RESOLUTION AGREEMENT

Princeton University

Case No. 02-11-2025

Princeton University (the University) assures the United States Department of Education, New 

York Office for Civil Rights (OCR), that it will take the actions detailed below pursuant to Title 

IX of the Education Amendments of 1972 (Title IX), 20 U.S.C. § 1681 et seq., and its 

implementing regulation, 34 C.F.R. Part 106. This Resolution Agreement has been entered into 

voluntarily by OCR and the University and does not constitute an admission by the University 

that its policies and procedures are not in compliance with Title IX or its implementing 

regulations.

During the course of the investigation, OCR has recognized that the University has engaged in 

ongoing and proactive efforts to enhance the effectiveness of its policies and procedures, expand 

the scope of resources, and expand educational and programming initiatives. 

The University has had a dedicated Title IX Coordinator in place. The University’s Title IX 

Coordinator has the authority to investigate allegations of sex and gender-based harassment, 

discrimination and violence prohibited by Title IX. The Title IX Coordinator is also responsible 

for providing annual training to members of the University community regarding the application 

and implementation of policies and procedures related to Title IX. The University has regularly 

notified all students and employees of the Title IX Coordinator’s contact information and 

responsibilities. 

The University has maintained and widely distributed a notice of non-discrimination affirming 

that the University does not discriminate on the basis of sex in its education programs or 

activities and that it is required by Title IX not to discriminate in such a manner.

A. Sexual Misconduct/Title IX Grievance Procedures

The University has submitted to OCR for its review and approval revised grievance procedures 

to address complaints of sexual misconduct (including sex discrimination, sexual harassment,

and sexual assault/violence) as required by the regulation implementing Title IX at 34 C.F.R. § 

106.8(b). While OCR has not yet reviewed these grievance procedures, the University affirms 

that these procedures are internally consistent and provide for the prompt and equitable 

resolution of complaints alleging sexual misconduct (including sex discrimination, sexual 

harassment, and sexual assault/violence) filed against students, employees, and third parties; and 

include, at a minimum, the following:

1

 

1

The University’s revised sexual misconduct policy and grievance procedures can be found at 

http://sexualmisconduct.princeton.edu/.
Page 2 of 13 – Resolution Agreement (Case No. 02-11-2025)

 notice that the procedures apply to complaints alleging all forms of sexual misconduct 

(including sex discrimination and/or sexual harassment/violence) filed against 

employees, students, or third parties;

 an explanation of how to file a complaint of sexual misconduct (which includes sex 

discrimination and/or sexual harassment/violence) pursuant to the policy and procedures;

 the name or title, office address, electronic mail (email) address, and telephone number of 

the individual with whom to file a complaint;

 definitions and examples of what types of actions may constitute sexual misconduct 

(including sex discrimination and/or sexual harassment/violence);

 a requirement that responsible employees promptly report sexual misconduct that they 

observe or learn about;

 provisions providing for the prompt, adequate, reliable, and impartial investigation of all 

complaints, including the opportunity for the parties to present witnesses and other 

evidence and to access information being considered in the grievance process (consistent 

with FERPA);

 provisions providing for the steps the University will take to eliminate a hostile 

environment when the complainant2chooses not to proceed with an informal or formal 

complaint or a hearing; 

 an explicit statement that the University will consider the effects of off-campus conduct 

when evaluating whether there is a hostile environment on campus; 

 provisions indicating that the University has an obligation to make reasonable efforts to 

investigate and address instances of sexual misconduct (including sex discrimination 

and/or sexual harassment/violence) when it knows or should have known about such 

instances, even when a complainant chooses not to participate in an investigation, and 

will respond to complaints, reports, or information about incidents of sexual misconduct 

to stop prohibited sexual misconduct, eliminate any hostile environment, take steps to 

prevent the recurrence of sexual misconduct and address any effects on campus from 

such conduct; 

 a description of the appropriate use of informal resolutions, if any, including: when 

informal resolution may be inappropriate (e.g., mediation is prohibited in cases of sexual 

assault, and those involving a student complaining of sexual harassment against an 

employee in a position of authority over the student); and that the complainant must be 

