University of Nebraska Omaha
DigitalCommons@UNO
Educational Leadership Faculty Proceedings &
Presentations
Department of Educational Leadership
11-2014
Campus Sexual Assaults: Times Are Finally
(Maybe) Changing
David L. Stader
Southeast Missouri State University
Jeanne L. Surface
University of Nebraska at Omaha, [email protected]
Jodi L. Williams
University of Missouri
Elisabeth M. Krimbill
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Recommended Citation
Stader, David L.; Surface, Jeanne L.; Williams, Jodi L.; and Krimbill, Elisabeth M., "Campus Sexual Assaults: Times Are Finally
(Maybe) Changing" (2014). Educational Leadership Faculty Proceedings & Presentations. Paper 8.
http://digitalcommons.unomaha.edu/edadfacproc/8
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Campus Sexual Assaults: Times Are Finally (Maybe) Changing
David L. Stader, EdD, Professor, Educational Leadership and Counseling, Southeast Missouri
State University, Cape Girardeau, MO
Jeanne L. Surface, EdD, Associate Professor, Educational Leadership, University of NebraskaOmaha, NE
Jodi L. Williams, MBA, EdD. Candidate, University of Missouri
Elisabeth M. Krimbill, EdS., Assistant Principal, Barbara Bush Middle School, San Antonio,
Texas.
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Campus Sexual Assaults: Times Are Finally (Maybe) Changing
Sexual assault on college and university campuses is a serious problem nationwide.
Although college men and women are sexually assaulted, college campuses may be particularly
dangerous places for young women (Grey, 2014; Karjane, Fisher, & Cullen, 2002; McCaskill,
2014 ). The physical, mental, and emotional devastation a sexual assault can have on a victim is
compounded by the fact that too many college-student victims must also confront the troubling
reality of being re-victimized by their schools (Karjane, et al., 2002; Krebs, Lindquist, Warner,
Fisher, & Martin, 2007 & 2009; McCaskill, 2014). Colleges and universities have discouraged
reporting, made reporting difficult, failed to use effective penalties to hold perpetrators
accountable, and have allowed student participation on sexual assault adjudication committees,
further endangering alleged perpetrators and victims’ privacy. Victims also fear a ‘blame the
victim’ mentality and reprisal for activities such as underage alcohol use preceding some assaults
or for having “sex in the residence hall” in violation of campus policy (Karjane,et al. 2002;
Lewis, Schuster, & Sokolow, 2010; McCaskill, 2014).
Defining sexual assault and accurately assessing the various ways in which women can
be victimized can be difficult (Fisher, Cullen, & Turner, 2000). To address this problem, Fisher
et al. (2000) used a series of very specific ‘screen questions’ and a well-defined reference period
in a nationwide study of campus sexual assault. The researchers asked questions such as “Since
school began in fall 1996, has anyone made you have sexual intercourse by using force or
threatening to harm you …? Just so there is no mistake, by intercourse I mean putting a penis in
your vagina (p 6).” Using this type of screen questions in a nationwide study of 4,446 women
attending a 2-or-4 year college or university in the fall of 1996, Fisher et al. (2000) found that
2.8% of respondents had experienced a completed rape (1.7%) or either attempted rape (1.1%)
with in the last seven months. This translates to a victimization rate of 27.7 rapes per 1,000
female students. While somewhat problematic, this data can be projected to indicate that nearly
5% of college women are victimized in a calendar year. Assuming that a typical college career
last approximately five years the percentage of completed or attempted sexual assault could be as
much as 20-25% of women enrolled in colleges and universities.
Krebs, et al. (2007; 2009) used a similar very specific set of screen questions to collect
surveys from 6800 undergraduate students (5,466 women and 1,375 men) at two large public 4year universities representing the southern and Midwestern parts of the United States. The
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defined reference point was sexual assault experiences since entering college. Self-reported
sexual assault among males was low (3.7%). The report therefore focused only on women’s selfreported sexual assault data. Approximately 20% of undergraduate women responding to the
survey report experiencing an attempted or completed sexual assault during their college years
(Krebs et al., 2007; 2009). When factoring in any sexual assault in the past 12 months, college
sophomores had the highest incidents of sexual violence. This pattern indicates that women may
be more vulnerable or more likely to be sexually assaulted in the first two years of college. Most
women in this study (84%) experiencing sexual assault report being incapacitated and unable to
provide consent. A small minority (0.6%) report being given a drug without their knowledge.
