Monday, January 28, 2019

IMPACT Chicago Comment on Title IX Proposed Changes



IMPACT Chicago is a nonprofit organization committed to ending violence and building a non-violent world in which all people can live safely and with dignity. Thousands of women and girls have taken self-defense with IMPACT Chicago. Within the past 30 years, we have offered programs at one time or another on almost every university campus in Chicago and in many high schools and elementary schools (e.g.  Chicago Waldorf School College of DuPage, Columbia College, DePaul University, Dominican University, Evanston Township High School, Francis Parker, Illinois Institute of Technology, Infinity Math, Science, and Technology High School, JCFS Therapeutic Day School, Latin School, University, Moraine Valley Community College, Northwestern University, Northeastern Illinois University, North Park Elementary School, North Park University, Northside College Prep, Roosevelt University, School of the Art Institute, St. Ignatius College Prep, University of Chicago). Of the participants in our programs 16 and older, 46% have experienced unwanted sexual contact and 25% have experienced unwanted sexual intercourse, with 10% identifying their experience as rape.
Based on our experience with college, high school, and middle school students, we conclude that proposed changes in Title IX guidelines will harm students. We have comments on three proposed changes.
1.     Definition of harassment: “Unwelcome conduct on the basis of sex that is so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the recipient’s education program or activity” or “Sexual assault, as defined in 34 CFR 668.46.” 106.30 Federal Register

To focus only on harassment and abuse that is “severe, pervasive, and objectively offensive” is harmful. “Nip it in the bud” is an old saying but one that is evidence-based. Research on effective management in schools indicates that interrupting disruptive behaviors at lower levels is more effective than trying to extinguish those behaviors once they have escalated (J.S. Kounin Discipline and Group Management in Classrooms, 1970; J. E. Brophy and C. M. Evertson Learning from Teaching 1976; C. M. Evertson and C.S. Weinstein Handbook of Classroom Management: Research, Practice, and Contemporary Issues 2013). Addressing inappropriate behavior in its earliest stages is effective in redirecting behavior that if left unattended could escalate into “severe, pervasive, and objectively offensive” behaviors with far-reaching negative consequences for targets, perpetrators, witnesses, and the school environment.
2.     Scope of an investigation: “In addition, the proposed regulations only require investigations in the event of sexual harassment within a recipient’s education program or activity.” 4.C. Cost Estimates, Federal Register

The proposal to permit schools to limit investigations to that which occurs within education programs or activities distorts the reality of students’ lives and educational systems.  Relationships among students and between students, faculty, and administrators go beyond educational programs and activities. A student who harasses another in a grocery store, in a student’s off-campus home, or other places is using a relationship developed within a school program, activity, or environment as the basis for the harassment. The fear, anxiety, and abuse that can result from sexual harassment outside of educational programs and activities affect students’ participation within educational programs and activities.
3.     Hearing process for higher education: “For institutions of higher education, the recipient’s grievance procedure must provide for a live hearing. At the hearing, the decision-maker must permit each party to ask the other party and any witnesses all relevant questions and follow-up questions, including those challenging credibility. Such cross-examination at a hearing must be conducted by the party’s advisor of choice…”. Section 106.45 (B)(3) Investigations of a Formal Complaint
The proposed changes presume false reporting is a major problem when research has consistently demonstrated that it is between 2-10 percent (D.Lisak, L. Gardinier, S.C. Nicksa, & A. M. Cote. 2010. “False allegations of sexual assault: An analysis of ten years of reported cases.” Violence Against Women: 16). Cross-examination by representatives of that institution will have a chilling effect on students, decrease reporting, and have negative effects on those who have been targeted.  
IMPACT Chicago challenges the proposed changes:
·       The definition of harassment and abuse narrowly focuses on the most egregious cases.
·       A narrow focus on harassment within educational programs and activities ignores how relationships developed in educational settings extend beyond educational systems.
·       A presumption that false allegations are rampart instead of building a policy on existing research and prioritizing the well-being of students who have experienced harassment or abuse.    

       IMPACT Chicago Comment (approved by the IMPACT Chicago Board of Directors) on 66 FR6760 “Nondiscrimination on the Basis of Sex in Education Programs or Activities Receiving Federal Financial Assistance," submitted  to Register.Gov on Sunday January 27, 2019. The official comment period has been extended to January 30. For background information and resources, check out "Add Your Voice: Proposed Title IX Changes and Sexual Harassment."


