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March-April 2012

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Implementing Yale's Sexual Misconduct Policy: The Process Of Institutional Change

Sexual assault and other forms of sexual misconduct are all too common on university campuses. The US Department of Education's Office for Civil Rights reports that 19 percent of female and 6.1 percent of male college students reported being victims of completed or attempted sexual assaults since entering college (DOE OCR, 2011; Krebs, 2007). The degree to which Penn State's reputation was tarnished by allegations that university officials may have covered up allegations of horrific sexual misconduct shows clearly the high stakes involved, not only (and especially) for the victims but also for institutions.

In this article (and in the new Yale University policies described below), the term “sexual misconduct” covers a range of behaviors that include rape, sexual assault (i.e., any kind of nonconsensual sexual contact), sexual harassment, intimate partner violence, stalking, and any other conduct of a sexual nature that is nonconsensual or has the purpose or effect of threatening, intimidating, or coercing a person or persons. Effective policies and procedures to prevent and respond to sexual misconduct not only are required by law but also are critical to creating a university community that values the open and free exchange of ideas, respects all of its members, and provides equal access to the full advantages of higher education. Ensuring the physical and psychological safety of students, faculty, and staff, a challenging task, has grown all the more so given the increasing internationalization of academia, where the social norms of many cultures now interface.

Although Yale repeatedly has espoused the values of community, in recent years the university has witnessed several serious incidents of sexual misconduct that have cast a shadow over those assertions. An investigation by the Department of Education's Office of Federal Student Aid recently determined that Yale had violated the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (as codified at 20 U.S.C. § 1092[f]), when it failed to include reports to the Sexual Harassment Grievance Board in its published on- and off-campus sex-crime statistics.

Moreover, in response to a complaint filed in spring 2011, the US Department of Education's Office of Civil Rights (OCR) launched an investigation into Yale's compliance with Title IX of the Education Amendments of 1972. (Yale is one of a number of universities currently under investigation by the OCR for alleged Title IX violations.) Title IX provides that “no person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving federal financial assistance” (20 U.S.C. §1681 [a]). Although the Title IX complaint is not publicly available, press reports suggest that it contains allegations of a hostile sexual environment at Yale.

In response to the complaint, Richard C. Levin, Yale's president, rapidly constituted an Advisory Committee on Campus Climate, comprising four distinguished Yale alumnae/i and chaired by Margaret H. Marshall, former chief justice of the Supreme Judicial Court of Massachusetts, to examine how sexual misconduct could be prevented and disciplined more effectively on campus. The Committee rendered its report in mid-September 2011, and less than two months later President Levin published both the report and his response to its recommendations (both are available at http://smr.yale.edu/).

The Advisory Committee endorsed the sweeping changes that the Yale WFF had recommended two years earlier in its Report of the Yale Women Faculty Forum Council on Sexual Misconduct at Yale (http://www.yale.edu/wff/documents/WFFReportonSexualMisconductatYale_000.pdf), which the administration had publicly embraced in late 2010. The Committee also highlighted the need to address binge drinking and help students address their own sexuality in today's “hook-up” culture.

Both the Committee and the WFF Report called for a website with a comprehensive set of links to all available resources pertaining to sexual misconduct. Yale now has such a site, http://smr.yale.edu/, which makes it clear that students may report incidents of sexual misconduct anonymously by calling the Yale Sexual Harassment and Assault Response & Education (SHARE) Center (http://sharecenter.yale.edu/), established in 2006 in response to earlier complaints of sexual misconduct on campus. The SHARE Center is staffed by mental health professionals who accept hotline calls 24/7. The Advisory Committee further recommended that all students be made aware of the Center's excellent counseling and advocacy services. President Levin announced that he would increase the Center's resources to meet the anticipated higher demand.

Student plaintiffs, in Alexander v. Yale, had as early as 1977 tried unsuccessfully to institute a university-wide grievance procedure for sexual harassment (Olivarius, 2011). Here we chronicle the process by which the WFF was successful in its attempt to spearhead the transformation of the varied and sometimes opaque policies and procedures of Yale's undergraduate, graduate, and professional schools into a state-of-the art university-wide policy. Our experience of institutional change might serve as a guide for others undertaking the urgent task of instituting new procedures to deal with sexual misconduct and show the way to catalyzing policy changes in other areas as well.

