Legal Services

The Board of Education’s Policy and Rule regarding pupil non-discrimination can be found by searching for the policies on BoardDocs.

Board Policy 411 - Equal Educational Opportunities (to view the policy, please visit BoardDocs and search for the policy)
Board Rule 411-Rule(1) - Equal Educational Opportunities Complaint Procedures (to view the policy, please visit BoardDocs and search for the policy)

In addition, each year the District provides proper notice of its Non-Discrimination Complaint procedures in the Pre-K and Elementary Student Expectation Books, Middle and High School Student Expectation Books and Employee Handbooks

Any student (or the parent/guardian of a student) who believes he/she has been discriminated against by another student, District employee or other person should immediately report the incident. Reports may be directed to a building administrator or to the District’s designated employee for receiving complaints regarding discrimination.  

Reports of discrimination are encouraged to be made in writing; however, verbal reports will be accepted. Reports may also be made confidentially.

All reports should include, to the best of the complainant’s ability, specific information regarding the discriminatory action(s) or inaction(s), the basis (e.g., age, race, sexual orientation, etc.) for the action(s) or inaction(s), the alleged offender(s) and any witnesses.

Links to the District’s report form are found below. The form can be printed and filled out by hand, or completed online.

Fill out Form Online (Llene el Reporte en línea)

Following receipt of the complaint, as required by law, the District will conduct an adequate, reliable, impartial investigation of the alleged incident(s) in accordance with legal requirements. Any investigation shall be conducted by a person who the District determines is not identified within the complaint as a party who is allegedly responsible for, or who was directly involved in, the underlying issue or incident. 

Where necessary, the District may implement interim responsive measures, pending the outcome of the investigation, that are intended to address any person’s safety and well-being, prevent continuation or escalation of a conflict, or prevent disruption to a student’s education or within any school environment. 

If the parent/guardian of either the alleged target or alleged perpetrator disagrees with the District’s conclusions, they may appeal the negative determination to the State Superintendent of Public Instruction. In order to work collaboratively with the parent/guardian to seek a timely and amicable resolution, the District requests an appeal first to the Deputy Superintendent, and subsequently to the Superintendent of Schools and Learning, prior to submitting an appeal to the State Superintendent of Public Instruction. 

The complaint must be filed within 300 days of the date the last alleged unlawful action occurred. If the complaint is filed after 300 days of the date of the last alleged unlawful action, it will be returned to the complainant and not processed.

The District’s designated employee for receiving complaints regarding discrimination under Wisconsin’s pupil non-discrimination law is:

Abby Tilkens
Discrimination & Title IX Coordinator
Green Bay Area Public School District
200 South Broadway
Green Bay, WI  54303
(920) 448-2284
Email Abby Tilkens

Wisconsin law also requires each school district to submit an annual compliance report the Department of Public Instruction and periodically conduct a self-evaluation of the status of pupil non-discrimination and equality of educational opportunity. The annual compliance report provides the number and type of discrimination complaints received by the district during the school year. The self-evaluation is a written report, prepared at least once every five years on a scheduled determined by the State Superintendent, that addresses: 1) the methods, practices, curriculum and materials used in counseling; 2) participation trends in athletic, extracurricular and recreational activities; and 3) trends and patterns in awarding scholarships and other forms of recognition and achievement. The District’s most recent self-evaluation reports are available as noted below:

Self-Evaluation, 9/11/23

• Wisconsin Department of Public Instruction Pupil Non-Discrimination Program
• Commitment to Education Brochure: English | Spanish | Hmong | Somali 

The District’s sexual harassment policy and rule can be found by searching for the policies on BoardDocs or by contacting the District’s Title IX Coordinator.

•  Board Policy 411.11, Sexual Harassment and Sexual Violence (to view the policy, please visit BoardDocs and search for the policy)
•  Board Rule 411.11, Sexual Harassment and Sexual Violence Complaint Procedures (to view the policy, please visit BoardDocs and search for the policy)

Any person (including a person who is not claiming to have been personally harmed/victimized by the alleged discrimination) may report a concern or allegation regarding prohibited sex discrimination (including sexual harassment) to the District.  Such reports may be submitted as follows:

1. In person, by mail, by telephone, by electronic mail, or through an online portal or webpage provided for this purpose (where available) to the District’s Title IX Coordinator using the contact information for the District’s Title IX Coordinator as listed above. 
2. In person reports should be made when the Title IX Coordinator is reasonably available during regular working hours.  Reports submitted by telephone, mail, electronic mail, or through an online portal or webpage (where available) may be made at any time. 
3. By reporting the alleged sexual harassment to any District employee who shall be responsible for forwarding the complaint to the District’s Title IX Coordinator for review and action as necessary. 
4. By any other means that results in the Title IX Coordinator actually receiving the person’s verbal or written report.

Alternatively, complaints can be made by completing the Discrimination & Harassment Complaint Form:

Fill out Form Online (Llene el Reporte en línea)

As required by the federal Title IX regulations, the District has established a formal grievance process for investigating and resolving “formal complaints” of “sexual harassment,” as those terms are defined in the regulations.

