![handle is hein.journals/vlrtoleg64 and id is 1 raw text is:
LEFT IN THE RAIN WITHOUT AN UMBRELLA: HOW DOE v. BROWN
UNIVERSITY LEAVES NONSTUDENTS UNSHELTERED BY FEDERAL
TITLE IX PROTECTIONS
EMILY S. BLEY*
Rain does not fall on one roof alone.1
I. THE PERFECT STORM: AN INTRODUCTION TO TITLE IX
Title IX of the Education Amendments Act of 1972 (Title IX) has been a
lightning rod for controversy since it first emerged decades ago as a means for
women to enter the world of college sports.2 The Act has significantly evolved
from its origins in the athletic realm; today, Title IX is arguably better known for
the protection it provides to sexual assault survivors than the equality it
establishes in university locker rooms.3 Though instances of sexual misconduct
are no more frequent in our contemporary society than at the time of Title IX's
passage, the issue of sexual misconduct has certainly achieved greater visibility
in recent years.4 Public reports of alleged sexual harassment and the filing of
formal legal complaints against offenders, have been central topics of discussion
* J.D. Candidate, 2020, Villanova University Charles Widger School of Law; B.A., 2017,
Saint Louis University. This Note is dedicated to my parents, Joseph and Susan, as well as my
sisters, Ellen, Erica, and Elyse, who have given me so much love and support over the years. I
would also like to thank the staff of the Villanova Law Review forproviding thoughtful feedback
throughout the writing and publication of this note.
1. Cameroonian proverb, WISE OLD SAYINGS, http://www.wiseoldsayings.comlrain-
quotes/ [https://penna.cc/89JP-JS9D] (last visited Oct. 4, 2018).
2. See Grayson Sang Walker, The Evolution and Limits of Title LX Doctrine on Peer
SexualAssault, 45 HARV. C.R.-C.L. L. REV. 95, 99 (2010) (explaining Title IX is best known
for role in expanding women's sports at high school and collegiate levels).
3. See generally Know Your Rights: Sexual Harassment and Sexual Assault Under Title
IX, AM. ASS'N U. WOMEN, https://www.aauw.org/what-we-do/legal-resources/know-your-
rights-on-campus/campus-sexual-assault/ [https://perna.cc/A2HF-M6H5] (last visited Oct. 4,
2018) (answering frequently asked questions about Title IX rights); Title IX, END RAPE ON
CAMPUS, http://endrapeoncampus.org/title-ix/ [https://perna.cc/Y3LJ-WVTQ] (last visited
Oct. 4, 2018) (listing resources available to students under Title IX); Title 1K, RAPE ABUSE AND
INCEST NAT'L NETWORK, https://www.rainn.org/articles/title-ix (last visited Oct. 4, 2018)
(explaining available enforcement mechanisms under Title IX); Title IX and Sexual Assault,
AM. CIVIL LIBERTIES UNION, https://www.aclu.org/know-your-rights/title-ix-and-sexual-
assault (last visited Oct. 4, 2018) (describing student rights under Title IX after sexual assault
occurs).
4. See Ann Jones, Sexual Harassment Has Not Changed So Auch Since the 1970s, THE
NATION (Dec. 12, 2017), https://www.thenation.com/article/sexual-harassment-has-not-
changed-so-much-since-the-1970s/ [https://perna.cc/EQK3-ZU4S] (detailing author's own
experiences with sexual harassment throughout the 1960s and 70s, as well as multiple stories
of sexual misconduct affecting other women). Jones noted that during the recent #MeToo
movement, some commentators grossly underestimated the universality of sexual harassment
toward women in the past few decades. See id. In Jones's words, None of this is new, though
we tend to act as if it were ... for instance, I heard three young women radio reporters explain
that women back in the 1970s or 1980s accepted 'unwanted male attention' in the office and in
life 'because that's just the way things were.' See id.](ViewImageLocal?handle=hein.journals/vlrtoleg64&div=1&collection=&method=preview&ext=.png&size=3)
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