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District 128 reviews Title IX audit; administration to reassign locker space and audit booster funds
Summary
A law-firm audit found District 128's overall athletic participation roughly proportional by gender but recommended targeted fixes for locker-room access and for reviewing private booster funding at Libertyville High School. The administration outlined an action plan and a timeline for further analysis and changes before the 2025–26 school year.
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District 128 school leaders and outside auditors presented the results of a Title IX audit and an associated action plan at the Jan. 26 Board of Education meeting, and administrators said they will begin immediate, limited changes while conducting a longer review of locker-room facilities and private booster funding.
The audit, conducted by school-law firm CREA Bochek, was presented by Stephanie Jones, a partner at the firm. Jones said auditors used “OCR’s compliance manual” as the basis for their review and that the audit examined three areas: athletic participation, equal treatment of participants, and non‑athletic activities.
The audit found participation rates between girls and boys were largely proportional over the most recent three school years and said disparities generally “fall within what we would consider a discrepancy interval.” But auditors and administrators identified two priority issues for follow-up: (1) locker-room accessibility and usability at both high schools and (2) the effect of private donations and multiple booster clubs on equitable opportunities, particularly at Libertyville High School.
Parent speakers and booster representatives described perceived disparities. Laura Weber, a parent, told the board the audit “confirms issues that parents raised” and pressed for faster action. Jeanette Hyam, president of Friends Wildcat Softball, said LHS has 31 athletic teams and “at least 10 different booster clubs” and reported that her softball booster account held $8,722.13. Dan Niklitsch, an LHS alumnus and volunteer coach, urged the board not to “alienate the groups that support our students” if changes are made.
In response, district staff outlined an action plan the administration said will combine immediate fixes with longer-term planning. The district said it will: - Implement near-term privacy and locker-room assignment changes this spring, including reassigning the building-attached locker room at Libertyville High School to girls’ soccer and girls’ lacrosse and moving boys lacrosse near the main gym; - Conduct a facilities assessment at both high schools to evaluate showering, toilet, storage, and overall usability, with buildings-and-grounds participation; - Gather financial summaries and records from Libertyville booster clubs in February and complete a financial review to understand how private donations affect program resources; - Establish a biannual Title IX review committee, continue annual Title IX training for administrators/coaches, and run periodic student-athlete perception surveys; and - Present a further update and recommendation to the board by the end of September 2025 about possible changes to booster‑funding structures for the 2025–26 school year.
Stephanie Jones described the action plan timeframe as “appropriate and relatively ambitious,” saying physical-plant changes can take time and that financial analysis will be necessary to measure any gaps. Jones also noted fine-arts programming at the district showed strong participation and funding and did not produce substantive equity findings.
Public commenters urged different approaches. Parent Marnie Navarro cautioned the board about relying on administrative guidance alone, saying “law is not established by any means” in reference to ongoing federal changes. Several boosters and coaches emphasized transparency of booster finances and urged solutions that preserve parental volunteering and fundraising.
Board members asked questions about timing and budget contingencies. District staff said small facility fixes (for example, privacy stalls) could be funded and completed quickly; larger renovations would require scope definition and budget planning and therefore might be placed in a capital plan for summer work or later fiscal-year budgeting depending on findings.
The board did not take a formal vote on the audit itself at the Jan. 26 meeting. Administrators characterized the presentation as the start of an implementation and monitoring process, not a single final decision. The district will return with additional financial and facilities analysis and recommendations before the start of the 2025–26 school year.
Why this matters: The audit and action plan address gender-equity requirements under Title IX and Office for Civil Rights guidance, and they could change how locker rooms are assigned, how booster donations are tracked or distributed, and how the district budgets for athletic facilities and support services.