Most of the assaults were perpetrated by someone the victim knew.
In a more recent study of 314 female undergraduates representing freshmen through
seniors, Lawyer, Resnick, Bakanic, and Kilpatrick (2010) found that 26.6% of participants
reported 168 total incidents of some sort of assault experiences since the age of 14. These
approximately 78 participants alone reported a total of 168 assault incidents. A majority of
participants (86%) who experienced one or more sexual assaults including rape described an
incapacitated assault due to the voluntary consumption of alcohol or drugs. Almost 16% reported
a drug-facilitated assault by at least partially involuntary consumption of alcohol or drugs. When
asked what drug was consumed prior to the assault, all (96%) of the participants reported the use
of alcohol. Similar to Krebs et al., (2007: 2009), most assaults where competed by someone the
victim knew.
Although the research into campus sexual assault is thin, incident rates found in these
studies are consistent. These studies indicate that as many as 20% of college women experience
either completed or attempted sexual assault during their college careers. In addition these
studies suggest that a) the intentional or unintentional overuse of alcohol by undergraduate
women significantly increases the risk of being sexually assaulted; b) most assaults are not
completed by strangers but someone the victim knew and possibly trusted at least to some extent:
and c) the use of ‘date rape’ drugs to facilitate campus sexual assaults does not seem to be
common.
Title IX and Campus Sexual Assault
Title IX is part of the Educational Amendments of 1972 (34 C.F.R. Part 106). The Act
states, in part, that “no person shall, on the basis of sex, be excluded from participation in, be
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denied the benefits of, or be subjected to discrimination under any academic, extracurricular,
research, occupational training, or other education program or activity operated by a recipient
which receives Federal financial assistance” (§ 106.31a). Basically any institution, public or
private, that takes federal funds in the form of student Pell grants, loans, or other federal monies
is required to abide by the law. Failure or refusal to do so may result in the removal of all federal
funds from the institution. The Office for Civil Rights (OCR) is responsible for enforcing Title
IX in PK-12 schools and institutions of higher education (Dear Colleague, 2010).
One of the most visible impacts of Title IX has been a significant increase in female
interscholastic athletic teams in colleges and universities (Dear Colleague, 2007). One of the less
visible impacts is the application of Title IX to incidents of sexual harassment and assault in
colleges and universities. Title IX provisions are enforced in the following two ways when
sexual violence is at issue: 1) Administrative enforcement by the Office of Civil Rights and 2)
the Federal court system (Cantalupo, 2014).
In April of 2011, the U.S. Department of Education Office for Civil Rights (OCR) issued
a “Dear Colleague” letter to colleges and universities clarifying their obligation under Title IX to
respond in a timely and effective manner to complaints of student sexual assault (Dear
Colleague, 2011). The Dear Colleague letter (2011) included a comprehensive directive
outlining the responsibilities of institutions of higher education when allegations of sexual
harassment and/or sexual violence are reported. OCR concludes that “a school that knows, or
reasonably should know, about possible harassment must promptly investigate to determine what
occurred and then take appropriate steps to resolve the situation” (Dear Colleague, 2011, p. 4
italics added). This statement means that reports made by the alleged victim, her or his friends,
or the victim’s parents must be investigated. If a student files a complaint with the school, the
school must process the complaint according to their established procedures. Because students
often experience the continuing effect of off-campus sexual assault in the educational setting,
schools should consider the effects of the off-campus conduct when evaluating whether there is a
hostile environment on campus (Surface, Stader, Graca & Lowe, 2012).
In cases involving criminal conduct (i.e. sexual assault), school personnel should
determine the appropriate law enforcement agency to notify. However, notification of law
enforcement does not release the institution from their legal responsibility to promptly respond
and investigate the alleged assault. Schools may not wait until the criminal investigation is
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completed to begin their own investigation. Once the complaint is filed, the school is also
obligated to inform the alleged perpetrator of the allegations and that retaliation is prohibited, as
well as explaining that if retaliation occurs a strong response from the institution will follow
(Dear Colleague, 2011).
The Letter went on to confirm that institutional student disciplinary procedures should
use a ‘preponderance of the evidence standard’ of review rather than the more rigorous ‘clear
and convincing evidence’ standard used by some institutions (McCaskill, 2014). Preponderance
of the evidence standard is typically defined as ‘more likely than not’, meaning it is more likely
the sexual assault occurred than it did not. According to OCR, this standard is necessary to
ensure an equitable disciplinary hearing because it is consistent with other civil rights laws.
