Editor’s note: This story contains descriptions of sexual assault and harassment involving minors. For more information, see our editorial standards.

“The first thing he asked me was whether I was a virgin or not.” Scroll down

“Do you really feel like you were raped?”

“Why aren't there more people talking about how we can protect people who are falsely accused?”

Responding appropriately to sexual assault and harassment incidents in schools requires sensitivity and training.

However, survivors aren't always afforded either.

Interviews with sexual assault survivors, federal investigations, and court documents show the cost can be steep. Scroll down

Responding appropriately to sexual assault and harassment incidents in schools requires sensitivity and training.

However, survivors aren't always afforded either.

Interviews with sexual assault survivors, federal investigations, and court documents show the cost can be steep. Scroll down

Responding appropriately to sexual assault and harassment incidents in schools requires sensitivity and training.

However, survivors aren't always afforded either.

Interviews with sexual assault survivors, federal investigations, and court documents show the cost can be steep. Scroll down


Julia Himmel/K-12 Dive

Camille had plans. As she waitressed during high school to help support her family, she dreamt of going to nursing school after walking the stage — and her grades spoke for her ambitions.

Then, just as her junior year was ending, Camille was drugged and gang-raped. 

There were witnesses and evidence: School peers who saw her before and after the assault, a former friend of Camille's who allegedly helped her attackers, a video circulating among her classmates of Camille lying unconscious and partially undressed on a bed, and subsequent harassment reported at school — all of which together should have triggered the school district's responsibility to protect her. 

But about three days after Camille's rape, when Sacramento City Unified School District was notified about it by one of her peers, the district made the first in a series of decisions that Camille believes derailed her future. 

Instead of fulfilling its responsibilities under Title IX — the civil rights law that protects students against sex discrimination in federally funded education programs — court documents show the California school district relied on law enforcement to investigate and respond to the assault. 

"I was pulled out of class and told to see the school resource officer," Camille recounted in court documents. Camille, who was a minor when the assault happened in 2016, and whose name was changed in court documents and again here to protect her privacy, said, "The first thing he asked me was whether I was a virgin or not."

Officer Joe Brown, the SRO, continued with a smile: Did she want to tell him what happened? Could she describe any details she remembered of her assault? 

Finally, "Do you really feel like you were raped?" 

Reporting this story

The reporting for this article draws from five federal investigations into various school districts' handling of Title IX responsibilities, as well as interviews with the U.S. Department of Education's Office for Civil Rights Assistant Secretary Catherine Lhamon, survivors of sexual assault and harassment, and Title IX advocates and lawyers. We reviewed hundreds of pages of court documents containing police records, school district officials' correspondence, school district documentation and sworn statements provided to courts. Individuals' names have been changed where noted to protect their privacy. Italics shown in quoted court documents reflect the original style of the documents, rather than emphasis by K-12 Dive.

Camille's experience at Sacramento City USD's C.K. McClatchy High School is not an isolated one. 

Federal investigations and court cases reviewed by K-12 Dive — along with interviews with civil rights lawyers, advocacy organizations and survivors — suggest that schools routinely delay or entirely brush off their responsibilities under the landmark civil rights law. At some point in the process, these schools pass the torch to a third party like law enforcement or a state agency.

Those third parties are often untrained and unqualified to take on Title IX responsibilities that include providing support to survivors and investigating in accordance with the federal statute. In fact, the National Association of School Resource Officers told K-12 Dive SROs do not usually carry out school districts' civil rights obligations under Title IX, and that they do not usually receive Title IX training as part of their core duties.

"Schools remain very eager to see local law enforcement step in and address this in lieu of a school response," said Brett Sokolow, a Title IX attorney and a co-founder of the Association of Title IX Administrators who has worked in the field for over two decades. "And there are a lot of school districts that either still think that that's the right approach, or just defer to it."

Court documents of incidents dating back to the 1990s show this pattern is not new. However, it's one that is now raising red flags for senior officials at the U.S. Department of Education — and for civil rights advocates and lawyers who say they're noticing this trend more frequently.

"I am seeing it distressingly often in investigations right now," said Catherine Lhamon, assistant secretary for civil rights at the U.S. Department of Education, who served in the same position under the Obama administration and also investigated such cases then. "I am very worried that there may be widespread belief in school communities that it is appropriate to defer to law enforcement and not to fulfill their own Title IX obligations to their students." 

Between late July and September alone, for example, the federal agency resolved at least five cases related to districts deferring their duties to third parties to the detriment of their students. 

