January 28, 2015
Filed Via Email: ocr@ed.gov
United States Department of Education
Citigroup Center
Attn: Office for Civil Rights
500 W. Madison Street, Suite 1475
Chicago, IL 60661-4544
Telephone: (312) 730-1560
Facsimile: (312) 730-1576
OCR.Chicago@ed.gov;
RE: Chandler Ackers, Jessy Silfer, Natalie Cafone and Dani Hemeon on behalf of
themselves and others similarly situated v. The University of Iowa.
Director of Office for Civil Rights:
Please consider this a civil rights complaint filed against the University of Iowa1 by four current
female student athletes who have been subjected to the discriminatory application of policies and
practices within the University of Iowa.
These practices have and will continue to result in the removal of highly qualified female coaches,
including but not limited to Complainants’ coach Tracey Griesbaum who was terminated on
August 4, 2014. The University of Iowa’s actions are thereby denying female student athletes the
benefits of their student-athlete experience because of sex in violation of Title IX.
An informal investigation shows that the removals of six highly qualified female coaches from
December 2008 to August 2014 resulted from discriminatory practices and decision-making
because of sex at the University of Iowa by its Athletic Department under the supervision of the
current Athletic Director, Gary Barta.
The key practices motivated by sex or gender stereotypes that have harmed student athletes are:
1. The University investigates and treats differently male and female student athletes who
raise concerns about their athletic experience.
2. The University investigates and treats differently male and female coaches who are the
object of complaints made by male and female student athletes.
3. The University engages in different practices and standards when investigating female
coaches.
4. The University permits males to engage in different coaching methods and treatment
of athletes than females.
5. The University generally holds female coaches to a higher or different standard than
male coaches.
                                                            
1
The University of Iowa, Office of the President, 101 Jessup Hall, Iowa City, Iowa 52242-1316, Phone
Number: 319-335-3549. The University of Iowa is an extension of the State of Iowa and represented by
the Iowa Attorney General’s Office.
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 6. The University has engaged in a pattern of removing highly qualified female coaches
because of gender.
7. The University refuses to investigate allegations of discrimination or violations of Title
IX when raised by student athletes.
Complainants allege that the University of Iowa has discriminated against them on the basis of sex
by engaging in these and other practices that either are discriminatory or have discriminatory
effects, in violation of Title IX of the Civil Rights Act of 1964 and its regulations. 20 U.S.C. §§
1681-1688; 34 C.F.R. Pt. 100, App. B.
Counterintuitive Issues of Gender Bias
There are a number of seemingly counterintuitive concepts and other foundations that are therefore
necessary to properly identify how gender bias is in play and harming the experience of student
athletes in violation of Title IX.2
Title IX has long been used as a means to regulate the denial of facilities or scholarships or the pay
of coaches. This “top down” approach has often overlooked how those differences in the
distribution of resources reflect the operation of gender stereotypes or gender bias. The harm from
gender biases, double standards and stereotypes are the primary source of continued inequality in
collegiate athletics.
Regardless of how Title IX has been applied to deal with differences in numbers – pay, facilities,
scholarships – there is no question Title IX protects female student athletes and female coaches
from gender discrimination. In a broad sense, this protection can mean ensuring that female
student athletes are entitled to the same experience as male student athletes. While that has been
                                                            
2
One counterintuitive set of facts might be that females (SA’s) are complaining about females (coaches)
and/or that Tracey Griesbaum (female) was replaced by a female and/or that there were females in the
decision-making process within administration. Therefore, with women involved how can gender bias be
present and working adversely to women? These issues can easily be explained and these facts do not
undermine the presence of gender bias, but either support it or at fit clearly within the pattern of how we
expect gender bias or stereotype to flow within a system that has women present but is controlled by male
decision-makers. For example, young female SA’s, just like their parents, can hold female leaders to a
different standard than males. Therefore, complaints by one female toward another does not mean gender
bias is not at work. Further, it is the reaction of administration to the complaints of young female SA’s
that is the major source of gender bias, not just the fact that a complaint was made. Regarding Coach
Griesbaum being replaced by a female, we all should know that stereotypes can easily result in one type
of female being preferred over another and indeed, that concept is at the very heart of a stereotype or
double standard. One minute the “softer” female is preferred and/or the “harder” female is no longer is
welcome, but in each case the opposite can be true. The point is that administration is making choices
about the type of woman they require, rather than the type of person. Further, when dealing with gender
bias and stereotype, other females in administration can hold each other to different standards based on
gender bias or react more strongly to a complaint about a woman compared to a man because of
expectations about how women are supposed to care for young adults compare to men. However, it is also
clear in this case that women were at best carrying water for males in positions of power and that Gary
Barta and Fred Mimms (two males) were the persons with the most influence over these processes.
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 focused on providing them with a decent playing field or comparable coach, it is clearly more than
that. It means that female student athletes should be entitled to the same level of competitiveness
experienced by males and it certainly means female student athletes should not be coddled or
dismissed as secondary to male student athletes based on outdated or patronizing views of the role
of women. It, of course, means that female students and coaches should not be treated differently
from male students or male coaches.
Gender bias is also not specific to a student or to a coach. Gender bias flows around women. It
can flow differently around different women. It flows in a manner where bias that adversely affects
one women will also adversely affect another. That is true even if, on the surface, one women
appears to benefit from action taken against the other women because of gender bias.
To fire female coaches for using coaching methods that are exactly the same as methods used by
male coaches is gender discrimination. This creates harm to the female coach, of course, but it
undermines the right of female student athletes to receive a similar experience to male student
athletes simply because of their sex and/or the sex of their coach.3
Title IX guarantees that female student athletes will not have the benefits of their participation in
athletics—uniforms, scholarships, facilities and coaching staff—denied or removed because of
gender.
This Complaint does not suggest the Complainants believe they are entitled to a specific coach.
Coaches may voluntarily or involuntarily leave for a variety of reasons that have nothing to do
with sex. However, Title IX ensures that their benefits as student athletes, including coaches, are
not removed or fired because of gender or sex. Removing Women’s Field Hockey Coach Tracey
Griesbaum because of her gender is just as much a violation of Title IX as taking away the team’s
uniforms because of gender.
This removal harms female student athletes because Coach Griesbaum met the highest standard of
coaching. While it is a clear detriment to the team to lose the skills and experience of Coach
Griesbaum compared with her replacement (a coach without any head coaching experience), even
if Coach Griesbaum was replaced someone who had exactly the same experience or ability, the
student athletes’ rights would be violated by the removal of their coach because of sex, or gender
stereotypes. Further, the issue at this stage is not the degree of harm, but the fact of harm resulting
from gender bias.4
                                                            
3
If we fire a coach because their methods appear harsh or appear mean, or appear intimidating to a
female student athlete because we think the female is sensitive or cannot take it or because of gender
stereotypes about the female student athlete, then we are firing the coach because of the gender, or sex of
the student athlete. If we fire a coach because her methods appear harsh or appear mean because we
apply a double standard or gender stereotype to the female coach then we are firing the coach because of
gender. In this case, we have both in play and either way, the source of the problem is gender or sex.
4
For example, if Pat Summit (1000 wins) is fired because she is female, or because of gender stereotypes
about her methods of coaching, but she is replaced by John Calipari, the fact that the female team may
still have a competitive program because of a similar skill set of the head coach does not undermine the
harm done by removing coach of a female team because she is female. Of course, Tracey Griesbaum
clearly has much greater head coaching experience than her replacement in this case.
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 Within this Complaint there is evidence of a pattern of treatment affecting several female coaches.
This evidence is here because the fundamental question regarding whether the Complainant’s or
other SA’s rights were violated concerns sex or gender. One of the primary sources of evidence
showing that sex was involved is that Coach Griesbaum is simply the latest in a disturbing pattern.
From 2008 to 2014, five other highly qualified female coaches were also removed or otherwise
subjected to discrimination because they are female and/or because their student athletes were
female.5 While such a pattern should not be necessary to show gender discrimination, it is evidence
that is disturbing on a number of levels.6
There is also evidence that when females or their parents complain about strong female coaches,
those complaints about that female coach result in an exaggerated response by the University.
Those complaints are then investigated entirely out of proportion to the facts or the actual risk to
the student athletes. This often occurs when a female student athlete or a parent uses pejorative
labels at risk from stereotype without facts to support them. Labels such as “bully” or “abusive”
or “intimidating.”
When male student athletes are actually physically harmed by the behavior of male coaches (13
male football players put into the hospital7), the University not only supported the male coach who
physically harmed the athletes by assuming the coach acted in good faith, but honored him by
giving him coach of the year8.

