by
Patrick Noonan, Owner & Principal at Grey Zone LLC | Workplace & Title IX Investigator
In 2025, The Education Department’s Office for Civil Rights (“OCR”) resolved zero Title IX matters and zero race discrimination cases after President Trump took office.
While this might suggest education institutions can take a deep breath when it comes to implementing their policies, that sentiment couldn’t be further from the truth.
Despite the many changes in how the administration is enforcing Title IX regulations or Title VI matters, race and sex discrimination are still illegal under federal law. And even despite the yo-yoing of regulations, Title IX also still requires schools to address sexual harassment through rigorous investigations and hearing procedures.
If anything, institutions need to be more vigilant in the current environment, as the administration also has a propensity to follow headlines with their enforcement actions. That means agency enforcement can be a sporadic and whiplash-inducing as human behavior and media cycles, which, as anyone who works in this space knows, can be pretty exhausting.
So, while we would all like to take a breather—and to be clear, we all need that from time to time—this is not a moment to take your eye off the ball. Rather, as we are already 1/3 of the way through the Spring semester, it’s a great time to start thinking about those fiscal year reports and whether there is some deck-clearing to be done between now and then.
If you could use a hand looking at and analyzing your data, or need some help with a backlog of cases, please reach out.
About the Author
Patrick Noonan is the owner and principal of Grey Zone LLC, an investigations and consulting firm specializing in workplace investigations, civil rights, and Title IX matters.
He has conducted hundreds of investigations across higher education, nonprofit, and workplace settings, and has held leadership roles in compliance and civil rights functions. His work focuses on producing clear, defensible findings in complex and high-stakes matters.
Read more about Patrick or about Grey Zone.
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