Graduation Semester and Year

Fall 2026

Language

English

Document Type

Dissertation

Degree Name

Doctor of Philosophy in Educational Leadership and Policy Studies

Department

Educational Leadership and Policy Studies

First Advisor

Dr. Merideth Billings

Second Advisor

Dr. Ericka Roland

Third Advisor

Dr. Catherine Robert

Abstract

This study examines how Title IX administrators exercise discretion when responding to ambiguous sexual misconduct reports referred to as yellow zone. The 2020 Title IX Rules and Regulations introduced a more restrictive definition of sexual misconduct, requiring behavior to be severe, pervasive, and objectively offensive (SPOO) to meet the threshold for formal institutional response. Despite the practical challenges these cases present for institutions, there is limited scholarly understanding of how Title IX administrators make decisions when responding to them. Guided by street-level bureaucracy theory (Lipsky, 1969, 1980, 2010), the study explored how institutional actors exercise discretion in response to regulatory pressures and organizational constraints. Using a phenomenological research design, I conducted semi-structured interviews with six Title IX professionals at two time-points from multiple four-year institutions. The findings indicate that administrator discretion is constrained by institutional leadership structures and by the formalized definitions embedded in federal policy. In response, administrators adapt their approaches through increased transparency in procedural communication and the use of informal practices to address yellow zone cases. These findings reveal that Title IX administrators’ discretion increasingly operates through less visible mechanisms shaped by organizational context. The study contributes to scholarship on policy implementation in higher education by illuminating how frontline administrators interpret and operationalize regulatory standards in complex and ambiguous cases.

Keywords

Title IX, Sexual misconduct, Policy, Institutional courage, Street level bureaucrat

Disciplines

Educational Administration and Supervision | Higher Education

License

Creative Commons Attribution 4.0 International License
This work is licensed under a Creative Commons Attribution 4.0 International License.

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