The state Division on Civil Rights released the complaint yesterday.

The complaint alleges that the girl, a 10-year-old in the fifth grade, "was subjected to differential treatment and harassment while a student at Sumner Elementary School."

The complaint goes on to say that Theresa Brown, who is black and was a vice principal at Sumner, punished the girl and her bilingual classmates by making them eat on the floor without lunch trays in front of other students who got to eat at tables. They were punished because of a broken chair and spilled water.

Brown and Rochelle Caldwell, a guidance counselor who is also black, threatened the students with extended punishment if they told their parents about it, the complaint alleges.

The girl's mother, in the complaint, alleges her daughter "was harassed based on her race and ancestry" and suffered "peer harassment . . . by other predominantly black students." The division will investigate to determine if the state's Law Against Discrimination was violated, according to spokesman Lee Moore. Depending on the outcome, fines and sanctions could be ordered.

District spokesman Bart Leff declined to comment on the complaint, citing personnel issues. The state Department of Education also is investigating the matter and the district's handling of it. There have been community protests calling for Brown to be fired.

The children were made to eat on the floor for two weeks starting Feb. 11. In March, after the punishment became known, Brown was transferred to East Camden Middle School with the same rank and $91,122 salary.

The Camden school board, however, decided to suspend and ultimately fire José Rivera, the students' bilingual teacher.

"I got lynched," said Rivera, who alleged that action was taken against him because he advised students to tell their parents.

"The troublemakers to the brightest kids were all saying the same thing. I said, 'Tell your parents,' " Rivera said.

Rivera was reprimanded for failing to tell the principal, according to a district memo dated March 3. "When you willfully chose to not inform the building principal, you failed to protect the physical well-being and safety of the students," the memo states.

Rivera said he did not tell the principal, who has since retired, because he thought he knew about it already.

Asked why Rivera was fired while Brown was transferred at full rank and pay, Leff said both were personnel matters he could not discuss.