Johns Hopkins Center for Talented Youth

Interim adjudication procedures for Title IX sexual and sex-based misconduct involving minor participants in non-degree programs¹(effective August 1, 2024)

In compliance with Title IX of the Higher Education Amendments of 1972 (“Title IX”), the Campus SaVE Act, and other applicable laws, the Johns Hopkins University (“JHU” or “the University”) prohibits sexual and sex-based misconduct in all JHU affiliated programs. This includes discrimination and harassment based on sexual orientation, gender identity, sex stereotypes, sex characteristics, and pregnancy and related conditions.

All minor participants in JHU non-degree programs (including, but not necessarily limited to, youth programs and camps) are expected to comply with the conduct expectations set forth in Sections II and III of the University’s Sexual and Sex-Based Misconduct Policy and Procedures (“SMPP”)

Reporting: Any individual who wishes to make a report or file a complaint of sexual and/or sex-based misconduct may use the University’s Online Reporting System or contact the University’s Title IX Coordinator, the executive director of the relevant non-degree program, or any other leader, teacher/instructor, or administrator at the relevant non-degree program.

Reports of sexual and/or sex-based misconduct may be filed anonymously, meaning that the individual files the report without providing their name or other identifying information. However, anonymous reporters are encouraged to speak with the Title IX Coordinator or their designee regarding the potential limitations of an investigation being conducted based on an anonymous report. Regardless of whether an investigation is conducted, anonymous reports will be reviewed to determine whether preventive or remedial action should be taken, such as prevention or educational programs, or increased safety patrols or monitoring. 

Individuals are encouraged, but not required, to report any potential criminal conduct to law enforcement authorities and can receive assistance from University employees if requested. 

Responsible employees: All individuals employed by JHU non-degree programs involving minor participants are considered “responsible employees” if they fit into either (or both) of the below categories:

• Employees who have the authority to institute corrective measures on behalf of the program
• Employees who have responsibility for administrative leadership, teaching or advising.

The above categories should be interpreted broadly and include individuals who supervise and/or monitor the well-being of minor participants in the programs, such as Resident Advisors and Teaching Assistants. Responsible Employees must promptly report any sex-based or sexual misconduct of which they become aware to the University’s Title IX Coordinator or designee consistent with the requirements set forth in Section V of the SMPP.

Responding to reports: Upon receiving a report of sexual and/or sex-based misconduct, the Title IX coordinator or designee will promptly contact the Complainant² to discuss the report, supportive resources, and potential interim supportive measures. Then, in consultation with other University administrators, it will be determined whether the alleged conduct will be adjudicated pursuant to the following procedures or another University process.³ The Complainant will be notified accordingly.

Interim measures and supports: Regardless of which University process applies, supportive resources and measures are available as set forth in Section VII of the SMPP. Supportive measures may include connection with an academic counselor or No Contact Orders between the involved parties. The interim removal of an accused individual from some or all programming pending the completion of the adjudication process can also be a supportive measure if University administrators conduct an individualized safety and risk assessment and determine that there is an imminent and serious threat to the health or safety of any student or other individual arising from the allegations of sex-based or sexual misconduct that justifies removal. 

Investigation: If it is determined that this adjudication process for sexual and sex-based misconduct applies, a written Notice of Allegations will be issued to both parties and an investigation may be conducted pursuant to the process set forth in Appendix G, Section G.2. of the SMPP. During the investigation, the investigator will collect and make available to the parties all relevant evidence pursuant to the process set forth in Appendix G, Section G.6. of the SMPP. The investigator also will question parties and/or witnesses to adequately assess credibility to the extent that credibility is in dispute and relevant to evaluating one or more allegation of sexual or sex-based misconduct. Relevant information obtained during credibility-related questioning will be shared with the parties as appropriate and in accordance with applicable law.

Determination: Once the investigation is complete, OIE will draft an investigative report summarizing the relevant evidence collected and determining whether the conduct alleged in the complaint constitutes a violation(s) of University policy. A “preponderance of the evidence standard” will be applied.

If OIE finds that no policy violation occurred, OIE will draft a final, written determination consistent with the requirements set forth in Appendix G, Section H.6. The completed investigation report will be forwarded to the appropriate program administrator. Until and unless the University issues a final determination of responsibility, the Respondent is presumed to be not responsible.

Sanctions: In cases where there is a determination that a policy violation occurred, the University will issue a sanction in accordance with Section H.7. of Appendix G to the SMPP.

Retaliation: Retaliation against a person because that person made a complaint or report of sex-based or sexual misconduct or participated in any way in the investigation or resolution of such a complaint or report, or who exercises their rights or responsibilities under University policy, procedures, or the law, is strictly prohibited and grounds for disciplinary consequences. 

Appeals: The final, written determination may be appealed pursuant to the process set forth in Section H.8. of Appendix G to the SMPP. Information about appeals will be included in the final, written determination described above.

The University’s SMPP shall govern any portion of the adjudication process not specifically referenced above.

¹ These procedures comply with the August 1, 2024 Title IX regulations and became effective on that date. The procedures have been given the designation of “interim” due to the short implementation period and numerous legal challenges pending against the Title IX regulations. The University will continue to seek feedback and consider potential policy improvements to best serve our community. In addition, the University will monitor legal developments that may impact this policy.

²In cases where the parties involved in a sex-based or sexual misconduct matter are minors, their parent(s) or guardian(s) will be notified. Both parties are permitted to have a supporter present (who can be a parent, guardian, lawyer, advocate or other individual) at all meetings throughout the sexual / sex-based misconduct adjudication process.

³These adjudication procedures do not apply to minors who are enrolled in undergraduate or graduate degreeseeking programs at other universities and who are taking a JHU course for credit; instead, the full procedures set forth in Appendix G of the SMPP govern Title IX Sex-Based and Sexual Harassment matters involving those individuals.