                                                            
5
The University may claim, for example, that they fired these coaches because they had more complaints
by SA’s than males. However, this is simply the operation of gender stereotypes toward female student
athletes as the number of complaints for coaches of female teams and particularly female coaches of
female teams will always be higher given that the players, the parents and administration place different
standards on female leaders to manage or reduce the risk of minor injury or emotional injury to young
females.
6
The University may point out that five of these coaches were also gay. That does not undermine in the
slightest that the behavior toward these women was primarily based on gender. There is a clear
connection between gender stereotypes and the fact that several of these coaches were also gay women.
Stereotypes have long associated male behavior positively with leadership and female behavior with
being limited to nurturing or family. Each of these gay women became subject to discrimination when
they were expected to resolve the emotional concerns of young females (investigated, pushed out or
terminated because of SA complaints) and/or when they each attempted to exercise their rights to start or
maintain a family relationship. One of the coaches adopted children, another got married and a third
moved in with their partner. Therefore, on the one hand exhibiting more agentic behavior (male) is
necessary for women (gay or not) to be accepted as a coach at any level. However, these women were
then harmed or punished by both a) the perceived failure to step away from agentic behavior when
preventing emotional upset of female students, and also b) when they intentionally sought to step away
from agentic behavior by starting a family or getting married. Therefore, while Coach Griesbaum may
have a separate claim for bias related to sexual orientation, it should be clear that the issues in this case
are all clearly and primarily connected to gender bias, stereotypes and double standards.
7
http://usatoday30.usatoday.com/sports/college/football/story/2012-06-27/iowa-rhabdo-football-playershospitalized/55866740/1
8 http://espn.go.com/blog/bigten/tag/_/name/chris-doyle
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 Further, when female student athletes (such as the Complainants) questioned their rights under
Title IX and questioned potential discrimination or violations of their rights by males in leadership
roles, their inquiries were ignored and dismissed.
Therefore, in addition to the pattern of gender discrimination toward female leaders, it is also clear
that regardless of whether the source of the complaint is male or female, the reaction of
administration to that complaint is both different and harmful.
Indeed, an exaggerated response to a female complaining about a female leader because of gender
stereotypes harms not only the coach, but also the other non-complaining teammates of the few
complaining females. These complaints enabled by the University interferes with the playing
experience of the females on the team who continue to approve of the coaching methods of the
female coach that are proper and have allowed them to remain competitive.
The University’s stereotype-motivated reaction to a minority group of females on the team
emotionally upset by the methods of the female coach also harms the females who complained. It
enables stereotypes about them as well as the coach and completely undermines the experience of
the entire team. It also does nothing to protect the females from actual abuse or harm. Finally, it
also harms the male student athletes who may desire to report actual abuse or harm, but are
dismissed because of gender stereotypes that associate their reporting with being more like women
than men.
It is clear at the University of Iowa responds differently depending on whether the object of the
complaint is male or female. The response is different and powered by gender stereotype. It is
also clear that the response is different and powered by gender stereotype depending on whether
the source of the complaint is male or female. Either situation results in harm to female coaches
and female student athletes and has resulted in harm to the Complainants, their team and to all
women’s programs at the University of Iowa. 9

                                                            
9 The gender bias that filters information in response to the complaint of a student athlete toward a female
coach (negatively toward the female coach) will also work in reverse or in a way that will continue to
harm female students as a whole. When a female student reports allegations of sexual assault toward a
male, the complaint of the student is often ignored and one reason is because that complaint is muted by
the operation of the same gender bias that can exaggerate the concern of the female student when directed
toward a female coach. This is part of why the issue of sexual assault has continued despite our agreement
(as a society) that women have a right to say “no.” This muted reaction to a complaint by a female against
a male for sexual assault is simply on other side of the bias coin to what is causing the exaggeration of
female complaints when directed at a female in a leadership role. This issue has appeared at Iowa just as
it has around the nation. (See- Iowa Athletic Department Cover-Up of Sexual Assault Investigated The
University of Iowa seems poised to join in ignominy the likes of University of Washington, University of
Colorado, ASU, Hofstra and the University of Georgia, all of whom have had to defend their athletic
departments in court for covering up rape and sexual assault promulgated by their football players.
http://title-ix.blogspot.com/2008/07/iowa-athletic-department-cover-up-of.html)
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 Failure of the University to Investigate as Violation of Title IX
There are a number of reasons why the duty to investigate of a University receiving federal funds
is vital to the underlying purpose of Title IX.






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A coach or student athlete only has 180 days to determine whether to file a
complaint on issues that are often beyond the knowledge of the coach or student or
dependent on the University to educate the coach or student about their rights under
Title IX.
Even with standard training, as discrimination has become more subtle or bias more
implicit, it is often difficult for a female coach or student athlete to identify how
gender bias has affected them.
Most coaches and students will ask the University to investigate as their goal is not
to file complaints or seek lawyers, but just to fix the problem. Permitting these
internal remedies to run their course causes delays and risks the 180 days running.
Often only the University has immediate access to information – including
statistics, the substance of complaints, protocol, coaching methods, and witnesses
– necessary to review the matter and provide a remedy. 10
The Office of Civil Rights also has limited resources to investigate discrimination
claims and as a matter of policy should require that a University conduct an
investigation as part of its obligations under Title IX or risk creating evidence of
knowledge or intent. 11

                                                            
10 In addition to access to the same social science cited throughout this Complaint and knowledge of
stereotypes generally, the University itself has access to experts on its own faculty including:
http://clas.uiowa.edu/sociology/people/kevin-t-leicht (Kevin Leicht's interests include sociology of

work, organizations and organization theory, social stratification, and political sociology. His
current research is examining gender inequality among professionals;
 http://clas.uiowa.edu/sociology/people/michael-lovaglia (Current research projects involve power
in exchange networks, group process effects on IQ scores, the effects of emotions on status
processes, and explaining why more women than men now attend colleges and universities. A new
project, Best Schools for Athletes, investigates how schools can promote athletic and academic
excellence without compromising either goal.)
 http://clas.uiowa.edu/sociology/people/sarah-harkness (Her research and teaching interests include:
social psychology, inequality, gender and intersectionality, health, and quantitative methods.)
 http://clas.uiowa.edu/sociology/people/karen-heimer (Karen Heimer conducts research and teaches
in the areas of gender and violence, criminal punishment, and criminology. She is currently
conducting research on gender differences in violent victimization and offending, as well as on
gender, race and imprisonment in the United States.)
 

11

Evidence that an employer failed to investigate in light of actual or constructive knowledge of
discrimination can be evidence of discrimination. See Chauffeurs, Teamsters and Helpers, Local Union
No. 238 v. Iowa Civil Rights Commission, 394 N.W.2d 375, 381 (1986); Davis v. National Railroad
Passenger Corporation, 733 F. Supp. 2d. 474, 487 (Del. 2010); Coley v. Consolidated Rail Corp. 561
F.Supp 645, 651 (E. D. Mich 1982); Dunn v. Wash. Cnty. Hosp., 429 F.3d 689, 692 (7th Cir.2005).
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 

The refusal of a University that is accepting federal funds to investigate good faith
concerns of discrimination toward a coach or a program places women at high risk
of continued discrimination and/or interferes with remedies, which should be itself
a direct violation of Title IX.

These Complainants have asked the University of Iowa on no less than three separate occasions
from August 2014 to November 2014, to investigate what happened to Coach Griesbaum, to
determine if gender was a factor in her removal and to inquire about their rights under Title IX.
The University has not only refused to investigate, it has responded in what can only be described
as a patronizing manner. The athletic director has used emotional arguments such as “your coach
will be fine,” and have tried to influence the players by providing them iPads. The University has
also suggested they cannot help them while “Tracey Griesbaum may be suing the University,” and
tried to dissuade them from appealing to another authority by telling them their complaints are not
protected under Title IX.
The four Complainants are asking the Office for Civil Rights to intervene and investigate the
patterns of gender discrimination that resulted in the removal of not only Tracey Griesbaum, but a
series of strong female coaches.12
Complainants ask that the Office for Civil Rights investigate how the response to player
complaints (male and female) has placed not only a number of female coaches at risk, but threatens
to undermine the competitive experience of those female student athletes who remain at the
University of Iowa.
The above-named Complainants therefore file this Office for Civil Rights Complaint on behalf of
themselves and all other similarly situated student athletes.
Context for Details and Witnesses Identified in Complaint
The information in this Complaint has been collected through a variety of sources. Complainants
are fact witnesses for their experiences on the team, for their efforts to obtain an investigation from
the University of Iowa and certain other observed differences in treatment such as the attempt to
provide iPads to the Field Hockey team as a bribe in response to their first attempt to ask the
University of Iowa for an investigation. The Complainants are also witnesses to the expectations
and desire to have access to coaching methods that are comparable to that of male student athletes
and the harm that results from the removal of Tracey Griesbaum because of her gender.
The vast bulk of other information is in the possession of the witnesses to these events that are
either obvious from the context provided or that are indicated in footnotes or in the witness list
attached to this complaint.
                                                            
