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Campus Department of Education Due Process Office for Civil Rights Press Release Title IX

Growing Numbers of Falsely Accused Persons Sue Colleges for High-Dollar Monetary Damages

PRESS RELEASE

Robert Thompson: 301-801-0608

Email: info@saveservices.org

Growing Numbers of Falsely Accused Persons Sue Colleges for High-Dollar Monetary Damages

WASHINGTON / September 19, 2024 – In the past, accused students who sued their colleges only sought to have their transcripts cleared so they could transfer and not suffer adverse consequences. But inspired by Johnny Depp’s successful 2022 defamation lawsuit against Amber Heard (1), falsely accused persons are now suing their former schools for large dollar awards.

Following are five high-dollar lawsuits that were resolved or filed in just the past year:

Pacific University, OR: A jury awarded $3.9 million to Peter Steele, falsely accused of sexual assault. The jury agreed that “Pacific University’s conduct constituted an extraordinary transgression of the bounds of socially tolerable conduct or exceeded any reasonable limits of social toleration.” (2)

Thomas Jefferson University, PA: During a 2018 party, surgical resident Jessica Phillips forced whiskey into faculty member John Abraham’s mouth and began to aggressively kiss him. She pulled him to the floor, where they had sex. But inexplicably, the university failed to investigate his complaint of sexual assault. Last December, a jury decided in favor of Abraham, awarding him $15 million for the university’s “outrageous conduct.” (3)

University of Detroit-Mercy, MI: A college counselor at University of Detroit-Mercy initiated an unauthorized investigation against a student who had been falsely accused at another school. In April the student filed a lawsuit, charging “the University’s egregious lack of any semblance of fair process whatsoever in connection with same.” The lawsuit seeks actual, compensatory, and punitive damages (4).

Yale University, CT: The Associated Press recently reported on a defamation lawsuit that was filed in May against 15 women’s advocacy groups. Saif Khan, acquitted of sex assault charges during a trial in 2018, was called a “rapist” in a court brief that the groups filed in 2022. The lawsuit seeks financial damages. “We would like for them to understand that there is harm to someone when you just label them,” explained Khan’s attorney (5).

Hofstra University, NY: Two weeks ago, John Doe filed a lawsuit against Hofstra University, after the institution allegedly failed to address the harassment and retaliation he suffered after his former romantic partner defamed him for being a “rapist.” The lawsuit accuses the institution of “condoning and/or failing to adequately address severe, pervasive, and objectively offensive gender-based harassment and retaliation, which resulted in Plaintiff being compelled to withdraw from the University.” (6)

To date, over 800 lawsuits have been filed by students against colleges alleging Title IX and related violations (7). Thus far, 280 cases have been resolved in favor of the falsely accused student (8), with hundreds of other cases resolved via confidential settlements (9.10,11).

Many of these campus adjudications appear to have been driven by an aggrieved sense of “mob justice,” which bears little resemblance to democratic ideals of impartiality, fairness, and the presumption of innocence. College administrators should work to remove the perception of Kangaroo Court procedures, or face legislative consequences.

Links:

  1. https://people.com/amber-heard-pays-johnny-depp-usd1-million-settlement-1-year-after-trial-depp-to-donate-it-to-5-charities-7511495
  2. https://www.opb.org/article/2023/08/21/pacific-university-forest-grove-oregon-education-lawsuit-sexual-physical-assault/
  3. https://www.inquirer.com/health/thomas-jefferson-university-john-abraham-rothman-federal-jury-20231211.html
  4. https://titleixforall.com/lawsuit-university-counselor-betrayed-falsely-accused-student/
  5. https://apnews.com/article/yale-rape-lawsuit-899c2e3108c88581bed31a674c842306
  6. Case 2:24-cv-06146-SIL. Filed 09/03/24.
  7. https://titleixforall.com/accused-students-database/
  8. https://docs.google.com/spreadsheets/d/1CsFhy86oxh26SgTkTq9GV_BBrv5NAA5z9cv178Fjk3o/edit?gid=0#gid=0
  9. https://docs.google.com/spreadsheets/d/1CsFhy86oxh26SgTkTq9GV_BBrv5NAA5z9cv178Fjk3o/edit?gid=877378063#gid=877378063
  10. https://docs.google.com/spreadsheets/d/1CsFhy86oxh26SgTkTq9GV_BBrv5NAA5z9cv178Fjk3o/edit?gid=1506863034#gid=1506863034
  11. https://docs.google.com/spreadsheets/d/1CsFhy86oxh26SgTkTq9GV_BBrv5NAA5z9cv178Fjk3o/edit?gid=569972415#gid=569972415
Categories
Department of Education Due Process Free Speech Gender Agenda Gender Identity Office for Civil Rights Title IX

Democratic-Appointed Judges Highly Critical of New Title IX Regulation

PRESS RELEASE

Robert Thompson: 301-801-0608

Email: info@saveservices.org

Democratic-Appointed Judges Highly Critical of New Title IX Regulation

WASHINGTON / August 27, 2024 – On April 19, the U.S. Department of Education issued its long-awaited Title IX regulation (1). Media accounts have generally classified supporters of the rule as “liberal,” while opponents of the policy categorized as “conservative.” (2) But subsequent judicial rulings have cast doubt on this convenient stereotype.

Over the last three months, 10 lawsuits have been filed against the controversial policy. In response, circuit courts, appellate courts, and the Supreme Court have handed down a total of 12 decisions. Eleven out of the 12 opinions have imposed a temporary injunction on the rule. (3)

One of the most unexpected aspects of the decisions is the fact that many judges appointed by Democratic lawmakers have been highly critical of the policy. This fact is revealed in two decisions: the August 16 ruling by the U.S. Supreme Court, three of whose members were named by Democratic presidents; and the July 24 decision by District Court Judge Rodney Sippel, nominated by President Bill Clinton in 1997:

Supreme Court: In their August 16 decision, Justice Sotomayor, with the concurrence of Justices Kagan and Jackson (along with Justice Gorsuch, nominated by a Republican president) authored this stunning rebuke of the Department of Education document (4):

“Every Member of the Court agrees respondents are entitled to interim relief as to three provisions of that Rule: 34 CFR §106.10 (2023) (defining sex discrimination), §106.31(a)(2) (prohibiting schools from preventing individuals from accessing certain sex-separated spaces consistent with their gender identity), and §106.2’s definition of hostile environment harassment.”