 

2

Consistent with OCR’s terminology, the term “complainant” used through this Agreement refers to an individual 

who is the subject of alleged sexual misconduct (including sex discrimination and/or sexual harassment/violence) 

for which a complaint or report is made.
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notified of the available informal options and the right to end the informal process at any 

time and begin the formal complaint process; 

 clarification that any informal resolution mechanism set forth in the procedures will only 

be used if the parties voluntarily agree to do so, that the complainant will not be required 

to resolve the problem directly with the respondent;

 provisions affording all parties equivalent rights during the process and appeal;3

 provisions prohibiting parties from personally cross-examining4each other during 

disciplinary processes;

 a statement that the preponderance of the evidence standard will be used for investigating 

and making findings relating to allegations of sexual misconduct (including sex 

discrimination and/or sexual harassment/violence); 

 an understanding that current students should not serve on hearing boards in cases 

involving allegations of sexual misconduct;

 designated and reasonably prompt timeframes for the major stages of the sexual 

misconduct grievance process that apply equally to the parties of the complaint, including 

the fact gathering, complaint resolution, and appeal processes, if any; 

 a description of the sexual misconduct/Title IX rights of complainants and available 

resources and reporting options, including confidential resources, support resources, such

as counseling and the SHARE office, disciplinary options, and the option to file or 

decline to file a complaint with a local law enforcement agency; 

 a statement of the University’s commitment to investigate complaints of sexual 

misconduct in all cases, and provide interim measures to the complainant as appropriate, 

regardless of the enrollment status of an accused student (e.g., a current versus former 

student); 

 a provision indicating that the University will comply with law enforcement requests for 

cooperation, that such cooperation may require the University to temporarily suspend the 

fact-finding aspect of a sexual misconduct/Title IX investigation while the law 

enforcement agency is in the process of gathering evidence, and that the University will 

promptly resume its sexual misconduct/Title IX investigation as soon as it is notified by 

the law enforcement agency that it has completed the evidence gathering process;

 a provision indicating that the University will implement appropriate interim steps during 

the university’s investigation period to provide for the safety of the complainant(s) and 

the campus community and the avoidance of retaliation; 

 

3

The University has informed OCR that character witnesses are not utilized in its revised grievance procedures.

4

The University has informed OCR that cross examinations are not utilized in its revised grievance procedures.
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 a statement that interim measures will not disproportionately impact the complainant, and 

that interim measures are available even if the complainant does not file or continue to 

pursue a complaint of sexual misconduct;

 a statement of the available interim measures and how they can be obtained (such as 

counseling, housing assistance, academic adjustment or other academic assistance, and 

stay away orders); 

 a provision noting that requests for interim measures may be made by or on behalf of the 

complainant to any University official involved with or responsible for Title IX 

compliance, including the Title IX Coordinator, and the Title IX Coordinator (or other 

designated official) will be responsible for ensuring the implementation of appropriate 

interim steps and coordinating the University’s response to these individuals cases with 

the appropriate offices on campus; 

 an explanation of the University’s confidentiality policy, which includes an assurance 

that the University will keep the complaint and investigation private to the extent possible 

and explains what type of information will be shared with the accused if a complaint is 

filed; 

 revisions to the University’s procedures to clarify that, while discretion remains 

important, parties are not restricted from discussing and sharing information related to 

their complaints with others that may support or assist them in presenting their case;

 a provision requiring concurrent written notification to both parties of the outcome of the 