12
The need to investigate the pattern prior to Tracey Griesbaum is required because a) it provides strong
evidence that gender or sex was behind the removal of their coach and a severe risk in this
Administration, b) the pattern of removing strong females has now affected the current and long term
experience of females at Iowa by inducing fear and into all women’s sports and c) the level of sanction or
remedy necessary to repair undo the harm may depend on the depth of the violation or problem.
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 Statement of Jurisdiction
The University of Iowa is a recipient of federal funding and is therefore subject to the antidiscrimination provisions of Title IX. Complainants allege that the discriminatory acts forming the
basis of this complaint occurred within 180 days of the filing of this complaint. The latest
discriminatory act was in November 2014 after the University refused to investigate
Complainant’s concerns that their Title IX rights were being violated with the removal of the coach
for the University of Iowa Field Hockey program because of gender. However, the other key event
was Coach Griesbaum’s termination on August 4, 2014, which is also within 180 days of the filing
of the Complaint. Other discriminatory acts that preceded this removal were ongoing and
continuing in nature. Therefore, this complaint is timely filed and the Office for Civil Rights has
personal and subject matter jurisdiction over this matter.
Statutory Framework
1. Title IX of the Education Amendments of 1972, codifed at 20 U.S.C. §§ 1681-1688,
provides that “[n]o person in the United States shall, on the basis of sex, be excluded from
participation in, be denied the benefits of, or be subjected to discrimination under any
education program or activity receiving Federal financial assistance[.]” 20 U.S.C.
1681(a)(emphasis added).
2. Pursuant to the 20 U.S.C. 1682 enforcement provision, the United States Department of
Education has authority “to effectuate the provisions of 1681…by issuing rules,
regulations, or orders” interpreting and explaining Title IX (20 U.S.C. 1681 et seq.), which
are found in 34 C.F.R. 106.41 et seq.
3. Generally, 34 C.F.R. 41(a) provides that “No person shall, on the basis of sex, be excluded
from participation in, be denied the benefits of, be treated differently from another person
or otherwise be discriminated against in any interscholastic, intercollegiate, club or
intramural athletics offered by a recipient, and no recipient shall provide any such athletics
separately on such basis.”
4. The University of Iowa is a recipient of federal financial assistance pursuant to 34 C.F.R.
106.2(h).
5. The University of Iowa and its Athletics Department, including the Women’s Field Hockey
Program, is a “program or activity” within the meaning of 20 U.S.C. 1681 pursuant to 20
U.S.C. 1687(2)(A) because “any part of” the University of Iowa receives federal financial
assistance pursuant to 20 U.S.C. 1687(4).
6. The University of Iowa must provide equal benefits to student athletes of any sex pursuant
to 34 C.F.R. 106.41.  
7. In determining equal benefits or opportunity in athletics, several factors should be
considered including, but not limited to, “[w]hether the selection of sports and levels of
competition effectively accommodate the interests and abilities of members of both sexes”
and the “[o]pportunity to receive [equal opportunity in] coaching and academic
tutoring….” 34 C.F.R. 106.41(c) (emphasis added). 
8. The history behind Title IX reveals that it was needed to overcome powerful gender
stereotypes held by much of society about the role of men in athletics compared to the role
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 of women in athletics.13 Prior to 1972, stereotypes about women as mothers, caretakers
and nurturers forced women into roles that were inconsistent with careers and leadership
in NCAA athletics;14Title IX was therefore intended to change the power of gender
stereotypes.15
                                                            
13

Title IX began its congressional life in earnest when an amendment was introduced in the Senate by
Senator Birch Bayh of Indiana, who explained that its purpose was to combat “the continuation of corrosive
and unjustified discrimination against women in the American educational system.” 118 Cong. Rec. 5803
(1972). During debate, Senator Bayh stressed the fact that economic inequities suffered by women can often
be traced to educational inequities. In support of the amendment, Senator Bayh pointed to the link between
discrimination in education and subsequent employment opportunities: The field of education is just one of
many areas where differential treatment [between men and women] has been documented but because
education provides access to jobs and financial security, discrimination here is doubly destructive for
women. Therefore, a strong and comprehensive measure is needed to provide women with solid legal
protection from the persistent, pernicious discrimination which is serving to perpetuate second-class
citizenship for American women. Id. at 5806-07. Senator Bayh decried the "sex discrimination that reaches
into all facets of education – admissions, scholarship programs, faculty hiring and promotion, professional
staffing, and pay scales." Id. at 5803 (1972). Congressional activity on the issue increased with the
introduction of various proposals in the House and Senate to end sex discrimination in education. Although
there was growing consensus that sex discrimination in education should end, there was little agreement as
to the best methods for reaching that goal. Some critics claimed that the legislation was intended to try to
maintain a certain quota or ratio of male to female students. Senator Bayh reiterated many times during the
debate that "the amendment is not designed to require specific quotas. The thrust of the amendment is to
do away with every quota." 117 Cong. Rec. 30, 409 (1971). The Senator went on to state that "[t]he language
of my amendment does not require reverse discrimination. It only requires that each individual be judged
on merit, without regard to sex." Id. (Sections from United States Department of Justice website – Title IX
Legal Manual)
14
“Gender stereotypes are not merely descriptive but also prescriptive, consisting of rules concerning how
men and women should behave. Agentic attributes (e.g., assertive, competitive, and independent) are
prescriptive for men, whereas communal attributes (e.g., warm, kind, and supportive) are prescriptive for
women — plausibly because agency is required for leadership and career success, whereas communality is
required for caring for the welfare of others.” Rudman, L.A., et al. Journal of Experimental Social
Psychology 48 (2012) 165–179 (internal citations omitted).
15
While discrimination in violation of Title IX must be "on the basis of sex," courts have held that subjecting
an individual to sex stereotyping may constitute sex discrimination. In Price Waterhouse v. Hopkins, 490
U.S. 228, 250 (1989), a Title VII case, the plaintiff was denied partnership in an accounting firm, due, in
part, to the attitudes of the senior partners who described her as "macho" and advised her to wear makeup
and jewelry and to dress in more feminine clothing. Id. at 235. The Supreme Court explained: In the specific
context of sex stereotyping, an employer who acts on the basis of a belief that a woman cannot be
aggressive, or that she must not be, has acted on the basis of gender... As for the legal relevance of sex
stereotyping, we are beyond the day when an employer could evaluate employees by assuming or insisting
that they match the stereotype associated with their group, for in forbidding employers to discriminate
against individuals because of their sex, Congress intended to strike at the spectrum of disparate treatment
of men and women result from sex stereotypes.
Id. at 250-51. (citations and internal quotations omitted). Several circuit courts have also addressed
gender-based harassment on the basis of stereotyping. Higgins v. New Balance Athletic Shoe, Inc., 194 F.
3d 252 (1st Cir. 1999)(Title VII); Galdieri-Ambrosini v. National Realty & Dev. Corp., 136 F. 3d 276, 289
(2nd Cir. 1998)(Title VII)("Evidence of sexual stereotyping may provide proof that an employment
decision or an abusive environment was based on gender.")(citing Price Waterhouse, 490 U.S. at 250-51
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 9. Gender stereotypes continue to impact the following key areas of Division I, II and III
athletics in various ways but are present at the University of Iowa and have affected the
Complainants and will affect other women at the University of Iowa:16
a. While women are permitted to apply for and compete equally with men in coaching
women, and little progress has been made on women coaching men, and currently,
more men hold head coaching jobs for women and that number is climbing.
i. In addition to of the termination of six highly qualified female coaches, two
of the female coaches were replaced with male coaches which is consistent
with the move away from females coaching females and no progress has
been made on women coaching men at Iowa. Further, on at least one other
occasion the University fired a female coach (Kelly Crawford) intending to
replace her with a male (Mark Hankins).
b. As a result of the enabling of player complaints based on gender stereotypes, the
University is engaging in discriminatory investigations, which results in
discriminatory terminations of female coaches.
i. Several of the female University of Iowa coaches from 2006-2014 were
removed because of the operation of stereotypes. No male has been
investigated in this way or removed as a result. There are examples of male
and female complaints about the men’s golf coach that have been ignored
as well as objective evidence that coaching methods resulted in harm to
male football players without any significant investigation.
c. Women in leadership roles are forced to work under double standards that prescribe
traditional female characteristics (nurturing, caring and motherly traits) while their
objective success (e.g. winning games and portraying leadership) requires them to
adopt traits that are traditionally associated with men. 17
                                                            
