GOVERNMENT OF THE DISTRICT OF COLUMBIA

DEPARTMENT OF HUMAN RIGHTS AND MINORITY BUSINESS DEVELOPMENT

 
In the Matter of:                   )
                                    )
ROLAND D. POOL and MICHAEL GELLER,  )     DOCKET NO.
                                    )
                    Complainants    )
     v.                             )
                                    )
BOY SCOUTS OF AMERICA, et al.       )
                                    )
                    Respondents.    )
                                    )
STATE OF ILLINOIS   )
                    )     SS
COUNTY OF PEORIA    )
  
 

AFFIDAVIT OF BOYD RIDLEY CRITZ, III

I, BOYD RIDLEY CRITZ, III, of 215 West Westwood Drive, Peoria, Illinois, depose and say under oath as follows:

1. I make this affidavit upon personal knowledge.
   
2. Since June, 1990, I have been Vice President for Exploring, an officer of the W. D. Boyce Council of the Boy Scouts of America. This Council is separately incorporated from the Boy Scouts of America, Inc. and is headquartered in Peoria, Illinois. From June, 1987 until assuming this Vice Presidency, I was Council Commissioner, also an officer, of this Council.
   
3. From 1984 until July 18, 1991, I was a faculty member of the W. D. Boyce Council's College of Commissioner Service. This College is the principal training event for Unit Commissioners, Administrative Commissioners at all levels, and Roundtable Commissioners and their staffs, in the W. D. Boyce Council. I had served this College on its faculty and as a member of its Steering Committee continuously since 1984 (its first year). I was presented the first earned "Doctor of Commissioner Service" degree awarded by the College. Iwas its second Dean, serving as such for three years, for which I was awarded the "Doctor of Commissioner Service honoris causa" by the faculty. I wrote many course syllabi still being used to explain Scouting policies. While I was Dean, the event's attendance expanded significantly and this College gained recognition as a "Regional happening," typically attracting participants from over twenty different Midwestern Councils, and faculty from many of these. In July of 1991, the Steering Committee of which I was a part was well under way in preparation for the next such event.
   
4. From early 1990 until September 30, 1991, I was a member of the Adult Advisory Committee for the then Area 3, East Central Region, President's Area Conference on Exploring. I was asked to serve by the principal adult advisor to its youth leadership. We had held one such event while I was on the adult committee and were preparing for another, to be held in early 1992.
   
5. In June of 1991, I testified at trial in Welsh vs. Boy Scouts of America, Inc., et al., U. S. District Court for the Northern District of Illinois, Eastern Division, Case Number 90 C 1671. I was subpoenaed on behalf of the plaintiffs, Mark G. A. Welsh, a minor, and Elliott A. Welsh, his father, who were denied Scouting as Tiger Cub and Adult Partner because they had were agnostic. Later, when Mark Welsh could have joined Cub Scouting without an Adult Partner, it was made clear that the Boy Scouts of America, Inc. would not permit his joining due to his own agnosticism. The plaintiffs' attorney qualified me as an expert witness on Scouting. I was prepared to testify on many subjects. They included interpreting Scouting policy, the extent that normal program content related to religion, the "fun" content of Scouting, the mind set of joining youth, how Scouting is designed to appeal to youth and parents, the degree of membership control, the content of adult leader training related to religion, how money is raised for Scouting at all levels, material sales in interstate commerce by the Boy Scouts of America, Inc., and much more. I have no transcript available at this time and do not specifically recall which subjects were covered in my actual testimony, but many were. In all cases, I testified truthfully.
   
