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Title IX

Title IX



Title IX of the Education Amendments of 1972 states
"No person in the United States shall, on the basis of sex,
be excluded from participation in, be denied benefit of, or
be subjected to discrimination under any education program or activity
receiving federal financial assistance." 


Jefferson College is committed to fostering an inclusive environment where all individuals are respected and empowered to achieve their goals. In pursuit of the mission, vision, and values of the College, as well as to be in compliance with all applicable local, state, and federal laws, the Jefferson College Title IX Sexual Harassment Policy and Grievance Process prohibits any form of discrimination on the basis of sex, inclusive of Sexual Harassment. Jefferson College is committed to providing a learning, working, and living environment where all persons are able to thrive personally, academically, and professionally.

The Jefferson College Title IX Sexual Harassment Policy and Grievance Process and the procedures within apply to all community members, including students, faculty, staff, contractors, and visitors. Any person who has been affected by any form of Sexual Harassment, Sexual Assault, Stalking, Dating Violence, or Domestic Violence, is strongly encouraged to make a report or speak to the Title IX Coordinator to learn more about options and resources available to them.

Jefferson College will respond promptly, equitably, and thoroughly to all reports of Sexual Harassment in order to eliminate the harassment, prevent its recurrence, and address the effects or impacts on any individual(s) involved. The Jefferson College Title IX Sexual Harassment Policy and Grievance Process provides Jefferson College community members with information to assist those who have been impacted by Sexual Harassment regardless of their status as a Complainant, Respondent, Witness, or other participant/third-party, and provides for equitable procedures for reporting, investigation, and resolution of reports.

The Jefferson College Title IX Sexual Harassment Policy and Grievance Process is also summarized below:

A two page brochure about how Jefferson College addresses sexual misconduct can also be accessed here.


The Jefferson College Title IX Sexual Harassment Policy and Grievance Process prohibits all forms of Sexual Harassment including Sexual Assault, Stalking, Dating Violence, and Domestic Violence against any Jefferson College community members of any sex, gender, gender identity, gender expression, or sexual orientation.

These acts can occur between individuals who are known to one another, or have an intimate or sexual relationship, or may involve individuals who are not known to one another. These acts can be committed by person(s) of any sex, gender, or other identity, and it can occur between people of the same or different sex or gender identities.

Jefferson College prohibits the following types of conduct under the Jefferson College Title IX Sexual Harassment Policy and Grievance Process:

1. Sexual Harassment: Sexual Harassment is any conduct on the basis of sex that satisfies one or more of the following:

a. An employee of the College conditioning the provision of an aid, benefit, or service of the College on an individual’s participation in unwelcome sexual conduct;

b. Unwelcome conduct determined by a reasonable person to be so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the school’s education program or activity; or

c. Sexual Assault, Dating Violence, Domestic Violence, or Stalking as defined in the Clery Act amended by the Violence Against Women Act (VAWA).

i. Sexual Assault: Sexual Assault is any sexual act directed against another person, without the consent of the victim, including instances where the victim is incapable of giving consent. Sexual Assault includes, but is not limited to, the following acts when they occur without consent of the victim:

Any penetration, however slight, of the genitals or anus of one person with the genitals of another person,
Any act involving the genitals of one person and the hand, mouth, tongue, or anus of another person,
Any sexual act involving penetration, however slight, of the genitals or anus of one person by a finger, instrument, or object,
Touching of another person’s genitals or breasts under or over the clothing,
Touching of one person with the genitals of another person under or over the clothing.

Sexual assault is also an offense that meets the definition of fondling, incest, or statutory rape as used in the FBI’s Uniform Crime Reporting system.

1. Fondling: The touching of the private body parts of another person for the purpose of sexual gratification, without the consent of the victim, including instances where the victim is unable of giving consent because of their age or because of their temporary or permanent mental capacity.

2. Incest: Sexual intercourse between persons who are related to each other within the degrees wherein marriage is prohibited by law.