(Title VII); Lindahl v. Air France, 930 F. 2d 1434, 1439 (Title VII)(9th Cir. 1991); Sheehan v. Purolator,
Inc., 839 F. 2d 99, 106-77 (Title VII)(2nd Cir.)(Kearse, J., dissenting, cert. denied, 488 U.S. 891, 109 S.Ct.
226 (1988)). Since Title VII legal theories are often used by courts to evaluate Title IX claims, sex
stereotyping violates the Title IX prohibition of discrimination on the basis of sex. The fact that the
harassment was based on the perception that the individual was not properly "manly" or "feminine" may,
in appropriate circumstances, be the basis for a sex stereotyping claim filed under Title IX. (Sections from
United States Department of Justice website – Title IX Legal Manual)
16
This context is important as the OCR reviews this matter. If not properly controlled, gender bias will
affect the perception, judgment and decisions made about female student athletes and female coaches.
Understanding that these biases are present is important to understanding this complaint and how these
events have harmed the Complainants and will harm other student athletes going forward.
17
Johnson, S. K., et al, (2008) The strong, sensitive type: Effects of gender stereotypes and leadership
prototypes on the evaluation of male and female leaders” Organizational Behavior and Human Decision
Processes 106, 39-60 (“…finding that feminine individuals expect that leaders are more sensitive than
masculine individuals, who expect that leaders are more masculine, strong, and tyrannical than feminine
individuals. Similarly, sensitivity was more strongly associated with female leadership, whereas
masculinity, strength, and tyranny were more strongly associated with male leadership. However, for
female leaders to be perceived as effective they needed to demonstrate both sensitivity and strength,
although male leaders only needed to demonstrate strength.”)
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 d. Societal stereotypes about women coaches affect decision-makers’ perceptions and
judgments about female coaches. Male coaches do not face these stereotypes
regardless of whether they coach men or women. 18
e. Gender bias and stereotypes also drive the response, or lack of proper response, to
complaints of females regarding sexual assault or risk of harm from other male
students or male coaches.
Representative Complainants’ Title IX Rights
10. Complainant Chandler Ackers is a female student athlete in good standing with the
University of Iowa.
11. Complainant Jessy Silfer is a female student athlete in good standing with the University
of Iowa.
12. Complainant Natalie Cafone is a female student athlete in good standing with the
University of Iowa.
13. Complainant Dani Hemeon is a female student athlete in good standing with the University
of Iowa.
14. The Complainants reside in Iowa City, Iowa during the school year and are members of
the University of Iowa Women’s Field Hockey team.
15. All four Complainants were recruited by Coach Tracey Griesbaum to play field hockey at
the University of Iowa.
16. The Complainants, and many similarly situated student athletes, chose to attend the
University of Iowa, in part, because of Tracey Griesbaum’s reputation in women’s field
hockey, her success record and her winning coaching methodologies.
17. The named Complainants, and other similarly situated student athletes, are to be held to
the highest standards required by Division I athletics.
18. Complainants, and similarly situated female NCAA athletes, are entitled to have their
coaches to be able to employ coaching methods that are at the same level of intensity,
quality and effectiveness as those employed by coaches of male student athletes.

                                                            
18
“Professional women vying for leadership roles face a double bind. In order to be perceived as qualified,
they must defeat gender stereotypes by presenting themselves as competent, confident, and assertive…
Thus, women's first hurdle to leadership is the “lack of fit” between feminine stereotypes and leadership
qualities… However, although women can clear this hurdle by demonstrating agency, they still face another
roadblock. This second hurdle consists of backlash, whereby agentic women are perceived as highly
capable, but risk prejudice and hiring discrimination for behaving counterstereotypically. Specifically,
backlash emerges when agentic women are judged as similarly competent, but less likable and hirable,
compared with identically behaving men. This dilemma represents a Catch-22 for women, such that they
must enact agency to be perceived as qualified for leadership, but risk penalties if they do so …” Rudman,
L. A., et al., Status incongruity and backlash effects: Defending the gender hierarchy motivates prejudice
against female leaders, (2012) Journal of Experimental Social Psychology 48, 165-179. (internal citations
omitted).
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 19. In addition to financial incentives, the University of Iowa also gave assurances to the three
female Complainants that they would be provided equal support by the University without
regard to gender.19
20. Complainants and similarly situated student athletes are entitled to equal access to benefits
regardless of sex including: use and quality of facilities, uniforms and equipment;
opportunities for scholarships; and high quality coaching.
21. Students are entitled to equal benefits in access to the provision of equipment; the
scheduling of games and practice time; travel and per diem allowances; provision of locker
rooms, competitive facilities, medical and training facilities and services; provision of
housing and dining facilities and services; and publicity. 34 C.F.R. 106.41(c)
22. Likewise, the Complainants and similarly situated student athletes are entitled to “levels of
competition [that] effectively accommodate the interests and abilities of members of both
sexes,” and “the opportunity to receive coaching” and “assignment of coaches.” 34 C.F.R.
106.41(c).
23. The Complainants and similarly situated student athletes are entitled to have these benefits
not denied to them because of sex.
24. The Complainants and similarly situated student athletes are entitled to have their coaches
hired by the University irrespective of sex or sex stereotypes.
25. The Complainants and similarly situated student athletes are entitled to having the
University of Iowa investigate equally and not treat differently any complaint regarding a
coach because the student complaining was a female verses a male.
26. Each of the Complainants was entitled under Title IX to have the University of Iowa not
hold their female coach and mentor to a different (higher or lower) standard because she
was a woman.
27. Each of the Complainants is entitled to have the University not hold female coaches to
different standards with regard to their coaching methods, compared to male coaches.
28. Each of the Complainants was entitled under Title IX to have their coaches’ coaching
methods be evaluated pursuant to objective standards irrespective of the sex of the coach.
29. Title IX implicitly guarantees that the complaints of all student athletes are handled with
equal respect, rigor, and scrutiny.
30. All student athletes are entitled under Title IX that the University not hold a female coach
to higher or different standards relative to male coaches, just as female student athletes
must be provided “equal athletic opportunity” and cannot be held to higher, lower, or
different standards than male student athletes.
31. All female student athletes are entitled pursuant to Title IX that the University not hold a
female coach to higher or different standard relative to male coaches who receive
complaints from the parents of female athletes or parents of male athletes.
32. Complainants have been harmed by the removal of Coach Griesbaum given that her
success at recruiting and competition at Iowa were unmatched. While replaced by her
assistant coach, the replacement coach has never been a head coach and as such the
Complainants and other SA’s on the team were denied access to coach of similar
                                                            
19
The University of Iowa Title IX policy available at http://diversity.uiowa.edu/policies/title-ix.
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 qualifications and certain denied access to the team of coaches under Coach Griesbaum
that has been part of the reason for success at Iowa.
Complainants’ Summary of Allegations:
Context for Changes in Management Structure that Exposed University to Increased Risk
of Gender Discrimination20
33. In August of 2000, long time women’s athletic director Dr. Christine Grant retired.21
34. In August of 2000, a task force was formed to study whether the men’s and women’s
athletic departments could be merged and to determine the impact on women’s athletics.22
35. In August of 2000, the study determined that departments could be merged. However, some
members of the committee objected to the merger, citing concerns that the merging of the
departments would harm the future of women’s athletics. (Report is attached)
36. Aware of the risk to equality for women, the University of Iowa committed to its
prospective student athletes that it would not permit the merger department to impact the
opportunities or progress of women in athletics.23
37. As a condition of the merging the men’s and women’s athletic departments, the University
of Iowa committed to certain conditions including:
a. That the senior women’s administrator would remain as a division deputy director
or second in command in the Athletic Department.
b. That cost savings from the merger would be used to expand opportunities for
women to further reduce the inequity that remained for women at the University.
38. From August of 2000 until August of 2006, the University of Iowa, under the direction of
Bob Bowlsby, generally met these conditions.
                                                            