Districts defer to law enforcement or other in Title IX cases

K-12 Dive reviewed 5 cases recently released by the Education Department's Office for Civil Rights

In those cases, schools looked to law enforcement or other outside parties — regardless of the kind of evidence surrounding the sexual harassment or assault incidents, and regardless of whether the alleged perpetrator was an employee or a student. Sometimes, districts delayed their Title IX responsibilities even without a record of law enforcement requesting that the district do so, or reneged on their responsibilities entirely despite glaring evidence that sexual assault took place.

While OCR rarely makes its pending investigations public, Lhamon confirmed this trend isn't limited to the five recently settled cases. The Education Department's civil rights enforcement arm has additional investigations pending that also raise the issue of schools deferring to law enforcement, she added.

"In the complaints that we're investigating, we are with some routine now seeing an issue of school districts and colleges [and] universities deferring to law enforcement as distinct from fulfilling their own Title IX obligations," Lhamon said. "And that worries me."


Although reporting to law enforcement triggers a criminal justice system response and can be required in some cases under mandated reporting or other state laws, a school district has its own obligations stemming from Title IX even in instances of criminal allegations. Those obligations include investigating on- and off-campus allegations under some circumstances, recordkeeping, and providing supportive measures for students affected by alleged sexual harassment and assault. It also requires schools to protect students from a hostile environment that would exclude them from or limit their education.

Title IX measures supplied by a school district in an educational setting are vastly different from measures taken by law enforcement in criminal proceedings.

"We use different processes. We use different standards," said Maha Ibrahim, a civil rights attorney for nonprofit Equal Rights Advocates. Ibrahim represented Camille in her case, which was resolved with a settlement in 2019.

The exterior of CK McClatchy High School is shown with pedestrian crossing in front of the building
McClatchy Senior High School, where a former student who sued Sacramento City Unified School District graduated from, is pictured above.

Some measures schools can take — after a report or complaint is made and also during the Title IX investigation period — include:

  • Counseling.
  • Extensions on class assignments.
  • Changes to work or class schedules.
  • Campus escort services.
  • Restrictions on contact between the parties.
  • Changes in work locations.
  • Leaves of absence from school.
  • Increased security.
  • Monitoring of certain areas of campus.
  • Other similar accommodations.

If a school's investigation concludes that a Title IX incident created a hostile environment and hindered a student's education, schools are then required to prevent recurrences and sometimes must provide remedies. 

Under no circumstances can Title IX obligations be entirely paused or delayed, according to the Education Department. 

While there may be instances where schools have to accommodate law enforcement activities — like rescheduling a student interview that's part of a Title IX investigation to avoid interfering with a police investigation — districts are required to make sure Title IX procedures, including providing interim support, are ongoing.


When Camille's mother, Ida, arrived at her daughter's school, she was not prepared for what she would hear. She was shocked. She felt confused. She cried. But then she informed Officer Brown she wanted to press charges against the boys who she believed had raped her daughter. 

Ida's name was changed in court documents and again here to protect her privacy.

Brown pushed Camille to not return to the school for the remainder of her junior year while he completed his investigation. “'It's okay, everybody else will forget about it by the end of the summer,'" Camille recalled Brown saying. 

That was just one of the many experiences with law enforcement and the school that Camille and her mother recalled as unhelpful or misleading during that summer, throughout her senior year, and, in fact, until she graduated over a year after the district was first put on notice of her reported sexual assault and subsequent harassment

"No one gave me any information about my rights under Title IX or for anything else," Camille said in court documents filed in March 2018. "No one even so much as asked me how I was doing." 

Camille's grades nosedived from Bs to mostly Ds and Fs, despite assurance from Brown that the school would freeze her grades during what she considered a forced absence from C.K. McClatchy. Meanwhile, her alleged assailants continued to attend school seemingly uninterrupted. 

Ultimately, Brown and other law enforcement would decide not to press charges against the boys. 

And in the end, Camille characterized the entire experience this way in a statement to the court: "I felt like maybe it was my fault."  

Sacramento City USD declined K-12 Dive’s request to comment on any aspect of the case after consulting with its legal team.


This timeline of events is compiled from accounts in court documents from Camille, her mother Ida, and her lawyers. The school district and Sacramento Police Department declined to comment to K-12 Dive with their version of events.

On or around May 21, 2016, during her junior year of high school, Camille is gang raped. Camille is told by her peer that a video shows her unconscious after the assault.

Several days later, a student notifies the school of the rape. The video is shared among classmates.

Camille begins to get prank calls and threats from her alleged rapists. The school directs Camille to school resource officer Joe Brown. Camille's mother Ida is called to the school and is notified of Camille's assault.

Brown suggests she should leave for the rest of the school year so "everybody else will forget about it by the end of the summer." The SRO assures Camille her grades will be frozen during what she considers her forced absence from school.

When Camille returns textbooks in-person at the end of the school year, she finds out her grades had tanked despite assurances otherwise from the SRO.

