Education department considers sexual harassment rules
The US Department of Education received 27 similar comments in December 2018 regarding the proposed rule on sexual harassment in schools. The campaign argued that the proposed regulation would make it easier for schools to ignore student survivors of sexual violence and sweep allegations of sexual harassment and assault under the rug.
Campaign window
Single day · 27 comments detected
Shape of the campaign
Each red dot is one comment that matched the campaign's template text. Grey dots are unrelated submissions to the same docket. The clustering algorithm groups comments by semantic similarity, not by exact string match, so light wording changes don't hide the pattern.
Scale
The template
“I am writing to oppose the proposed Title IX rule. Requiring live cross-examination of survivors at adjudication hearings will deter reporting and re-traumatize complainants. The narrower definition of harassment as conduct that is "severe, pervasive, and objectively offensive" sets the threshold so high that most harassment will not meet it. The Department should withdraw this proposal and keep the 2011 and 2014 guidance.”
Attribution
Who organized this?
The National Women's Law Center, Know Your IX, and allied civil-rights groups circulated template comments through their networks opposing the proposed Title IX rule. The campaign argued the proposed cross-examination requirements and narrower definition of sexual harassment would deter survivors from reporting.
Attribution is based on publicly available evidence. It does not imply wrongdoing.
Migration analysis
Did the campaign's language make it into the final rule?
The May 2020 final rule retained live-hearing cross-examination and the narrower severe-pervasive-objectively-offensive harassment definition that the campaign opposed. The campaign's framing did not appear in the operative text; the language was later softened in the Biden administration's 2024 replacement rule.
Phrase overlap
Campaign template
“Narrower definition of harassment as conduct that is 'severe, pervasive, and objectively offensive' sets the threshold so high that most harassment will not meet it”
Final rule text
Sexual harassment means... unwelcome conduct determined by a reasonable person to be so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the recipient's education program or activity
34 CFR § 106.30 (2020 rule, superseded 2024)
Phrase overlap is correlation, not causation. Many advocates and agency staff use the same vocabulary; matching language is not evidence the campaign drafted the rule.
Rule outcome
Did it influence the final rule?
The Department of Education finalized the 2018 Title IX rule in May 2020, retaining cross-examination at live hearings and a narrower harassment definition. The Biden administration replaced it with a new Title IX rule in April 2024, which was then partially blocked by federal courts in several states.
Rule outcomes are matters of public record. Astroturf does not claim the campaign caused or prevented the outcome.
> Technical details
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