Additionally, this is the evidentiary standard used by OCR when investigating a school’s alleged
failure to comply with Title IX (Dear Colleague, 2011).
Administrative enforcement by the Office for Civil Rights is generally prompted as a
result of a complaint being filed with OCR over a college or university inadequately responding
to sexual harassment or assault report. OCR undertakes a comprehensive investigation of current
policies and practices regarding sexual harassment/assault, reviews files of previous sexual
harassment/assault cases, and reaches conclusions regarding compliance with Title IX and OCR
guidelines. Concerns are usually resolved with a ‘letter of findings,’ which outlines changes to be
made to policy and practices in future cases (Cantalupo, 2014). As long as the institution adopts
these changes and demonstrates commitment to enforce them, OCR generally closes the
investigation. OCR does not have the ability to award monetary damages to survivor/ victims of
sexual assault even when it is clear the institution mishandled the complaint.
Title IX and the federal courts
The second avenue of Title IX enforcement is through the federal court system. Title IX
applies to all schools that accept federal funds. Thus, court decisions in one area, PK-12 for
example, applies equally to institutions of higher education. Although Title IX legislation does
not mention sexual harassment or assault, the Second Circuit Court was one of the first courts to
apply Title IX to college student allegations of sexual harassment by male faculty (Alexander v.
Yale University, 1980). Furthermore, the U. S. Supreme Court has established that monetary
damages are available to victims of sex discrimination under Title IX (Franklin v. Gwinnett
County Schools, 1992). Subsequently, the U. S. Supreme Court developed guidelines for
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determining if monetary damages are available (Gebser v. Lago Vista Independent School
District, 1998). In Gebser, a high school student had sexual relations with one of her teachers but
did not report the relationship to school officials. The relationship became known when the
police found the teacher and student having sex in the teacher’s car. The teacher was arrested.
However, the Court established that a district would not be liable unless a school official who
could take disciplinary action had knowledge of the situation and acted with deliberate
indifference.
Institutional liability for student-on-student sexual harassment or assault was established
by the U. S. Supreme Court one year later in Davis v. Monroe County Board of Education
(1999). Fifth grader LaShonda Davis was the victim of prolonged pattern of sexual harassment
by a classmate. LaShonda and her mother reported the incidents to school officials. During this
time, LaShonta’s grades suffered and she contemplated suicide. The Court held that school
districts could be liable for student-on-student sexual harassment when 1) school personnel have
actual knowledge of the harassment; 2) school personnel are deliberately indifferent to the
harassment or respond in a clearly unreasonable manner in light of the known circumstances
and 3) the harassment is so severe, pervasive, and objectively offensive that is can be said to
deprive the victim(s) access to educational opportunities (Alexander & Alexander, 2011; Stader,
2013 Italics added). The District Court of Connecticut (Kelly v. Yale, 2003) further established
that campus sexual assault is actionable under Title IX by stating “After Yale received notice of
the harassing conduct, it had a duty under Title IX to take some action to prevent the further
harassment of Kelly.” This court, along with others, has established that a single incident of
sexual assault arises to the level of sexual harassment by stating “There is no question that a
rape, as alleged by Kelly, constitutes severe and objectively offensive sexual harassment under
the standard set forth in Davis ( See also Jennings v. University of North Carolina, 2007).
These court decisions establish that once school officials have knowledge or should have
knowledge of sexual assault, Title IX triggers a host of legal obligations. Basically, Franklin,
Gebser, and Davis establish that institutions can be held monetarily liable for sexual harassment
or assault when relevant officials have actual notice of the harassment and are deliberately
indifferent or respond in an unreasonable manner once notice has been given (Alexander &
Alexander, 2011). In one way the requirement that relevant officials have actual notice can
actually create more incentive for institutions to discourage reporting, make reporting difficult,
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or push the investigation off to local law enforcement (Cantalupo, 2014). However, Federal
courts have started to consistently apply Title IX standards to allegations of institutional
deliberate indifference to student sexual assaults. For example, an institutions failure to properly
investigate a sexual assault claim or meaningfully and appropriately discipline the offender can
be seen as meeting the deliberate indifference standard (S. S. v. Alexander, 2008). Allowing the
alleged student to continue to attend classes with the victim or inform the victim that she should
change classes (Terrell v. Delaware, 2010), discouraging the filing of a police report, accepting
the alleged perpetrators denial at face value, and encouraging the victim to leave her job while
allowing the alleged perpetrator to remain (S.S. v. Alexander, 2008) are just a few examples of
institutional deliberate indifference to allegations of student-on-student sexual assault.