University’s investigation and any appeal; 

 a provision requiring that, if requested by the complainant, the University will promptly 

implement a one-way no contact order (with the burden of no contact on the accused) if 

the University has made a finding of responsibility under the sexual misconduct policy, 

even if an appeal may be filed, or has been filed and is pending;

 notice of the opportunity for both parties to file an appeal, to the extent the procedures 

allow appeals, and for both parties to participate equally in the appeal process, even if the 

party has not herself or himself filed an appeal;

 an assurance that the appeal will be conducted in an impartial manner by an impartial 

decision-maker trained in issues of sexual misconduct/Title IX;

 examples of the range of possible disciplinary sanctions, and the types of remedies 

available to the complainant and others;

 an explanation of how disciplinary actions, if any, relating to a sexual misconduct 

complaint (e.g., underage drinking before a sexual assault) will be handled in the 

complaint procedure;

 a statement that the complainant’s past sexual history will typically not be used in 

determining whether sexual misconduct occurred; except where consent is at issue, prior 
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consensual activity between the two parties, while not determinative, may be relevant to 

determining whether consent was sought and given, recognizing that consent to one 

sexual act does not constitute consent for another sexual act; in addition, the past sexual 

history may be relevant under limited circumstances, for example, to explain injury.

5

 

 a statement that medical and counseling records are privileged and confidential 

documents that students will not be required to disclose. 

 a statement that retaliation is prohibited against any individual who files a complaint of 

sexual misconduct/Title IX, participates in a complaint investigation in any way, or 

opposes in a reasonable manner an act or policy believed to constitute sex discrimination;

Reporting Requirements:

6

a) The University has submitted to OCR for its review and approval its sexual 

misconduct/Title IX grievance procedures revised in accordance with Section A 

above. The University also has submitted to OCR the link to the webpage where 

the revised grievance procedures are located. The University affirms that these 

grievance procedures have been adopted and implemented by the University, and 

all faculty, staff, and students have been provided with notice regarding the 

grievance procedures for resolving sexual misconduct/Title IX complaints 

together with information on how to obtain a copy of the grievance procedures. 

b) Within 45 calendar days of written notification from OCR of its approval of the 

revised sexual misconduct/Title IX grievance procedures, the University will 

again provide written confirmation to OCR that the revised procedures were 

adopted and implemented and that all faculty, staff, and students were provided 

with written notice regarding the grievance procedures for resolving sexual 

misconduct/Title IX complaints together with information on how to obtain a 

copy of the grievance procedures. The University will again confirm to OCR that 

it has, at a minimum, made this notification through the University’s website;

electronic mail messages to faculty, staff, and students; as well as by any other 

additional means of notification the University has deemed effective to ensure 

that the information is widely disseminated. The University will again provide to 

OCR copies of or a link to its revised student handbooks and any other 

publications that contain the procedures, and a link to its webpage where the 

revised sexual misconduct/Title IX procedures are otherwise located.

 

5

This takes into account OCR’s guidance issued on April 29, 2014: “Questioning about the complainant’s sexual 

history with anyone other than the alleged perpetrator should not be permitted. Further, a school should recognize 

that the mere fact of a current or previous consensual dating or sexual relationship between the two parties does not 

itself imply consent or preclude a finding of sexual violence.” This also takes into account New Jersey law. 

6

OCR will attempt to review and approve all documentation submitted to OCR pursuant to the Reporting 

Requirements of Sections A through L of this Resolution Agreement within 60 calendar days of receipt.
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B. Individuals On-Call to Notify Complainants of Available Options and Coordination 

with Law Enforcement Agencies

By February 1, 2015, the University’s policies and procedures will reference the following:

 Upon receipt of a sexual misconduct (including sex discrimination and/or sexual 

harassment/violence) complaint or report (including receipt by the University campus 

police department), the University will provide to the complainant a written notice 

describing the available options, including pursuing a criminal complaint with a law 

enforcement agency, pursuing the University’s investigation process, or pursuing both 

options at the same time; and the potential consequences of pursuing both options (i.e.,

possible temporary suspension of the fact-finding aspect of the University’s investigation 

while the law enforcement agency is in the process of gathering evidence). The 

University will document which option(s) the complainant wishes to pursue or decline. 