In describing Yale's new procedures, we pay particular attention to those changes necessitated by the guidelines issued by the Department of Education's OCR in its “Dear Colleague” Letter of April 4, 2011 (DOE OCR, 2011, http://www2.ed.gov/about/offices/list/ocr/letters/colleague-201104.pdf). This letter supplemented the OCR's Revised Sexual Harassment Guidance of 2001 (DOE OCR, 2001).

The Yale Women Faculty Forum (WFF)

The WFF was formed in 2001 to promote scholarship on women and gender in all disciplines and to spearhead gender equity and policy initiatives through activism, research, mentorship, and programming. The forum, composed primarily of senior female faculty from schools throughout Yale, spans boundaries of discipline, department, professional school, and unit. It is funded by the Offices of the President and Provost and headed by one or two faculty chairs, who are assisted by two postdoctoral associates. The WFF accomplishes much of its substantive work through groups of faculty with particular investments or expertise in an issue of importance identified by the WFF Council, such as institutional change, child care, salary equity, diversity, and promoting the role of women and minority faculty members as public thought leaders.

The WFF played a pivotal role in the transformation of Yale's piecemeal sexual-misconduct policies into a unified policy predicated on the principles of clarity, transparency, centralization, and ongoing evaluation and improvement. Acting through its Working Group on Sexual Misconduct, in October 2009 the WFF published the Report of the Yale University Women Faculty Forum Council on Sexual Misconduct at Yale, known as the WFF Report (available at http://www.yale.edu/wff/documents/WFFReportonSexualMisconductatYale_000.pdf).

This report was not commissioned by the administration but was instead a bottom-up effort. After a group of students and faculty called the inadequacies of the current sexual-misconduct policies to the attention of the WFF co-chairs, they created a Working Group to review the policies and formulate more effective ones. The WFF Report proposed a university-wide policy that would bar all forms of sexual misconduct by any member of the community, create streamlined and readily accessible reporting mechanisms, mandate ongoing training, and require continuous policy reassessment and improvement.

In July 2010, a sexual-misconduct committee established by the provost recommended the proposed policy's adoption (with minor changes), and the policy became effective July 1, 2011. The procedures governing the newly established University-Wide Committee on Sexual Misconduct (UWC), contact information for the twenty-nine committee members, and a list of resources are now accessible to the entire Yale community on the Office of the Provost's UWC website (http://provost.yale.edu/uwc), as well as through the new Sexual Misconduct Response site at http://smr.yale.edu.

The WFF's Working Group on Sexual Misconduct

The Working Group on Sexual Misconduct comprised seven faculty members, four administrators, and five students, drawn from Yale College, the School of Management, the School of Medicine, the Faculty of Arts and Sciences, the university library, finance and administration, and the WFF staff. The Working Group co-chairs were initially Professor Constance E. Bagley and WFF associate Molly Clark-Barol, then Bagley and Professor Priyamvada Natarajan (assisted by WFF associates Arun Storrs and Jessica Svendsen). Over ten months, an additional twenty-two faculty members and five other staff members from throughout the university provided comments on preliminary drafts of the WFF Report. Other consultants included two lawyers from Yale's Office of General Counsel, who met with the co-chairs of the Working Group to discuss both general principles and specific language.


 The WFF Working Group's research revealed wide variations among the policies and procedures applicable to different members of the Yale community.

The broad participation of multiple stakeholders in the WFF Report's preparation was instrumental in generating the widespread support necessary for its acceptance by the president and provost and for its timely implementation. A chorus of voices on campus—including a newly revamped undergraduate Women's Center; an Office of Lesbian, Gay, Bisexual, Transgender and Queer Resources; a special advisor to the dean of Yale College on Gender Issues; and the SHARE Center—had been advocating for change. The WFF formed part of this chorus of advocacy.

The recommendations in the 2009 WFF Report built on existing best practices at Yale and elsewhere. Prior initiatives included the establishment of the SHARE Center, the Committee on Sexual Harassment and Sexual Assault Prevention Education's report on Yale College's undergraduate sexual harassment and assault policies (released in September 2009), and revamped Yale Medical School policies that took effect in 2009.

The Process

Over the course of the 2008–2009 academic year, the WFF Working Group collected data on sexual misconduct policies at Yale and other universities. The group also conducted telephone and in-person interviews with individuals at Yale, in advocacy organizations, and elsewhere and reviewed the relevant scholarly literature.