3. Statutory Rape: Sexual intercourse with a person who is under the statutory age of consent.

ii. Dating Violence: Violence committed by a person who is or has been in a social relationship of a romantic or intimate nature with the victim (Complainant). The existence of such a relationship shall be based on consideration of the following factors that include the length of the relationship, the type of relationship, and the frequency of interaction between the persons involved in the relationship. Dating Violence includes, but is not limited to, sexual or physical abuse or the threat of such abuse. Dating Violence does not include acts covered under the definition of Domestic Violence.

iii. Domestic Violence: A felony or misdemeanor crime of violence committed by a current or former spouse or intimate partner of the victim (Complainant); by a person with whom the victim shares a child in common; by a person who is cohabitating with, or has cohabitated with, the victim as a spouse or intimate partner; by a person similarly situated to a spouse of the victim under the domestic or family violence laws of the jurisdiction in which the crime of violence occurred; or by any other person against an adult or youth victim who is protected from that person’s acts under the domestic or family violence laws of the jurisdiction in which the crime of violence occurred.

iv. Stalking: Engaging in a course of conduct directed at a specific person that would cause a reasonable person to fear for their safety or the safety of others or suffer substantial emotional distress. Course of conduct means two or more acts, including, but not limited to, acts in which the stalker directly, indirectly, or through third parties, by any action, method, device, or means, follows, monitors, observes, surveils, threatens, or communicates to or about, a person, or interferes with a person’s property. Substantial emotional distress means significant mental suffering or anguish that may, but does not necessarily require medical or other professional treatment or counseling. Reasonable person means a reasonable person under similar circumstances and with similar identities to the victim.

The State of Missouri’s Revised Statutes provide information on state laws pertaining to the offenses listed in the above section. More information on the State of Missouri Statutes as it pertains to sexual offenses (including sexual assault, rape, and statutory rape) can be found in RSMO.566. More information on the State of Missouri Statutes as it pertains to Incest can be found in RSMO.568; information on Domestic Violence can be found in RSMO.565; and Stalking can be found in RSMO.565. All Revised Statutes for the State of Missouri can be accessed online at:

Consent, Force, Coercion, and Incapacitation

As noted in the above definitions of Prohibited Conduct, occurrences of Sexual Harassment involve acts that occur without consent. This section will further define and clarify consent, force, coercion, and incapacitation as it relates to Prohibited Conduct under this policy.

Effective Consent

Consent is an active, conscious, voluntary, and freely-given decision by each participant to engage in mutually agreed-upon sexual activity. Consent must exist from the start to the finish of each form of sexual contact. Consent consists of mutually understandable words and/or actions that indicate a willingness to engage freely in sexual activity. Consent can never be effectively gained by force, threats, coercion, or by taking advantage of the incapacitated state of another individual. A lack of physical resistance or a lack of verbal refusal does not indicate that the person is providing consent. Consent may not be assumed or inferred based upon silence, passivity, lack of resistance, or lack of active response.

Any party may withdraw their consent for the sexual activity at any time during the sexual activity. Withdrawal of consent may be demonstrated in a variety of ways through words or actions that indicate a desire to end the sexual activity. Once consent is withdrawn, sexual activity must cease immediately. Recognizing the dynamic nature of sexual activity, individuals choosing to engage in sexual activity must evaluate consent in an ongoing manner and communicate clearly throughout the states of sexual activity. Consent to one form of sexual contact does not constitute consent to all forms of sexual contact. Consent to sexual activity with one person does not constitute consent to activity with any other person. Each participant in a sexual encounter must consent to each form of sexual contact with each participant. Additionally, individuals with a previous or current intimate relationship to each other do not automatically give initial or continual consent to sexual activity. The mere fact that there has been prior intimacy or sexual activity does not, by itself, imply consent to future acts.

There are times when a person may give consent but the consent may not be considered effective. An individual who is under force, threat of force, coerced, or incapacitated is considered unable to provide effective consent. These situations are outlined in the next sections.

Force and Coercion

Force is the use or threat of physical violence, intimidation, or coercion in order to overcome another individual’s freedom to choose whether or not to participate in sexual activity. For the use of force to be demonstrated, there is no requirement that an individual resist the sexual advance or request, however, resistance will be viewed as a clear demonstration of non-consent.