 The University campus police will promptly notify the Title IX Coordinator upon receipt 

of any complaint or report of alleged sexual misconduct. The University will not wait for 

the conclusion of a criminal investigation or criminal proceeding to begin its own sexual

harassment/violence investigation though, as noted below, it will temporarily delay the 

fact-finding portion of its sexual harassment/violence investigation during law 

enforcement’s evidence gathering process; and if needed, it will take immediate steps to 

protect the student in the educational setting. 

Reporting Requirement: By February 15, 2015, the University will provide to 

OCR a copy of a written notice to a complainant developed consistent with 

Section B above, and a website link to the University’s notice. 

C. Sexual Misconduct/Title IX Training

Background - Training the University Community:

The University has been, and will continue to be, committed to publicizing, disseminating and 

providing a comprehensive education and prevention program that educates the University

community about the University’s policies and procedures and engages the University 

community to address the entire spectrum of prevention; strengthen individual knowledge and 

skills; promote community education; educate responsible employees; foster coalitions and 

networks, and devote resources to the education, prevention and environmental change efforts to 

address issues related to alcohol and other drugs. The University affirms that it presents multiple 

education and prevention initiatives for the campus community throughout the year. 

Educating Employees Involved with Title IX Compliance:

In addition to information and education to the broad University community, the University

affirms that it provides comprehensive ongoing training for all community members involved 

with processing, investigating or resolving complaints of sexual misconduct or who may 

otherwise assist in the coordination of the University’s compliance with Title IX. These include 

trainings for Assistant Title IX Coordinators; the Sexual Harassment/Assault Advising, 

Resources and Education (SHARE) office and SHARE Peer Advisors; the Ombuds office; 
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Residential College Advisors; officials involved in the disciplinary process; Title IX 

investigators; community members who have volunteered to serve as advisors to complainants 

and respondents in student disciplinary processes involving sexual misconduct allegations, 

Athletics, the LGBT Center, the Women’s Center, the Office of the Dean of the Faculty, Human 

Resources, the Office of the Dean of Undergraduate Students, and the Office of the Dean of the 

Graduate School. 

1. Training Employees Responsible for Recognizing and Reporting Sexual Misconduct. 

By October 1, 2015 and by the same date in 2016 and 2017, the University will provide training 

to all staff responsible for recognizing and reporting incidents of sexual harassment (including 

but not limited to residential college advisors (RCAs), campus police, faculty, administrators, 

counselors, general counsels, athletic coaches, health personnel, and any other responsible 

employees, to the extent they are not confidential resources under policy or applicable law). The 

training will cover, at a minimum: the revised grievance procedures; the obligation of staff to 

report sexual misconduct including what should be included in a report, any consequences for 

the failure to report, and the procedure outlining their responsibility to students’ requests for 

confidentiality); how to report sexual misconduct pursuant to Title IX and the revised grievance 

procedures; the person(s) to whom sexual misconduct must be reported; how to recognize and 

identify sexual misconduct and the behaviors that may lead to and result in sexual misconduct;

the University’s responsibilities under Title IX to address such allegations; and the relevant 

resources available. The training should also include information on the reporting obligations of 

University staff; the student’s option to request that their identifying information not be shared 

with the respondent or that no action be taken; the existence of available confidential advocacy, 

counseling, or other support services; and their right to file a sexual harassment complaint with 

the University and to report a crime to campus or local law enforcement; as well as the attitudes 

of bystanders that may allow conduct to continue; the potential for victimization of students who 

may have experienced sexual misconduct and its effects on students; appropriate methods for 

responding to a student who may have experienced sexual misconduct; and the impact of trauma 

on students who experience sexual misconduct. During the training, the University will provide 

copies of revised sexual misconduct/Title IX grievance procedures to all attendees or refer them 

to their location within the publications they already possess.

Reporting Requirement: By October 15, 2015, and by the same date in 2016

and 2017, the University will provide documentation to OCR demonstrating that 

it has provided the training referenced in Section C (1) above. The documentation 

will include, at a minimum, the date(s) of the training; the name(s) and title(s) of 

the trainer(s); a copy of any materials used or distributed during the training; and 

a sign-in sheet with the names and titles of the individuals who attended the 

training. 