Although Yale had previously promulgated a university-wide Statement on Sexual Harassment that banned sexual harassment and discrimination based on sex, and parts of the university had adopted their own policies on various forms of sexual misconduct, the WFF Working Group's research revealed wide variations among the policies and procedures applicable to different members of the Yale community. Most importantly, there was no university-wide definition of “sexual misconduct” or uniform adjudication procedures for handling complaints.

In addition, it was often difficult to locate the specifics of the policies and procedures that did exist. Fourteen flow charts, created by WFF researchers, graphically documented the complex and divergent procedures for complainants in Yale's various schools. Nor were there generally agreed-upon procedures for evaluating how well any of these policies were working in practice. And finally, although computerized or in-house training sessions were required of all supervisors, these sessions were inadequate to educate the broader community.

Although the Working Group communicated with Yale's Office of General Counsel to ensure that the proposed policy would comply with applicable federal (both Title VII and Title IX) and state law, the WFF aspired to do more than just generate a set of rules. It sought to craft a policy that reflected the institution's commitment to the ideals of openness, equal opportunity, and social justice, as summed up in President Richard C. Levin's vision of “strengthening Yale as a great place to study, teach, research, and work.” Transparency, continuing education, and regular oversight were deemed critical to ensure that the policy was working as intended.

By bringing together experts from a range of disciplines, the Working Group tapped into diverse knowledge bases, such as studies on unconscious bias and the impact of stereotypes (Banaji, multiple; Brescoll, 2008). The group also consulted best practices in proposing Yale's new policies. For instance, Brown, Columbia, Cornell, and the University of Virginia offered procedures for the resolution of allegations of sexual misconduct that were more centralized, streamlined, and well articulated than Yale's patchwork system.

Recommendations

The WFF Report identified seven components necessary to create an effective set of sexual misconduct policies and procedures:

  1. An articulation of the policy and procedures;

  2. The establishment of appropriate reporting mechanisms;

  3. The creation of fair informal and formal resolution mechanisms;

  4. Widespread communication of the policy and procedures;

  5. The provision of adequate training;

  6. The adoption of an institutional crisis-management protocol to deal with incidents of sexual misconduct and the aftermath thereof; and

  7. An ongoing collection of data, a monitoring of results and an assessment of the protocol's effectiveness.

    Demarcating the line between the degree of free speech appropriate for unfettered academic  inquiry and expression and intimidating or threatening conduct can be difficult.


The Report adopted the definition of the term “sexual misconduct” in the second paragraph of this article (“conduct of a sexual nature that is nonconsensual or has the purpose or effect of threatening, intimidating, or coercing a person or persons”) and emphasized that it included a broad range of offenses, from the subtle forms of discrimination that undermine professional equity, such as sexually intrusive questions, to the kinds of incidents more likely to garner media attention. The enlarged and clarified definition of sexual misconduct, now adopted at Yale, was one of the achievements of the WFF Report.

The proposed policy included a comprehensive and easily accessible university-wide policy on sexual misconduct. It

  1. Bars all forms of sexual misconduct by any member of the community, including faculty, staff, and students;

  2. Includes definitions of “sexual misconduct” and “consent,” with illustrative examples; and

  3. Distinguishes sexual misconduct from other offenses and places it within the context of community and professional values.

Data suggest that an individual is thirteen times more likely to tell a friend or confidante than file an official report after experiencing sexual misconduct (Fisher, 2000); hence, most sexual misconduct goes unreported. To address this, the WFF Report recommended anonymous and third-party reporting options of the sort offered by the University of California-Los Angeles and the University of Virginia, as well as clarification of the circumstances under which confidentiality could be assured.

It also recommended that the University develop a single, streamlined, university-wide system for both informal and formal resolution of complaints of sexual misconduct, in place of the disjointed procedures then in place. This included a comprehensive, single-point-of-entry online information resource containing all of Yale's sexual-misconduct policies, procedural options, and resources—as well as a tab on the Yale homepage entitled “Safety at Yale” that would link directly to the sexual-misconduct policy website and to all the other relevant university resources. (Although Yale ultimately created a sexual misconduct website, it has not yet added a “Safety” tab to its homepage.)