20
The witnesses to these events will be Christine Grant, Bob Bowlsby (former AD), Members of the
Committee who examined the reasons for merging departments, various coaches who were present during
the tenure of Mr. Bowlsby and the transition to Mr. Barta including those identified in this Complaint
who were hired prior to 2006.
21
Dr. Christine Grant served as the first women’s athletic director at the University of Iowa after the
passage of Title IX and served in that role from 1973-2000. The University of Iowa Women’s Field
Hockey field is named after her. See http://btn.com/2012/10/12/title-ix-retrospective-profiling-drchristine-grant/; see also http://now.uiowa.edu/2014/11/media-advisory-christine-grant-discuss-politicssport-college-education-nov-11.
22
Witnesses: Mary Coleman (Former President of U of I), Ann Rhodes, Bonnie Slatton (Co-Chairs of
Task Force),
23
The point regarding the transition from separate athletic departments and its connection to the removal
of so many coaches suggests that rather than making progress forward, the University of Iowa is
transitioning back to what is known as a “gendered organization.” “to say that an organization….is
gendered means that advantage and disadvantage, exploitation and control, action and emotion, meaning
and identity, are patterned through and in terms of a distinction between male and female, masculine and
feminine.” Burton, Borland, Mazerolle,. “They cannot seem to get past the gender issue”: Experiences of
young female athletic trainers in NCAA Division I intercollegiate athletics, Sports Management Review
15, p. 304-17 (2012).
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 Context For Administrative Decisions Allegedly Made Because Of
A “Poor Record” Or “Player Complaints
39. At the University of Iowa, four out of six female coaches removed from 2008 to 2014 were
removed because of alleged “poor records.” All six of the female coaches have been
removed, undermined or encouraged to leave because of “player complaints.”
40. While Gayle Blevins and Tracey Griesbaum are not affected by the excuse of a “poor
record” as the Office for Civil Rights considers the University’s “reasons” of “poor
records” of any coach, it should consider the context of each sport and the admissions of
the University that contradict those reasons.
a. It is clear that in all six cases, the University of Iowa Administration has refused to
support the female coaches in the face of efforts of a few players or parents or even
one male assistant coach to undermine the leadership role of female coach.
b. University of Iowa Administration has expressed that it requires seven years to
turn around a program. Three of the female coaches – Fredrick, Crawford and
Dingman – were provided far less than seven years after being hired. Consistent
with that admission of the University, that it takes seven years, men in nonrevenue sports have been given well over seven years to turn around their
programs before they were terminated.
c. In addition to setting the seven year time frame for all coaches, University of
Iowa Administration has openly told female coaches that they “did not expect the
coach to turn around the program” or told them that “they would not be evaluated
on the win-loss record” or made other comments that suggest that the University
is fully aware of the added barriers to moving a poor program into one that is
competitive.
41. Despite the above context, when faced with a coach who sought to challenge a lack of
facilities, or who received a few complaints from student athletes, the University would
then use the “excuse” of a poor record in combination with player complaints against that
female coach. Both excuses were powered by gender stereotypes.
42. As the Office for Civil Rights reviews this matter and considers how player or parent
complaints about coaching factored into the removal of coaches, it should note that the
University of Iowa Administration is aware or should be aware of the very high risks of
stereotype or gender bias that place female coaches and student athletes at risk:
a. The University should be aware that female players and parents of female players
will report behavior of female coaches differently (more frequently and for less risk
of physical harm) than male players or parents of male players will report on the
behavior of a coach.24
                                                            
24
Morrongiello, B. A., & Zdzieborski, D., Normand, J., (2010) Understanding gender differences in
children’s risk taking and injury: A comparison of mothers’ and fathers’ reactions to sons and daughters
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 b. University of Iowa Administration is aware or should be aware that players of any
gender, and parents of any gender, will hold women in leadership (coaching)
positions to higher standards than they placed on males in leadership positions.
c. University of Iowa Administration is aware or should be aware that male and
female players and parents of male and female players will hold female leaders
more responsible for emotional reactions of young student athletes (such as “she
was mean to me,” “she is intimidating,” or “I feel bad about myself”) and yet not
hold male leaders responsible in the same way.
d. University of Iowa Administration is aware or should be aware that male student
athletes are discouraged from reporting emotional upset resulting from the behavior
of male coaches and are discouraged from reporting risk of physical harm based on
the behavior of male coaches.
43. The combination of these gender stereotypes create a situation where female complaints
are exaggerated and permitted to take down competent female coaches, but male
complaints about men, are often ignored resulting in actual risk to the male student athletes.
Evidence of Removing Strong Female Coaches Because of Gender/Sex25
44. In August of 2006, a new Athletic Director, Gary Barta, was hired.
45. The first significant event occurred when Cindy Fredrick was terminated as the women’s
volleyball coach in December 2008.26
46. The excuse used to remove Coach Fredrick was her record and player complaints.
47. Regarding her record it is important to note the following:
a. Coach Fredrick was handed a very poorly supported Volleyball program when she
arrived at Iowa.
b. Prior to coming to Iowa Coach Fredrick had success in turning women’s athletic
programs around.

                                                            
misbehaving in ways that lead to injury, Journal of Applied Developmental Psychology, 31 322-329, p.
328. (internal citations omitted).
25
Witnesses to most of these events include the named coaches (Cindy Fredrick, Gayle Blevins, Mandi
Kowal, Kelly Crawford, Sharon Dingman and Tracey Griesbaum), plus assistant coaches such as Diana
Thompson (assistant coach to Gayle Blevins), Lisa Celluci (assistant coach to Tracey Griesbaum and now
head coach of women’s FH), Other witnesses include members of administration (SWA Jane Meyer), as
well as players such as members of the men’s and women’s golf teams during termination of Kelly
Crawford. The contact information for the coaches is provided but the players contact information would
be with the University. Key documents will include the record of player reviews for male and female
coaches during this time, the details on investigations into player or parent concerns for each coach, the
lack of investigation into concerns raised about male coaches including Mark Hankins (men’s golf) and
Chris Doyel (men’s’ football). Complainants are seeking assistance from the OCR to investigate these
matters as Complainants do not have access to the documents and witnesses and the University has
abjectly refused to respond to Complainant’s requests or to cooperate.
26
Cindy Fredrick can be contacted at UNLV or cjfredrick@gmail.com.
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 c. Coach Fredrick was given 3-4 years; she was not given anywhere close to seven
years to turn her program around despite having barriers in her path (poor support,
no separate facility etc.).27
48. Coach Fredrick was, as with many other female coaches at Iowa and around the United
States, adversely affected by player complaints. These complaints were also used as a
reason to terminate her.
49. Coach Fredrick was a female who challenged the administration regarding equality under
Title IX.28
50. The second serious event occurred during the last two years of the tenure of the Hall of
Fame softball coach Gayle Blevins, or during the 2008-2009 and 2009-2010 seasons.
Coach Blevins retired in June of 2010.29
a. Coach Blevins was effectively forced to retire because the University of Iowa held
her to a different standard than any male coach in the University.
b. Coach Blevins was not supported by the University of Iowa when a male assistant
coach undermined her authority with her players.30
c. Blevins sought authority to remove this coach, but the University of Iowa refused
her request in a manner that would never have been used to deny a male head coach
the right to control his staff.
d. Coach Blevins was not supported in her efforts to remove her assistant coach either
because he was a male, or in the alternative, because she was a female that was not
provided the authority otherwise provided to male head coaches in selection and
retention decisions regarding assistant coaches.
e. In addition to differences in treatment with respect to authority to make decisions
regarding her staff, a female player’s parent made a public complaint about Coach
Blevins.
                                                            
27
Athletic Director Barta handed the women’s volleyball program to a male after firing two women who
were only given 3 years and 4 years respectively to turn around a program without the benefit of the separate
volleyball floor. Coach Dingman and Coach Fredrick can testify to these events. There is other evidence of
support for the male volleyball coach including marketing efforts that show that administration did not
really get behind the program until a male was put in charge as well as the fact that the University paid the
male coach substantially more than the two females. The same odd pattern followed when after a boathouse
was finally put in place (without help from administration) Coach Kowal was removed and replaced with
a male and later, when the male left voluntarily, he was again replaced with a male.
28
Coach Fredrick can testify regarding her experiences and her efforts. Tracey Griesbaum can testify to
how Fredrick would challenge administration, thereby identifying herself as a strong female and the
reaction of administration would be different (more negative) when compared to when a male, such as Mark
Hankins, would challenge administration.
29
Gayle Blevins can be reached at gblevs@gmail.com. Also, Gayle’s assistant coach, Diane Stephenson
(phone–765-427-5075) also has information on the pattern of behavior at the University.
30
A male hired as an assistant by the female or who are a peer of that coach on the same staff, may have
doubts about the decisions of the female coach. These doubts are normally powered by gender stereotypes.
(Burton, Borland, Mazerolle – “They cannot seem to get past the gender issue”: Experiences of young
female athletic trainers in NCAA Division I intercollegiate athletics, Sports Management Review 15, p.
304-317 (2012) – “male coaches of male sports perpetuated a stereotype of female incompetence in the
male domain of sport by continually challenging the professional decisions of our participants.”
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 f. Coach Blevins understood that the University would not support her in response to
this complaint of a parent.
g. As a result of the University of Iowa Administration’s actions and lack of support,
Coach Blevins resigned.31
51. On or about June of 2011, the University of Iowa forced the women’s golf Coach-- Kelly
Crawford to resign.32
a. The alleged reasons for her termination were initially that there were some “poor
reviews” by the players. When Coach Crawford challenged this excuse, it was
changed to be about her “record.”
b. As with Coach Fredrick, Coach Crawford had a strong history of coaching or
developing programs prior to coming to Iowa.33
c. As with Coach Fredrick, Coach Crawford was not provided seven years to turn
around her program as she was fired after only 4 seasons (2007-2011).34
d. While replaced by a female, Coach Crawford eventually learned that the real reason
she was being removed was to make way to replace her with a male coach, Mark
Hankins. Mr. Hankins was to be offered the job to coach both men and women’s
golf.
e. The plan to replace the female coach with a male was sidelined after the females
reported that they did not want to play for Mr. Hankins given his treatment of the
male players. Unlike the investigations launched into the behavior of almost all
female coaches, Athletic Director Barta did not investigate these complaints but
instead continued to support Mr. Hankins including recently providing Mr. Hankins
with a promotion into Administration in August of 2014.
f. Prior to this time, Mr. Hankins had been given a number of other privileges denied
to male coaches including a) not being investigated for player complaints, b) being
permitted to engage in fundraising for his program c) being permitted to purchase
an expensive travel van denied to the females and e) being allowed to challenge
administration in a manner denied to female coaches.35

