


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