Consistent with its understanding of the importance of training in this area, the committee recommended that the university ensure that every member of its community (including all incoming graduate students, teaching assistants, lecturers, and faculty and staff in non-supervisory roles) receive training on sexual misconduct policies with refresher courses on at least an annual basis and university follow-up to evaluate the efficacy of these training programs and to underscore the importance of the issues involved.

The Report suggested that Yale University develop a rapid-response plan to ensure the prompt promulgation of information and updates of incidents of sexual misconduct and, when indicated, the university response through investigation, disciplinary action, remediation, and support.

Finally, the Report recommended the creation of a university-wide committee on sexual misconduct, which would promulgate the proposed policy and then handle both informal and formal complaints by faculty, students, and staff. This committee would also regularly gather, store, and review data on sexual misconduct at Yale and periodically disclose an appropriate subset of that data to the Yale community while honoring privacy and confidentiality. Other data-gathering responsibilities of the committee would be periodically to survey a representative sample of all university constituencies to assess (a) knowledge of the policies and procedures on sexual misconduct, (b) faith in those systems, and (c) experience utilizing them.

In the spirit of transparency, the Yale WFF made its Report publicly available on its website in October 2009, about a month after distributing it to the president, provost, and general counsel. In response, in late 2009 Provost Salovey convened an advisory committee composed of individuals throughout the university to review the WFF's recommendations; in a similar commitment to open communication, the provost posted the advisory committee's July 2010 report (available at http://provost.yale.edu/news-announcements/report-sexual-misconduct-committee) on the Office of the Provost website in October 2010.

The committee, which was chaired by Professor Michael Della Rocca, embraced the comprehensive definition of sexual misconduct and “fully endorse[d] the recommendation in the WFF Report that the policies and procedures dealing with cases of sexual misconduct at the university be made more transparent and more accessible” through a single website. It also accepted the WFF Report's recommendation that a university-wide committee be established “that will handle and resolve, through formal and informal means, complaints of sexual misconduct at Yale” while maintaining a limited measure of procedural autonomy for the professional schools.

The Yale University-Wide Committee on Sexual Misconduct (UWC) became operational on July 1, 2011. The UWC is “an accessible, representative, and trained body to answer informal inquiries and fairly and expeditiously address formal and informal complaints of sexual misconduct.” Training for its members includes two four-hour sessions taught by legal counsel, mental health professionals, and other experts. The UWC comprises twenty-nine faculty, staff, and student members from throughout the university, with ten forming the core group and nineteen the at-large group.

The Policy

The new policy, which declares that sexual misconduct “is antithetical to the standards and ideals of our community and will not be tolerated,” went into effect on July 1, 2011. It includes most but not all of the WFF's recommendations; some that were not initially adopted were added in November 2011. It also subsumes the university's Policy on Teacher-Student Consensual Relations, which limits—and with respect to undergraduates, bars—sexual relationships between teachers and students. In addition, it prohibits the making or sharing of photographs, video, or other auditory or visual recordings of sexual activity without explicit consent.

The new policy articulates a clear definition of consent: a “clear, unambiguous, and voluntary agreement between the participants to engage in specific sexual activity” (for more detail, see “Definition of Sexual Consent” on the Sexual Misconduct at Yale site, http://smr.yale.edu/definitions-sexual-misconduct-consent-and-harassment). It makes it clear that “when there is a lack of mutual consent about sexual activity, or there is ambiguity about whether consent has been given, a student can be charged with, and found guilty of, committing a sexual assault or another form of sexual misconduct.” Further, “consent cannot be obtained from someone who is asleep or otherwise mentally or physically incapacitated, whether due to alcohol, drugs, or some other condition.” Because “consent to some sexual acts does not imply consent to others,” partners “must evaluate consent in an ongoing fashion and should communicate clearly with each other throughout any sexual encounter.”

Threatening speech that is “sufficiently serious to constitute sexual harassment” is now included in the definition of sexual misconduct. Demarcating the line between the degree of free speech appropriate for unfettered academic inquiry and expression and intimidating or threatening conduct can be difficult. The WFF Working Group had identified this issue in its Report and encouraged the university to seek legal guidance on the issue and disseminate it to the community. Although the Advisory Committee did not consider the issue as within its purview, it did note (and President Levin agreed) that certain hate speech might violate university values even if it does not rise to the level of illegal harassment, and it should be promptly condemned.