Coercion is the use of unreasonable pressure that compels another individual to initiate or continue sexual activity against their will. Coercion can include a range of behaviors, including physical/emotional force, intimidation, manipulation, implied threats, misuse of authority, or blackmail which places a person in fear of immediate harm or physical injury that causes them to engage in undesired sexual activity. Continuing to pressure an individual who has made it clear that they do not want to engage in sexual activity or go beyond a certain point of sexual interaction may be considered coercive. When evaluating coercive behavior, factors such as the frequency, duration, location (in regard to potential isolation of the recipient of the unwanted sexual contact), and intensity of coercive behaviors will be considered.


Incapacitation is a state where an individual is unable to make an informed decision to engage in sexual activity because they lack conscious knowledge of the nature of the act (an ability to understand the who, what, when, where, why, or how of the sexual interaction). An individual who is incapacitated is unable to provide effective consent. An individual who knows or who should have reasonably known under the circumstances that the individual(s) they are attempting to or have engaged in sexual activity with violates this policy if the behavior falls within the elements found in the Prohibited Conduct section of this policy. Behavior that may occur outside of the elements of Prohibited Conduct may be addressed by other College policies and procedures.

Incapacitation is defined as the inability, temporarily or permanently, to give consent because the individual is mentally and/or physically unable to make informed, reasonable judgements. An individual is incapacitated, and therefore unable to provide effective consent, if they are asleep, unconscious, or otherwise unaware that sexual activity is occurring.

Incapacitation may result from the use of alcohol and/or drugs. Incapacitation is a state beyond drunkenness or intoxication. Consumption of alcohol or other drugs alone is insufficient to establish incapacitation. The impact of alcohol and drugs varies from person to person, however, warning signs that a person may be approaching incapacitation include slurred speech, vomiting, diminished coordination, erratic behavior, combativeness, loss of consciousness, or emotional volatility. Evaluating incapacitation requires an assessment of how the consumption of alcohol and/or drugs affects an individual’s decision-making ability, awareness of consequences, ability to make informed judgments, and/or capacity to appreciate the nature of the act(s).

Evaluating incapacitation also requires an assessment of whether a person should have been aware of the other individual’s (or individuals’) incapacitation based on objectively and reasonable apparent indications of impairment when viewed from the perspective of a reasonable sober person. If there is any doubt as to the level or extent of the other individual’s intoxication or impairment, the safest course of action is to forgo or cease any sexual contact or activity. Use of alcohol or drugs is never an excuse for a person to commit Sexual Harassment (inclusive of all forms of sexual assault, dating violence, domestic violence, and stalking under this policy) and does not diminish a person’s responsibility to obtain informed, freely-given, and effective consent.


Jefferson College strongly encourages the prompt reporting of any incident of sexual or gender-based discrimination or harassment to the College. Because behavior that violates the  Jefferson College Title IX Sexual Harassment Policy and Grievance Process may also be a violation of law, any individual who has been subjected to sexual assault or harassment is also encouraged to consider criminal or civil legal options. An individual may also file a complaint with the U.S. Department of Education’s Office for Civil Rights, the Equal Employment Opportunity Commission and/or the Missouri Human Rights Commission. 

Any person who is aware of or who has experienced any form of Sexual Harassment may make a report at any time, within or outside College business hours, to the Title IX Coordinator. Reports may be made by the person who experienced the unwanted contact but may be made by any person including third parties, students, staff, faculty, parents, or community members. These reports may be made in person, verbally, by phone, in writing through mail or electronic mail, through the College’s Maxient reporting portal (found in MyJeffco or at, or any other manner that delivers the information to the Title IX Coordinator at any time.

Upon receipt of information alleging a violation of Jefferson College Title IX Sexual Harassment Policy and Grievance Process, the Jefferson College Title IX Coordinator (or Deputy Title IX Coordinator) will respond promptly to the Complainant to present options for filing a formal complaint, to discuss the availability of and implementation of supportive measures designed to preserve educational and/or program access (including safety options and options for reporting to law enforcement), as well as to discuss the investigation and grievance process. The Title IX Coordinator will take the victim/Complainant’s wishes into account when presenting information and evaluating whether or not to file a formal complaint against the responding party (Respondent).

