The latest update from Albert Roberson, on where the civil rights docket is heading this term.
Read the updateInstitutions carry an obligation that outlasts whoever is holding it. We hold civil rights compliance to the standard it will eventually be read against, for colleges, PK-12 districts, and workplaces. The stakes are high. The standard should be higher.
Every engagement runs inside one or more of these five. Knowing which one governs a matter, and when more than one does, is the first decision in the file and the most commonly missed.
Compare all five20 U.S.C. § 1681 · 34 CFR Part 106
Sex discrimination and sex-based harassment in education programs receiving federal funds.
Learn more42 U.S.C. § 2000d · 34 CFR Part 100
Discrimination on the basis of race, color, or national origin in federally funded programs.
Learn more42 U.S.C. § 2000e · 29 CFR Part 1604
Employment discrimination, harassment, and retaliation by covered employers.
Learn more42 U.S.C. § 12101 · 29 U.S.C. § 794
Disability access, accommodations, grievance process, and digital accessibility.
Learn more20 U.S.C. § 1092(f) · 34 CFR § 668.46
Campus crime reporting, timely warnings, and the annual security report.
Learn moreThe intersections are where files fail
A single course of conduct can be Title VI and Title IX at once, and analyzing only the more familiar one is the most common way an institution ends up with an incomplete record.
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Title IX, Title VI, and Clery Act obligations carried across a full institutional portfolio, from intake through resolution and OCR coordination.
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District-scale coordination on a dedicated PK-12 fee schedule, because the obligation does not scale with the budget.
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Title VII investigations, harassment and retaliation matters, and the policy architecture that keeps findings defensible.
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Title IX •
On September 29, the Department of Education formally repealed the vacated 2024 Title IX amendments and restored the prior text across 23 sections of 34 CFR Part 106. The substance is in the deletions, and any policy drafted against the 2024 text needs a line-by-line check.
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Policy •
A federal court vacated the Department of Education's 2025 anti-DEI grant directive because it never defined what it prohibited. The Department's pending EDGAR proposal would write a more specific standard into the grant regulations themselves, and institutions should prepare for that version.
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ADA / 504 •
A September 23 final judgment removed the integration provisions from the 2024 HHS Section 504 rule. The rest of the rule, including its web and mobile accessibility requirements, remains in effect for institutions that receive HHS funds.
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Title IX •
OCR's September 17 resolution agreement with Virginia Beach City Public Schools is, at its core, a recordkeeping case. Its most portable lesson concerns what happens after an accused employee leaves.
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Compliance updates, training dates, and audit-ready guidance for higher-ed, PK-12, and workplace teams. The Fractional Digest monthly, the Coordinator's Brief quarterly.
Certifications, bootcamps, and residential retreats for the people who hold the coordinator seat. The curriculum is built from the same casework the firm carries, which means the practice standards taught in the room are the standards applied in the field.
Five days, forty hours, twenty-four seats. August 9 to 13, 2027. Referral or sponsor required.
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Evidence, empathy, and procedural mastery. The firm's most requested credential for sitting investigators.
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Five days, forty hours, eighteen seats at 8,150 feet. January 17 to 21, 2028.
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Campus security authorities, Clery geography, timely warnings, and the annual security report, for the people who have to produce it every October.
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Three kinds of work. A matter you are already in, a seat that needs covering, or capability you want built before the next one arrives.
01
A matter has already happened. Someone has to run it, hear it, or review it.
InvestigationsInvestigation takeoverHearing officer and decision makerAppeals reviewExpert witness services
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The seat itself, or the machinery behind it, before a matter arrives.
Fractional leadershipInterim coveragePolicy and process designMandatory reporting designDigital accessibility programClery Act complianceOCR matter supportCompliance review and audit readiness
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What your people learn, and what they work from once we are gone.
Certified trainingCustom institutional trainingBoard and governance trainingCertifications, bootcamps, retreatsThe PlaybooksKnowledge HubAdvisory Coffee TalksOnePointe
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Intake through final determination in 240 pages. What the regulations require, and what defensible practice looks like.
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Accommodations, documentation, digital accessibility, and the structural work that prevents complaints.
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Engagements begin with a scoping conversation. We look at the portfolio you are carrying, the exposure you are managing, and the seat you need covered, then we tell you plainly whether we are the right firm for it.
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Most people who join this firm arrive through the practitioner network rather than a posting. Tell us what you have carried and what you want to carry next, and we will tell you plainly whether there is a fit.
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