Except in extreme situations, all communications with the SHARE Center are strictly confidential. Informal complaints to the UWC are “kept as confidential as possible, but information about incidents of sexual misconduct must be shared with relevant administrators and a Title IX coordinator so that the University can take action if necessary for reasons of safety. In planning any response, the wishes of the person are given full consideration.”

Procedures

The president and provost gave the deans of Yale College, the Graduate School of Arts and Sciences, and Yale's thirteen professional schools discretion to retain their local procedures, but only the Yale Law School retained its own body for hearing formal cases of sexual misconduct. Even in cases involving the Law School, the complainant has the option of having the UWC handle the matter. Thus, Yale now has university-wide standards banning sexual misconduct by faculty, staff, and students (as well as certain third parties, such as guests and consultants), and a centralized decision-making body that handles both formal and informal cases.

However, only students may bring cases to the UWC against staff members. In addition, complaints against a member of the unionized staff (and certain other excluded staff) are addressed by the Title IX officer of the university or of a school (or by other identified personnel), not the UWC.

A strength of the new UWC procedures is the provision of specific time limits for steps in the adjudication process. For example, the hearing panel must submit its report within seven days after the final hearing session. As a result, a formal complaint process should take about 60 days, leading to quicker resolutions.

Sexual misconduct cases often require significant fact-finding efforts. To ensure that the facts are marshaled completely and fairly, the procedures require an “impartial fact-finder from outside the university to assist in the investigation of the case,” who must deliver a report to the Secretary of the UWC within twenty-one days of his or her appointment. The report is provided to the parties and the panel in advance of the hearing.

Both parties have an opportunity to appear at the hearing (singly with audio access while the other party is testifying unless both parties agree to appear jointly). A party may be accompanied by an advisor at any stage of the process, but the advisor may not speak for the party during an interview with the fact-finder or a formal hearing. If one party is entitled to a legal representative, then the other may also be accompanied by one.

After reviewing all the evidence, the panel discusses the case, then votes on culpability by secret ballot. UWC panel decisions are made by majority vote, with no abstentions permitted. In accordance with the updated Title IX guidance released by the OCR on April 4, 2011, the Yale regulations require proof by a “preponderance” of the evidence (unlike the prior rules in Yale College, which required proof by a “clear preponderance”), extend the right of appeal to both the complainant and the respondent, and do not suspend the university grievance process pending a criminal investigation or prosecution.

When determining culpability, the panel may take into account a respondent's prior formal discipline for other acts of sexual misconduct and any criminal conviction arising out of the conduct at issue. But previous accusations not resulting in formal discipline, criminal investigations, and pending cases are not deemed “evidence of misconduct.”

In his November 10, 2011 letter responding to the Advisory Committee recommendations, President Levin instructed “the UWC to apply any and all penalties, including expulsion where warranted” (see “Response from the President to the Report of the Advisory Committee on Campus Climate,” available on http://smr.yale.edu). For the purposes of assessing penalties, the panel receives information on previous penalties received for similar violations.

There is a final decision-maker in cases of sexual misconduct who may accept, reject, or modify the panel's conclusions or recommendations in whole or in part. But if that person modifies or rejects the panel's conclusions or recommendations, then he or she must explain the decision to the panel in writing.

Previously, final decisions were usually handled by the dean of the relevant school: the dean of Yale College would decide cases involving students and faculty at the College (with student-on-student cases being decided by the Yale College disciplinary committee), the dean of the Medical School would decide cases involving members of the Medical School, and so forth. Now cases brought against a faculty member are decided by the provost, ones against a student or trainee are decided by the dean of the respondent's school, and ones against staff members are decided by the associate vice president for human resources.

The accused and the complainant have limited rights of appeal based on procedural errors or the discovery of relevant new evidence not reasonably available to the appealing party prior to the UWC hearing. An appeal from the provost's decision regarding a faculty member is made to the president; an appeal from a dean's decision regarding a trainee or student is made to the provost; and an appeal from a decision by the associate vice president for human resources regarding a staff member is made to the vice president for human resources and administration.