2. Training for Community Members Involved In Implementation of 

Sexual Misconduct/Title IX Grievance Procedures. 

By February 1, 2015, and by the same date in 2016 and 2017, the University will provide its 

Title IX Coordinator and designees and any other University officials/students directly involved 

in receiving, processing, investigating, adjudicating, and/or resolving complaints of sexual 

misconduct with training on the University’s sexual misconduct/Title IX grievance procedures,
Page 8 of 13 – Resolution Agreement (Case No. 02-11-2025)

the University’s obligations regarding the investigation of complaints; guidance from OCR; and 

Title IX’s prohibitions on retaliation. The training will also include instruction on how to 

conduct and document adequate, reliable, and impartial sexual misconduct/Title IX 

investigations for those charged with investigative duties, including information on working with 

and interviewing persons subjected to sexual violence; information on particular types of conduct 

that would constitute sexual violence, including same-sex sexual violence; the proper standard of 

review of allegations of sexual misconduct (preponderance of the evidence); information about 

coordination and communication between the University and the local external law enforcement, 

information on consent and the role drugs and alcohol can play in the ability to consent; the 

importance of accountability for individuals found to have committed sexual misconduct; the 

need for remedial actions for the respondent, complainant, and school community; how to 

determine credibility; how to evaluate evidence and weigh it in an impartial manner; how to 

conduct sexual misconduct/ Title IX investigations; confidentiality; the effects of trauma; and 

cultural awareness training regarding how sexual misconduct may impact students differently 

depending on their backgrounds.

Reporting Requirement: By February 15, 2015, and by the same date in 2016

and 2017, the University will provide documentation to OCR demonstrating that 

it has provided the training referenced in Section C (2) above. The documentation 

will include, at a minimum, the date(s) of the training; the name(s) and title(s) of 

the trainer(s); a copy of any materials used or distributed during the training; and 

a sign-in sheet with the names and titles of the individuals who attended the 

training.

D. Campus-Based Committee

1. The University has informed OCR that it has maintained a standing committee on Sexual 

Misconduct Policies, Prevention and Programs (SMPPP), led by the University’s Title IX 

Coordinator and including officials from the Provost’s office, Office of the Dean of the 

Faculty, Office of the Dean of the Graduate School, Office of the Dean of Undergraduate 

Students, Human Resources, the Department of Public Safety and the residential colleges. 

The SMPPP has been tasked with oversight of campus activities related to sexual 

misconduct, harassment, and assault. 

The University has provided to OCR information regarding the establishment of a 

committee called the Faculty-Student Committee on Sexual Misconduct, which includes

undergraduate and graduate students, faculty members and administrators from a crosssection of the University. This committee will review and monitor systemic issues 

relating to sexual misconduct and Title IX compliance, including our applicable policies, 

procedures, trainings and campus climate. This committee will identify and recommend, 

by October 1, 2015, and the same date annually thereafter as necessary, among other 

things, strategies to ensure that students understand their rights under Title IX and the 

University’s sexual misconduct policy and procedures; understand how to report possible 

violations of sexual misconduct policy/Title IX; and to ensure that the University takes 

each complaint seriously and provides a prompt and equitable response in accordance 

with the requirements of Title IX. Additionally, the committee will recommend 

additional strategies for improving the effectiveness of the University’s procedures,
Page 9 of 13 – Resolution Agreement (Case No. 02-11-2025)

support services, and resources available to students and for the prevention of sexual 

misconduct, including outreach and educational activities. The committee will submit 

recommendations to the University for consideration. 

Reporting Requirement: By December 1, 2014, and by the same date in 2015 

and 2016, the University will provide OCR with a list of names and titles of the 

members of the Faculty-Student Committee on Sexual Misconduct, and meeting 

dates. 

