•

Answer:  Again, we cannot talk about specific cases, but as noted above, 
regardless of how a reporter elects to end the informal process, school officials 
take a number of steps with both parties, these include:   
o Discussing expectations for behavior with respondent, including 
confidentiality, and reiterating the school’s prohibition against retaliation 
and related consequences; if appropriate, based on the facts of the case 
and the desires of the reporter, the school will issue a no contact order 
against the respondent   
o Continuing counselling, religious support and 24-hour access to CARE 
team for the reporter as he/she requests, as well as to the respondent 
o Reminding both the reporter and the respondent that the reporter can 
invoke formal proceedings at any time and that records are maintained 
for use in any future proceedings 

•

As far back as the Guidance in 1997, and as late as the Questions and Answers 
published in 2014, the Department of Education has recognized that a school’s 
ability to respond to a report of harassment or assault is limited when a reporter 
does not wish to initiate formal action against the respondent. The DOE has 
suggested schools review, update and publicize the school’s policies, conduct 
additional training for the department or organization where the problem 
occurred, and/or implement other systemic measures at the site or department 
where the alleged activity occurred.   
o In this instance, the school conducted a review of its policies, and 
ultimately published revised policies in 2012.   
o The Citadel’s unique structure allows it to publish information to the 
entire student body quickly and relatively personally: each cadet 
company of approximately one-hundred cadets includes three cadets 
specifically trained as human affairs specialists.  The CARE team sends 
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updates, reminders, and reinforcements to these cadets periodically, 
including after incidents; cadets attend numerous mandatory formations 
each day, and the human affairs teams publish this information at those 
formations.  In some cases, the CARE team itself will conduct special, 
dedicated training to an individual company, during one of the two 
weekly one hour training sessions that all cadets attend.   
o More broadly, the CARE team provides continuing sexual assault and 
sexual harassment prevention education for all cadets, including required 
classes during each year of a cadet’s college career. 
Prevention education focuses on definitions, laws, expectations, 
prevention strategies, communication styles, risk-behavior 
identification/mitigation, healthy relationships, bystander intervention 
education, and the relationships between sexual assault/sexual 
harassment (SA/SH) and alcohol/other drugs (see Educational Programs).  
 
A quote from John Gedney, Title IX Coordinator, The Citadel: 
Historically, sexual misconduct reporting among college students has been very low, 
sometimes because they fear the consequences to their reputations, etc.  The informal process 
has helped turn reporting around by providing an option for members of the college 
community to report incidents and get information and help without exposing themselves 
through a formal process.  This option is vitally important in military colleges where students 
eat, train, sleep, and study together as units.  As the policy we were acting under at the time of 
the report states:  “If you only want assistance with getting counseling and medical treatment, 
you may report the incident to the Ombudsman, the Infirmary, The Assistant Commandant for 
Administration and Coeducation, The Sexual Assault Response Coordinator (SARC) or Assistant 
SARC, or the Special Assistant to The President, and request this assistance as outlined in 
paragraph E below.  It is critical that you report the incident to someone so you can get 

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help.  We do strongly encourage you to report the perpetrator since this individual may have a 
pattern of behavior where he/she has assaulted other victims.” 
As mentioned in the 2001 Title IX Guidance:  “Once a school has notice of possible sexual 
harassment of students –– whether carried out by employees, other students, or third parties –– 
it should take immediate and appropriate steps to investigate or otherwise determine what 
occurred.”   The informal process allow us to “Otherwise determine what occurred” without 
immediately invoking our formal procedures, which require a written statement and reporters 
opening themselves up to providing details and names to an investigator, and perhaps having 
to participate in a disciplinary board.      
During the entire informal process, the reporter is reminded that he/she has the option 
to invoke the formal process.  Sometimes they choose to go that route, but often they 
don’t.  While the informal process doesn’t provide the same responses as a formal process, it 
does create safer, healthier campuses because more students report misconduct, are provided 
with opportunities to receive advocacy and other support services, are more aware of their 
options for reporting and protection and, when they do opt to provide the name of the 
accused, colleges have records and the opportunity to provide more education. 

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