Their statement expressed a categorical disapproval of the new regulation’s plan to:

  1. Redefine sex to include “gender identity.”
  2. Allow transgender students to use bathrooms and locker rooms designated for members of the opposite sex.
  3. Create a new definition of “hostile environment harassment” which would have the effect of chilling free speech and negating Supreme Court precedent.

Circuit Court Judge Sippel:  On May 7, the states of Arkansas, Missouri, Iowa, Nebraska, North Dakota, and South Dakota filed their complaint against the Department of Education (5).  Eleven weeks later, Judge Rodney Sippel of the Eastern District of Missouri issued his opinion. His 56-page decision expressed concerns about the same three issues enumerated by the Supreme Court, but went far beyond that. The Sippel ruling also expressed doubts about:

  • Irreparable Injury: “The loss of First Amendment freedoms, for even minimal periods of time, unquestionably constitutes irreparable injury.”
  • Overly Broad Scope: “Damages are not available for simple acts of teasing and name-calling among school children, however, even where these comments target differences in gender.”
  • Spending Clause: “Since Title IX was enacted pursuant to Congress’s authority under the Spending Clause of the Constitution…the Supreme Court ‘insists that Congress speak with a clear voice’ when imposing conditions on the receipt of federal funds,”
  • Statutory Authority: Judge Sippel rebuked the Department of Education for exceeding its “statutory authority” a total of 10 times in his decision.
  • Arbitrary and Capricious: The Judge repeatedly criticized the Title IX regulation for being “arbitrary and capricious.”

At the end, Democratic-appointed Judge Sippel penned this stunning conclusion: “After due consideration of all the foregoing authorities in light of the aforementioned differences between the two statutes, Bostock’s express disavowal to bathrooms or locker rooms or other statutory schemes, and in the absence of controlling authority, the Court concludes that plaintiffs have met their preliminary burden of demonstrating a fair chance of prevailing on their argument that Bostock should not apply to Title IX, and that the Department exceeded its statutory authority and/or acted contrary to law in redefining ‘on the basis of sex’ for purposes of Title IX.”

Following the 12 decisions, the Title IX policy has been frozen in the 26 states of LA, MS, MT, ID, TN, KY, OH, IN, VA, WV, KS, AK, UT, WY, TX, AR, MO, OA, NE, ND, SD, AL, FL, GA, SC, and OK, as well as in thousands of schools in 45 states attended by children of Moms for Liberty members and by members of the Young America’s Foundation (6).

Given the bipartisan legal and public (7) opposition to the Title IX regulation, and given its high implementation costs, governors and school superintendents in the remaining 24 states should consider instructing their schools to not implement the moribund Title IX regulation.

Links:

  1. https://titleixforall.com/wp-content/uploads/2024/04/Unofficial-version-of-the-final-regulations.pdf
  2. https://www.k12dive.com/news/title-ix-final-rule-reaction-opponents-supporters/714560/
  3. https://www.saveservices.org/2022-policy/abolish-doe/
  4. https://www.supremecourt.gov/opinions/23pdf/24a78_f2ah.pdf
  5. https://arkansasag.gov/wp-content/uploads/2024-05-07-Arkansas-v.-US-Dept-of-Education-Filemarked.pdf
  6. https://www.saveservices.org/2022-policy/abolish-doe/
  7. https://www.saveservices.org/2024/02/public-opinion-polls-reveal-growing-public-opposition-to-policies-driven-by-gender-agenda/
Categories
Department of Education Due Process Gender Agenda Gender Identity Office for Civil Rights Press Release Title IX

Unanimous: Supreme Court Justices Voice Opposition to Three Major Title IX Provisions

PRESS RELEASE

Robert Thompson: 301-801-0608

Email: info@saveservices.org

Unanimous: Supreme Court Justices Voice Opposition to Three Major Title IX Provisions

WASHINGTON / August 22, 2024 – In a stunning move, all nine Supreme Court justices expressed their opposition to three key provisions in the new Title IX regulation (1). In its August 16 decision in support of the appellate court rulings to block enforcement of the new rule, the nine Justices expressed their unanimous disapproval of the new regulation’s plan to:

  1. Redefine sex to include “gender identity.”
  2. Allow transgender students to use the bathrooms and locker rooms designated for members of the opposite sex.
  3. Create a new, overly broad definition of “hostile environment harassment” (the Title IX regulation brazenly seeks to negate the Supreme Court’s definition of “sexual harassment,” as delineated in its landmark Davis v. Monroe decision (2)).

The SCOTUS decision affirmatively states, “Every Member of the Court agrees respondents are entitled to interim relief as to three provisions of that Rule: 34 CFR §106.10 (2023) (defining sex discrimination), §106.31(a)(2) (prohibiting schools from preventing individuals from accessing certain sex-separated spaces consistent with their gender identity), and §106.2’s definition of hostile environment harassment.”

The opinion comes on the heels of a string of defeats for the Biden Administration’s effort to revamp the Title IX law, enacted in 1972 to ban sex discrimination in schools. Prior to the Supreme Court ruling, the Biden Administration had lost in 7 out of 8 district court decisions, and lost in 3 out of 3 appellate court opinions (3).

As a result, the Title IX policy has been blocked in the states of LA, MS, MT, ID, TN, KY, OH, IN, VA, WV, KS, AK, UT, WY, TX, AR, MO, OA, NE, ND, SD, AL, FL, GA, SC, and OK, as well as in thousands of schools in 45 states attended by children of Moms for Liberty members and by members of the Young America’s Foundation (4). As a result, the 2020 Title IX regulation still remains in effect for those states and schools.

In recent months, the tide has turned against Marxist-inspired transgender ideology. These developments include growing scientific skepticism, opposition in public opinion polls, state-level laws (5), and hostility expressed by political candidates (6).

In addition, SAVE recently established a Citizen Watchdog program to monitor school compliance with the recent judicial Title IX decisions (7).

The Supreme Court decision applies only to the preliminary injunctions against the Title IX regulations, so its August 16 ruling will not be the last word on the subject. But the unanimity of opposition to three key regulatory provisions lends credence to critics of the controversial policy.