2. By October 15, 2015, and by the same date in 2016 and 2017, the University will submit

to OCR for review a list of recommendations submitted by the Faculty-Student 

Committee on Sexual Misconduct, as well as a list of those recommendations adopted by 

the University. In particular, this list will include a copy of the committee’s

recommended actions relating to the procedures, outreach, and training, and/or other 

University practices addressed by this Agreement, together with supporting information 

that explains the bases for the recommendation (such as climate checks), and the 

University’s plans with respect to those recommendations (including timeframes for such 

plans). The University will complete these plans in accordance with stated timeframes or 

as agreed upon following OCR’s review. 

Reporting Requirement: By October 15, 2015, and by the same date in 2016 

and 2017, the University will provide a report to OCR of the steps taken with 

respect to the committee recommendations. 

E. Information Sessions

1. The University has informed OCR that it has provided information to students consistent 

with Section C above; nonetheless, beginning August 15, 2015, the University will offer 

annual information sessions to students so that they are aware of the University’s

prohibition against sexual misconduct; how to recognize such sexual misconduct when it 

occurs; and how and with whom to report any incidents of sexual misconduct (including 

sex discrimination, sexual harassment and sexual assault/violence). In addition, the 

sessions will cover the University’s sexual misconduct/Title IX grievance procedures; as 

well as a general overview of Title IX, the rights it confers on students, the resources 

available to students who have experienced sexual misconduct), including access to the 

Sexual Harassment/Assault Advising, Resources, & Education, and interim remedies 

during the course of an investigation), and the existence of OCR and its authority to 

enforce Title IX. These sessions may be provided as part of the existing annual student 

orientation for new and returning students, and existing annual residence life orientation 

for students residing in campus housing.

Reporting Requirement: By October 15, 2015, and by the same date in 2016 

and 2017, the University will provide documentation to OCR demonstrating 

implementation of Action Item E (1) above; including a description of each 

information session and the dates that the information sessions were held. 
Page 10 of 13 – Resolution Agreement (Case No. 02-11-2025)

2. By October 1, 2015, the University will develop and implement a public awareness and 

bystander intervention campaign aimed at educating students about sexual misconduct

and safe strategies for bystander intervention.

Reporting Requirement: By October 15, 2015, and by the same date in 2016 

and 2017, the University will provide documentation of its public awareness and 

bystander intervention campaign.

F. Dissemination of Information Regarding Sexual Misconduct (including sex 

discrimination and/or sexual harassment/violence)

By February 15, 2015, the University will, as appropriate, revise its existing materials or develop 

new materials on sexual misconduct to be distributed to students during orientation and upon 

receipt of complaints of sexual misconduct and submit such materials to OCR for review. The 

materials will contain information on what constitutes a sexual misconduct; what to do if a 

student has been subjected to sexual misconduct and contact information for on- and off-campus 

resources for students who have been subjected to sexual misconduct. In addition, the University 

will include information on how to file a complaint of sexual misconduct with the University; the 

name and contact information for the University’s Title IX Coordinator or the individual with 

whom complaints are filed, and a description of the Title IX Coordinator’s role; information on 

how to obtain counseling and academic assistance in the event of sexual misconduct; and 

information on what interim measures can be taken to protect a complainant and how to request 

interim measures if the alleged perpetrator lives on campus and/or lives in the same dorm and/or 

attends the same classes as the complainant. 

Reporting Requirement: Within 60 days of OCR’s approval of the materials 

referenced in Section F above, the University will provide documentation to OCR 

demonstrating that it has implemented Section F above, including a link to where 

the material is posted on the University’s website. The documentation will 

include information about which of the University offices will be responsible for 

distributing the materials upon receipt of a complaint of sexual misconduct 

(including sex discrimination, sexual harassment, and/or sexual assault/violence).

