UNITED STATES DEPARTMENT OF EDUCATION OFFICE FOR CIVIL RIGHTS 500 WEST MADISON ST., SUITE 1475 CHICAGO, IL 60661-4544 REGION V ILLINOIS INDIANA IOWA MINNESOTA NORTH DAKOTA WISCONSIN July 28, 2017 Dr. Raynard Kington President Grinnell College 1115 Eighth Ave Grinnell, IA 50112 Re: OCR Docket #05-15-2361 Dear Dr. Kington: On March 2, 2015, the U.S. Department of Education (Department), Office for Civil Rights (OCR) received the above-referenced complaint filed with OCR against Grinnell College (College) alleging discrimination on the basis of sex and also retaliation. Specifically, the complaint alleged: 1. Throughout the 2013-2014 and 2014-2015 school years, the College has subjected students, including Student A, to a hostile environment based on sex when the College failed to appropriately respond to complaints of sexual violence. 1 2. XXX, the College retaliated against Student A in XXXX when the College’s Title IX Coordinator disclosed Student A’s identity as a victim of sexual violence XXXXXXX. 3. Because Student B 2, XXXX, supported XXX, XXXXX, and XXXXXX, XXXX terminated Student B XXXX. OCR is responsible for enforcing Title IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. §§ 1681-1688, and its implementing regulation, 34 C.F.R. Part 106, which prohibit discrimination on the basis of sex in any education program or activity operated by a recipient of Federal financial assistance. Title IX also prohibits retaliation for certain protected activities. As a recipient of Federal financial assistance from the Department, the College is subject to Title IX. 1 The complaint was also filed on behalf of three other students. OCR determined those students’ allegations were not timely filed and, thus dismissed their allegations on July 22, 2015. 2 In correspondence dated July 22, 2015 notifying the parties of the complaint allegations, OCR identified Student B as Student D. The Department of Education’s mission is to promote student achievement and preparation for global competitiveness by fostering educational excellence and ensuring equal access. www.ed.gov Page 2 On July 22, 2015, OCR notified the parties it was opening an investigation into the allegations of discrimination and retaliation. XXX On November 4, 2015, Students A and B, through counsel, notified OCR in writing that they are withdrawing the instant complaint. Under Section 110(l) of OCR’s Case Processing Manual, OCR will administratively close an investigation when the Complainant withdraws the complaint and there are no systemic issues that warrant continuing the investigation. During the course of OCR’s investigation, OCR learned that the College revised its Title IX policy and grievance procedure that were in effect and applicable to Student A and Student B’s claims. Based on the settlement agreement and the revisions to the Title IX policy and procedures, OCR has determined that there are no systemic issues pending that warrant OCR continuing the investigation, and is, therefore, administratively closing the complaint effective the date of this letter. The letter sets forth OCR’s determination in an individual OCR case. This letter is not a formal statement of OCR policy and should not be relied upon, cited, or construed as such. OCR’s formal policy statements are approved by a duly authorized OCR official and made available to the public. The complainant may file a private suit in federal court, whether or not OCR finds a violation. Please be advised that the University may not harass, coerce, intimidate, retaliate, or discriminate against any individual because he or she has filed a complaint or participated in the complaint resolution process. If this happens, the individual may file another complaint alleging such treatment. Under the Freedom of Information Act, it may be necessary to release this document and related correspondence and records upon request. In the event that OCR receives such a request, we will seek to protect, to the extent provided by law, personally identifiable information, which, if released, could reasonably be expected to constitute an unwarranted invasion of personal privacy. Page 3 We wish to thank you and your staff for the cooperation extended to OCR during our complaint processing. If you have any questions about this letter, please contact Leticia Magdaleno, OCR Attorney, at 312-730-1590 or by email at Leticia.Magdaleno@ed.gov. Sincerely, Marcela Sanchez-Aguilar Supervisory Attorney cc: Leslie Gomez, Esq. (via e-mail lgomez@cozen.com)