Title IX Game Changers
Lewis, Schuster, and Sokolow (2010) argue that courts have become ‘fed up’ with
college responses to allegations of sexual assault. The authors point to four court cases they
believe are ‘game changers’ in Title IX litigation of alleged mishandling of sexual assault in
colleges. These cases include Jackson v. Birmingham (2005), Simpson v. University of Colorado
(2007), Williams v. the University of Georgia (2007), and Jennings v. the University of North
Carolina (2007).
Jackson (2005) involves retaliation for reporting or complaining about sex
discrimination. Roderick Jackson was employed by the Birmingham School District as physical
education teacher and girls’ basketball coach. In 1999 he was transferred to the high school. He
discovered that the girls’ team was not receiving equal funding and access to equipment and
facilities compared to the boys’ team. He complained to his supervisor about the inequalities.
Shortly thereafter, ee soon begin receiving negative evaluations and in 2001 he was relieved of
his basketball coaching duties. The U. S. Supreme Court held that Title IX’s private right of
action (established in Gebser and Davis) applied to claims of retaliation for complaining about
sex discrimination. This logic was later applied to coaching complaints about sex discrimination
in college athletic programs. As a result, California State University-Fresno faced multiple Title
IX retaliation claims. Two of these cases were decided by juries for $5.85 million and $19.1
million (for a more detailed discussion see Buzuvis, 2010). While these cases are not about
student-on-student sexual harassment they effectively demonstrate that retaliation for reporting
allegations of sexual assault is forbidden. Additionally, retaliation by the athletic department or
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a coach for reporting alleged sexual assault against a student athlete could result in significant
damages.
During the late 90s and early 2000s the University of Colorado at Boulder was a football
powerhouse. As part of the football team’s recruiting process the athletic department paired
visiting recruits with an “ambassador” that were to show recruits a “good time.” Anne Gilmore
and Lisa Simpson were two of the employed student ambassadors. At an off-campus apartment
both Gilmore and Simpson were sexually assaulted by players and recruits. The women brought
a Title IX suit (Simpson v. U. of Colorado at Boulder, 2007) alleging that 1) CU had an official
policy of showing recruits a “good time,” 2) the alleged assaults were caused by a failure to train
and properly supervise ambassadors, and 3) the likelihood of such misconduct was so obvious
that CU’s failure constituted deliberate indifference. On appeal the 10th Circuit Court of Appeals
expanded the definition of deliberate indifference to include a failure to provide adequate
training or guidance that is obviously necessary. The university chose to settle the lawsuit,
agreeing to pay $2.5 million to Lisa Simpson and $350,000 to Anne Gilmore (Lewis et al.,
2010). Basically, Simpson put colleges on notice that they may be liable when the institution
created a discriminatory environment (Lewis, et al., 2010). For example, as will be reviewed in
the next case, the possible consequences of a higher education institution admitting a studentathlete with a known history of allegations of sexual assault or date violence and then failing to
provide adequate training and supervision of the student may result in liability.
In the evening of January 14, 2002 Tiffany Williams received a call from University of
Georgia (UGA) basketball player Tony Cole (Williams v. the University of Georgia (2007). He
invited her to his dorm room where they had consensual sex. However, a friend of Cole’s was
hiding in the restroom and subsequently sexually assaulted Williams. Cole then called another
friend who came to the room and also sexually assaulted Williams. Williams returned to her
residence hall and called a friend who urged her to report the rape to campus police. Williams
said she was afraid to do so. Later she called her mother who contacted UGA police. After filling
a report, Williams left UGA. An UGA disciplinary panel held hearings almost a year after
receiving the sexual assault reports from the university police. Two of the accused students,
including Cole, had left the university by that time and the panel decided not to sanction any of
the students.
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Tiffany Williams brought a $25 million Title IX and §1983 suit against UGA, the Board
of Regents of the University System, James Harrick, the former head basketball coach, Athletic
Director Vince Dooley, and UGA President Michael Adams. It was discovered that Cole was not
academically eligible for admission to UGA and was admitted under a “special admissions”
policy that required presidential approval. The head basketball coach had recruited Cole and
helped him get admitted to a community college. However, Cole was dismissed from the
community college after allegations that he sexually assaulted two female employees. He
pleaded no contest to criminal charges. The coach, athletic director, and the president were aware
of his dismissal and no contest plea, as well as another, previous and his dismissal from another
community college for disciplinary problems, including making lewd suggestions to a female
store clerk.