G. Climate Checks

By October 1, 2015, again by the same date in 2016 and 2017, the University will conduct (in 

consultation with the campus-based committee mentioned above in Section D) a climate check 

with students to assess the steps an measures taken pursuant to this Resolution Agreement and

otherwise by the University to achieve its goal of a campus free of sexual misconduct, in 

particular sexual assault/violence. The climate check may be accomplished through a written or 

electronic survey, provided that students receiving the survey also are notified of a contact 

person, such as a counselor, should they wish to discuss this issue in person. Any survey used 

should contain questions about the student’s knowledge of sexual misconduct (including sex 

discrimination and/or sexual harassment/violence) any experiences with sexual misconduct while 

attending the University; and the student’s awareness of the University’s sexual misconduct/Title 

IX policies and procedures. 
Page 11 of 13 – Resolution Agreement (Case No. 02-11-2025)

By January 15, 2015, the University will submit for OCR review and approval a description of 

the tools used for conducting a climate check or series of climate checks. OCR will respond to 

the University by February 15, 2015. The description will include the University’s strategy for 

implementing the climate check(s) and analyzing the results. Information gathered during these 

climate checks will be used to inform future proactive steps taken by the University to provide an 

environment that is safe and supportive to all students and in compliance with Title IX. Finally, 

part of the University’s ongoing climate checks will include informing students about to whom

they can report concerns of sexual misconduct (including sex discrimination and/or sexual 

harassment/violence), such as the Title IX Coordinator or a counselor, as described in other 

provisions of this Agreement. The University will submit proposed future revisions to its 

climate check tool(s) for OCR review and prior approval during the monitoring of the 

Agreement. 

Reporting Requirement: By October 15, 2015, and by the same date in 2016

and 2017, the University will provide documentation to OCR demonstrating 

implementation of Section G above, including a description of how the climate 

check(s) were completed summary frequency tables of the student responses 

formatted in manner that does not disclose the responses of individual students;

and proposed actions, if appropriate, that the University plans to take in response 

to the information gathered during the climate checks. This reporting date may be 

postponed depending on when OCR provides responses to the University under 

this section.

H. Coordination with Local Law Enforcement

By February 1, 2015, the University will send a letter to the Mercer County Prosecutor’s Office

and any other external local law enforcement agencies with jurisdiction over the University and 

its students requesting a Memorandum of Understanding (MOU), where there is not an existing 

MOU, to improve communication and coordination and to address the protocols and procedures 

for referring allegations of sexual misconduct, sharing information, and conducting 

contemporaneous investigations. The overall goal of any MOU should be to aid the University 

in complying with Title IX, to the extent permitted by applicable privacy and confidentiality 

laws. The letter will state: (1) that in instances where conduct of a sexual nature is involved, the 

University is required to investigate in accordance with Title IX but will temporarily delay the 

fact-finding portion of its Title IX investigation during external local law enforcement’s evidence 

gathering process; (2) that upon notification from the Mercer County Prosecutor’s Office or a 

law enforcement agency that the Prosecutor’s Office has completed its evidence gathering 

process, the University must promptly resume its fact-finding portion of its Title IX 

investigation; and (3) that during the pendency of the initial evidence gathering by the police, the 

University will not be precluded from providing witnesses with information about their Title IX 

rights or resources for students who experience sexual misconduct or taking such interim actions 

as may be necessary to ensure the safety and support of any students who experience sexual 

misconduct and the safety of the campus community. 

Reporting Requirement: By February 15, 2015, the University will provide a 

copy of this letter to OCR and any written response by the Mercer County 

Prosecutor’s Office and other law enforcement agencies with jurisdiction over the 
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University and its students. The University will submit the existing MOUs

developed with these law enforcement agencies to OCR for review and approval. 

1. The University will include in the University’s Title IX administrative investigatory file 

relating to a complaint of sexual misconduct, documentation of the date on which the 

University temporarily suspended fact-finding while the Mercer County Prosecutor’s 

Office or other external law enforcement agencies were in the process of gathering 

evidence, and the date on which the University resumed its Title IX administrative 

investigation. 

Reporting Requirement: By July 15, 2015, and by the same date in 2016 and 

2017, the University will provide a copy of the Title IX administrative 

investigative files for any student who has filed a complaint of sexual misconduct

with the Princeton Police Department or any other law enforcement agency and 

with the University the previous academic year. 

