Gender Inequity Among the Gender Equity Enforcers

Peter Wood

Several days ago I published an essay about a new policy on sexual harassment issued by the U.S. Office of Civil Rights.  The policy, which expands the definition of sexual harassment and removes various procedural protections for those accused, was presented in a letter to the president of the University of Montana.  The authors, however, declare that the rules imposed on Montana are meant to be a “blueprint” for colleges and universities nationwide.

The Montana letter has prompted an outpouring of scathing criticism from nearly all points on the political spectrum, and very little in the way of public support, though there is this from ThinkProgress

My article was picked up by Glenn Reynolds on his Instapundit blog.  He excerpted a phrase in which I referred to the “campus sexual harassment industry," and added: 

And here’s a piece of research I’d like to see: What’s the racial/gender makeup of the campus student-conduct offices regulating this sort of thing? I’ll bet it’s not representative of the student body.

The National Association of Scholars has lots of other things on its plate but I thought it might be worth a few hours of collective effort to see whether we could provide Professor Reynolds an insta-answer.  Thanks to NAS staff members Glenn Ricketts, Ashley Thorne, Michael Toscano, and Tessa Carter, I can report the following.

We looked at a random sample of 52 colleges and universities across the country. (Download the data in PDF here.)  The sample included public and private institutions, and we attempted to create geographical balance.  The only other restriction was that we looked for institutions that have some degree of national recognition.

Reynolds’s phrase “campus student-conduct offices regulating this sort of thing” turned out to be a little tricky.  On some campuses there is indeed an office that approximates this description, but on many others there are multiple offices charged with different parts of the regulation.  There can be:

  • An office for students to make harassment allegations
  • A separate office for all employees including faculty members to make harassment allegations
  • A separate office for faculty members to make allegations
  • A Title IX officer charged with ensuring Title IX compliance in all its forms.  (Title IX of the Higher Education Act was cited by the Office for Civil Rights as its authority for the “blueprint.”)
  • A Title IX staff in which Title IX and other responsibilities are distributed, sometimes with specialists handling sexual harassment allegations
  • An office charged with investigating allegations, which may be separate from the office that receives the allegations
  • An office charged with handling the “judicial process”

This makes it difficult simply to count up personnel, but it isn’t particularly difficult to gather relevant information. 

Almost every college and university has a designated Title IX coordinator.  We tried without success to obtain a list of all the designated college and university Title IX Coordinators in the U.S.  OCR was not answering its phones.  The Association of Title IX Administrators (ATIXA) has a membership list but it is available only to members.  The Feminist Majority Foundation says, “Although the Title IX regulations require that the names and contact information of Title IX coordinators be made public, there is no comprehensive listing of Title IX coordinators. However, we now have a list of Title IX Coordinators in state education agencies (PDF).” 

Many colleges and universities have in addition to a Title IX Coordinator a collection of “deputy Title IX Coordinators” or employees listed as Title IX “contacts.”  The Title IX Coordinators, Deputies, and contacts, of course, don’t exhaust the personnel who work on harassment issues.

We also found that Title IX Coordinators can be “certified,” as can “Title IX Investigators.”  Some of this requisite training is provided through ATIXA.  The National Center for Higher Education Risk Management (NCHERM) also offers such training.  To become a certified Title IX Coordinator via ATIXA training will set you back $2500, a fee that “includes attendance for four days, extensive training materials, and certification. Continental breakfast each morning and afternoon snacks each afternoon” are provided. A modest investment for a promising career with a future, thanks to OCR.

Another complication is that OCR’s focus on “sexual harassment” blurs into other categories.  Sexual assault and rape lie outside the official purview of OCR but it has long taken the view that assaults and rapes create a “hostile environment” or a “climate” in which harassment flourishes. The “blueprint” letter expands on this. It declares that, “A single instance of rape is sufficiently severe to create a hostile environment,” and then expands this idea still further: “a single instance of sexual assault can constitute a hostile environment.” These declarations give credence to those colleges and universities that already tend to blur the lines between speech and violence. Some colleges speak of “sexual misconduct” as a category that includes both. The blurring under the rubric “sexual misconduct” may go even further, erasing the line between intentional and unintentional behavior and the line between unwelcome attention to individuals and general public expression.  We also encountered the term “sexual violence” which may be the same as “sexual assault” but which appears in some instances as a separate category distinct from “sexual assault.”  At least one university put “sexual harassment” under the broader rubric of “sex discrimination.”