                                                            
31
The qualifications of Coach Blevins compared to the person who replaced her should be self-evident. In
31 years as a head coach, Blevins compiled a record of 1,245 wins, 588 losses and 5 ties. At the time of
her retirement, Blevins was the second-winningest softball coach in NCAA Division I history. She never
had a losing season at Iowa or Indiana.
32
Kelly Crawford can be reached at 319-430-0525 or kellycraw88@hotmail.com
33
Coach Crawford was the head golf coach at UC Irvine for six years. During that short time she had the
program ranked 13th in the country when she left to come coach at Iowa.
34
Coach Crawford was told by several in administration (Fred Mimms) that “she was not going to be able
to turn the program around.”
35
In addition to the negative experience of Cindy Fredrick who sought to challenge administration
regarding facilities and other rights provided under Title IX, in 2010, there was a public challenge to these
same issues (lack of support and problems with facilities) made by a female gymnastics coach, Larissa
Libby. After this challenge, the female gymnastics coach was brought in and chastised and told to “not do
that again” or risk termination. http://www.hawkeyesports.com/sports/wgym/mtt/larissa_libby_233112.html
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 52. The next discriminatory event occurred on or about May of 2012, when the University of
Iowa removed the rowing coach Mandi Kowal.
a. During her career, Coach Kowal was required to be successful without access to a
boathouse.
b. After working hard to obtain a boathouse, she was removed and replaced with a
male.
c. A female student athlete complained about “playing while injured.” The complaint
was enabled by the gender stereotypes of administration and used against Coach
Kowal. The coaching methods of the male rowing coach staff was far more
aggressive than anything used by the female coaching staff.36
53. The next event occurred on or about January 2014, the University of Iowa removed the
women’s volleyball coach Sharon Dingman.37
a. As with Coach Frederick and Coach Crawford, Coach Dingman had success prior
to coming to the University of Iowa.
b. Coach Dingman was finally able to obtain a new floor for volleyball but was then
fired before she had any real chance to take advantage of it.
c. Since leaving Iowa Coach Dingman has been nominated for coach of the year.
54. The next event, and the one most directly affecting the Complainants, was the removal of
Tracey Griesbaum.38
a. Coach Griesbaum had been at Iowa for 22 years and a head coach for 14.
b. Coach Griesbaum maintained a competitive program including leading the team
to three Big Ten Tournament Championships, one regular season Big Ten
Championship, six NCAA Tournament appearances and the 2008 NCAA Final
Four. 39
c. Coach Griesbaum has been an example to all coaches, male and female, about
proper effective coaching methods.
d. Coach Griesbaum, as with almost all female coaches, received complaints from
female players and parents.
e. In 2014, she was subjected to an in-depth investigation based on two anonymous
complaints. No violations were found, but she was terminated on August 4, 2014.
f. Coach Griesbaum was terminated because of double standards in coaching. Her
methods were not only proper, but were less intimidating than male coaches who
continue to be permitted to coach at Iowa. 40

                                                            
36
Mandi Kowal can testify to these events and to her struggles to obtain the basic needs to compete.
Phone-319-330-1265, or mkowaltris@gmail.com
37
Sharon Dingman can be reached at 906-251-1601 or Sharon.dingman@gmail.com
38
Tracey Griesbaum can be reached at tracey.griesbaum.icloud.com.
39
Tracey’s accomplishments on University website: http://www.hawkeyesports.com/sports/wfieldh/mtt/griesbaum_tracey00.html, https://www.facebook.com/reinstateTG,
40
http://espn.go.com/espnw/news-commentary/article/11773583/what-heck-going-iowa-athleticdepartment
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 55. These violations are a continuation of the pattern of demeaning and undermining women
within the University of Iowa’s Athletics Administration and coaching staff.41
Enabling or Encouraging Female Player Complaints Differently than Male Complaints
56. Player complaints or parent concerns have been used as excuses to remove or interfere with
the careers of almost every single female coach at Iowa while under the administration of
Gary Barta (e.g. Cindy Fredrick, to Gayle Blevins, to Kelly Crawford, to Mandi Kowal, to
Sharon Dingman and Tracey Griesbaum). The “concerns” include female coaches being
mean, not emotionally supportive, or that the female coach is pushing the female student
athlete too hard. Some of these accusations include that players had to receive counseling
or that they were forced to play injured.
57. Consistent with this pattern, on or about May 7, 2014, two female student athletes (or their
parents) pressured the University of Iowa to investigate the coaching methods of Tracey
Griesbaum.
58. Coach Griesbaum was accused by these athletes of bullying behaviors, verbal harassment,
and intimidation.42
59. The University of Iowa’s reaction to these two complaints reveal the gender-based double
standard in place when receiving female player complaints compared to male player
                                                            
41
 These gender issues and retaliation also extend into administration. As required by the agreement tied
to the merging of the athletic departments in 2000, the SWA and second in command at the University
was a woman until August of 2014. At that time Gary Barta hired a male that he preselected and \paid
$70,000 more per year for doing half the work previously assigned to the female SWA Jane Meyer. Mr.
Barta has now removed Jane Meyer entirely from her position in the athletic department in direct
retaliation for Jane Meyer’s association with Tracey Griesbaum and has indicated that he will not return
Ms. Meyer to her position until the complaints of Tracey Griesbaum are resolved.   
42
On November 6, 2014, the University responded to questions regarding “Why did Athletics Director
Gary Barta remove Tracey Griesbaum as field hockey coach?” with the following:









Over the past few years, some student-athletes complained of mistreatment and bullying by Coach
Griesbaum. The Athletics Department reviewed these allegations but was unable to substantiate them.
In the spring of 2014, Gary Barta received additional allegations from more than one student-athlete,
including complaints of harassment and intimidation. Given the seriousness of these issues, and the
past history of allegations, Gary Barta asked for an investigation to be conducted by officials from
outside the Athletics Department.
An investigator from the Department of Human Resources and an investigator from the Office of
Equal Opportunity and Diversity jointly conducted an investigation that included interviews with
more than 40 people associated with the field hockey program over a three month period.
The investigators concluded that there was insufficient evidence to substantiate a violation of
university policy. However, the investigators stated that they found it “very concerning that several
SAs consistently described a team environment of fear, intimidation, and/or mistreatment by Coach
Griesbaum and that several SAs indicated that they felt pressured to play injured.”
After reviewing the findings of the investigation Barta concluded that there was substance to these
persistent allegations and that he had to protect the students. Based upon the results of the
investigation and his discussion with Coach Griesbaum, he decided that a change in leadership was
necessary.
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 complaints; this results in a double standard being imposed on female coaches who act
with comparable competitive rigor as their male counterparts.
60. Coach Griesbaum is not known for yelling, screaming or intimidating players. There is no
evidence that she ever used foul or abusive language, and the majority of Coach
Griesbaum’s former players would confirm that. However, there are numerous videos of
male coaches using foul language, screaming at athletes, and throwing objects in a tantrum
at or around others. There is also evidence that 13 athletes were hospitalized for
overworking them. Those male coaches are still secure in their positions, yet Coach
Griesbaum was removed for alleged mistreatment of players.43
61. Despite the concerns and that a lawsuit has been filed against the University of Iowa for
severely injuring a football player, the University of Iowa has supported the coach who
was found to have overworked and exposed the student athlete to substantial physical harm.
62. Overreacting to a female concern that is nothing more than a minor issue, while ignoring
the physical risks of harm to male players is a form of gender discrimination.
63. As a result of the two complaints directed toward Coach Griesbaum’s coaching methods,
the University of Iowa launched a full-scale investigation into Coach Griesbaum. That
investigation included the interviewing of forty people and the devotion of a considerable
number of hours into the investigation.
64. Despite the depth of the investigation and the enabling of these complaints of the female
players and their parents, there were no founded complaints of any kind or of a serious
nature directed toward Griesbaum or her coaching staff.
65. The investigation ultimately concluded that Griesbaum did not violate any University of
Iowa policies.
66. As a result of gender stereotypes guiding the University response to player complaints,
Coach Griesbaum was terminated on August 4, 2014.
67. Had Tracey Griesbaum been a male with the same coaching methods, skills and winning
record, she would not have been investigated or terminated.

