A Concerning Title IX Assessment for CSU System

In recent years the CSU system’s Title IX offices have been under immense scrutiny in the national press. One student’s experience at Stanislaus State with Title IX issues has shed light on the university’s need for further improvement.

The California State University (CSU) system has significantly overlooked complaints of sexual harassment and discrimination, according to a long-awaited Title IX and Discrimination, Harassment, and Retaliation (DHR) Assessment Systemwide report.

The comprehensive 232-page analysis revealed that the CSU system also lacks procedures to address misconduct that is not completely discrimination or harassment yet “disruptive to the learning, living, and working environment,” such as bullying or intimidation.

Under Title IX, a civil rights law of the Education Amendments of 1972, the CSU Board of Trustees, through the Office of the Chancellor, appointed the Cozen O’Connor Institutional Response Group in March 2022 for a systemwide assessment of the CSU’s implementation of programs to prevent and address discrimination, harassment, and retaliation (DHR) based on protected statuses, including sex and gender.

“The CSU is initiating a Title IX assessment across the nation’s largest public four-year higher education system to ensure the health, safety and welfare of our students, faculty and staff. We will continue to fortify our commitment to be leaders of Title IX innovation and response,” the CSU announced in its report.

Cozen O’Connor evaluated the strengths, challenges and resources across all 23 university campuses and the Chancellor’s Office. Their assessment identified opportunities for systemwide coordination, alignment, oversight and efficiency to support implementation efforts.

On May 24, 2023, Leora D. Freedman, Vice Chancellor for Human Resources at the California State University system, reported on the findings and recommendations of the assessment to the Committee on University and Faculty Personnel.

“The goal of Cozen O’Connor’s assessment is to strengthen and improve the culture of our campuses and at the Chancellor’s Office so that it is better aligned with our institutional values… As we continue to navigate these complex and evolving laws we commit to compliance and implementing it with care and compassion,” Chancellor Freedman said.

The Chancellor’s office explained they are committed to implementing these changes with care and compassion, but a Stan State student’s experience explains otherwise.

Stan State’s Assessment and Response to the Title IX Conversation

The O’Connor report for Stan State highlights behavior that doesn’t fall under Title IX but is affecting campus culture and the ability to talk about issues.
The assessment states:

“As with other CSU universities, Stanislaus State struggles in its response to conduct issues that may not fall under the Nondiscrimination Policy, but are nonetheless disruptive to the living, learning, and working environment. As on many CSU campuses, we learned about concerns, particularly from faculty, that other conduct of concern is underreported and that it has ineffective institutional responses that have allowed it to continue unchecked for years,” the report advised.

“Faculty shared concerns about microaggressions and potential bias incidents, reflecting that the administrative structures were insufficient to provide consistent and responsive action. Stanislaus State has no consistent and formalized mechanism for responding to and navigating these behaviors. As a result, the university triages these behaviors in an ad hoc manner, leading to inconsistent responses, which have led to perceptions by students, staff, and faculty that there is a lack of accountability,” the assessment said.

Veronica Sexton (Creative Media, Senior) felt she encountered the same type of behavior that was highlighted in the report when she tried to report on Title IX discussions. Her experience is highlighted in the video at the top of the page.

Cozen O’Connol recommended in the report that Stanislaus State work closely with the Chancellor’s Office to develop a formal process to address reports of other conduct of concern.

Efforts to Contact Title IX by Students

Stanislaus State announced via email in March of 2024 personnel changes to the Title IX office. Stan State contracted with Grand River Solutions to further their efforts in the area of Title IX, Discrimination, Harassment and Retaliation (DHR), Clery and employee disability accommodations. They describe Grand River’s as:

“Grand River will provide our campus with a broad range of Title IX and equity consulting services to support us in achieving campus wide goals,” said the email from Human Resources Equal Opportunity and Compliance.

Erica Moorer Taylor of Grand River Solutions was named interim Title IX/DHR coordinator in the email, but it was suggested all requests for Title IX/DHR services continue to be directed to Julie Keo, the deputy Title IX/DHR coordinator.

Currently, the Stan State website lists Kimberly Anderson as the Interim Director Title IX Coordinator. At some point Erica Taylor left, but the University populace was not advised and Kimberly Anderson was appointed in her place. According to an email The Signal obtained, Kimberly Anderson works for the third-party Grand River Solutions with many years of experience in Title IX, which is noted in her bio on the Grand River Solutions website.

According to the Stan State website, Anderson’s role is to monitor and oversee the campus-wide implementation of CSU’s Title IX policies and procedures, including coordination of training, education, communications, supportive measures and investigations for students, faculty, staff and third parties.

Julie Keo is still the Interim Assistant Director and Deputy Title IX/DHR Coordinator at CSU, assisting with Title IX policy and procedures, investigations and mandatory training. Laura Boren is the Interim Deputy TIX Coordinator/DHR Administrator, and Lupita Hernandez is a TIX/DHR Specialist, as listed on Stan State’s website.

The California State University, Stanislaus Title IX (DHR) Assessment by O’Connor also indicates the Stan State website needed clearer updates and improvements.

According to the report, “many changes are straightforward, such as updating the name and contact information for the staff in EPC. It also appears that the entire university website is undergoing an update, as we received some “under construction” notices as we searched. In June 2023, we learned that the university is planning to revamp its website, thereby permitting EPC to address gaps on its pages.”

As of December 2024, The Signal found broken links were still present on the EPC (Title IX) webpage. One of the broken links found on Stan State’s website is supposed to lead to a copy of the California State University, Stanislaus Title IX (DHR) Assessment.

The Stan State Community was informed in March 2024 of the partnership with Grand River Solution and appointed Erica Moorer Taylor as the Title IX Coordinator.

Contrary to the notice sent out to students, in May 2024, Paul Norris was still listed as the Title IX Coordinator in certain places on the Stan State’s website.

On May 31, 2024, Sexton was advised by Stan State HR to file a complaint with Erica Moorer Taylor, who at the time, was listed as the Title IX Coordinator. She wished to file a complaint about her interaction with an administrator while covering a Title IX protest.

Several days later, on June 3, 2024, Sexton hadn’t received a response from Taylor, and a Human Resources employee at Stan State sent her an email advising that Stan State had a new Title IX Coordinator, Kimberly Anderson.

At some point during the three days, the Title IX coordinator had changed. Students were not informed of this change, and it seems that only Sexton was notified of this when she received the email from the HR employee.

In the email Sexton received, it stated, “Team, Erica Taylor is transitioning full time to CSU Channel Islands Title IX. Although we’ll miss her, we are excited to share Kim Anderson, is named interim Title IX Coordinator. For those of us who have not met Kim, You can find her company bio here. Kim has partnered with us here in Title IX since February 2024.”

Due to the turnover in the Title IX office and the contact information on the website not being kept up to date, Sexton has felt confused on how to follow up with her complaint.

A year and a half after the assessment came out, it seems there are still changes that need to be made at the Stan State Title IX office as well as the university as a whole.