Monday, January 21, 2019

Support Group for African American Women Assault Survivors

LaShanda Nalls, Director of Trauma Therapy, Resilience
[photo:Antonio Perez/Chicago Tribune]

In "'That's a huge trigger.' In wake of R. Kelly documentary, a support group for black assault survivors" Chicago Tribune, Alison Bowen interviews LaShanda Nalls, a therapist and director of trauma therapy at Resilience (formerly Rape Victims Advocates), about a support group for  African-American. female-identified women who have been affected by sexual trauma. The support group begins Thursday January 24. Nalls is committed to making the group a place for healing and for making it clear that black women and girls matter. 

There is currently a waitlist.  For more information,  (312)443-9603 or email.

Monday, January 14, 2019

Add Your Voice: Proposed Title IX Changes and Sexual Harassment

Education Secretary Betsy DeVos has proposed a major overhaul to the way colleges and universities handle sexual misconduct complaints. 

How will these proposed changes affect people who are sexually harassed on college campuses?

  • What constitutes sexual harassment will be limited, requiring someone to experience severe, repeated, or escalating harassment before they can file a Title IX complaint.
  • Schools will not be required to investigate sexual harassment that occurs off-campus at parties, bars, and online.
  • Students will have to report to a high ranking university official instead of a teacher or mentor they know.
There is a Notice and Comment Period until January 28, 2019. Please make your voice heard.

Some Resources for  Learning More and for Making a Comment
Devos' New Sexual Assault Guidelines are Open for Public Comment
End Rape on Campus Toolkit
#HandsOff IX Submit a Comment
#KnowYourIX Notice and Comment
National Women's Law Center Comment Guide re Title IX


Monday, January 7, 2019

Tracy Koppel: Even Though Adrenaline is Rushing Through You, You Are Still Thinking

Tracy Koppel, author of both young adult novels and adult novels, and mother of two teens, took the IMPACT Core Program in 1991 at the University of Chicago. She returned 23 years later to take Defense Against an Armed Rapist and plans to take Defense Against Multiple Assailants within the next couple of years. Her daughter completed IMPACT for Girls five years ago, the Core Program two years ago, and Defense Against an Armed Rapist in November 2018. Instructor Martha Thompson who was part of the Instructor Team for Tracy’s Core Program 27 years ago, met up with Tracy to chat about IMPACT.

What led you to taking that first IMPACT class?
I was a suburban girl living in the city and had concerns about my safety.  I wanted to be able to fight back. I heard about personal security classes but also I heard that most of them weren’t effective. When I heard that IMPACT was going to be offered at the University of Chicago, I read about it and was impressed.

What do you recall taking from that experience?
After IMPACT, I felt much better prepared. I was more comfortable going to unfamiliar places and walking alone at night. My husband came to the graduation and was thrilled when he saw me take down a mugger faster than anyone else in the class.

I have never consciously used IMPACT, but one time I was walking home alone at night and got a feeling that I was being watched. I turned and saw a guy walking behind me. I walked faster, and turned to look again and saw that he was closer to me. A university bus was up ahead and I boarded it even though I didn’t know exactly where it was going. The guy watched the bus take me away. I didn’t panic, I thought clearly, and I made a decision about what to do to keep myself safe. What I learned from that experience was even though my adrenaline was rushing through me, I was still thinking.

You took an advanced course 4 years ago—what led you to taking that course and what did you get from it?
It had been 23 years since I had done the Core Program and I thought it was time to refresh my skills. Taking that class boosted my confidence in my own preparedness. Even after 20+ years, I knew what to do.  It also changed how I watch television. I now get very annoyed when characters don’t use the skills I have to deal with weapons like I’ve been taught.  I also get very annoyed when the good guys get up close to a bad guy, because I know how the bad guy could take control of the situation.  Still, I love being able to point out things that Hollywood gets wrong.

Your daughter has taken several IMPACT courses. What does it mean to you that she has had this experience?
My daughter has taken three classes. It is huge for me as a mom, knowing that when she is on her own—whether walking around by herself or on a date—she can take care of herself.

What is something you can say to others about IMPACT?
While taking the class, even though you know that the scenarios are, in a sense, a “game,” they feel very real. The adrenaline gets going like it is real. That means that by the end of a Core class, you have defended yourself from attack many times. We know this kind of training works. I could still take down a mugger after 23 years without doing anything to reinforce the training I took during CORE.