An individual who is alleged to be the victim of conduct that could constitute sexual harassment under the federal Title IX regulations (i.e., a Title IX “complainant”), or a parent or guardian who has a legal right to act on behalf of such an individual, may file a formal complaint of sexual harassment.  No Title IX complainant is obligated to file a formal complaint, but a qualifying formal complaint is necessary for the District to start an investigation using the District’s formal Title IX grievance process. 

Complainants are expected to file formal complaints of sexual harassment with a District Title IX Coordinator by submitting a document or electronic submission in person, by U.S. mail, or by electronic mail, using the contact information specified above.  In addition, the District will accept submissions of a formal complaint through an online portal or webpage provided for this purpose (where available) so long as the electronic submission contains the complainant’s physical or digital signature or otherwise indicates that the complainant is the person filing the formal complaint.

Additional requirements for formal complaints of Title IX sexual harassment, including a description of the required content for a formal complaint, are set forth in Board of Education Policy 411.11. 

District Response to Reports and Complaints of Sex Discrimination and to Formal Complaints of Sexual Harassment under Title IX – The District has established grievance procedures through which the District structures its response to reports that allege unlawful discrimination on the basis of sex in any education program or activity of the District.  Those procedures are set forth in Rule 411-Rule (1)  and Rule 511, as published on the District’s website.  The purpose of such procedures is to provide for the prompt and equitable resolution of any report or complaint of alleged sex discrimination, excluding formal complaints of sexual harassment under Title IX (which are subject to a different process). 

Any time that the District has actual knowledge of sexual harassment or allegations of sexual harassment that could constitute a violation of Title IX, the District has obligations to respond to such knowledge in a manner that is not deliberately indifferent and in a manner that treats the alleged victim(s) of sexual harassment and the alleged perpetrator(s) of sexual harassment equitably. Such a response includes, but is not limited to, offering supportive measures to a complainant and investigating and resolving any formal complaint that presents allegations of Title IX sexual harassment using the formal grievance process that the District has adopted for such formal complaints.  District procedures for responding to alleged sexual harassment under Title IX, including the formal grievance process, are set forth in Rule 411.11, as published on the District’s website. 

Training for the District's Title IX team is an ongoing effort.  Training includes in-house and training with Title IX experts.  Please see below for training our Title IX team has received.

Title IX Coordinator

The District's Title IX Coordinator has received the following training from the Association of Title IX Administrators (ATIXA) located on the following site:  ATIXA Training Materials:

• 2021 K-12 Title IX Coordinator & Administrator Advanced
• 2020 Title IX Regulations Implementation Training and Certification Course
• 2020 Title IX Regulations Overview - Commitment Beyond Compliance for K-12 School Districts
• SPOO or Not SPOO?  That is the Question Webinar
• R3 Webinar - Ten Things to Know About the New Title IX Regulations

The Title IX Coordinator also received the following training:

•  Title IX Bootcamp for K-12 (With Updates):  Four Session Series (EducationAdminWebAdvisors)
  • Session 1 - Title IX Procedural Requirements
  • Session 2 - Investigating Sexual Harassment
  • Session 3 - Finalizing the Investigation/Making Decisions
  • Session 4 - Other Issues Related to Title IX
• Title IX and Biden Administration:  Predicting Changes for K-12 Schools
• Wisconsin Association of School Boards
• Facilitators of Informal Resolutions - Part 1
• Facilitators of Informal Resolutions - Part 2
• CESA 7 - Legal Network - Investigation Training (September 2020)

Title IX Investigator

The District's Title IX Investigator has received the following training from the Association of Title IX Administrators (ATIXA) located on the following site:  ATIXA Training Materials:

• K-12 Title IX Coordinator One: Foundations
• 2022 ATIXA Annual Conference
• Centering Credibility on the Front Lines of Title IX
• K-12 Intake
• Is Your Policy Shop In order? How K-12 Districts can Tame Their Policy Beast
• Pregnant and Parenting Students - Addressing Advanced Compliance Issues
• Title IX Jurisdictional Issues
• When Title IX and the IDEA Intersect
• Civil Rights Approach to Comprehensively Preventing 
• Sexual Harassment and Gender-Based Violence in Education
• 2021 K-12 Investigation Report Writing
• 2021 K-12 Investigator Level One

The District Investigator also received the following training: 

• CESA 7 - Legal Network - Investigation Training (September 2020) 
• Wisconsin Association of School Boards and Boardman & Clark, LLP Title IX Training

Title IX Decision-Makers

• Wisconsin Association of School Boards and Boardman & Clark, LLP Title IX Training
• Board of Education Training - August 9, 2021

Title IX Appeal Decision Makers

• Wisconsin Association of School Boards and Boardman & Clark, LLP Title IX Training

District Administrators

• 2020 Title IX New Regulations Overview for Administrators

• Wisconsin Department of Public Instruction Pupil Nondiscrimination Program
• United States Department of Education Office for Civil Rights