In January, 2014, the Civil Rights Division of the Department of Justice (DOJ) and the Office for Civil Rights in the Department of Education (ED) issued a joint "Dear Colleague Letter" to K-12 schools. The topic discussed in their joint letter is whether administrators are punishing minority children more harshly than white children for the same infractions. Zero-tolerance policies in school give straightforward discipline guidance to administrators by removing discretion in the enforcement of a rule. The straightforward link between an infraction and its consequences gives fair warning to students what the consequences will be should they break a particular rule. The hard question is why do zero-tolerance policies come under attack under the civil rights laws? One possible explanation is that the application of these rules is "overbroad," and leads to serious and lasting consequences for the students who are suspended or expelled. In this article, Epstein examines some of the practical and legal issues that informed the preparation of the guidance letter from ED and DOJ, including the zero-tolerance and disparate impact theories that form its foundation. Epstein also looks at the legal issues that emerge from the aggressive interpretation of Title IV and Title VI of the Civil Rights Act and also at the procedures by which ED and DOJ seek to impose their proposals.