In the words of commentator Aaron Flanigan, “Whether or not they realize it now, American parents are standing on the precipice of one of the most far-reaching, extremist, and dangerous transformations of the education system in American history.” (8)

Links:

  1. https://www.supremecourt.gov/opinions/23pdf/24a78_f2ah.pdf
  2. https://www.oyez.org/cases/1998/97-843
  3. https://www.saveservices.org/2022-policy/abolish-doe/
  4. https://www.scag.gov/media/pskl4phx/ks-v-u-s-dept-of-education-list-of-schools-enjoined.pdf
  5. https://www.saveservices.org/2024/08/states-pass-new-laws-to-block-the-marxist-inspired-gender-agenda/
  6. https://www.saveservices.org/2024/07/schools-urged-to-delay-implementation-of-title-ix-rule-until-legal-challenges-are-resolved/
  7. https://www.saveservices.org/2022-policy/network/
  8. https://amac.us/newsline/education/the-new-biden-harris-rule-that-could-upend-the-election/?utm_objective=website_traffic&utm_source=website&utm_campaign=real_clear_politics&utm_medium=shared_content&utm_content=tnb082024
Categories
Department of Education Due Process Gender Identity Office for Civil Rights Title IX

Federal Judges Sound the Death Knell on Joe Biden’s ‘Gender Identity’ Experiment

PRESS RELEASE

Robert Thompson: 301-801-0608

Email: info@saveservices.org

Federal Judges Sound the Death Knell on Joe Biden’s ‘Gender Identity’ Experiment

WASHINGTON / July 15, 2024 – Over 50 years ago, Marxist Shulamith Firestone laid out her grand vision for gender equality: “genital differences between human beings would no longer matter culturally…The tyranny of the biological family would be broken.” (1) As far-fetched as her proposal might sound, activists around the world began to take up the challenge, concocting their theory of “transgenderism.”

Accordingly on his first day in office, President Biden issued an Executive Order that decreed, “All persons should receive equal treatment under the law, no matter their gender identity or sexual orientation.” (2) On April 19 of this year, the Biden Department of Education issued its final Title IX rule that expanded the meaning of sex to include “gender identity.” (3)

Response to the new policy was resoundingly negative. Numerous governors and state superintendents of education instructed their schools to ignore the rule (4). One editorial ridiculed the policy as a “repulsive attempt to erase biological truth.” (5)

Literally within days, state Attorneys General and others began to file nine lawsuits seeking to overturn the policy (6).  To date, five decisions have been handed down. Remarkably, every one of decisions imposed a temporary injunction for their respective states on the “arbitrary and capricious” Title IX rule:

  • June 13: Judge Terry Doughty for the states of Louisiana, Mississippi, Montana, and Idaho (7).
  • June 17: Judge Danny Reeves for Tennessee, Kentucky, Ohio, Indiana, Virginia, and West Virginia (8).
  • July 2: Judge John Broomes for Kansas, Alabama, Utah, and Wyoming, plus all schools attended by the children of Moms for Liberty and by members of the Young America’s Foundation (9).
  • July 11: Judge Matthew Kacsmaryk for the state of Texas. In addition, the judge noted that he is considering extending his injunction to all 50 states in the nation (10).
  • July 11: Judge Reed O’Connor for the Carroll Independent School District in Texas (11).

In parallel fashion, the Department of Health and Human Services issued a separate regulation in May requiring states to pay for so-called “gender affirming” treatments (12). This rule, which also relies on a bloated definition of sex to include gender identity, was met with several lawsuits as well.

On July 3, two federal judges issued injunctions against the DHHS rule. The first applied to Texas and Montana (13). More devastating to the Washington bureaucrats, the second decision blocked the DHHS rule throughout the entire nation (14).

Topping off this remarkable string of decisions, on June 28 the United States Supreme Court issued a ruling that overturned the long-standing Chevron doctrine (15). In the past, the Chevron doctrine provided a legal fig leaf to the Department of Education and other federal agencies seeking to escape accountability and issue intrusive regulations.

Seldom in American jurisprudence have judges issued a series of decisions within a period of just four weeks, all with the intended effect of blocking the implementation of ill-conceived and unlawful federal regulations.

As these lawsuits continue to be litigated, the 229 organizational members of the Title IX Network will continue to monitor the situation and take appropriate action (16). Interested organizations that wish to join the Title IX Network should contact Robert Thompson at rthompson@saveservices.org

Links:

  1. https://www.marxists.org/subject/women/authors/firestone-shulamith/dialectic-sex.htm
  2. https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/executive-order-preventing-and-combating-discrimination-on-basis-of-gender-identity-or-sexual-orientation/
  3. https://www.federalregister.gov/documents/2024/04/29/2024-07915/nondiscrimination-on-the-basis-of-sex-in-education-programs-or-activities-receiving-federal
  4. https://www.saveservices.org/2024/04/do-not-comply-fight-americans-revolt-against-new-title-ix-rule/
  5. https://nypost.com/2024/04/22/opinion/bidens-title-ix-revisions-are-a-repulsive-attempt-to-erase-truth/
  6. https://www.saveservices.org/2022-policy/abolish-doe/
  7. https://storage.courtlistener.com/recap/gov.uscourts.lawd.205659/gov.uscourts.lawd.205659.53.0.pdf
  8. https://storage.courtlistener.com/recap/gov.uscourts.kyed.104801/gov.uscourts.kyed.104801.100.0.pdf
  9. https://www.bloomberglaw.com/public/desktop/document/KansasStateofetalvUnitedStatesDepartmentofEducationetalDocketNo52?doc_id=X7VSH1UVO6B9K1AAI088P6TS9IF
  10. https://www.newsweek.com/transgender-policy-texas-schools-donald-trump-kacsmaryk-title-ix-1924387
  11. https://storage.courtlistener.com/recap/gov.uscourts.txnd.390056/gov.uscourts.txnd.390056.43.0.pdf
  12. https://www.federalregister.gov/documents/2024/05/06/2024-08711/nondiscrimination-in-health-programs-and-activities
  13. https://acrobat.adobe.com/id/urn:aaid:sc:VA6C2:b4159447-f7c6-4f28-81d3-11dd1d78de37
  14. https://www.tn.gov/content/dam/tn/attorneygeneral/documents/pr/2024/section-1557-opinion.pdf
  15. https://www.bbc.com/news/articles/c51ywwrq45qo
  16. https://www.saveservices.org/2022-Policy/
Categories
Civil Rights Department of Education Due Process Free Speech Office for Civil Rights Press Release Title IX

As Second Judge Strikes Down Title IX Regulation, Dept. of Education Resorts to Orwellian Clichés

PRESS RELEASE

Robert Thompson: 301-801-0608

Email: info@saveservices.org

As Second Judge Strikes Down Title IX Regulation, Department of Education Resorts to Orwellian Logic

WASHINGTON / June 24, 2024 – Federal Judge Danny Reeves handed down a preliminary injunction last Monday against the controversial Title IX regulation for the states of Tennessee, Kentucky, Ohio, Indiana, Virginia, and West Virginia (1). Reeves’ decision follows a similar ruling issued on June 13 by District Judge Doughty, who struck down the controversial regulation in Louisiana, Mississippi, Montana, and Idaho (2).