Efforts of the Complainants to Obtain Investigation and Remedy
68. After the termination of Tracey Griesbaum on August 4, 2014, the Complainants
approached Gary Barta and his new second in command, Gene Taylor to ask the University
to reinstate Coach Griesbaum and to investigate her removal.
69. Despite having access to all the records regarding the removal of coaches, the player
complaints and the ability to easily compare the coaching methods of males, the University
of Iowa has repeatedly refused to interview a single witness or examine a single document
to investigate these concerns.
                                                            
43
Witnesses to the events that lead to the termination of Tracey Griesbaum, are Tracey Griesbaum, Lisa
Celluci, all current and former players on the women’s field hockey team. They include the
Complainants and the parents of Complainants. Witnesses include all head coaches of field hockey in the
Big 10 who can verify their coaching methods and that of Coach Griesbaum.
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 70. Starting in August 2014, the Complainants attempted to raise the concerns outlined in this
complaint up the chain of command to the University of Iowa Administration. The
processes available include complaining to the Athletic Department, The Ombudsperson’s
Office, and the University of Iowa Equal Opportunity and Diversity Office.
71. Though the Athletic Department was the focus of their complaint, the Complaints still tried
to report their concerns to Athletic Director Gary Barta and to the University President,
Sally Mason.
72. On August 18, 2014, the Complainants and other members of the team met with Gary Barta
(Athletic Director) and his newly hired male second in command, Gene Taylor to ask for
the reinstatement of Coach Griesbaum and/or an investigation into her removal.44
73. On August 25,, 2014, Complainants Ackers and Silfer met with the Ombudsperson Cynthia
Joyce. They provided Ms. Joyce with a written discrimination complaint. At that time, Ms.
Joyce appeared understanding and appeared willing to look into the complaint.
74. On August 26, 2014, Complainants Ackers and Silfer met with University of Iowa Equal
Opportunity and Diversity employees Lisa Brewster and Tiffani Stevenson-Earl to try and
discuss the gender discrimination complaint. These Equal Opportunity and Diversity
employees told Complainants that they would “let them know” if their office was going to
investigate Mr. Barta and the Athletic Department.
75. The next week (first week of September 2014) Complainants met again with Ms. Brewster
and another person in the Equal Opportunity and Diversity Office. They informed the
Complainants that they were going to investigate one part of their Complaint and were
going to assign that investigation to Judy Whetstine.
76. At some point after this meeting with Ms. Brewster where the University suggested they
would investigate, the University then informed the Complainants they were not going to
investigate their complaint because they believed that Coach Griesbaum was going to file
a lawsuit. 45
                                                            
44
During this meeting it was made clear that Coach Griesbaum had not been removed because of the
substance of the complaints, but the number of them. They claimed to the Student Athletes that they “had
no choice” but to fire Tracey Griesbaum. Mr. Barta also admitted that “there is no proof of broken
policies.” The requests of the SA’s to investigate this matter were abjectly refused by Mr. Barta. It was
also at the end of this meeting that Mr. Barta offered the team use of IPads in an effort to put them off.
Even if other SA’s were given IPads, the appearance of a bribe made this very improper. Further, one of
the Complainants (Chandler Ackers) learned that they provided IPads that did not even have the same
internet access features (benefits) as those provided to males.
45
As of the filing of this Complaint, Tracey Griesbaum has not filed any lawsuit. Regardless, it makes no
sense to ignore the complaints of student athletes regarding their rights under Title IX because someone
else is filing or may be filing suit on another matter. If this is the University policy it means that Student
Athletes can never file a complaint that will be heard by the University so long as someone else may be
filing a lawsuit. The law also supports the notion that the University’s decision to ignore the concerns of
these Complainants for that reason was improper and illegal. “[A]n employer may not rely on an alleged
fear of a lawsuit [or gender stereotypes] as a reason to shortcut its investigation of harassment and to justify
an employment decision adverse to the putative harasser that in itself violates Title VII.” Sassaman v.
Gamache, 566 F.3d 307, 315 (2nd Cir. 2009).
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 77. On October 15, 2014, the Complainants filed another Title IX complaint directly with the
university President, Sally Mason. The complaint alleged that Coach Griesbaum was
removed because of her gender and that the University responds differently to complaints
by student athletes based on gender.
78. On October 22, 2014, the Complainants received an acknowledgment from Georgina
Dodge of their complaint of gender discrimination.
79. On October 30, 2015, the Complainants met with Ms. Dodge and Jennifer Modestou to
discuss the Title IX complaint sent to President Mason. During this meeting Ms. Dodge
told Complainants that they “had no complaint against the University.” The response to
the Complainants was both patronizing and dismissive. The comments to the Complainants
focused more on their “emotions” or “being upset” about losing their coach than on their
concerns of gender discrimination and Title IX.
80. From August 26, 2014 to the present, the University of Iowa has continued to ignore
Complainants and refused any investigation into their concerns despite the serious
implications for all female coaches and female student athletes at the University of Iowa.46
Requested Remedies
81. Pursuant to the enforcement provision in 20 U.S.C. § 1682, the United States Department
of Education has authority “to effectuate the provisions of section 1681…by issuing rules,
regulations, or orders of general applicability...” further, “[c]ompliance with any
requirement adopted pursuant to [the enforcement provision] may be effected by the
termination of or refusal to grant or to continue assistance under such program or activity
to any recipient … or by any other means authorized by law[.]” 20 U.S.C. § 1682(1)-(2).
                                                            
46
Research has established that stereotype-based expectations influence perceptual processing of social
information (Bodenhausen & Lichtenstein, 1987; Devine, 1989; Fiske & Taylor, 1991; Hamilton &
Trolier, 1986). This means that our biases and stereotypes affect our judgment about the motives and
behavior of young women who report risk of harm and our perceptions of the behavior of male and
female leaders who may be accused of causing harm. This occurs in response to complaints of sexual
assault by student athletes. It has consistently been found that male observers blame rape victims more
than female observers; a finding which is replicated within both traditional (Bell et al., 1994; Furnham &
Boston, 1996; Proite et al., 1993) and current research (Davies et al., 2009; Schneider et al., 2009; Sims et
al., 2007). (From: Van der Bruggen and Grubb – A Review of the literature related to rape victim
blaming: An analysis of the impact of observer and victim characteristics on attribution of blame in rape
cases. Aggression and Violent Behavior, Vol. 19,(5): p. 523-531 (2014)) Further, student athletes are at
risk of “stereotype threat”, which is a situation where the gender bias becomes so strong that even females
who do not believe they are inferior athletes can internalize the gender stereotype and affect their
performance as student athletes. (See, Chalabaev et al, The influence of sex stereotypes and gender roles
in participation and performance in sport and exercise: Review and future directions, Psychology of Sport
and Exercise 14 (2013), 136-144 – “Stereotype threat is a situationally induced identity threat that occurs
when an individual fears being judged negatively based on negative in-group stereotype.” “It is not
necessary to perceive one’s abilities and motivations in accordance with existing stereotypes in order to
suffer their negative consequences.” “This effect (negative performance from stereotype threat), occurred
on expert soccer players, who have presumably not internalized the stereotypes that females are not
competent and should not participate in masculine sports.”
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 82. As a result of the discrimination directed toward a number of female coaches, all female
student athletes at the University of Iowa have been harmed, or are at risk of being harmed,
by denial of equal opportunity and access to quality coaching.
83. Complainants and similarly situated female student athletes are entitled to equal access to
the level of competition male student athletes can expect in addition to equal access to
coaching methods that contribute to the success of men’s athletic programs. Under Title
IX, a coach should be permitted to coach irrespective of gender.
84. The decline in the number of female coaches and female mentors disproportionately limits
the level of competition and coaching for women’s athletics.
85. The culture of fear for female coaches at the University of Iowa, as a result of this pattern
of discrimination, has undermined the coach/student athlete experience at the University
of Iowa.
86. The culture of fear at the University of Iowa has diminished the benefits owed to female
student athletes under Title IX.
87. Current and future women’s field hockey players are specifically being denied the coaching
strategy, the team environment, and the recruiting leverage that formed the equation of
success of the last fourteen years Coach Griesbaum led their program.
88. The University of Iowa should be required to:
a. Engage in a cooperative investigation with the Office for Civil Rights;
b. Immediately preserve and produce all documents related to the tenure and removal
of the coaches referenced in this complaint;
c. Conduct joint interviews with the Office for Civil Rights of all coaches, players,
and witnesses identified in this complaint;
d. Examine the coaching methods of all male coaches and contrast and compare those
methods to the female coaches who have been removed;
e. Examine all player complaints in the last ten years and assess those complaints and
the responses to those complaints by gender;
f. Draft a policy that requires an immediate investigation into allegations of denials
of rights under Title IX or gender discrimination toward coaches or programs.
g. Create protocol that prevents the operation of bias in the assessment of the
seriousness of complaints based on gender;
h. To develop objective protocols for coaching methods, which include discussing
complaints with coaches prior to launching full investigations, and to only permit
complaints to be investigated when players identify behavior that breaches those
protocols;
i. To be required to monitor the type and number of complaints registered by females,
males, and parents of each by gender of the complainant and the coach;
j. To require a qualified, independent, and diverse team of investigators;
k. To require training on the identification and removal of gender bias and double
standards from administration’s decision-making process on hiring, investigations,
and retention of female coaches.