After a suicide attempt, Camille is diagnosed at the hospital with depression and PTSD from her rape and treatment by the school. A hospital social worker raises the possibility of 504 and IEP evaluations.

Prank calls and threats from her alleged rapists continue despite her mother notifying the school.

Camille's mother calls the SRO about 20 times throughout the summer, with no response.

Schools are required to conclude Title IX investigations within "reasonably prompt time frames." The Education Department says they typically take about 60 days. Probes can, however, vary depending on complexity.

After a Title IX investigation is concluded, a district is required to provide notice of its outcome in writing to both parties.

Camille and her mother had yet to hear back from the district.

Prior to the start of Camille's senior year, the SRO tells her mother "he didn't think he could do much with what he had," and her mother felt he would not be investigating further.

During the fall of Camille's senior year, her mother goes to the school nearly weekly to request help.

Camille's mother goes two to three times to request IEP and 504 evaluations. The school denies those requests.

The school denies Camille’s request to complete her senior year with independent study at home because there is a waiting list to join that program. No additional information is provided.

The school recommends Camille transfer to another school.

Camille continues to face harassment from her alleged rapists, be ostracized by her peers, and be denied accommodations like assignment extensions and breaks during the school day.

Camille's attorney from Disability Rights California helps her request IEP and 504 evaluations that had been denied by the school district until now.

With just a few weeks left before graduation, the school accommodates her request for a 504 plan. By this time, Camille's grades have already taken a hit.

Camille, who once had a B average, graduates with mostly Ds and Fs.

Julia Himmel/K-12 Dive

In the cases K-12 Dive reviewed, districts' decisions to hand off their Title IX responsibilities to untrained third parties — rather than having them handled by a designated and trained Title IX coordinator as required by federal regulations — were often followed by incomplete investigations, victim-blaming or a biased view of survivors' experiences.

Nonetheless, these are the same outside parties that districts sometimes rely on to guide the outcome of Title IX allegations, according to K-12 Dive's review of OCR documents. 

An investigation into Pflugerville Independent School District in Texas, for example, found a district social worker involved the police department, which — after investigating, and after the county district attorney declined to prosecute — closed an alleged case of sexual assault during the 2018-19 school year "due to a lack of corroborating evidence."

When the Title IX complainant requested a no-contact order between the student and the alleged assailant, the school told her it couldn't provide one because no criminal charges had been made in the case, according to OCR documents. No-contact orders are allowed by Title IX under certain circumstances.

Meanwhile, a school building administrator claimed in the OCR investigation that a no-contact order was actually in place — but the district did not show documentation to prove it.

After the police investigation, Pflugerville's superintendent hired an outside investigator. 

That investigator told OCR the student's "credibility went down based on her responses to questions about whether she tried to scream during the alleged incident and her physical demeanor during the interview," according to the agency.

The investigator never interviewed the alleged harasser because "she just did not think the assault happened," OCR documents show. 

Yet various research has shown that victims of sexual assault often report freezing — rather than screaming or otherwise resisting — due to an involuntary biological response.

The outside investigator also said she didn't interview the alleged harasser because she could not locate him and that "interviewing additional witnesses would have dragged out the investigation," per the federal agency's findings.

In the end, the district's Title IX coordinator adopted the outside investigator's findings and told the complainant that the district could not confirm the alleged sexual assault took place.  

"By her own admission, the Title IX Coordinator's only involvement with this complaint consisted of issuing the final notice of the outcome," said OCR. 

Pflugerville Independent School District did not respond to K-12 Dive's multiple requests for comment.

Because Title IX investigation outcomes often influence whether districts work to prevent future incidents, skewed results can ultimately lead to long-term systemic failures to accommodate survivors and ensure their physical, social, emotional and academic well-being. 

Sometimes, deferring to third parties while districts pause or abdicate their Title IX responsibilities also perpetuates a system that leaves the door open for future harassment or assaults.

"It's a matter of connecting the threads and realizing that the issue isn't district by district, it's systemic," said Sokolow. 


"Gulliver's Travels" was playing on the classroom television when Thomas Matthews — then a 3rd grade teacher — put Karen Freeman's daughter on his lap. 

At the back of the classroom, with the lights off and the rest of the students facing the TV in the opposite direction, Matthews "proceeded to slide his hand into her underwear and placed his fingers in her vagina and moved his fingers in and out of her vagina for approximately one hour," court documents describe. As the movie ended, Matthews "removed his fingers from SF's vagina" and told her to go back to her seat. 

The next time this happened, later that same month in June 1999, students were watching "Oliver Twist." Freeman's daughter, SF, would turn 8 by the end of that school year. 

Since she was a minor, SF's name was abbreviated in the court documents detailing these incidents that K-12 Dive reviewed. 