I. Complaint Reviews

By February 1, 2015, in accordance with its revised grievance procedures, the University will 

review the complaints and reports of sexual misconduct made from academic year 2011-2012 to 

September 1, 2014, to determine whether the University investigated each complaint or report 

promptly and equitably, including but not limited to, assessing: whether the appropriate 

definitions and analyses were used under Title IX; the appropriate evidence standard in 

investigating allegations of sexual misconduct; the interim relief provided to protect the 

complainant during the pendency of the investigation; the written notice of the outcome 

(including any appeal) and appeal rights to the complainant and the accused; and the steps taken 

to prevent the recurrence of sexual misconduct and to address any hostile environment created by 

the misconduct. The University will take appropriate action to address any problems identified in 

the manner in which these complaints were handled, including providing appropriate remedies 

that may still be available for the complainants in these cases, such as counseling or academic 

adjustments; though the University is not expected to reinvestigate or rehear matters that have 

been finally resolved under University policy.

Reporting Requirement: By February 15, 2015, the University will submit to 

OCR for review and approval the results of its review conducted pursuant to 

Section I, specifically identifying any sexual misconduct complaints or reports 

that were not handled promptly and equitably, all supporting materials relating to 

the University’s review, and the University’s planned action(s) to address any 

problems identified in the review. 

Reporting Requirement: Within 45 days of OCR’s approval, the University

will take appropriate action to address any problems identified in its review.

J. Remedies for Students 1, 2, and 3

By February 1, 2015, the University agrees to provide to Students 1, 2, and 3 reimbursement for

appropriate University-related expenses as well as expenses for counseling, that Students 1, 2, 
Page 13 of 13 – Resolution Agreement (Case No. 02-11-2025)

and 3 incurred from the date on which each student first reported alleged sexual assault/violence 

to the University to the date of resolution; and inquire as to the student’s need for any remedial 

measures. Student 1: Date of Report XXXXXXXX; Date of Resolution XXXXXXXX

(includes respondent’s appeal process and denial of Student 1’s appeal); Student 2: Date of 

Report: XXXXXXXX Date of Resolution XXXXXXXX; Student 3: Date of Report 

XXXXXXXX, Date of Resolution XXXXXXXX.

Reporting Requirement: By February 15, 2015, the University will provide 

documentation to OCR demonstrating the University’s compliance with Section J.

K. Tracking of Complaints

By October 15, 2015, and by the same date in 2016 and 2017, the University will provide OCR

with documentation concerning its responses and handling of all sexual misconduct/Title IX 

allegations reported during the previous year, including a summary of the allegations reported to 

the University and information about the individual(s) who received and processed the initial 

complaints, the outcome of the sexual misconduct/Title IX investigations, as well as the outcome 

of any disciplinary matters related to the allegations, and any supporting documentation. 

L. Monitoring

The University understands that OCR will not close the monitoring of this agreement until OCR 

determines that the University has fulfilled the terms of this agreement and is in compliance with 

the regulations implementing Title IX, at 34 C.F.R. Part 106, which were at issue in this 

case. The University also understands that by signing this agreement, it agrees to provide data 

and other information in a timely manner in accordance with the reporting requirements of this 

agreement. Further, the University understands that during the monitoring of this agreement, if 

necessary, OCR may visit the University, interview staff and students, and request such 

additional reports or data as are necessary for OCR to determine whether the University has 

fulfilled the terms of this agreement and is in compliance with the regulations implementing Title 

IX, at 34 C.F.R. Part 106, which were at issue in this case. In addition, the University 

understands and acknowledges that OCR may initiate administrative enforcement or judicial 

proceedings to enforce the specific terms and obligations of this agreement. Before initiating 

administrative enforcement (34 C.F.R. §§ 100.9, 100.10), or judicial proceedings to enforce this 

agreement, OCR shall give the University written notice of the alleged breach and a minimum of 

sixty (60) calendar days to cure the alleged breach.

10/12/2014 /s/

________________________________

Date Sankar Suryanarayan

Acting General Counsel

Princeton University