So when we went looking for offices that deal with policy and enforcement on “sexual harassment” we found ourselves in a bureaucratic maze in which various offices might combine or segregate sexual harassment with other kinds of harassment, and/or sexual assault, and/or unwelcome verbal interactions between individuals, and/or actions (such as assigning a book that someone takes offense to as “sexist”) that could be construed as contributing to a “hostile environment.”

So, Professor Reynolds, that assignment was harder than it looked.


We examined 52 institutions.  All have Title IX Coordinators as mandated by law for all institutions receiving federal funding.

At 43 of them (82.7 percent), the Title IX Coordinator is a woman. At 9 of the institutions (17.3 percent), the Title IX Coordinator is a man. 

In 24 of the 52 institutions, we found lists of staff members beyond the Title IX Coordinator who work on Title IX issues or are listed as responsible for dealing with sexual harassment issues. In these 24 cases, 49 of the additional 67 staff (73.1 percent) are women.  All our assignments are on the basis of names and sometimes photographs. Our inability to identify transgender individuals may marginally affect the accuracy of our tabulations. 

We had no access to data about the racial identities of Title IX Coordinators. 

We found that 32 of the 52 Title IX Coordinators (61.5 percent) were bureaucratically part of their institution’s Equal Opportunity/Diversity/Equity/Access operation. 

Departments of Title IX Coordinators

Equal Opportunity/Diversity/Equity/Inclusion/Access:


Dean of Students/Student Affairs:


Human Resources:


Sexual Harassment/Sexual Misconduct/Sexual Assault:






Risk Management:




Analysis and Comment

We noticed that at least 7 of the 52 Title IX Coordinators list law degrees in their profiles. 

Glenn Reynolds speculated that the “racial/gender makeup of the campus student-conduct offices” that enforce sexual harassment regulations is not “representative of the student body.”  With that in mind we looked up on the U.S. Department of Education’s Integrated Postsecondary Education Data System (IPEDS) the sex ratios of undergraduate enrollment at our 52-institution sample.  The lowest percentage of females was at North Dakota State (43 percent); the highest percentage of females was at Quinnipiac University in Hamden, Connecticut (62 percent female).   Only one other college, Gordon College in Wenham, Massachusetts (61 percent female) topped 59 percent.  The general range was 49 to 59 percent female. 

By this metric, women are substantially overrepresented in the position of Title IX Coordinator.   To be “representative of the student body,” approximately 27 to 29 of the 52 Title IX Coordinator positions (~55 percent) should have been held by women. But in our sample, 43 of the positions (83 percent) are held by women.  Likewise women appear overrepresented in the staff positions of the relevant campus offices, but the level of overrepresentation was less than for the top positions (73.1 percent of the positions are held by women). 

Considering that the overwhelming preponderance of sexual harassment allegations are directed by women at men, the disproportion of women to men in the positions charged with interpreting and enforcing the sexual harassment rules is a legitimate concern.  Are male students who are accused of sexual harassment likely to receive fair-minded treatment in these offices?  They already face a system of rules and definitions jerry-rigged by the Office of Civil Rights to deny them the presumption of innocence and to minimize due process guarantees. 

This isn’t the place to elaborate those concerns.  We have focused rather on the straightforward issue of staffing in a position where the “gender” (we prefer the old-fashioned word “sex”) of the people in charge might reasonably be thought to have some bearing on the integrity of the process.  In other situations, such disproportions would plainly be a cause for apprehension rising perhaps to a claim of bias.  This is not to impugn the integrity of any individual holding the position of Title IX Coordinator.  It is simply to point out that this is a position of genuine and growing authority on college campuses that is disproportionately held by women. 

That fact undermines the principle of gender equity that is at the heart of Title IX.  This is ironic but it is not merely irony.  Title IX rules are perceived by many as unjustly enforced.  The gender disproportion among those who enforce the rules substantiates that perception.

Download the data (PDF) >

Image: ESPNHS.

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