Throughout the 1998-99 school year, during which SF was in Matthews' class, the teacher molested her about once a week. And when a custodian witnessed and reported one such incident, it wasn't the first time the district had been notified of Matthews' behavior at Shohola Elementary School — far from it. 

A birds-eye view of Shohola Elementary School in Delaware Valley Unified School District
Thomas Matthews, who was later convicted for sex crimes against his former elementary school students, taught at Delaware Valley School District’s Shohola Elementary School (pictured above) in the 1990s.
Retrieved from Ryan Balton/YouTube on December 12, 2023

In fact, a civil rights complaint filed on behalf of the Freemans a decade later, in 2008, against Delaware Valley School District for Title IX civil rights violations shows the district was aware of Matthews' behavior as early as November 1994, or four years prior to his repeated assaults on SF. 

Around three years prior to SF's molestation, in the 1995-96 school year, the district was made aware of the sexual abuse perpetrated by Matthews — including massaging and rubbing — against two other elementary students. 

But each time a complaint was made, and after brief investigations by the principal and superintendent, the district allowed Matthews to return to the classroom with nothing more than a single seven-day suspension, warnings to "not touch or pester any female employee or person," and threats of job loss if his actions continued. 

They continued. 

"Your continued failure to understand the seriousness of your actions is of great concern to the district," wrote then-Superintendent James Melody to Matthews in a March 1996 note, about two years before the abuse of SF began. "In summary, this incident was not isolated."

But instead of conducting a thorough Title IX investigation and then following through on its responsibilities to ensure Matthews couldn't continue his pattern of behavior that left the school unsafe for children, the district increased his access to students. 

In December 1998, a month after Matthews had begun molesting SF, he was appointed team coach for the elementary school's Odyssey of the Mind program, an extracurricular activity that the district website says can begin as early as kindergarten.

In June 1999, the same month Matthews sat SF on his lap and digitally penetrated her, he was named student council advisor. 

While the suit details the molestation of five students over the course of five years, Matthews taught at the district for some 18 years between 1982 and 2000, when he resigned after an additional allegation surfaced. During those nearly two decades, he taught grades 2, 3 and 4. 

On Nov. 2, 2006, Matthews was sentenced in criminal court to 11 ½  to 24 years for sex crimes against minors. 

Among the jury's findings were two counts of aggravated indecent assault of persons younger than 13 years, two counts of corruption of minors, and 19 counts of indecent assault of persons younger than 13. 

The decision came one decade after Delaware Valley School District was first notified of Matthews’ sexual advances toward elementary students, and one decade after it was required by Title IX to take steps to prevent its recurrence. 

K-12 Dive reached out to multiple past and current school and district employees for Delaware Valley School District who declined to comment on the case, while others could not be reached.


At least five cases settled since July by OCR include various incidents showing districts to have failed their students at nearly all points of the Title IX process while relying on law enforcement instead. The cases document how districts, in a number of separate instances, failed to report, investigate, offer interim supportive measures during investigations, properly discipline students, or notify students or families of the outcome of their complaints. 

In New Jersey's Newark Public Schools, for instance, the district was found to have abandoned its Title IX responsibilities to investigate complaints in both student-to-student and employee-to-student incidents.

In a 2018 incident involving a Newark elementary school teacher alleged to have had four sexual encounters with a student — including watching pornography, masturbation, oral sex and attempted anal sex — the district notified the Newark Police Department and the state's Department of Children and Families' Institutional Abuse Investigation Unit, a third-party agency. 

But while the investigation unit substantiated allegations of sexual abuse and molestation nearly a year after the student reported them, the district never investigated on its own whether the teacher violated Title IX, because it was "not our role to investigate," the district's harassment, intimidation and bullying specialist told OCR. 

Overall, OCR found the Newark district didn't investigate any alleged incidents that the federal agency reviewed of employee-to-student sexual harassment and assault during 2017-2020, and further found that this failure happened before and continued after that three-year period. The district declined K-12 Dive's requests for comment.

In Texas' Garland Independent School District, OCR found the district "routinely delayed its investigations until after law enforcement concluded its activities" and did so sometimes without even asking law enforcement if a delay was necessary, according to a July letter sent to the district after the investigation's conclusion.

In the interim, school and district officials failed to provide student survivors with support — despite eventual findings from law enforcement of substantiated claims of harassment or assault — and responded largely by disciplining students. These failures persisted despite evidence in some alleged incidents.

In one case of alleged student-to-student sexual harassment in Garland ISD, the district completed its Title IX investigation within nine days, but took no disciplinary action until after law enforcement arrested the two alleged harassers — which came 35 days after the complaining parties filed reports. Outside of a stay-away agreement put in place a week after the initial reports, OCR found no evidence the district provided any other interim measures during its investigation or after it determined that alleged sexual harassment had occurred. 

