After Supreme Court Title IX arguments, Great Valley School District faces federal investigation

The day after the Supreme Court heard arguments in two landmark cases on the issue of boys competing in girls sports and gaining access to their private spaces, the U.S. Department of Education’s Office for Civil Rights (OCR) announced investigations into 18 educational institutions across the country due to Title IX violations.

Great Valley School District (GVSD), located in Chester County, is one of the entities under investigation as a result of a complaint filed by a local resident and former school board member, Bruce Chambers.

On the same day OCR announced the investigations, it contacted Chambers via email about the complaint he filed on March 25, 2025.

“OCR is opening an investigation to examine whether the District has a policy or practice of allowing male students to participate in athletic programs designated for female students and whether the District has a policy or practice of allowing male students to use intimate facilities, including locker rooms, designated for female students in violation of Title IX and its implementing regulation,” wrote the Compliance Team Leader.

The letter said, “OCR’s initiation of an investigation is not itself evidence of a violation of federal civil rights laws and regulations. During the investigation, OCR is neutral; OCR will collect and analyze the evidence it needs in order to make a decision about the complaint.”

Chamber’s complaint alleges GVSD’s policy 103.3, “Transgender and Gender Expansive Students,” violates Title IX and the President’s Executive Orders issued last year.

“The Great Valley School District violates Title IX by enforcing Policy 103.3 that will ‘ensure the safety, comfort, and healthy development of transgender and gender expansive students,’” wrote Chambers in his complaint. “Policy 103.3 provides these students with the ability to feel safe and comfortable using sex-segregated intimate restroom and locker room facilities as well as participating in physical education, sports and other school activities consistent with their ‘gender identity.’  However, this policy is in violation of Title IX as it denies students whose ‘gender identity’ is the same as their sex the ability to feel safe and comfortable in the use of the sex-segregated common restrooms, locker rooms, and in their participation in sports, physical education classes, and other school activities.”

Prior to filing the complaint last March, Chambers contacted the GVSD board three different times asking them to rescind the policy. He warned that if they failed to do so, he would contact OCR.

According to Chambers, the board responded, “At this time, our legal counsel has advised that our current policies are consistent with established legal precedent. We will continue to monitor any developments related to this issue to ensure that we remain compliant with the law.”

GVSD did not respond to a request for comment about the investigation.

Chambers, who previously served on the board from 2009 to 2012 and was Board President from 2010 through 2011, is pleased that OCR is finally investigating.

“Early last year, I read about the OCR investigations into several school districts in Northern Virginia. The policies in those districts which resulted in the discrimination claims were the same or similar to the policies at GVSD,” said Chambers. “As a result, I sent the information to the GVSD Board, but they did nothing. I contacted them further, seeking a recission of the policies in Policy 103.3, but they did not respond. I then informed them that if they did not take action, that I would file a Civil Rights Complaint against GVSD. The response I received was that they were following the advice of their attorneys and no changes would be made. At that point I filed the complaint with the Office of Civil Rights of the US Dept of Education.”

The policy referenced by Chambers includes the following statements:

“Students shall be allowed to use the restroom that corresponds to the gender identity they consistently assert at school. No student will be required to use a restroom that conflicts with their consistently asserted gender identity.”

“The District will provide a transgender or gender expansive student with access to the locker room that corresponds to the gender identity they consistently assert at school.”

“Transgender and gender expansive students shall be permitted to participate in athletic programs/opportunities and physical education classes in a manner that is consistent with their consistently asserted gender identity.”

Based on an analysis conducted by Broad + Liberty last summer, GVSD is not the only local school district with a specific “Transgender and Gender Expansive Students” policy. Over 40 percent of public school districts in Chester, Montgomery, Delaware, Bucks, and Philadelphia Counties have a policy similar to Great Valley that clearly articulates that students can use the bathroom that aligns with their gender identity. An additional 21 percent of local districts recognize gender identity as a protection under their Title IX Nondiscrimination policy. Only 37 percent of local districts do not include “gender identity” in their Title IX policy; however, that does necessarily mean that students cannot use the bathroom of their choosing.

While GVSD is currently the only district in the state under an OCR investigation based on its Title IX policies and practices, it seems only a matter of time before more districts are impacted. 63 percent of local districts are in direct violation of both Title IX and the President’s Executive Orders.

Based on its press release, OCR is committed to fully investigating Title IX violations similar to the allegations in Chamber’s complaint.

“In the same week that the Supreme Court hears oral arguments on the future of Title IX, OCR is aggressively pursuing allegations of discrimination against women and girls by entities which reportedly allow males to compete in women’s sports. Time and again, the Trump Administration has made its position clear: violations of women’s rights, dignity, and fairness are unacceptable,” said Assistant Secretary for Civil Rights Kimberly Richey. “We will leave no stone unturned in these investigations to uphold women’s right to equal access in education programs—a fight that started over half a century ago and is far from finished.”

Beth Ann Rosica resides in West Chester, has a Ph.D. in Education, and has dedicated her career to advocating on behalf of at-risk children and families. She covers education issues for Broad + Liberty. Contact her at [email protected].