Using the phrase “arbitrary and capricious” eight times, Judge Reeves addressed the regulation’s subjective definitions of “gender identity,” women’s sports, student privacy and safety, free speech, parental rights, and more (3). The judge’s 93-page decision did not mince words (4) – the following is just a sampling:

  • “The Department’s new definition of ‘discrimination on the basis of sex wreaks havoc on Title IX and produces results that Congress could not have intended.” – Page 25
  • “The likely consequences of the Final Rule are virtually limitless…. the Final Rule creates myriad inconsistencies with Title IX’s text and its longstanding regulations.” – Page 27
  • “the Final Rule authorizes, if not encourages, arbitrary and discriminatory enforcement pursuant to definitions of harassment that are almost entirely fact-dependent.” – Page 55
  • “officials seemingly failed to seriously account for the possibility that abolishing sex-separated facilities would likely increase the incidence of crime and deter large swaths of the public from using public accommodations altogether.” – Page 75
  • “Rather than address the evidence provided by the plaintiff-States and others during the commenting period, the Department throws its figurative hands in the air and says, ‘too bad.’” – Page 76

Judge Reeves’ decision also highlighted the plight of a 15-year-old West Virginia biological girl referred to as “A.C.” Alluding to transgender athlete Becky Pepper-Jackson, a biological male, the judge wrote, “A.C. asserts that it is apparent that B.P.J.’s status as a biological male gives B.P.J. an advantage over A.C. and other female athletes.”

But A.C. is not the only person to have been harmed by the Department of Education’s Marxist-inspired Title IX mandate (5):

  1. Three middle school boys in Wisconsin were charged with a Title IX harassment complaint when they refused to refer to a female classmate as “they/them.” (6)
  2. John Abraham of Thomas Jefferson University was seduced and raped by Jessica Phillips at an alcohol-fueled party. When Abraham reported the assault to university Title IX officials, his complaint was ignored because, according to the favored narrative, “women never abuse.” (7)
  3. When Prisha Mosley developed mental health problems, doctors persuaded her undergo “gender-affirming” treatments, including removal of her breasts, at the age of 17. Last month, a North Carolina judge ruled that her lawsuit can move forward (8).

Rather than expressing compassion or remorse, the Department of Education responded to the judges’ recent decisions with a bureaucratic retort (9): “Title IX guarantees that no person experience sex discrimination in a federally-funded educational environment…we will continue to fight for every student.”

“Fight for every student”?

The Department’s tone-deaf dismissal recalls the infamous pronouncement of George Orwell: “The Party told you to reject the evidence of your eyes and ears. It was the final, most essential command.”

Links:

  1. https://storage.courtlistener.com/recap/gov.uscourts.kyed.104801/gov.uscourts.kyed.104801.100.0.pdf
  2. https://storage.courtlistener.com/recap/gov.uscourts.lawd.205659/gov.uscourts.lawd.205659.53.0.pdf
  3. https://www.federalregister.gov/documents/2024/04/29/2024-07915/nondiscrimination-on-the-basis-of-sex-in-education-programs-or-activities-receiving-federal
  4. https://www.saveservices.org/2024/06/arbitrary-and-capricious-federal-judge-rejects-and-ridicules-dept-of-educations-title-ix-rule/
  5. https://www.plutobooks.com/9780745341668/transgender-marxism/
  6. https://will-law.org/kiel-title-ix/#:~:text=Background%3A%20Three%20eighth%20grade%20students,District’s%20position%20appears%20to%20be
  7. https://www.inquirer.com/health/thomas-jefferson-university-john-abraham-rothman-20231207.html
  8. https://www.iwf.org/2024/05/17/independent-womens-forum-prisha-mosley-wins-legal-victory-groundbreaking-lawsuit-against-gender-affirming-medical-professionals/#:~:text=The%20lawsuit%20was%20brought%20against,at%20just%2017%20years%20old.
  9. https://www.politico.com/news/2024/06/13/title-ix-blocked-louisiana-00163364
Categories
Department of Education Due Process Gender Identity Office for Civil Rights Sexual Harassment Title IX

Arbitrary and Capricious: Federal Judge Rejects and Ridicules Dept. of Education’s Title IX Rule

Arbitrary and Capricious: Federal Judge Rejects and Ridicules Dept. of Education’s Title IX Rule

SAVE

June 19, 2024

In April, the Department of Education issued its long-awaited Title IX Rule. In response, nine separate lawsuits were filed, seeking to block the new regulation.

On June 17, Judge Danny Reeves issued a preliminary injunction for the states of Tennessee, Kentucky, Ohio, Indiana, Virginia, and West Virginia. Concluding that “the Department of Education seeks to derail deeply rooted law with a Final Rule,” the judge ordered:

  1. The motions for a preliminary injunction/stay filed by Tennessee, Kentucky, Ohio, Indiana, Virginia, and West Virginia [Record No. 19] and Christian Educators Association International and A.C. [Record No. 63] are GRANTED.
  2. The United States Department of Education and Miguel Cardona, Secretary of the U.S. Department of Education, along with their secretaries, directors, administrators, and employees, are ENJOINED and RESTRAINED from implementing, enacting, enforcing, or taking any action in any manner to enforce the Final Rule, Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance, 89 Fed. Reg. 33474 (Apr. 29, 2024), which is scheduled to take effect on August 1, 2024.

Using the words “arbitrary and capricious” eight times, Judge Reeves did not mince words in his 93-page decision, which addressed the subjective definitions of “gender identity,” women’s sports, student privacy and safety, free speech, parental rights, and more.

