Title IX Services

Sobel Law Solutions provides Title IX services to individuals and institutions across the country. The practice represents complainants and respondents in proceedings at colleges, universities, and K-12 schools, conducts independent investigations for institutions, and litigates Title IX claims in federal court. The work spans the full procedural arc, from the notice of allegations through investigation, hearing, appeal, and federal litigation when necessary.

The four service lines below cover the firm’s Title IX work. If you are a student, faculty member, administrator, or institutional client and your situation does not fit cleanly into one of them, reach out to discuss the matter directly.

Title IX of the Education Amendments of 1972, 20 U.S.C. Section 1681, provides that "no person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal financial assistance." The statute is enforced administratively by the Department of Education's Office for Civil Rights, through institutional grievance procedures required by federal regulation, and through private civil actions in federal court.

For monetary damages claims, the Supreme Court's framework from Gebser v. Lago Vista Independent School District, 524 U.S. 274 (1998), and Davis v. Monroe County Board of Education, 526 U.S. 629 (1999), requires that the plaintiff show actual notice of harassment to an appropriate person with authority to take corrective action, plus the institution's deliberate indifference to that notice. Davis extended Title IX liability to student-on-student harassment where the harassment is severe, pervasive, and objectively offensive and effectively bars the victim's access to an educational opportunity. The Sixth Circuit applies Gebser and Davis rigorously, particularly on the actual-notice and deliberate-indifference prongs (Kollaritsch v. Michigan State University Board of Trustees, 944 F.3d 613 (6th Cir. 2019); Snyder-Hill v. Ohio State University, 48 F.4th 686 (6th Cir. 2022)). Emotional-distress damages are not available against funded institutions under the Spending Clause framework articulated in Cummings v. Premier Rehab Keller, P.L.L.C., 596 U.S. 212 (2022), which restricts Title IX monetary recovery in important ways.

For institutional procedure, the regulatory landscape has been turbulent. The 2020 Title IX regulations at 34 C.F.R. Part 106 were briefly displaced by the Biden Administration's 2024 Title IX regulations (89 Fed. Reg. 33474), which took effect August 1, 2024. On January 9, 2025, the United States District Court for the Eastern District of Kentucky vacated the 2024 regulations nationwide in Tennessee v. Cardona, No. 2:24-cv-072-DCR (E.D. Ky.), holding that the regulations exceeded the Department's statutory authority. The 2020 regulations have controlled in every jurisdiction since the vacatur and remain controlling as of May 2026. Constitutional due process protections apply in addition for public-institution proceedings, including the Sixth Circuit's requirement of meaningful cross-examination in credibility cases under Doe v. Baum, 903 F.3d 575 (6th Cir. 2018). The four service lines above each apply this framework from a different vantage point. For deeper doctrinal treatment, see the federal litigation page and the case-pattern analyses on the blog.