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Russell Froman opened his session by explaining the evolving landscape of Title IX and how its interpretation has shifted across different presidential administrations. Originally associated with athletics and gender equity in resources, Title IX has since become most closely tied to cases of sexual misconduct and harassment in educational settings. Froman reminded participants that Title IX is fundamentally about ensuring equitable access to education and that violations can now result in schools and districts facing federal funding freezes—something that had not occurred until recent years.

The presentation outlined the three categories of misconduct covered under Title IX: quid pro quo harassment (requests for sexual favors in exchange for benefits), sexual harassment that is severe, pervasive, and objectively offensive enough to limit access to education, and the most egregious forms of misconduct including sexual assault, dating violence, domestic violence, and stalking. Froman stressed that every K–12 school receiving federal funds must designate a trained Title IX coordinator whose name is publicly accessible, and that all staff members—from custodians to coaches—are mandatory reporters of potential Title IX concerns.

Froman also reviewed the requirements and processes schools must follow once a complaint is made. He explained the distinction between informal and formal complaints, the importance of supportive measures that protect student safety without being punitive, and the roles of the complainant, respondent, investigator, decision-maker, and appeal decision-maker. He highlighted that parents act as complainants or respondents when minors are involved, and that schools must carefully document all steps and maintain records for at least seven years. He also emphasized that informal resolution is possible in many cases if both parties agree, but it is not allowed when staff members are accused of harming students.

The session concluded with practical guidance for maintaining compliance and fairness. Froman underscored that schools must keep their policies accessible, ensure investigations are equitable, and always provide both parties with the same rights, information, and opportunities. He also warned that Title IX violations now carry lifelong consequences for students, as many colleges inquire about past Title IX findings during admissions. His final takeaway was clear: if schools consistently approach complaints with fairness, transparency, and equity, they will both protect students and remain compliant with the shifting Title IX requirements.


Title IX Requirements for K-12 Education

Presenter:
    Russell Froman, Arnold Law Firm

Date/Time: September 6, 2025
Conference: 2025 Governance Conference
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Session Summary

This session provided an overview of Title IX requirements for K–12 schools, explaining the categories of misconduct it covers and the responsibilities of coordinators, staff, and administrators in handling complaints. It highlighted key processes, documentation rules, and the importance of fairness and transparency, noting that consistent compliance protects students while safeguarding schools from significant risks.