These are highlights from his strongly worded opinion:

“This case concerns an attempt by the executive branch to dramatically alter the purpose and meaning of Title IX through rulemaking… the new rule contravenes the plain text of Title IX by redefining ‘sex’ to include gender identity, violates government employees’ First Amendment rights, and is the result of arbitrary and capricious rulemaking. If the new rule is allowed to take effect on August 1, 2024, all plaintiffs will suffer immediate and irreparable harm.” – Page 1

“But then came the administrative state, lacking any real power to rewrite a law that Congress duly passed, with its bureaucratic cudgel.” – Page 8

“The Department declined to provide a specific definition of “gender identity,” but understands the term to “describe an individual’s sense of their gender, which may or may not be different from their sex assigned at birth.” – Page 10

Judge Reeves’ decision highlights the plight of a 15-year-old West Virginia girl, A.C., who reportedly “feels uncomfortable dressing and undressing in the presence of biological males.” Referring to transgender athlete Becky Pepper-Jackson, a biological male, the judge wrote, “A.C. asserts that it is apparent that B.P.J.’s status as a biological male gives B.P.J. an advantage over A.C. and other female athletes.” – Page 14

“an agency has no authority to promulgate a regulation that ‘undoes the unambiguous language of the statute.’” – Page 16

“The Department’s new definition of “discrimination on the basis of sex” wreaks havoc on Title IX and produces results that Congress could not have intended….For example, the new rules provide that recipients may separate students for purposes of fraternities and sororities, but not for purposes of utilizing bathrooms.” – Page 25

“The likely consequences of the Final Rule are virtually limitless…. the Final Rule creates myriad inconsistencies with Title IX’s text and its longstanding regulations.” – Page 27

“The First Amendment to the United States Constitution stands as a sentry over one of the Nation’s most indispensable freedoms through a proclamation clear and uncompromising: “Congress shall make no law . . . abridging the freedom of speech, . . . .”  – Page 32

“It is unclear how the Government’s articulated position can be seen as anything less than a tacit endorsement of a content-based heckler’s veto.” – Page 46

“The Department understands gender identity to describe an individual’s sense of their gender, which may or may not be different from their sex assigned at birth.” Id. But the Department’s response offers no guidance whatsoever. Arguably worse, it suggests that this term of vital importance can be subjectively defined by each and every individual based entirely upon his or her own internal sense of self.” – Page 50

“Further, the Final Rule authorizes, if not encourages, arbitrary and discriminatory enforcement pursuant to definitions of harassment that are almost entirely fact-dependent.” – Page 55

“the Final Rule’s text is vague and overbroad in a way that impermissibly chills protected speech” – Page 56

“The plaintiff-States claim that the Department has also failed to account for the impact its Final Rule will have on the constitutional right of parents to influence their children’s education. A longstanding right recognized by the Supreme Court is the right for parents to raise their own children as they see fit.” – Page 63

“But the Final Rule then specifies that schools may no longer apply the regulations’ allowance for sex-separation against males who identify as females or females who identify as males. Id. It seems obvious that the Department simply failed to consider these contradictory aspects when promulgating the Final Rule.” – Page 63

“Indeed, the Final Rule’s provisions seemingly bind administrators to treat such children “consistent with [their] gender ident[ies]” on school grounds, even if that conflicts with parental preferences. Id. at 41571. Therefore, school personnel would be forced to improperly insert themselves into constitutionally protected family affairs not only to act when gender discrimination is claimed but to “prevent its recurrence and remedy its effects.” – Page 64

“it implies that Title IX could supersede parental preferences about a child’s treatment depending on the case.” – Page 65

“The Department asserts that there is not ‘a ‘long-standing construction’ of the term ‘sex’ in Title IX to mean ‘biological sex.’  See 87 Fed. Reg. at 41537. But this argument is severely undermined by the series of congressional amendments and agency regulations since the statute’s enactment that consistently have construed ‘sex’ as a male-female binary. Indeed, past regulations from the Department are direct evidence that a definition has been in place.” – Page 67

“Nonetheless, despite society’s enduring recognition of biological differences between the sexes, as well as an individual’s basic right to bodily privacy, the Final Rule mandates that schools permit biological men into women’s intimate spaces, and women into men’s, within the educational environment based entirely on a person’s subjective gender identity. This result is not only impossible to square with Title IX but with the broader guarantee of education protection for all students.” – Page 75

“Ultimately, the Department’s failure to provide any concrete, contradictory data to the concerns raised by the States, parents, and educators renders it is difficult to fathom how it determined that “the benefits” of the new regulations ‘far outweigh [their] estimated costs.’… This miscalculation is underscored by the fact that officials seemingly failed to seriously account for the possibility that abolishing sex-separated facilities would likely increase the incidence of crime and deter large swaths of the public from using public accommodations altogether.” – Page 75

“It is an inescapable conclusion based on the foregoing discussion that the Department has effectively ignored the concerns of parents, teachers, and students who believe that the Final Rule endangers basic privacy and safety interests…. Rather than address the evidence provided by the plaintiff-States and others during the commenting period, the Department throws its figurative hands in the air and says, ‘too bad.’” – Page 76

“The Department predicts that recipients of federal funds will see a ten percent increase in Title IX complaints and investigations under the Final Rule.” – Page 81

“the plaintiff-States contend that the Final Rule would cause their citizens to endure a variety of irremediable harms including violations of their bodily privacy by students of the opposite sex.” – Page 87

“This regulation is arbitrary in the truest sense of the word. As explained above, the Department has failed to demonstrate why recipients are allowed to inflict more than de minimis harm in some situations but not in others when there is no meaningful difference (e.g., living facilities versus showers).” – Page 90

“Each subsection in which these provisions appear contains a severability clause that provides: ‘If any provision of this subpart or its application to any person, act, or practice is held invalid, the remainder of the subpart or the application of its provisions to any person, act, or practice shall not be affected thereby.’ 34 C.F.R. §§ 106.9; 106.16; 106.48. The severability clause has little impact on the Court’s analysis because the impermissible definition of ‘discrimination on the basis of sex’ in 34 C.F.R. § 106.10 permeates the remaining regulations.” – Page 90

“the Department of Education seeks to derail deeply rooted law with a Final Rule that is set to go into effect on August 1, 2024. At bottom, the Department would turn Title IX on its head by redefining “sex” to include “gender identity.” But “sex” and “gender identity” do not mean the same thing. The Department’s interpretation conflicts with the plain language of Title IX and therefore exceeds its authority to promulgate regulations under that statute.” – Page 91