Even if a formal UWC hearing concludes that a respondent's actions do not violate Yale's policies on sexual misconduct, those same actions may still violate an individual school's standards of behavior. For example, certain hate speech might not be sufficient to create a hostile environment but still violate an individual school's code of conduct. Such behavior may be the subject of separate school proceedings, as long as the school bases its proceedings on the facts found by the UWC. This provision was important to gaining consensus on the new university-wide procedures because it ensured that individual schools could impose higher standards of conduct on their members than those embodied in the sexual misconduct policies.

There is a two-year statute of limitations that generally bars formal complaints more than 24 months after the most recent alleged instance of sexual misconduct or 12 months after leaving the university (except ones made by a Title IX coordinator)—a response to the concern that the due-process rights of respondents might be impaired if too much time elapsed between the event and the hearing of the case.

Yale policy strictly forbids retaliation against individuals who report, file complaints, cooperate in any investigation, or hear formal or informal complaints of sexual misconduct. But some have expressed the concern that a person fearful of retaliation might want to wait until he or she left Yale to initiate proceedings, regardless of when the conduct occurred. For example, a first-year law student might want to wait until he graduated and received a sought-after clerkship before bringing a complaint against a faculty member.

The Secretary of the UWC retains records of its proceedings…thereby enhancing institutional memory and ensuring the fair and equitable treatment of like cases over time.

The policy gives Title IX coordinators the right to bring cases on behalf of individuals who are neither current nor former members of the Yale community, provided that the respondent is a current Yale faculty member, trainee, student, or staff member and was in one of these roles at the time of the alleged misconduct, as well as that the events complained of occurred on the campus or in connection with a Yale-sponsored event not more than two years before the date the complaint is filed (this is extended to four years for informal complaints). A Title IX coordinator may also bring a complaint when there is evidence that the university's policy on sexual misconduct has been violated and his or her intervention is needed to ensure that the matter reaches the UWC.

The Secretary of the UWC retains records of its proceedings—including all complaints, hearing panel reports, and decisions—thereby enhancing institutional memory and ensuring the fair and equitable treatment of like cases over time. The Secretary and Title IX coordinators summarize each informal and formal complaint of sexual misconduct and its resolution and submit the summaries to the university's Title IX coordinator. Furthering the goal of transparency, the coordinator publishes a statistical summary of the complaints each January and July, with an anonymous list of disciplinary actions taken.

Conclusion

The Working Group structure and collaborative process that the Yale WFF employed may show other institutions a way to enhance the physical and psychological safety of their community members. Having effective policies and procedures to prevent, respond to, report, and keep the community informed about incidents of sexual misconduct is fundamental.

Moreover, the transformation of Yale's policy and procedures, advocated and shepherded by the WFF and hastened by the Title IX complaint, constitutes a successful values-based, ground-up institutional change model that might be applied to other policy shifts as well. The experience of Yale suggests that change initiatives coming from within may promote more effective and enduring policy shifts than those imposed from the outside. Once such change is underway, though, external forces can provide the added impetus needed for rapid translation into action and can also help sustain momentum.

But although faculty interest groups, working alongside but independently from administrators, can serve as a powerful catalyst for the evolution of community governance and values, leadership—not only by the president and provost but also by the deans, faculty and students—is critical, as is ongoing dialogue about healthy relationships, risky behavior, and personal responsibility. Only then will universities be genuinely inclusive and safe places for all their members.

Websites

1. Yale University Sexual Harassment and Assault Response & Education (SHARE) Center , http://sharecenter.yale.edu/

2. Yale University, Office of the Provost, University-Wide Committee on Sexual Misconduct , http://provost.yale.edu/uwc

3. Yale University, Sexual Misconduct Response at Yale , http://smr.yale.edu

4. Yale Women Faculty Forum , http://www.yale.edu/wff

Resources

4. Bagley, C. and Natarajan, P. (October 30 2009) No silence, no fear: Preventing sexual misconduct at Yale. Yale Daily News Retrieved from http://www.yaledailynews.com/news/2009/oct/30/bagley-and-natarajan-no-silence-no-fear/

4. Banaji, M. , http://www.people.fas.harvard.edu/~banaji/multiple; see

4. Brescoll, V. L. and Uhlmann, E. L. (2008) Can an angry woman get ahead? Status conferral, gender, and expression of emotion in the workplace. Psychological Science 19:3, pp. 268-275.

4. , http://uscode.house.gov/uscode-cgi/fastweb.exe?getdoc+uscview+t17t20+3771+1++percent28clerypercent29Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act, 20 U.S.C. § 1092(f).