Another case — this time caught on video — showed a male student "apparently forcing" a female student to perform oral sex. According to the incident file, the alleged perpetrator was arrested and charged with felony rape. 

Despite the video evidence, OCR found the district "responded to the incident solely in the disciplinary context." The district failed to produce evidence showing it offered the girl any interim support or had investigated whether she had faced a sexually hostile environment — both required by Title IX. 

The district disagrees with OCR's findings in the case, and it maintains that it consistently followed state education and penal codes by removing students charged with sexual assault from campus.

"While OCR may not always agree with our nomenclature, students were addressed under the District’s student discipline process, so as to ensure student safety," said Garland ISD spokesperson Jason Wheeler in an email. "GISD takes the most aggressive approach allowable under Texas law to respond to severe student discipline issues, including sexual harassment and sexual assault." 

The district did not address Title IX compliance concerns, like providing interim support, in Wheeler's response to K-12 Dive.

Overall, OCR's review of Garland ISD found only 6 of the 48 records the district provided of student-involved sexual assault between 2017 and 2020 showed the allegedly harassed student had been offered or provided "some form" of interim measures.

"The vast majority of the files that we reviewed reflected that the school didn't offer those supportive services to students," Lhamon said. "That is heartbreaking, and flatly inconsistent with the school's obligations under Title IX." 

Sometimes, districts even fell short in disciplining alleged perpetrators of sexual assault. In one incident reviewed in OCR's investigation of Utah's Alpine School District, an administrator overseeing a Title IX incident allowed the mother of a student who "touch[ed] a girl between her legs using 3 fingers" to set the consequences for her child. 

Ultimately, it's the victims who pay the often hefty price of districts' failures to abide by Title IX. 


Approximately 1 in 6 boys have been sexually abused before the age of 18 in the U.S.

That number is higher for girls, at 1 in 4.

Approximately 27% of 14- to 17-year-olds in the United States have been sexually victimized in their lifetimes.

An estimated 10% of K–12 students will experience sexual misconduct by a school employee by the time they graduate from high school.

Though staggering, these numbers are likely an underestimate due to reporting barriers.

One of those barriers is law enforcement involvement, say Title IX advocates and lawyers.

Still, some schools continue to involve law enforcement and other untrained outside agencies, sometimes against students' preference or without permission.

In those schools, the result is a culture that potentially deters reporting, denies students accommodations, and makes it difficult for students to achieve academic and social-emotional success.

Julia Himmel/K-12 Dive

By the time Camille returned to C.K. McClatchy for her senior year — and following what she considers a forced absence from school at the end of her junior year — things had escalated even more.

Throughout the summer, Camille had received death threats and harassing phone calls from those whom she believed to be her assailants. 

"I would answer the phone and hear a bunch of boys on the other line breathing," she recalled in her lawsuit. "They would call over and over and over again until I picked up." One boy threatened to "beat [her] ass."  

During her senior year, Camille's alleged rapists bragged about "having sex" with her, called her a "slut" and a "liar," and laughed and stared at her in the hallways. 

The threatening phone calls and subsequent bullying would continue for the remainder of her senior year, and for months even after her graduation in 2017, despite repeated pleas from Camille and her mother to Officer Brown. 

Later, Camille would see Brown, who never spoke with her again after her initial interview, "talking and laughing with the boys who raped me." The Sacramento Police Department, which employed Brown at the time and continues to do so today, declined to share its version of events.

However, the police department did say in an email that Brown had been trained under Title IX as part of school district policy. Brown could not be reached for comment, despite multiple attempts to locate him through the police department and the school district. 

K-12 Dive also requested the release of Sacramento Police Department’s records under the Freedom of Information Act to locate information related to the involvement of Brown in Camille’s case. SPD declined to share such records, which it said were related to an investigation and therefore exempt from disclosure.

The above documents were obtained by K-12 Dive from Sacramento Superior Court.

"Going to school was like going to prison," said Camille. "I felt like the school was not a safe place for me, since no one was doing anything to stop the behavior … I had to walk down the hall and see my rapists every day, many times per day." 

Camille's grades began to decline after she was denied an individualized education plan evaluation for special education and a Section 504 plan evaluation for disability accommodations, which she requested to navigate mental health challenges following her rape. She recalls being denied requested breaks during the school day and extensions on her assignments. She developed stomach problems, and she lost 35 lbs. during her senior year. 

In June 2016, Camille attempted suicide. Her diagnosis: depression and PTSD as a result of the alleged rape and her subsequent treatment by the school. 


As in Camille's experience, districts that often delay Title IX processes or sweep them under the rug — relying instead on law enforcement or other third parties to intervene — can create ongoing hostile environments to the detriment of their students. 