The district court dismissed Williams’ Title IX and §1983 claims. On appeal, the 11th
Circuit Court of Appeals reversed the district court’s decision to dismiss Williams’ Title IX
complaint, but upheld the dismissal of her § 1983 complaint. The court reasoned that the
defendants’ knowledge of Cole’s prior acts established prior knowledge. Therefore, the failure to
take immediate corrective action combined with the failure to monitor and supervise Cole
amounted to deliberate indifference. The case was settled out of court for an undisclosed amount
(Lewis et al., 2010).
In another case, the University of North Carolina at Chapel Hill head woman’s soccer
coach Anson Dorrance apparently habitually engaged in sexually explicit conversations with his
players. He also engaged in sexually inappropriate advances to at least one player, Debbie
Keller. Sophomore Melissa Jennings reported this conduct to Susan Ehringhaus, Legal Counsel
to the University. On first reading this sounds like an easy Gebster case (Lewis et al., 2010).
However, Dorrance is one of the most successful soccer coaches in the country. Ehringhaus told
Jennings to ‘work it out’ with Dorrance. She was cut from the squad the next year. Her parents
submitted several complaints to the Chancellor. Finally the Athletic Director reviewed the
allegations and sent a mild letter of reprimand to Dorrance. Jennings then brought suit under
Title IX and § 1983 personnel liability against the coach and general counsel. When the suit was
announced Jennings was subjected to harassment and was told the university could not guarantee
her safety. She withdrew and attended another university. The district court granted summary
judgment to the university. On appeal, an en banc appeals court held for Jennings finding all
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three Davis standards were met (Jennings v. the University of North Carolina (2007). Jennings
settled for $375,000 and Keller recieved a six-figure settlement before filing suit (Lewis, et al.,
2010). If Williams and Jennings demonstrate anything, it is that athletic departments should not
oversee sexual harassment/assault allegations against student-athletics or coachers. However,
more than 20% of institutions currently give the athletic department oversight of sexual assault
accusations involving student athletes. This practice creates significant challenges for victims
(McCaskill, 2014).
Finally, Lewis, et al., (2010) contend that multi-million dollar judgments may become
commonplace and they may be right. In 2009, Arizona State University (ASU) paid $850,000 to
settle a Title IX suit by a female student who was raped in her dorm room by one of the school’s
football players (Munson, 2009 February 3). The perpetrator was in trouble from the first few
days on campus. He was accused of grabbing and touching women in the dorm, exposing
himself to female staff members and threatening freshman women. As in Simpson and Williams,
the suit claimed the university had placed the victim in a dangerous position. Five women
recently settled with the University of Connecticut for nearly $1.3-million to settle a Title IX suit
alleging the mishandling of their complaints of sexual assault (Vendituoli, 2014 July 18). The
victims claimed that University police had withheld information on two sexual assault reports,
and failed to take rape and death threats seriously. One of the complainants was a member of the
women’s hockey team at UConn. After she told the university she had been raped by a male
hockey player her coach told her she would ‘bring the team down’ if she continued to play. She
received the largest settlement of $900,000. As these and other Title IX complaints and
settlements become public, it is anticipated that more alleged victims of campus sexual assault
will come forward and file lawsuits under Title IX (Vendituoli, 2014 July 18).
Conclusions
These lawsuits and settlements indicate that many institutions have failed to comply with
Title IX and best practices in effectively adjudicating accusations of sexual violence. These
lawsuits should serve as a warning shot that Federal courts will no longer allow institutions to
deny the problem of sexual assaults, make reporting difficult, or to mishandle the complaints
once the appropriate officials know or reasonably should have known These cases should also
serve as a ‘wake-up call’ that federal courts have expanded the definition of deliberate
indifference. Of particular note is the move toward finding that institutions may be held liable for
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creating the danger by 1) ignoring allegations of sexual assault or recruiting athletes that have
been charged or found responsible for sexual assault at another institution (Williams v. the
University of Georgia (2007); Jennings v. the University of North Carolina (2007); 2) ignoring
reports of coaches discouraging reporting sexual harassment or assaults by student athletes; and
3) retaliation for reporting sexual violence to school officials (Munson, 2009 February 3;
Vendituoli, 2014 July 18).
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Williams v. University of Georgia 367 F.3d. 1255 (11th Cir. 2007).