4. Fisher, B. S., Cullen, F. T. and Turner, M. G. (2000) The sexual victimization of college women, National Institute of Justice and U.S. Department of Justice, Bureau of Justice Statistics.available through the National Criminal Justice Reference Service athttps://www.ncjrs.gov/pdffiles1/nij/182369.pdf

4. Krebs, C. P., Lindquist, C. H., Warner, T., Fisher, B. S. and Martin, S. L. (2007) The campus sexual assault study: Final report, National Institute of Justice.available through the National Criminal Justice Reference Service at http://www.ncjrs.gov/pdffiles1/nij/grants/221153.pdfThe performance period for the study is January 2005 through December 2007

4. Olivarius, A. (April/May 2011) , Retrieved from http://www.thenewjournalatyale.com/2011/04/title-ix-taking-yale-to-court/posted online April 18, 2011Title IX: Taking Yale to court. The New Journal, New Haven, CT

4. , available at http://www.dol.gov/oasam/regs/statutes/titleix.htmTitle IX, Education Amendments of 1972, 20 US Code, §1681–1688

4. US Department of Education, Office of Federal Student Aid, School Participation Team – New York/Philadelphia (May 23 2011) Final program review determination prepared for Yale University, available at http://federalstudentaid.ed.gov/datacenter/cleryact/yale/YaleFPRD52311.pdfThe time period under review was 2001–2006

4. US Department of Education, Office for Civil Rights (2001) Revised sexual harassment guidance, available at http://www2.ed.gov/about/offices/list/ocr/docs/shguide.pdf

4. US Department of Education, Office for Civil Rights (April 4 2011) “Dear Colleague” letter guidance, available at http://www2.ed.gov/about/offices/list/ocr/letters/colleague-201104.htmlhttp://www2.ed.gov/about/offices/list/ocr/letters/colleague-201104.pdfsupplementing the OCR's Revised sexual harassment guidance (2001)

4. Yale College Committee on Sexual Harassment and Assault Prevention Education (May 22 2008) Report of the committee on sexual harassment and assault prevention education in Yale College, available at http://yalecollege.yale.edu/sites/default/files/shape_cmte_report_0.pdf

4. Yale College Sexual Harassment Grievance Board (2006) A report by the Yale College Sexual Harassment Grievance Board to Dean Peter Salovey of its review of the handling of reports from Yale undergraduates regarding sexual assault, Available at http://www.yale.edu/yalecollege/administration/committees/harassment/reports/pdf/sexual_harassment.pdfOn file with the editors

4. Yale University, Advisory Committee on Campus Climate (Sept. 15 2011) Report to the president and fellows of Yale University of the Advisory Committee on Campus Climate, available at https://light.its.yale.edu/messages/attachments/w3_71679_CampusClimateReport.pdfhttp://smr.yale.edu/

4. Yale University, School of Management Vision statement on diversity, retrieved from http://mba.yale.edu/why/diversity/vision.shtml

4. Yale University, Office of Equal Opportunity Programs Definition of sexual misconduct, sexual consent, and sexual harassment, available at http://www.yale.edu/equalopportunity/policies/index.html

4. Yale University policy on teacher-student consensual relations, available at http://www.yale.edu/equalopportunity/policies/index-review.html#policy

Constance E. Bagley (connie.bagley@yale.edu) is a professor in the practice of law and management at the Yale School of Management and co-author of Managers and the Legal Environment: Strategies for the 21st Century (6th ed. 2010).

Priyamvada Natarajan (priyamvada.natarajan@yale.edu) is a professor of astronomy and of physics at Yale and the chair of the Yale Women Faculty Forum (WFF) for 2011–12.

Liena Vayzman (liena.vayzman@yale.edu) is a gender equity and policy postdoctoral associate at the WFF.

Laura Wexler (laura.wexler@yale.edu) is a professor of American studies and of women's, gender, and sexuality studies at Yale; she was co-chair of the WFF from 2008 to 2011.

Shirley McCarthy (shirley.mccarthy@yale.edu), a professor of diagnostic radiology and of obstetrics and gynecology at the Yale School of Medicine. For more information about the WFF and to access its research and resources, please visit http://www.yale.edu/wff. To contact the WFF, email wff@yale.edu.

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