“A rule that compels speech and engages in such viewpoint discrimination is impermissible.” – Page 92

“Notably, the Department does not provide a sufficient explanation for leaving regulations in place that conflict with the new gender-identity mandate, nor does it meaningfully respond to commentors’ concerns regarding risks posed to student and faculty safety.” – Page 92

 

Categories
Department of Education Due Process Free Speech Gender Agenda Office for Civil Rights Press Release Title IX

Federal Judge Blocks Sweeping Title IX Regulation in Four States, Stunning LGBTQ Advocates

PRESS RELEASE

Rebecca Hain: 513-479-3335

Email: info@saveservices.org

Federal Judge Blocks Sweeping Title IX Regulation in Four States, Stunning LGBTQ Advocates

WASHINGTON / June 17, 2024 – This past Thursday federal Judge Terry Doughty handed down a temporary injunction against the new Title IX regulation (1). The sweeping federal regulation, issued on April 19, makes numerous changes to the original Title IX law, including expanding the definition of sex to include “gender identity” (2).

Noting that Title IX “was written and intended to protect biological women from discrimination,” Louisiana District Judge Doughty reasoned, “Such purpose makes it difficult to sincerely argue that, at the time of enactment, ‘discrimination on the basis of sex’ included gender identity, sex stereotypes, sexual orientation, or sex characteristics. Enacting the changes in the Final Rule would subvert the original purpose of Title IX: protecting biological females from discrimination.”

The judge also ruled the new regulation violates the free speech clause of the Constitution, the Spending Clause, and the Administrative Procedures Act. Doughty’s ruling applies to the states of Louisiana, Mississippi, Montana, and Idaho.

The transformative Title IX regulation is encountering strong opposition across the country (3). To date, a total of nine lawsuits have been filed to block the controversial Title IX policy (4):

  1. States of Alabama, Florida, Georgia, and South Carolina, and the Independent Women’s Law Center, Independent Women’s Network, Parents Defending Education, and Speech First (5)
  2. States of Tennessee, Kentucky, Ohio, Indiana, Virginia, and West Virginia (6)
  3. States of Louisiana, Mississippi, Montana, Idaho, Louisiana Department of Education, Rapides Parish School Board, and 17 Louisiana School Districts (7)
  1. States of Arkansas, Missouri, Iowa, Nebraska, North Dakota, and South Dakota (8)
  2. States of Kansas, Alaska, Utah, and Wyoming, Moms for Liberty, Young America’s Foundation, Female Athletes United, et al. (9)
  3. State of Texas and Two UT-Austin Professors (10)
  4. State of Oklahoma (11)
  5. Oklahoma Department of Education (12)
  6. Carroll Independent School District (Texas) (13)

Decisions on many of these complaints are expected during the upcoming month.

In addition, 68 members of the U.S. House of Representatives have co-sponsored H.J. Resolution 165 that seeks to block the controversial regulation (14).

Advocates for LGBTQ rights were furious over the judge’s decision. Human Rights Campaign president Kelley Robinson charged, “Today’s decision prioritizes anti-LGBTQ+ hate over the safety and well-being of students in the state. This is MAGA theatrics with the dangerous goal of weaving discrimination into law.” (15)

Earlier this month the Pew Research Center reported on the results of a national survey that shows 65% of registered voters believe whether a person is a man or woman is based on their biological sex at birth. In 2017, only 53% of voters believed that sex was biologically based (16).

Links:

  1. https://storage.courtlistener.com/recap/gov.uscourts.lawd.205659/gov.uscourts.lawd.205659.53.0.pdf
  2. https://www.federalregister.gov/documents/2024/04/29/2024-07915/nondiscrimination-on-the-basis-of-sex-in-education-programs-or-activities-receiving-federal
  3. https://www.saveservices.org/2024/04/do-not-comply-fight-americans-revolt-against-new-title-ix-rule/
  4. https://www.saveservices.org/2022-policy/abolish-doe/
  5. https://defendinged.org/wp-content/uploads/2024/04/TitleIxLawsuit.pdf
  6. https://content.govdelivery.com/attachments/INAG/2024/04/30/file_attachments/2863214/Complaint%20-%20FINAL,1.42.pdf
  7. https://htv-prod-media.s3.amazonaws.com/files/file-stamped-louisiana-v-u-s-dep-t-of-education-title-ix-662fda6716ff7.pdf
  8. https://arkansasag.gov/wp-content/uploads/2024-05-07-Arkansas-v.-US-Dept-of-Education-Filemarked.pdf
  9. https://www.slfliberty.org/wp-content/uploads/sites/12/2024/05/20240514-Complaint-Doc.-1.pdf
  10. https://www.documentcloud.org/documents/24705968-texas_bonevac_hatfield-v-deptofed-amended-complaint-224-cv-00086-z
  11. https://kfor.com/wp-content/uploads/sites/3/2024/05/24-05-06_complaint.pdf
  12. https://oklahoma-council.files.svdcdn.com/production/assets/img/Final-OSDE-Title-IX-Rule-Complaint.pdf?dm=1715092438
  13. https://dm1l19z832j5m.cloudfront.net/2024-05/Carroll-Independent-School-District-v-US-Dept-Ed-2024-05-21-Complaint.pdf
  14. https://www.congress.gov/bill/118th-congress/house-joint-resolution/165/text?s=2&r=1&q=%7B%22search%22%3A%22HJ+Res+165%22%7D
  15. https://www.hrc.org/press-releases/us-district-court-enjoins-new-title-ix-rule-in-louisiana-mississippi-montana-and-idaho-blocking-enforcement-of-federal-civil-rights-law-for-lgbtq-students
  16. https://www.pewresearch.org/politics/2024/06/06/gender-identity-sexual-orientation-and-the-2024-election/
Categories
Department of Education Discrimination Due Process Free Speech Gender Agenda Office for Civil Rights Press Release Title IX

SAVE Stands in Support of Resolution 165 That Seeks to Block the New Title IX Regulation

PRESS RELEASE

Rebecca Hain: 513-479-3335

Email: info@saveservices.org

SAVE Stands in Support of Resolution 165 That Seeks to Block the New Title IX Regulation

WASHINGTON / June 12, 2024 – The Department of Education recently issued a new Title IX regulation that redefines sex to include “gender identity” (1). In response, 68 members of the U.S. House of Representatives are co-sponsoring a resolution that seeks to block the new regulation. H.J. Resolution 165 states simply:

