Title IX is a federal statute with regulations (a set of instructions) that prohibits recipients of federal funding from engaging in discrimination on the basis of sex in education programs or activities. 

Title IX isn’t limited to athletic programs or colleges and universities. The District receives federal funding because it is a public education system. Therefore, the District must comply with Title IX. Title IX’s anti-discrimination mandate covers school enrollment/admissions and employment.

Sex-based discrimination also includes sexual harassment.

A Title IX Coordinator helps ensure the District is complying with Title IX. The Title IX Coordinator does this in part by monitoring compliance with district policies and procedures and keeping abreast of regulatory obligations. Through oversight of the Title IX program, the Title IX Coordinator identifies, prevents, and fixes sex-based discrimination.

The Title IX Coordinator also plays an important role in sexual harassment complaints. After sexual harassment complaints are received, the Title IX Coordinator reaches out to each individual person who was the reported target of harassment, even before an investigation starts, to see what, if any assistance might be needed. If possible, the Title IX Coordinator will help coordinate the assistance.

The Title IX Coordinator also helps ensure sexual harassment investigations are investigated according to established procedures, are compliant, and handled thoroughly and impartially.

Yes. Title IX defines sexual harassment in a very specific way. However, that defintition doesn’t change other definitions of sexual harassment, for instance in the Rights and Responsibilities Handbook, or Policy 415.00.

Conduct that does not constitute sexual harassment within the meaning of Title IX will be addressed under other applicable policies and procedures, such as Policy 415.00, the Rights and Responsibilities Handbook, or prior staff directives. Conduct that is substantiated under those policies or procedures could subject that person to discipline and/or other follow up action.

The definition of sexual harassment, for the purposes of Title IX, includes the following conduct, on the basis of sex:

• Unwelcome conduct determined by a reasonable person to be so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the District’s education program or activity; or
•  District Personnel conditioning (explicitly or implicitly) the provision of an aid, benefit, or service of the District on an individual’s participation in unwelcome sexual conduct (quid pro quo); or
• One of the following four (4) offenses within the meaning of the Title IX Grievance Procedures:
  • Stalking;or
  • Domestic violence; or
  • Dating violence; or
  • Sexual assault.

These defiitions are very specific. The Title IX Grievance Procedures provide more information on prohibited conduct.

Conduct that does not fall under the definition of sexual harassment as defined by Title IX will be addressed under other applicable misconduct policies or procedures.

Yes: Title IX applies to staff and students.

The Title IX Grievance Procedures specify rights afforded to all persons regardless of role. For example, students and staff both have the right to receive supportive measures after making a complaint, and have the right to be advised or supported by a person of their choice during a Title IX matter. The Title IX Coordinator will conduct sexual harassment investigations for both students and staff.

You have a right to make any kind of sex-based discrimination complaint. You also have the right to defend yourself if you are the subject of a Title IX complaint. 

Regardless of your role, you have the right to have someone support or advise you during a Title IX proceeding, such as your parents (if you are a minor) or a union representative (if you are unionized staff).

The Title IX Grievance Procedures contain more information about your rights and how to exercise them. If you need an accommodation or assistance understanding these rights, please contact the Title IX Coordinator for assistance.

Policy 102.00 “Equal Opportunity/Non Discrimination” and the Title IX Grievance Procedures address Title IX and are compliant with the Department of Education’s regulations on how to investigate and resolve Title IX complaints.

Policy 415.00 “Harassment, Discrimination, Violence, and Retaliation” also incorporates Title IX’s non-discrimination mandate. In addition to sex-based discrimination, Policy 415.00 also prohibits discrimination based on gender identity and expression, sexual or affectional orientation, and other protected classes.

A “415 complaint” is a complaint alleging a violation of Policy 415.00. Policy 415.00 prohibits discrimination, harassment, and violence on the basis of sex and more protected classes such as race, disability, national origin, and public assistance status.

Title IX and Policy 415.00 prohibit sexual harassment and sex discrimination. Complaints alleging sexual harassment will immediately be routed to the Title IX Coordinator, who will follow up and investigate according to the Title IX Grievance Procedures. Other complaints alleging sex-based discrimination will be investigated under existing procedures in Policy 415.00.

Under the Title IX Grievance Procedures, District Personnel (i.e. teachers, EAs, principals, bus drivers, custodians, cafeteria workers, nurses, counselors, 360 staff, TAs, etc.) with knowledge of sexual harassment or possible sexual harassment must make reports to the Title IX Coordinator and to their supervisor or administrator (principal/assistant principal).  District Personnel who are unclear about this requirement should consult with their supervisor and/or the Title IX Coordinator.

It’s okay! Contact the Title IX Coordinator or the EEO Director with questions or concerns:

Desiree' Payne
Title IX Coordinator
Desiree.Payne@spps.org, TitleIX@spps.org
360 Colborne Street, St. Paul MN 55102
651-767-8394 (office)
612-430-2805 (cell)

Maria Eustaquio
EEO Director
maria.eustaquio@spps.org, HumanRightsOfficer@spps.org
360 Colborne Street, St. Paul, MN
651-744-6950 (office)