Please note, all employees of the College, unless specifically designated as a Confidential Reporting Source for Title IX, are required to report matters that fall under the Jefferson College Title IX Sexual Harassment Policy and Grievance Process to the Title IX Coordinator or to a Deputy Title IX Coordinator.  Jefferson College’s Confidential Reporting Source is the licensed mental health therapist contracted to provide counseling services for the student body (office located on the second floor of the Student Center, or by calling 636.481.3215 to make an appointment) or medical provider(s) at the Mercy Health on campus clinic located in Viking Woods.

Jefferson College’s Title IX Coordinator and Deputy Title IX Coordinators are listed below:

Title IX Coordinator

Dr. Kim Harvey-Manus

Vice President of Student Services and Title IX Coordinator

Physical mailing address: 1000 Viking Drive, Student Center, Hillsboro, MO 63050

Office location: Student Center, 2nd floor, Room 205

Phone/Email: 636.481.3200/

Deputy Title IX Coordinators

Tasha Welsh

Director of Human Resources

Office location: Administrative Building

Phone/Email: 636.481.3157/

Michael J. Booker, Ph.D,

Associate Dean of Humanities

Office Location: Arts & Sciences (ASI) 110B

Phone/Email: 636.481.3312/

Kristine Bogue

Behavioral Concerns and Student Conduct Coordinator/
Title IX Investigator

Office location: Student Center, 2nd floor, Room 209

Phone/Email: 636.481.3262/

Privacy and Confidentiality in Reporting Prohibited Conduct

Jefferson College will keep confidential the identity of any individual who has made a report or complaint of sex discrimination, including any individuals who has made a report or filed a formal complaint of Sexual Harassment, any Complainant, any individual who has been reported to be the perpetrator of sex discrimination, any Respondent, and any witness, except as may be permitted by:

  • the FERPA (Family Educational Rights and Privacy Act) statute or FERPA regulations;
  • requirements of law; or
  • to carry out the purposes of the regulations of Title IX, including the investigation, hearing, or judicial proceeding arising as a result of allegations of sex discrimination or Sexual Harassment.
  • In cases where a formal complaint has been filed, disclosures of identities are necessary in order to provide the proper notice as required under federal regulations. However, in all cases the disclosure of personally identifiable information will be conducted with the utmost attention to the privacy of the individuals involved.

The Intersection of Title IX and The Clery Act

In order to comply with the federal law known as the Clery Act, the College is required to collect and report specific statistical information related to incidents of sexual assault, domestic violence, dating violence, and stalking that take place on College owned or controlled properties or at College-sponsored programs or events. This information is provided to the College’s Clery Compliance Coordinator for assessment for inclusion in daily crime statistics, timely warning reports, and for potential inclusion in the College’s Annual Safety and Security Report.The information contained in Clery reports tracks the number of Clery-reportable offenses and does not include the names or identifying information about the person(s) involved in the report. The College may share non-identifying information about reports received in aggregate form. 


A two page brochure about how Jefferson College addresses sexual misconduct can also be accessed here.

Supportive Measures are non-disciplinary, non-punitive measures put in place to assist any party impacted by Sexual Harassment in order to restore or preserve their equal access to their educational program, educational activity, or employment. Supportive measures are provided free of cost and can be used by any person involved in a report of Sexual Harassment regardless of whether or not a formal complaint is filed. Supportive Measures can remain in place regardless of the outcome of a Grievance Process and are available to students and employees throughout their time at the College. 

Jefferson College Supportive Measures

COMTREA on campus mental health services for students: Contact 636.481.3209 to schedule an appointment.

Personal Assistance Services for full time employees:

Jefferson College Police Department: Safety escorts may be provided as well as support for overall safety concerns. Contact 636.481.3500 or 911 in an emergency.

Academic Success Center: Located on the first floor of the Technology Center on the Hillsboro campus, staff in the ASC can assist students with tutoring, test preparation, and writing skills. ASC also has resources at the Arnold/Imperial locations, and via online services.

Student Financial Services: Located on the first floor of the Student Center, staff in Student Financial Services can assist a student with questions or concerns related to their financial aid package.

Disability Support Services: Located on the first floor of the Technology Center, staff in DSS can assist students who may wish to learn more about disability accommodations on campus.

Residential Life accommodations (when applicable): This may include a room or apartment change, space permitting.

