Title IX Complaint Template

United States District Court for the [District] of [State]

[Plaintiff Name],
Plaintiff,

v.
[Educational Institution],
Defendant.

Case No. [To be assigned]

COMPLAINT

Plaintiff alleges:

I. Jurisdiction and Venue

1. This action arises under Title IX of the Education Amendments of 1972, 20 U.S.C. § 1681 et seq.
2. Jurisdiction is proper pursuant to 28 U.S.C. §§ 1331 and 1343.
3. Venue is proper in this District pursuant to 28 U.S.C. § 1391 because the events occurred and the Defendant resides in this District.

II. Parties

4. Plaintiff [Name] is a [student/former student/employee] of [Institution] residing in [City, State].
5. Defendant [Institution] is a recipient of federal financial assistance and subject to Title IX.

III. Facts

6. Plaintiff experienced [sexual harassment/assault/gender discrimination] on [Date(s)].
7. Plaintiff reported the incident(s) to [Title IX office/administrators] on [Date].
8. Defendant failed to respond promptly and effectively, including [failure to investigate, inadequate measures, retaliation].
9. Defendant’s deliberate indifference created or permitted a hostile educational environment.
10. Plaintiff suffered damages including emotional distress, educational setbacks, and loss of opportunities.

IV. Causes of Action

Count I – Title IX Sex Discrimination

11. Defendant’s deliberate indifference to known acts of sex discrimination deprived Plaintiff of access to educational benefits.

Count II – Title IX Retaliation (if applicable)

12. Defendant retaliated against Plaintiff for reporting discrimination by [disciplinary actions, denial of resources, harassment].

Count III – State Law Claims (optional)

13. [Negligence, breach of contract, equal protection via § 1983, etc.]

V. Damages

14. Plaintiff seeks compensatory damages for emotional distress, medical expenses, and educational losses.
15. Plaintiff seeks injunctive relief requiring Defendant to adopt and enforce compliant policies, training, and monitoring.
16. Plaintiff seeks attorneys’ fees and costs under 42 U.S.C. § 1988 and applicable law.

VI. Jury Demand

17. Plaintiff demands a trial by jury on all triable issues.

VII. Prayer for Relief

WHEREFORE, Plaintiff requests judgment against Defendant for:
- Compensatory damages;
- Injunctive and declaratory relief;
- Attorneys’ fees, costs, and expenses; and
- Such other relief as the Court deems just and proper.

Respectfully submitted,

[Law Firm Name]

By: ________
[Attorney Name] (Bar No. [Number])
[Address]
[Phone]
[Email]

Date: [Date]