Green Bay school district violated Title IX by failing to investigate sexual misconduct

The Green Bay Area Public School District failed to complete investigations into reported sexual misconduct in back-to-back school years, violating federal Title IX rules.

The U.S. Department of Education on Friday announced that the district entered into an agreement with the department to address compliance concerns regarding its responses to sexual harassment.

The Department of Education’s Office for Civil Rights found the Green Bay school district violated Title IX in the 2018-19 and 2019-20 school years. Title IX is a federal law that protects people from discrimination based on sex in education programs or activities that receive financial assistance from the federal government.

According to the Department of Education, the district consistently failed to complete Title IX investigations of reported sexual misconduct, including in instances when law enforcement was already investigating.

“When the District was aware that law enforcement was conducting an investigation, the Title IX process would often pause, and the District staff would not pursue their own investigation into the allegation,” wrote Karen Mines, regional director for the Office for Civil Rights Chicago Office, in a letter to district officials.

The district also did not investigate reported employee sexual misconduct after an employee resigned, according to the Department of Education.

“The District’s decision not to complete its investigation because the accused employee resigned categorically failed the District’s Title IX obligation to determine whether sex discrimination occurred,” Mines wrote.

In a statement, the Green Bay Area Public School District said the Office for Civil Rights audit found a “paperwork technicality based on the auditors’ interpretation of district policy” and ignored the “lack of direction” in Title IX regulations in place at the time.

“The OCR took five years to contact the District to propose the resolution agreement, which strongly suggests that the violations identified were technical in nature and that no student rights were ever jeopardized by the District’s Title IX practices,” the district statement reads. “Ultimately, we are confident in the District’s sound practices in this context.”

The district says it worked in collaboration with law enforcement and did not conduct its own investigation to make sure it did not “interfere with law enforcement’s investigation” or create additional trauma for victims.

In the letter to the district, Mines said police investigations do not relieve the district of its duties under Title IX and “are not determinative of whether sexual harassment occurred under Title IX.”

Regarding allegations that it failed to investigate employees who resigned, the Green Bay school district said it “prioritized providing support to the alleged victims over paperwork that at the time was not required.”

The audit of its Title IX practices began in May 2020. According to the school district, it came “following news reports related to an August 2019 incident that occurred off of school premises during the summer months.”

Courtney Roznowski, a former paraprofessional in the district, was arrested in August 2019 on sexual assault of a child charges, according to WLUK-TV and other local media reports. 

Online court records show Roznowski was convicted on one felony count of exposing genitals to a child after she was charged with five felonies related to child sex abuse.

The Green Bay Area School District’s agreement with the Department of Education to conclude the audit includes commitments by the district to ensure policies comply with Title IX.

According to the Department of Education, the district has to:

• Implement a centralized recordkeeping system;
• Train employees on how to respond to sex discrimination;
• Give students training about how to recognize and report sexual harassment;
• Administer a survey to students regarding sexual harassment in district schools;
• And give the Department of Education information about the district’s response to each complaint of sexual harassment under Title IX for this school year and next school year, if requested.

“The Green Bay Area Public School District has now committed to take the steps necessary to effectively address sexual harassment in district schools,” said Catherine Lhamon, assistant secretary for Civil Rights at the Department of Education, in a statement. “OCR looks forward to active work with the district to ensure its full compliance with Title IX.”