Reciprocal No Contact Orders: Either party may request a No Contact Order at any point in the process or in the absence of a formal complaint. No Contact Orders are reciprocal, non-punitive administrative orders from the school designed to preserve all parties' access to educational and employment opportunities.

Change of Class Schedule or other academic arrangements: Either party may request or be assigned a class schedule change as available. Other academic accommodations may be implemented in conjunction with the Title IX Coordinator and Instructional staff/faculty.

Change of Working environment: In conjunction with Human Resources and the Title IX Coordinator, employees (including student workers) may receive supportive measures within the working environment in order to maximize safety and minimize disruption.

Mercy Clinic on campus to address health needs: Contact 636.543.2290

Supportive Measures on campus can be implemented in conjunction with or in the absence of a formal complaint, and are available to any impacted party, including Complainants, Respondents, Witnesses, or other third-parties. For more information on support at Jefferson College, please visit: or


Community Resources – the Title IX Coordinator may refer a person to any of these community resources in order to provide additional support as needed.

Behavioral Health Response Hotline: BHR provides confidential telephone counseling to people in mental health crises as well as mobile outreach services, community referral services and critical incident stress management (CISM). BHR’s crisis hotline and mobile outreach services are provided free of charge to the public by paid professional staff who have master’s degrees in their respective behavioral science disciplines. 1.800.811.4760

The Trevor Project: National organization providing crisis intervention, resources and suicide prevention services to LGBTQ young people ages 13-24.  866.488.7386 (24/7)

Trans Lifeline Hotline: 877.565.8860 A grassroots hotline and microgrants non-profit organization offering direct emotional and financial support to trans people in crisis - for the trans community, by the trans community.

Domestic Violence Shelter and support in Jefferson County: A Safe Place, COMTREA

Sexual Assault and Interpersonal Violence Supportive Services: Safe Connections
Hotline at 314.531.2003,

Child Abuse Hotline online reporting and other resource options for victims and families related to child abuse:

Jefferson County Health Department at 636.797.3737,

To obtain a forensic sexual assault examination (often referred to as a "rape kit") go to the Emergency Room of local hospitals such as Mercy South, Mercy Jefferson, Missouri Baptist, BJC, or Saint Louis University Hospital.

Legal Services of Eastern Missouri: LSEM provides high-quality civil legal assistance for low-income people. Legal services are most frequently provided in areas relating to domestic violence and other family law issues, children, education, health, housing and homelessness, public benefits, elder law, immigration, and consumer matters. 4232 Forest Park Avenue St. Louis, MO 63108; 314.534.4200 1.800.444.0514.

Obtaining Orders of Protection in Jefferson County: Any victim of stalking or an adult abused by a present or former spouse, adult family or household member, or adult who is or has been in a continuing social, romantic or intimate relationship, or a person with whom the victim has a child may file for an ex parte order of protection.  No filing fee, court costs or bond is required to file, nor do you need a lawyer to file.  The petition must be filed in the county where the petitioner resides, where the alleged abuse occurred or where the Respondent may be served. Jefferson County Courthouse, 300 Main Street Hillsboro, MO 63050; 636.797.5443.

Jefferson County Sheriff's Office: The sheriff’s department will apprehend criminals and investigate crimes in Jefferson County.  The sheriff’s department has also designated a victim services coordinator, who can be reached at 636-797-5017  The Sheriff's office is located at 400 1st Street, Hillsboro, MO 63050.  636.797.5000.

For questions or concerns related to Immigration: United States Citizenship and Immigration Services department offers assistance for those seeking citizenship, green cards, and working in the United States.

Any person desiring more information on College or Community Resources in the aftermath of any form of sexual assault or sexual harassment is strongly encouraged to contact the Title IX Coordinator at 636.481.3258 and/or make a report to local law enforcement.


