Section I: Introduction

As required by the U.S. Department of Education under new Title IX Regulations, effective August 14, 2020, this Policy addresses certain types of sexual misconduct via a defined process.  The scope of this Policy is set forth in Section II, below.  This Policy contains citations to the applicable Title IX Regulations throughout.  See 34 C.F.R. Part 106.

For the complete Rhodes Sexual Misconduct Policy, which addresses sexual misconduct beyond the scope of the Title IX Regulations, please click here.

For the complete Rhodes Anti-Harassment and Discrimination Policy, which addresses sexual harassment involving employees that does not meet the definitional requirements of “sexual harassment” under this Formal Grievance Policy, please click here.

This Formal Grievance Policy proceeds in four additional sections.


Section II defines the scope of this Formal Grievance Policy. Under the new Title IX Regulations, sexual harassment (a subset of sexual misconduct) must be investigated and adjudicated according to the procedures set forth in this policy. Although the new Title IX Regulations narrowly define sexual harassment, Rhodes remains committed to providing a higher education environment that is free from sexual discrimination, sexual misconduct, and gendered violence. To that end, sexual misconduct that does not rise to the level of sexual harassment as defined by the U.S. Department of Education, or that does not meet Title IX’s jurisdictional requirements, will still be investigated and addressed under the Rhodes Sexual Misconduct Policy or, in the case of Faculty or Staff, under the Anti-Discrimination and Harassment Policy.

Section III contains the U.S. Department of Education’s statements regarding equitable treatment under the Title IX Regulations. The concepts of equitable treatment include the provision of supportive measures and waiting until the grievance process concludes to make conclusions.  

Section IV contains Rhodes’ Formal Grievance Process, as required by the Regulations. This section contains information on filing a Formal Complaint of sexual harassment, the investigation process, the role of the Title IX Coordinator, Title IX’s live hearing requirements, the appeals process, and other topics. Students, faculty, and staff should consult this section to learn about the process Rhodes will use to investigate and adjudicate allegations of sexual harassment.

Section V explains that Rhodes will not retaliate against any person for that person’s involvement in the Title IX process.

This Formal Grievance Policy, as dictated by the U.S. Department of Education (USDOE), along with the comprehensive Rhodes Sexual Misconduct Policy and the Anti-Discrimination and Harassment Policy, are intended to define, address and remedy sexual misconduct for Rhodes students and employees.

Rhodes prohibits sexual misconduct by faculty, staff, students and those who use Rhodes facilities. The prohibition applies regardless of the gender of the individuals involved and includes sexual relationships involving a status differential and those between peers, colleagues, and co-workers.

This Policy applies to all members of the Rhodes community, including students, faculty and staff, and its terms supersede any contrary school policies pertaining to the investigation or adjudication of “sexual harassment” as defined in Section II.A. below.

Rhodes College is committed to ensuring a safe learning environment that supports the dignity of all members of the Rhodes community. As required by Title IX of the Education Amendments of 1972, Rhodes prohibits all unlawful discrimination, harassment and retaliation on the basis of sex, gender, gender identity, gender expression, or sexual orientation in any employment decision, admissions determination, education program or educational activity. This policy applies to all members of the Rhodes Community.

Rhodes, through the Title IX Coordinator, has jurisdiction over and the authority to receive, investigate, hear and resolve Reports and/or Complaints brought by or against any member of the Rhodes Community that invoke Title IX. The Title IX Coordinator is ultimately authorized to enact procedures that include specific instructions for reporting, investigating and resolving Title IX Complaints and Reports. Any questions about this policy, Rhodes’ processes under Title IX, or reports of alleged sexual misconduct should be directed to the Interim Title IX Coordinator:

Inez Warner
Rhodes College
Southwestern Hall, Ste. 200
2000 North Parkway
Memphis, TN 38112

The Title IX Coordinator, in conjunction with the Director of Human Resources (for faculty and staff matters), will oversee all matters relating to sex discrimination (including sexual harassment) on campus, including distribution of policies, educational programs, investigations, policy enforcement, and follow-up with complainants and respondents in investigations. Any questions regarding this Formal Grievance Policy or Title IX generally may be directed to the Title IX Coordinator.