“Resolved by the Senate and House of Representatives of the United States of America in Congress assembled, That Congress disapproves the rule submitted by the Department of Education relating to ‘Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance’ (89 Fed. Reg. 33474; published April 29, 2024), and such rule shall have no force or effect.” (2)

In support of the Resolution, Education and the Workforce Committee Chairwoman Virginia Foxx charged, “The Biden administration’s final rule hacks Title IX into pieces and expunges decades of progress for women and girls across the nation. This is a clear and present threat, and one that cannot go unaddressed.” (3)

To date, nine lawsuits have been filed to block the controversial Title IX policy (4):

  1. States of Alabama, Florida, Georgia, and South Carolina, and the Independent Women’s Law Center, Independent Women’s Network, Parents Defending Education, and Speech First (5)
  2. States of Tennessee, Kentucky, Ohio, Indiana, Virginia, and West Virginia (6)
  3. States of Louisiana, Mississippi, Montana, Idaho, Louisiana Department of Education, Rapides Parish School Board, and 17 Louisiana School Districts (7)
  1. States of Arkansas, Missouri, Iowa, Nebraska, North Dakota, and South Dakota (8)
  2. States of Kansas, Alaska, Utah, and Wyoming, Moms for Liberty, Young America’s Foundation, Female Athletes United, et al. (9)
  3. State of Texas and Two UT-Austin Professors (10)
  4. State of Oklahoma (11)
  5. Oklahoma Department of Education (12)
  6. Carroll Independent School District (Texas) (13)

The most comprehensive lawsuit, from Alabama, Florida, Georgia, and South Carolina (5), charges the new regulation not only promotes harmful gender transitioning among underage students, but also impairs free speech, parental rights, bathroom privacy, women’s sports, and due process for the falsely accused.

The new Title IX policy affirms the Marxist vision to bring about a “sexless” society. In the words of Shulamith Firestone, the end goal of feminist revolution must be the elimination of the “sex distinction itself: genital differences between human beings would no longer matter culturally…The tyranny of the biological family would be broken” (14).

Stop Abusive and Violent Environments – SAVE – strongly supports H.J. Resolution 165.

Links:

  1. https://www.federalregister.gov/documents/2024/04/29/2024-07915/nondiscrimination-on-the-basis-of-sex-in-education-programs-or-activities-receiving-federal
  2. https://www.congress.gov/bill/118th-congress/house-joint-resolution/165/text?s=2&r=1&q=%7B%22search%22%3A%22HJ+Res+165%22%7D
  3. https://marymiller.house.gov/media/press-releases/rep-mary-miller-introduces-legislation-reverse-bidens-title-ix-rule-which#:~:text=WASHINGTON%20%E2%80%93%20Today%2C%20Congresswoman%20Mary%20Miller,women%20and%20girls’%20private%20spaces.
  4. https://www.saveservices.org/2022-policy/abolish-doe/
  5. https://defendinged.org/wp-content/uploads/2024/04/TitleIxLawsuit.pdf
  6. https://content.govdelivery.com/attachments/INAG/2024/04/30/file_attachments/2863214/Complaint%20-%20FINAL,1.42.pdf
  7. https://htv-prod-media.s3.amazonaws.com/files/file-stamped-louisiana-v-u-s-dep-t-of-education-title-ix-662fda6716ff7.pdf
  8. https://arkansasag.gov/wp-content/uploads/2024-05-07-Arkansas-v.-US-Dept-of-Education-Filemarked.pdf
  9. https://www.slfliberty.org/wp-content/uploads/sites/12/2024/05/20240514-Complaint-Doc.-1.pdf
  10. https://www.documentcloud.org/documents/24705968-texas_bonevac_hatfield-v-deptofed-amended-complaint-224-cv-00086-z
  11. https://kfor.com/wp-content/uploads/sites/3/2024/05/24-05-06_complaint.pdf
  12. https://oklahoma-council.files.svdcdn.com/production/assets/img/Final-OSDE-Title-IX-Rule-Complaint.pdf?dm=1715092438
  13. https://dm1l19z832j5m.cloudfront.net/2024-05/Carroll-Independent-School-District-v-US-Dept-Ed-2024-05-21-Complaint.pdf
  14. https://www.marxists.org/subject/women/authors/firestone-shulamith/dialectic-sex.htm
Categories
Campus Due Process False Allegations Free Speech Press Release Title IX

Blockbuster Lawsuit Filed Against 15 Women’s Rights Organizations for Defamation

PRESS RELEASE

Contact: Lawrence DeMarco, LLM

Telephone: +1 215-901-1930

Email: ldemarco@boysandmen.net

Blockbuster Lawsuit Filed Against 15 Women’s Rights Organizations for Defamation

WASHINGTON / May 31, 2024 —   Saifullah Khan, a former Yale University student who was acquitted of rape charges in 2018, has filed a defamation lawsuit against 15 prominent women’s rights organizations. (1) The lawsuit alleges that despite Khan’s acquittal in a court of law, the defendants falsely labeled him a “rapist” in a legal filing, causing severe damage to his reputation. (2)

Khan, an Afghan refugee who came to the United States as a child, was a full scholarship student at Yale University. In 2015, he was accused of sexual assault by a female classmate following a Halloween party. Following a highly publicized trial in 2018, the jury found Khan not guilty on all charges. (3)

Despite the acquittal, Yale University launched an internal disciplinary proceeding, found him responsible for sexual misconduct, and expelled him. Khan then sued Yale in 2019 for $110 million, claiming the university had denied him due process. (4)

Normally, accusers are granted immunity by courts when they testify in a legal proceeding. But in this case, the Connecticut Supreme Court ruled last June that Yale’s disciplinary procedures lacked adequate due process protections to provide the accuser immunity for her testimony, allowing Khan’s accuser to be potentially held liable for defamation (5).

Two weeks ago, Khan expanded his legal battle, filing a new defamation suit against 15 women’s rights organizations, including the National Women’s Law Center, Legal Momentum, Jewish Women International, and others. (6) The complaint alleges these groups falsely characterized Khan as a “rapist” and made other defamatory statements in a legal filing, which caused him substantial reputational harm.