A formal complaint may be filed in one of two ways:

  1. The Complainant can choose to initiate the formal complaint and grievance process by, in writing or via electronic message, indicating to the Title IX Coordinator their desire to have the College investigate their report. The complaint must be signed (either physically or digitally, or in some other way that makes it clear that the Complainant is the person filing the complaint) and sent to the Title IX Coordinator. The Complainant must be the person who experienced the Sexual Harassment and who is participating in or attempting to participate in the College’s education activity or programs. A person who is not affiliated with the College is unable to initiate a formal complaint under these procedures.
  2. Where a Complainant may decline to file a formal complaint, the Title IX Coordinator will assess the known circumstances of the situation and determine whether or not a formal complaint will be filed by the Title IX Coordinator themselves. In this situation, the Title IX Coordinator will contact the Complainant to discuss supportive measures, the filing of a formal complaint, and the grievance process. The Title IX Coordinator will take the Complainant’s wishes into account as well as the need for campus safety when evaluating whether or not to file a complaint. In the event that the Title IX Coordinator initiates the formal complaint and grievance process, the Title IX Coordinator does not become the Complainant but is still responsible for the coordination of an equitable and thorough grievance process.

Jefferson College seeks to remove barriers to individuals reporting Sexual Harassment. An individual who reports or who is involved in a report of Sexual Harassment will not be subject to disciplinary action for their own personal consumption of alcohol or drugs at or near the time of the incident, provided that such violations did not and do not place the physical health or safety of another person at risk. Jefferson College may initiate an educational discussion or pursue other educational or therapeutic methods regarding alcohol or other drugs for those individuals.

Jefferson College will investigate allegations in a formal complaint, unless the College is prohibited from doing so by Title IX regulations or other laws.


Please note, the content on this site is a summary.  Please see the Jefferson College Title IX Sexual Harassment Policy and Grievance Process for a detailed description of the grievance process. 

The investigation conducted under the Jefferson College Title IX Sexual Harassment Policy and Grievance Process is designed to provide a fair, thorough, and impartial gathering of facts. At all times the burden of proof and gathering evidence or information sufficient to reach a determination of responsibility (based on the preponderance of the evidence standard) is upon the College and not on the parties themselves.  Hearings shall be conducted live and may be conducted with parties in remote locations or virtually, provided that the parties are able to see and hear each other simultaneously.  


No person may intimidate, threaten, coerce, or discriminate against any individual for the purpose of interfering with any right or privilege under Title IX or the Jefferson College Title IX Sexual Harassment Policy and Grievance Process. Retaliation includes, but is not limited to, words or actions that intimidate, threaten, coerce, or discriminate against someone whole or in part because an individual has:

  • Made a report or filed a complaint alleging misconduct under this policy;
  • Provided information, statements, or other information for an investigation;
  • Assisted in or participated in any part of the grievance or hearing process;
  • Refused to participate in any part of an investigation, grievance, or hearing process; or who has
  • Exercised other rights under this policy.

Note: The exercise of First Amendment/free speech rights is not considered Retaliation under the Jefferson College Title IX Sexual Harassment Policy and Grievance Process. Additionally, a determination of responsibility (whether that be for a finding of responsible or not responsible) does not indicate on its own that the other party (or parties) made materially false or bad faith statements.

Jefferson College expects all members of our community to participate in the process of creating a safe, welcoming, and respectful environment on campus and in campus programs and activities. In particular, the College expects that Jefferson College community members will be active bystanders and will take reasonable and safe actions to prevent or stop an act of Sexual Harassment should they witness one. Taking action could include, but is not limited to, direct intervention when it is safe for one to do so, enlisting the assistance of friends or other persons to assist, and/or contacting or seeking support from person(s) in authority. Community members who choose to take these actions will be supported by the College and protected from retaliation as well as from policy violations that may have been present during the situation, such as underage alcohol use or drug use.


The Title IX Coordinator and Deputy Coordinators are available to answer any additional questions you may have or to hear your comments on the Title IX process. 

Additionally, the following information may be helpful:


 What if Bears Killed One in Five People?  Watch the video to find out!


Can two-minutes and a smart phone change the way you think about consent?
This video, originally created as part of Campus Clarity's award-winning online training program Think About It, teaches the concept of consent by considering a series of realistic scenarios in an approachable manner.


It's On Us Pledge

To RECOGNIZE that non-consensual sex is sexual assault.
To IDENTIFY situations in which sexual assault may occur.
To INTERVENE in situations where consent has not or cannot be given.
To CREATE an environment in which sexual assault is unacceptable and survivors are supported

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