In a letter the university received Monday, the Education Department recommended that the school be fined $27,500 - the maximum amount allowed - for each of 13 violations of the federal Jeanne Clery Act, adding up to a total fine of $357,500. The law requires all schools that take federal funding to compile and report data about crimes that occur on campus. It also requires the schools to provide timely warnings to students and staff about crimes that pose a potential threat to campus safety.

The Education Department launched its investigation of EMU after it was discovered that the school had lied about the death of a student on campus. Laura Dickinson was found dead in her dorm room in December 2006. Although campus and state police immediately suspected that she might have been killed - she was naked from the waist down and had a pillow over her head - the school's press release said there was "no reason to suspect foul play." The school did not reveal - even to Dickinson's family - that police were investigating her death as a homicide until 10 weeks later, after police arrested a suspect in her death, also an EMU student.

Security on Campus, a Pennsylvania-based nonprofit group that promotes and monitors schools' compliance with the Clery Act, filed a complaint in March 2007 asking the Education Department to investigate Eastern Michigan.

The most recent letter from the Education Department, signed by Mary E. Gust, director of the Administrative Actions and Appeals Division, reiterated the findings laid out in the department's final report, released in November. Gust's letter labeled EMU's response to Dickinson's death "an egregious violation" of the Clery Act and called its initial statement that foul play was not suspected "reprehensible." But the department's criticism of EMU extended beyond Dickinson's murder, with the report citing "very serious, numerous and repeated" Clery Act violations extending as far back as 2003.

Among the department's findings were that EMU failed to establish a timely warning policy and that, from 2003 through 2005, it failed to report accurate statistics about sexual assaults and alcohol, drug and weapons violations. Some crimes were misclassified - for example, forcible sex offenses reported as non-forcible offenses - while other crime reports failed to include all the required information, such as the location of the incident. The Education Department report also found discrepancies between some of the data EMU provided to the department and the statistics it included in its annual report released to the public.

In a press release, EMU Provost and Executive Vice President Donald Loppnow did not dispute the Education Department's report and said its findings were consistent with the university's own internal reviews. However, the school has asked for a hearing to review the size of the fines. It must file any appeal by Jan. 4.

"We expected this and we will accept the final outcome once we have completed the process," Loppnow said. Loppnow has been serving as the university president since the school's Board of Regents fired former President John Fallon, who was in office at the time of Dickinson's death.

The setting of EMU's fines brings the school a step closer to resolving all the issues surrounding Dickinson's death. Last week, the school and the Dickinson family released a joint statement announcing that the school had agreed to pay the family $2.5 million, although it did not admit any wrongdoing. A lawsuit filed by Fallon in October, alleging that EMU's regents fired him to prevent him from revealing the board's violations of Michigan's Open Meetings Act, still is pending in state court.

EMU's press release highlighted recent improvements to campus safety, including increased police patrols, more video surveillance and the hiring of an outside firm to conduct a security audit. The Education Department report also noted that EMU had improved its Clery Act compliance, but it said that the school still was not fulfilling all its obligations and that the improvements it has made "do not diminish the seriousness of the violations that existed at the time of the review."

S. Daniel Carter, senior vice president of Security on Campus, said the group hopes the record-setting fine against EMU will improve Clery Act compliance nationwide.

"We believe the fine is appropriate, that it sends a strong signal to EMU and to other schools that Clery Act compliance must be taken seriously," he said. Although EMU's failure to report Dickinson's death as a possible homicide was "probably the single most egregious violation we've ever seen," the other shortcomings cited by the Education Department were "not too terribly different" from common failures at other schools, Carter said.

"We're making a point of talking about the underlying systemic and policy violations [at EMU]," he said. "Because it's those deficiencies that really allowed the most horrible parts of it to happen."

According to Security on Campus, EMU is only the fourth school ever fined for Clery Act violations, and only one fine - against Salem International University in West Virginia - reached into the six-figure range, at $200,000.

Carter said this history has allowed schools such as EMU to become lax in complying with the law.

"There's no pressure on them to comply," Carter said. "And that's what led to the state of affairs that was found on [EMU's] campus a year ago."

But Carter said he expects more schools to face fines for Clery Act violations in the future, noting that the Education Department in 2005 released its first comprehensive guide on how to comply with the law.

"The ignorance defense ... isn't going to fly anymore."