Survivors who spoke with K-12 Dive cited feelings of depression and isolation, as well as difficulty completing coursework. 

"Their experience with school has already been sort of irrevocably damaged," said Ibrahim of survivors like Camille with whom she's worked. "Even though they may have physically been still attending school — showing up — they were shells." 

They also said they had dropped out of extracurriculars. Oftentimes, multiple survivors attending the same district and even the same school reported these feelings. 

In many instances, affected students leave their districts to complete their education elsewhere. "They just get themselves out of the environment," said Title IX attorney Sokolow. "So they're really being denied educational access that Title IX was designed to preserve." 

OCR's case findings show much of the same.

"As we investigated we heard the same story again and again," one principal noted in cases where Utah's Alpine Unified School District allowed teachers to resign or retire without investigating whether the teachers' misconduct created a hostile environment for students. The principal called it "eerie how similar the stories were, though most ended early with students transferring or quitting." 


A K-12 Dive analysis of the OCR cases and additional anecdotal evidence from survivors suggests districts that shirk their Title IX responsibilities in favor of law enforcement are often the same districts that have discrepancies in reporting, poor recordkeeping practices, and scant training for staff. 

Garland, for example, clocked zero incidents of student-on-student sexual assault in the 2017-18 school year, one incident in the 2018-19 school year, and then 47 incidents in the 2019-20 school year. Staff-involved incidents of sexual assaults during those years similarly started at zero, jumped to three the following year, then doubled to six during the 2019-20 school year. The district serves over 50,000 students.

Two Garland high schools that served up to 2,500 students each reported zero documented incidents during the entire three years. 

In another example, Alpine School District reported one sexual assault in the 2017-18 school year through Civil Rights Data Collection. However, when OCR inquired about the number for its investigation into the complaint against the district, the count jumped to 20 for the same school year.

The Utah school district did not respond to K-12 Dive's multiple requests for comment.

Not only do some districts fail to properly count incidents of sexual harassment and assault in their education programs, they also can fail to properly document steps taken in such incidents. 

In some cases OCR reviewed, for instance, incidents that would be considered sexual harassment or assault under Title IX were miscoded by schools or districts as bullying, intimidation or criminal behaviors. 

Perhaps as a result of such miscoding, districts don't always involve their Title IX coordinators and instead rely on untrained staff, third-party agencies or law enforcement to respond. This is despite federal Title IX regulations requiring districts to appoint a trained and unbiased Title IX coordinator to carry out responsibilities like investigations and providing supportive measures. 

"At best, we find schools that just think it's an overwhelming topic, and they're afraid of it and they'd rather push it off on some other 'professional,' and unfortunately, they think law enforcement is that professional," said Ibrahim, the civil rights attorney who represented Camille during the 2019 case. "At worst, they're looking for this kind of an invitation to shove it off."

In Newark, the district's Title IX coordinator did not coordinate the district's Title IX efforts up until at least August, when OCR released its findings. 

OCR in fact found no evidence that Newark's Title IX coordinator was involved in investigating any of the 38 student-to-student incidents reviewed. Instead, the district's anti-bullying coordinator was responsible for overseeing alleged Title IX student-to-student violations. And incidents involving employees weren't investigated by the district at all —  instead, they were handed over to the New Jersey Department of Children and Families.

According to records provided to OCR by Alpine Unified School District, the Utah district involved its Title IX coordinator in its response to only one of the 92 reported sexual assaults during the federal agency's review period. 

And even when Title IX coordinators are present to oversee districts’ compliance with the civil rights law, K-12 Dive's analysis of the cases show these employees are sometimes undertrained, overworked, or both. 

In Garland ISD, for example, the Title IX coordinator informed federal authorities she hadn't received Title IX training until October 2020 — a year and a half after she began in that position. 

Coordinators in Garland and other districts OCR investigated often served in multiple capacities, perhaps leaving little time to focus on Title IX.  In the two Texas districts, some of those additional roles included being interim principal, chief of academics and leadership, or assistant director of student services. 

Perhaps as a result, school administrators sometimes couldn't even identify their district's Title IX coordinator. In Newark, out of 27 current and former district employees interviewed by OCR, only 12 knew the coordinator's name. 

"The Title IX coordinator is literally nowhere ever. They are a ghost," Ani Chaglasian, an 18-year-old advocate and survivor from Los Angeles, told K-12 Dive. Chaglasian is the co-founder of Protect Kids Not Abusers, a student-led organization advocating to end violence against and online exploitation of children and youth.

Chaglasian says Burbank Unified School District, where she is currently a student, didn't adequately respond when she notified staff that her tutor had posted hundreds of explicit images of her online. Chaglasian did not want to go into details of her case, but she alleged that harassment led her to drop out of in-person schooling between March 2022 and January 2023 and attend a virtual independent study program at a nearby district. 