“I was acquitted in a court of law, yet trusted and powerful organizations continued to defame me,” stated Khan.  He further explained that he doesn’t have a national agenda, but just wants to clear his name. (1)

The defendants, with combined assets exceeding $200 million, have not yet publicly responded to the suit. However, the case is likely to raise important questions about the boundaries of protected speech versus defamation in the context of sexual misconduct allegations during school hearings.

Links:

  1. https://thepostmillennial.com/breaking-former-yale-student-acquitted-of-rape-charges-files-defamation-lawsuit-against-15-liberal-organizations#google_vignette
  2. https://appellateinquiry.jud.ct.gov/DocumentDisplayer.aspx?AppId=2&DocId=qIg2wdaGkywLFsHjxUajVA%3d%3d
  3. https://www.thecut.com/2018/03/yale-student-saifullah-khan-not-guilty-rape-trial.html
  4. https://thepostmillennial.com/former-yale-student-cleared-to-sue-accuser-over-false-allegations
  5. https://freespeechproject.georgetown.edu/tracker-entries/connecticut-supreme-court-repeals-absolute-immunity-for-accuser-in-yale-sexual-assault-case/
  6. https://civilinquiry.jud.ct.gov/DocumentInquiry/DocumentInquiry.aspx?DocumentNo=27589553
Categories
Civil Rights Department of Education Due Process Free Speech Legal Office for Civil Rights Press Release Sexual Harassment Title IX

‘Naked attempt to strong-arm our schools:’ Five Lawsuits Seek to Block Sweeping Title IX Rule

 PRESS RELEASE

Rebecca Hain: 513-479-3335

Email: info@saveservices.org

‘Naked attempt to strong-arm our schools:’ Five Lawsuits Seek to Block Sweeping Title IX Rule

WASHINGTON / May 6, 2024 – It’s not often that a new federal regulation triggers such revulsion that five lawsuits are filed within days of its release. On April 19 the Department of Education issued its long-awaited Title IX regulation, which redefines sex to include “gender identity” (1). Within 11 days, five complaints against the new policy had been filed in federal courts by the following groups:

  1. States of Alabama, Florida, Georgia, and South Carolina, and the Independent Women’s Law Center, Independent Women’s Network, Parents Defending Education, and Speech First (2)
  2. States of Tennessee, Kentucky, Ohio, Indiana, Virginia, and West Virginia (3)
  3. States of Louisiana, Mississippi, Montana, and Idaho (4)
  4. State of Texas (5)
  5. Rapides Parish (Louisiana) School Board (6)

All of the lawsuits contend the new regulation exceeds the Department of Education’s legal authority, and violates the Administrative Procedure Act because its provisions are arbitrary and capricious.

The lawsuit from Alabama, Florida, Georgia, and South Carolina, the most comprehensive of the five, charges the new regulation not only promotes harmful gender transitioning among underage students, but also impairs free speech, parental rights, bathroom privacy, women’s sports, and due process for the falsely accused.

The lawsuit from the Attorneys General of Louisiana, Mississippi, Montana, and Idaho charges the Title IX rule is a “naked attempt to strong-arm our schools into molding our children … in the government’s preferred image of how a child should think, act, and speak” (3) — an accusation that recalls the Communist Party’s earlier crusade to mold an obedient “New Soviet Man” (7).

The lawsuit from the Rapides Parish School Board documents the myriad policy changes that schools would be required to make. The complaint states defiantly, “The school board does not have and does not intend to adopt a policy mandating that staff or students use pronouns that reflect students’ perceived gender identity when doing so is inconsistent with a student’s sex.”

Indeed, Louisiana Attorney General Liz Murrill commented, “This is all for a political agenda, ignoring significant safety concerns for young women students in preschools, elementary schools, middle schools, high schools, colleges and universities across Louisiana and the entire country” (8).

The new – some would say, revolutionary – Title IX policy accords with the Marxist vision to bring about a “sexless” society. In the words of Shulamith Firestone, the end goal of feminist revolution must be the elimination of the “sex distinction itself: genital differences between human beings would no longer matter culturally…The tyranny of the biological family would be broken” (9).

In addition, the governors of Arkansas (10) and Nebraska (11) ordered their schools to ignore the new Title IX policy. The previous week, similar directives had been issued in Florida, Louisiana, Oklahoma, and South Carolina (12).

The new regulation will impose sweeping changes on our nation’s schools. Brett Sokolow, head of the Association for Title IX Administrators, predicts that “60-70% of what we have in place now will need to change in some way to comply with the new Rule” (13).

Which means dramatically increased budgets and institutional clout for the highly politicized Title IX offices across the nation.

Links:

  1. https://www.federalregister.gov/documents/2024/04/29/2024-07915/nondiscrimination-on-the-basis-of-sex-in-education-programs-or-activities-receiving-federal
  2. https://defendinged.org/wp-content/uploads/2024/04/TitleIxLawsuit.pdf
  3. https://content.govdelivery.com/attachments/INAG/2024/04/30/file_attachments/2863214/Complaint%20-%20FINAL,1.42.pdf
  4. https://htv-prod-media.s3.amazonaws.com/files/file-stamped-louisiana-v-u-s-dep-t-of-education-title-ix-662fda6716ff7.pdf
  5. https://www.texasattorneygeneral.gov/sites/default/files/images/press/Title%20IX%20Complaint%20FIled.pdf
  6. https://adfmedialegalfiles.blob.core.windows.net/files/RapidesParishSchoolBoardComplaint.pdf
  7. https://en.wikipedia.org/wiki/New_Soviet_man#:~:text=From%20its%20roots%20in%20the,post%2Dscarcity%20and%20unprecedented%20scientific
  8. https://dfipolicy.org/press-release-the-defense-of-freedom-institute-and-the-states-of-louisiana-mississippi-montana-and-idaho-first-to-file-lawsuit-against-biden-administration-over-new-title-ix-rules/
  9. https://www.marxists.org/subject/women/authors/firestone-shulamith/dialectic-sex.htm
  10. https://governor.arkansas.gov/news_post/sanders-signs-an-executive-order-to-protect-arkansas-students-women-and-girls/
  11. https://www.centralnebraskatoday.com/2024/05/03/gov-pillen-nebraska-will-not-comply-with-the-biden-administrations-rewrite-of-title-ix/
  12. https://www.saveservices.org/2024/04/do-not-comply-fight-americans-revolt-against-new-title-ix-rule/
  13. https://www.atixa.org/blog/title-ix-youve-never-had-a-regs-implementation-like-this-before/