6. The following occurred directly as a result of and relatively immediately following my act of testifying:
   
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            a)  I received a letter dated July 18, 1991 from one
                Robert D. Stubblefield, acting in his capacity as
                Council Commissioner of the W. D. Boyce Council, Boy
                Scouts of America.  A copy of that letter marked
                "Attachment A," is attached and made a part hereof
                by this reference.
            b)  I later learned that Mr. Dale L. Sielaff, President
                of the W. D. Boyce Council, Boy Scouts of America,
                made inquiry of the Boy Scouts of America, Inc. as
                to whether my testimony would permit removing me
                from office as a Council Vice President, which
                inquiry was answered negatively.  I also learned
                that Mr. Sielaff was aware of the action of Mr.
                Stubblefield prior to the time it occurred.
            c)  Following the above, I wrote to and conversed with
                Mr. Sielaff.  In conversation Mr. Sielaff said that
                in the corporate context, even though I was only an
                officer of a licensee and not of the defendants in
                the case then at issue, testifying for the
                plaintiffs would have been viewed with extreme
                disfavor.  Mr. Sielaff confirmed that he made the
                inquiry referred to.  He stated that I could serve
                out my present term and that, until it expired, I
                "would have difficulty continuing to work with my
                former friends" on the Council.  He referred to my
                "former friends" several times.  I would describe
                his tone as snide.  His manner was that of a person
                speaking with someone he found distasteful.  His
                implication was that I would no longer have such
                difficulty after my term expired as I would not
                likely have another.  In that, Mr. Sielaff could
                not, of course, speak for the Council.  [I suspect
                in spite of Mr. Sielaff's views, I was later
                nominated and elected to serve as Vice President for
                Exploring for another term, the present one.]
            d)  I later received a letter dated September 30, 1991
                from one Raymond Lee, Jr., in his capacity as Acting
                President, Area 3, Region 7, Boy Scouts of America,
                Inc. an operating division without separate legal
                existence, rather than for a separately incorporated
                and chartered Council.  Seemingly unconnected with
                the events related above, read closely the common
                thread of Mr. Sielaff is evident.  A copy of that
                letter, marked "Attachment B," is attached and made
                a part hereof by this reference.  I was informed
                by the principal adult advisor who had asked me to
                serve in the position from which Mr. Lee "relieved"
                me that he had not even been consulted about the
                letter or the decision which prompted it.
      
    
   

   These events must be interpreted in light of and in spite of a portion of my testimony noting that I believed in a deity, had subscribed and continued to subscribe to the Declaration of Religious Principle of the Boy Scouts of America, Inc. (Without a transcript available, precise quotes are impossible.)
7. Prior to my testimony in the case referred to above, I had served the Boy Scouts of America in many capacities. My membership tenure is now approximately 38 years. I was a Cub Scout, Boy Scout and Explorer. I have served as Assistant Webelos Leader in one Cub Scout Pack, Assistant Scoutmaster in two different Boy Scout Troops in two different Councils, Scoutmaster of three Troops in two different Councils, Committee Member for an Explorer Post, Unit Commissioner, Assistant District Commissioner, District Commissioner (for three and one half years, during which time I built my staff from about fifteen people to over sixty five), Council Executive Board Member, Council Commissioner (the position now held by Mr. Stubblefield) and Council Vice President for Exploring (my present position).
8. I have twice taken training at Philmont Scout Ranch and all of the training listed hereafter in this paragraph and the immediately following paragraph. I have served on many W. D. Boyce Council training staffs, including those for Cub Scout Leader Basic Training. I was twice asked to and served on a Cub Scout Leader Basic Training staff subsequent to receiving the original of Attachment A hereto. In each case, ironically, a portion of my assignment was to specifically explain to the training participants the religious program elements and policies pertaining to Cub Scouting. The author of Exhibit A hereto did not control the selection of this training staff.
9. I have also served on the staff for Boy Scout Leader Basic Training, Explorer Advisor Training, Train-The-Trainer and Enhanced TTT conferences, Den Leader Workshops, Council Pow-Wows for Cub Scout leaders, Commissioner Conferences, and Boy Scout Junior Leader Training.
10. As a matter of financial support, I have been among the highest individual contributors to the W. D. Boyce Council's annual "Sustaining Membership Enrollment" for some years. My contribution for 1991, the year during which I was removed from the positions noted above, was $1,200. There are, of course, other large cumulative annual expenses in Scouting leadership service. Additionally, I made a contribution in excess of $7,500 to the Council's recent capital fund campaign. This in spite of not having, by any standards, accumulated great financial wealth.
11. My Scouting history is recited, not for personal aggrandizement, but to show that attempts at reprisal happen even with respect to a long-time Scouter with a history of significant and effective personal service as well as significant financial contributions and outlays. As adult Scouting is a service to youth, such attempts, sadly, harm the youth, not the adult.
12. I reaffirm that I believe in a deity and subscribe to the Declaration of Religious Principle of the Boy Scouts of America, Inc. Also, I herein state that for so long as I have been aware of my personal sexuality, I have never been nor have I believed myself to have been other than heterosexually oriented.

This Affidavit is four pages long, not including the two Attachments hereto. All except the first are numbered, and the first three pages have been initialed at the bottom with the initial appearing to the immediate right of my signature.

 
BOYD RIDLEY CRITZ, III                         Initial
Subscribed and sworn to before me the     day of September, 1992.
Notary Public