Following her experience, however, Chaglasian became a well-known Title IX advocate for other survivors in her district. Over the past two years, Chaglasian says she has assisted her peers in filing over 150 Title IX reports or complaints in the 14,300-student district. 

Email screenshots provided by Chaglasian show her peers relying on Chaglasian to access resources and information following alleged sexual harassment or assault. The screenshots show Chaglasian connected students with local law enforcement, which she says was done at the district's urging.

For instance, one screenshot shows she wrote in a March 31 email to Steve Ferguson, president of the Burbank Unified School District Board of Education, that she had connected students with a sergeant at Burbank Police Department and attorneys. 

"I'll continue to push the resource out," Chaglasian wrote to Ferguson, but added that students were too "anxiety-riddled" to speak with law enforcement, and that they were "extremely hesitant to retraumatize themselves for the same output."

Ferguson declined to speak with K-12 Dive.

Students protest Burbank Unified School District by holding signs
Ani Chaglasian, a sexual harassment survivor and student advocate at Burbank Unified School District, is pictured in March 2023 holding a protest sign that reads "JBHS Protects Rapists."
Permission granted by Ani Chaglasian
Students hold protest signs
In March 2023, students protest Burbank Unified School District's handling of sexual harassment and assault complaints.
Permission granted by Ani Chaglasian

Deferring Title IX obligations to police or state agencies is especially anxiety-inducing for students of color and immigrant students, given the historically fraught relationship the groups have had with law enforcement. These are also some of the same student populations that are more likely to experience sexual violence and who also may have more trouble accessing legal representation.

"When the school is, from the get-go, trying to abdicate its responsibility to the police — that chills reporting significantly," said civil rights attorney Ibrahim. "Even more than it's already chilled." 

Years after Camille graduated from Sacramento City Unified School District, for example, her case is seen as a reason "why you don't report to the school if something happens to you," Ibrahim said. 

The civil rights lawyer added that awareness has become especially entrenched in the immigrant Latino community, to which both Camille and her assailants belonged. 

"Because they will send you to the school resource officer for the Title IX investigation," Ibrahim said. "That might even be worse than what happened to you. They're not going to protect you. They're gonna send you to the cops."  

The above documents were obtained by K-12 Dive from Sacramento Superior Court.

Chalina Morgan-Lopez, an Afro-Latina who survived sexual assault on the other side of the nation in North Carolina, said she would face a similar dilemma — if for a different reason. 

"When a Black man harms you, especially as a Black woman, you're less likely to report to law enforcement, because you fear what a police officer might do to him," said Morgan-Lopez, who is also a board member of SafeBAE, a nonprofit organization founded by teen sexual assault survivors that advocates for Title IX awareness in public schools. "Is it really worth putting his life at risk?" 

When deciding on the answer to that question, Morgan-Lopez says, sometimes a Black survivor may have to consider this: It's "me or him." 


The increasing frequency with which OCR is noting school districts deferring to law enforcement in its investigations coincides with an increase in overall Title IX complaints — and specifically an increase in sexual harassment complaints — over the past decade. 

In 2012, OCR recorded 350 complaints related to sexual harassment. One decade later, in 2022, the Education Department's civil rights enforcement arm received more than double that number, 833. 

As of Dec. 8, OCR had received some 673 sexual harassment-related complaints this year. However, the agency does not code its Title IX cases to indicate whether law enforcement was involved.

Given this, and a lack of federal data tracking this situation, it's difficult to corroborate the anecdotal evidence OCR officials note in their cases or whether this reflects trends in districts nationwide. 

Sokolow, whose organization works with districts nationwide on Title IX matters, estimates that at least 60% of districts are semi- or noncompliant with Title IX overall. Contributing to the problem is a lack of school resources to comply with civil rights laws in general, as well as increased turnover among their staff that work with Title IX, he said.

Because of that turnover, the few districts that are investigated by the Education Department eventually return to noncompliance after their federal monitoring period expires, he said. 

"It's kind of like the Wild West," Sokolow said. "It's really challenging to maintain any consistency among schools, because we can't keep people in the seats."

Lhamon said the department is unsure why it is seeing cases more often in which districts are deferring to law enforcement.

However, advocates and lawyers have a hunch: Former Secretary of Education Betsy DeVos' 2020 Title IX regulations — now in the process of revision by the Biden administration —  increased protections for accused perpetrators of sexual harassment and assault. As such, they have made districts hyper-alert about potential liability when following Title IX procedures, including investigating sexual harassment or assault complaints.

"We went from very informal resolution to very due process-centric approaches that became slow, cumbersome and very, very adversarial," said Sokolow.  