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 Conclusion
Based on the above, Complainants respectfully request that the Office for Civil Rights accept
jurisdiction over their claims and initiate an investigation into the allegations contained herein on
behalf of themselves and similarly situated student athletes. Complainants further request that the
Office for Civil Rights require the University of Iowa to create a corrective action plan that would
ensure its future compliance with Title IX of the Educational Amendments of 1972 to the 1964
Civil Rights Act, such that its Athletic Department hiring, firing, retention and investigation
practices do not result in the disparate treatment of, or otherwise discriminate against, student
athletes and their female coaches on the basis of sex. Complainants respectfully request that the
Office for Civil Rights agree to monitor any resolution reached and to provide the University of
Iowa family of students, parents, alumni, former coaches, and fans with an opportunity for
comment and ongoing involvement.

Filed on Behalf of:
Chandler Ackers
Jessy Silfur
Natalie Cafone
Dani Hemeon

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 Witness list47
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Complainants and Student Athletes
Chandler Ackers, Jesse Silfer, Natalie Cafonie and Dani Hemeon Knowledge of
reasons they selected University of Iowa and coaching methods of Tracey Griesbaum.
Observations of coaching methods toward all members of team. Knowledge of efforts to
obtain investigation of University into gender discrimination and removal of Coach from
August 2014 to present.
Members of the Field Hockey Team – These are unnamed but can be contacted through
the University or Complainants
Unnamed Female Student Athletes – Similarly situated SA’s attending the University
prior to the Complainants (some of whom will offer information) and who will be harmed
by the discrimination in future.
Female Coaches and Administrators Adversely Affected
Cindy Fredrick - Knowledge of her coaching methods compared to males and her
efforts to challenge administration on Title IX equity issues prior to her termination by
Barta. Knowledge of the state of the program (lack of support, lack of facilities) prior to
her arrival at Iowa. (Currently head volleyball coach at UNLV.
Gayle Blevins – Softball coach at Iowa who left for lack of support from Barta
Administration. Knowledge of her support under Christine Grant and Bob Bowlsby and
the lack of support under Gary Barta.
Kelly Crawford – Golf Coach. Knowledge of her coaching experience prior to Iowa, the
reasons used for her termination, her efforts to get her job back, the player complaints
about Mr. Hankins and the differences in how she was permitted to participate in funding
efforts to improve facilities compared to Mr. Hankins.
Mandi Kowal – Former women’s rowing coach fired by Barta. Knowledge of the
Rowing program and how male coaches were treated more favorably than female
coaches. She also has knowledge regarding a student athlete she was forced to coach that
was removed from the field hockey program.
Sharon Dingman – Volleyball Coach at Iowa fired by Barta. Knowledge of the barriers
to success of her program and the reasons for termination.
Tracey Griesbaum – Field Hockey coach at Iowa. Knowledge of coaching methods
used over career compared to coaching methods of other Big 10 Field Hockey coaches as
well as coaching methods of males at the University of Iowa.
Lisa Celluci –Assistant Field Hockey Coach under Tracey Griesbaum and replacement
of Tracey G. Knowledge of her observations and approval of all coaching methods used
by Tracey Griesbaum, and Gary Barta’s decision to hire Celluci to replace Greisbaum
despite knowing that Celluci had approved or participated in the coaching methods of
Griesbaum. Knowledge of her personal efforts to obtain further investigation into the
removal of Griesbaum and statements by Barta that “she and Tracey are different
people.”

                                                            
47
The general statement of knowledge does not suggest this is all the information for any witness. Other
witnesses (not listed here) and additional knowledge are contained in context of complaint and in
footnotes. Most contact information can be obtained from the University.
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Larissa Libby – Women’s Gymnastics Coach. Knowledge of her challenge to the
equality of facilities and support and her the threat by Mr. Barta directed toward her to
never do that again or risk termination.
Jane Meyer – SWA and second in command in administration prior to Barta. Demoted
by Barta in August of 2014 and removed by Bara from the athletic department in
December of 2014 in retaliation for complaints of discrimination. Knowledge of the
efforts to replace her as SWA and her removal from Athletic Department due to gender.
University Administration
Gary Barta – Current Iowa Athletic Director. Knowledge of the complaints of
Complainants, the failure to investigate their complaints, the complaints of other student
athletes and how the university supported male or failed to support female coaches, and
of the efforts of Cindy Fredrick to seek more equal facilities for Volleyball
Sally Mason – Knowledge of the failure of the University to investigate the pattern of
discrimination toward female coaches under Barta’s tenure. Knowledge of the failure to
investigate removal of Tracey Griesbaum or violations of Title IX based on requests of
Complainants.
Cynthia Joyce - Ombudsperson/Office of the Ombudsperson - Knowledge of the
complaints made by Complainants and reasons for the failure of the AD to permit any
investigation into these complaints.
Linda Stewart Kroon – Women’s Resource and Action Center - Knowledge of the
complaints made by Complainants and reasons for the failure of the AD to permit any
investigation into these complaints.
Tiffani Stevenson-Earl - Equal Opportunity and Diversity - Compliance Specialist and
ADA Coordinator - Knowledge of the complaints made by Complainants as well as
reasons for the failure of the AD to permit any investigation into these complaints.
Lisa Brewster - Equal Opportunity and Diversity – Knowledge of the complaints made
by Complainants and reasons for the failure of the AD to permit any investigation into
these complaints.
Georgina Dodge – Knowledge of University policies that require investigation into
allegations of discrimination and violations of Title IX. Knowledge of refusal by Athletic
Department to investigate removal of coaches and/or refusal by Athletic Department to
permit other University departments to conduct investigations into Athletic Department.
Direct knowledge of Complainant’s complaints and her own failure to investigate.
Jennifer Modestu - Knowledge of University policies that require investigation into
allegations of discrimination and violations of Title IX. Knowledge of refusal by Athletic
Department to investigate removal of coaches and/or refusal by Athletic Department to
permit other University departments to conduct investigations into Athletic Department.
Judy Whetstine - Knowledge of University policies that require investigation into
allegations of discrimination and violations of Title IX. Knowledge of refusal by Athletic
Department to investigate removal of coaches and/or refusal by Athletic Department to
permit other University departments to conduct investigations into Athletic Department.
Male Coaches and Comparators
Fran McCaffrey – Men’s basketball coach. Knowledge of his coaching methods (level
of yelling, aggression or anger) compared to that of Tracey Griesbaum and other females.
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Knowledge that his methods are certainly no less aggressive and likely more aggressive
than Tracey Greisbaum. Knowledge that he has never been investigated by
administration despite being fined for his aggressive behavior during games.
Jack Dahm – Men’s Baseball coach – Knowledge of his coaching methods compared to
female coaching methods.
Terry Anderson – Men’s golf coach – Knowledge of his coaching methods compared to
Tracey Griesbaum and that he was provided more than seven years to gain success in his
program.
Mark Hankins – Men’s golf coach –Knowledge of his coaching methods (yelling,
aggressive behavior etc) compared to that of Kelly Crawford (women’s golf coach fired
by Barta) Knowledge that he was not investigated by Barta despite knowledge about his
behavior toward male student athletes and female students.
Bond Shymansky – Women’s Volleyball coach – Knowledge of increased advantages in
recruiting due to new floor and knowledge of his coaching methods (level of aggression)
compared to that of female coaches.
Kirk Ferentz – Football coach - Knowledge of coaching methods and how his methods
and that of his staff are at least as aggressive if not much more aggressive than any
method use by Tracey Griesbaum
Chris Doyle –Strength coach who has knowledge of his actions towards male athletes
that seriously endangered their physical health as well as his continued support,
promotion and increases in pay that resulted after these events.
Persons with Factual and Additional Expert Knowledge
Bob Bowlsby – Former Athletic Director at Iowa. Knowledge of the progress at Iowa in
maintaining compliance with Title IX and advancing the role of women prior to 2006.
Christine Grant – Knowledge of the progress at Iowa in maintaining compliance with
Title IX and advancing the role of women prior to 2006.
Faye Thompson – Athletic trainer for Field Hockey and also other sports. Can testify
regarding the protocols in place that render it almost impossible for a coach to play
someone injured and how the University’s claims that one player “claimed to play
injured” is without any foundation and if so, should not be laid at the feet of the coach.
She can also testify about her personal observations of the coaching methods of Tracey
Griesbaum and other women compared to men.
Ned Amendola, MD –is the Director of the UI Sports Medicine Program and has served
as the head team physician for the Hawkeye football team and other Hawkeye athletic
teams since fall 2001. As team physician, Amendola attends all games, is responsible for
the care of all the athletes. Dr. Amendola supports the treatment by the SA’s by Coach
Griesbaum will, along with Faye Thompson, directly undermine the efforts of the
University to claim they had any concerns about any SA playing injured.
Various Experts - There are a number of experts who may be important to this case, but
who may be willing to offer information without compensation or in the role of witness.
In addition to Christine Grant (Title IX), and Dr. Amendola, these may include Laura
Burton (Laura.burton@uconn.edu) or other social scientists referenced in various
footnotes such as Fn’s 10, 14, 18, 20, 23, 24, 30 and 45.

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