The regulations provided an advantage to accused students by making it harder to find them in violation of Title IX. 

The change of one word, from "or" to "and," contributed to that shift. While the Obama-era regulations prevented harassment that was "severe, pervasive or objectively offensive," regulations finalized under the Trump administration required harassment to be "severe, pervasive and objectively offensive." 

This changed the definition of "harassment" to one that required districts to tick off more boxes when investigating formal sexual harassment or assault complaints. 

What's more, the regulations permitted for the first time the use of a standard of "clear and convincing evidence" when deciding whether incidents took place. This standard — a higher one than the "preponderance of the evidence" typically followed by school districts in Title IX cases — is also used in some criminal proceedings. 

Schools were also required to assume a "presumption of non-responsibility" for alleged assailants until proven otherwise, according to 2020 regulations.

"You can put that kind of evidentiary standard on the government before they're allowed to take away somebody's freedom," said Ibrahim of the distinction between law enforcement and Title IX proceedings. "How dare you put that kind of evidentiary standard on a student who is merely seeking protection from their school for what is supposed to be a student misconduct investigation?" 

Proponents for Devos' rule say it provided necessary protections for those accused of committing or being involved in sexual harassment incidents. 

In the Obama administration's rules and the new proposals under President Joe Biden, "there's no accountability for complainants, so a complainant can make up the story," said Keith Altman, founder of K Altman Law and an education attorney who often defends students accused of sexual harassment under Title IX. 

In those cases, Atlman said, DeVos' regulations provide protections for the accused student from being wrongly disciplined. "If a complainant loses in these circumstances, typically there are no long lasting effects for the complainant," he said. "But if a respondent loses, it can be devastating to their educational progress." 

Biden's proposed regulations, which the Education Department has not yet finalized, say that using the "preponderance of the evidence" standard of proof for Title IX investigations "would best promote compliance with Title IX," but allows institutions to use a higher standard of proof — “clear and convincing evidence” — in some cases. 

They also define harassment as "sufficiently severe or pervasive," a much broader definition than those under the 2020 regulations.

With Title IX regulations set to change for the third time in the span of three administrations, advocates and lawyers are closely tracking what's next. 

Petition against Delaware Valley High School
A Delaware Valley High School student launched an online petition in 2021 to protest how the school handled a sexual harassment incident.
Retrieved from Change.org on December 12, 2023
Petition against Delaware Valley High School
Former Delaware Valley School District students signed the petition because they say the district had repeatedly allowed harassment and assault to continue.
Retrieved from Change.org on December 12, 2023

As regulations fluctuate, systemic Title IX failures can perpetuate a cycle of noncompliance, underreporting or poor recordkeeping, and ongoing hostile environments over years or even decades.

Delaware Valley School District, which employed child molester Thomas Matthews for nearly two decades, was again accused in 2021 by a high school student and her mother over what they said were Title IX failures after a series of alleged student-on-student harassment incidents. The student and her mother said the district didn't properly respond to their sexual harassment complaint, leading to a student-led protest and a petition challenging the district's sexual harassment response with 233 signatures. 

Many of those signing the petition say they were former students who had experienced an environment where they felt unprotected from sexual harassment or assault.

Ani Chaglasian, who described her Title IX coordinator as a "ghost" inaccessible to her and other student survivors, watched the same employee be unanimously named superintendent by Burbank Unified School District's school board this past September. The current superintendent and former Title IX coordinator of Burbank Unified School District, John Paramo, declined to comment after initially agreeing to a conversation with K-12 Dive. 

The same district was sued last year by two students who claim it knowingly employed high school teacher Rex Bullington, an alleged child molester, for years. The two students suing the district were allegedly molested 18 years apart.     

Camille ultimately received a $400,000 settlement in her case against Sacramento City Unified School District. The settlement came more than two years after her graduation and three years after the alleged 2016 assault. 

Some of the original defendants, including Brown, were dropped from the lawsuit after it was filed. The social worker and the school counselor who Camille and her mother looked to for guidance remain employed by the district today. These employees declined to comment or did not respond to requests from K-12 Dive. The district noted that it no longer has SROs in its schools.

Camille, meanwhile, decided to use a portion of her settlement toward nursing school — per her original plans that she and her lawyers say were pushed off track because of the district’s actions. 

Still, she had this to say in 2019 when her case was settled: “I want people to know that even if nobody believes you, you need to have the strength to let other people know. Even if it might seem really scary and you feel like the whole world is against you, in the end, it ends up being beneficial not only for you, but for everybody else.

"And that’s the only way change is made.”

Editor's note: If you or someone you know has experienced sexual violence or abuse, resources are available for support from the Rape, Abuse & Incest National Network.

Visuals Editor Shaun Lucas contributed to this story.