Resident Assistants (RAs) and peer leaders are some of the first students that incoming freshmen meet when they come to campus. They join new student week groups, lead CarlTalks (including one about consent) and are there to orient and welcome students. They are set up to be role models and mentors. They receive training on a variety of issues, including consent, in preparation for New Student Week. There is no guarantee, however, that these peer leaders haven’t committed Title IX violations themselves.

Four of the twelve campus offices with peer leaders explicitly list mentorship as one of the main roles of that position. In the offices where peer leaders are mentors, they are often paired one on one with incoming freshmen to provide advice and develop relationships to help students find community. RAs, who are not one of the groups listed as mentors, are placed on each floor of dorms to provide community and advice to the floor. They are often advertised as a resource for students to turn to if they need support. Peer leaders have varying degrees of access to student information: RAs, for example, have access to a list of the dorm room information for every student in their area. Areas typically include a few dorm buildings.

Title IX, the federal statute guaranteeing equality in universities, is the basis for university policies against sexual misconduct. In this article, Title IX violations refer to violations of Carleton’s Policy on Sexual Misconduct, which includes sexual assault, rape, domestic or dating violence, stalking or sexual exploitation. After misconduct is reported, students who have been assaulted have the option of pursuing a formal complaint which leads to an investigation. Depending on the results of the investigation, the students then proceed to a hearing. In the hearing, according to the Policy on Sexual Misconduct, “if the Decision-Makers determine that the Respondent has committed Sexual Harassment, they are also responsible for determining appropriate sanctions.”

Title IX designates certain people as mandated reporters of sexual misconduct. That group includes RAs. Carleton, in its policy on sexual misconduct and in its requirements for peer leaders, designates all peer leaders as mandated reporters. 

The peer leader program is run by a centralized Peer Leader committee, which provides resources and a shared application process, but the offices themselves hire students. The manual distributed by the committee to the offices, to be later edited and distributed to peer leaders, describes peer leaders’ status as mandated reporters: “Carleton’s Policy Against Sexual Misconduct requires Peer Leaders, faculty, and staff who learn of possible policy violations to report that information either directly to the Title IX Coordinator or the Title IX Deputy for Faculty and Staff or through a Community Concern Form.”

When offices hire peer leaders, however, they have no access to student records, including Title IX records, according to a variety of sources in the college administration.

Amy Sillanpa, one of the co-chairs of the Peer Leader Committee and the director of community standards, was unable to tell the Carletonian whether offices hiring peer leaders would know whether a student had committed Title IX violations. 

When asked whether offices in the peer leader program, which is overseen by the Peer Leader Committee that she co-chairs, would know whether students applying to be Peer Leaders had committed Title IX violations, Sillanpa was unsure. “I’m not directly involved with the hiring,” she said. “As co-chair, Tanya Hartwig and I work to coordinate the Peer Leader committee meetings to make sure we’re staying on top of the committee’s responsibilities.”

Tanya Hartwig, the other co-chair of the Peer Leader Committee and the assistant director of Residential Life, confirmed that offices do not have access to Title IX records when hiring peer leaders, including RAs. RAs can be fired for a variety of reasons, including engaging in underage drinking or unauthorized access to spaces. According to Hartwig, Title IX violations are not a reason an RA would be fired.

“The results of a Title IX formal process could impact where somebody is able to live, in which case we might have to take some things into consideration about where a person is at,” said Hartwig. “I don’t know that a result of the Title IX process would result in someone losing their position.”

Hartwig brought up that trust is an important aspect of the RA program. “RAs do put in the most training hours, and it does [make a difference] in a way of ‘how do we build trust with students so that they feel comfortable coming to us and then, how do we teach how to assure folks that when they come with this very private information in a very vulnerable moment, that that’s safe.’”

When asked whether the possibility of having RAs with a history of Title IX violations poses an issue to building that trust, Hartwig said, “our hope is that when we build our RA teams, that we are able to find a variety of folks with a variety of experiences and backgrounds, and that a student living in a particular area of campus, even if they don’t feel comfortable going to their RA, that there’s another Res Life person around that they would feel comfortable going to, whether that be another RA or their area director. Or that their RA has provided and shared other resources on campus to hopefully get them pointed in the right direction of another resource. So even if a student doesn’t feel like their RA is the person that they want to go to when they’re in need of some support, that they hopefully have other options of folks that they can go to and find trust in.”

The Family Educational Rights and Privacy Act (FERPA) was cited as “only the staff members who work with the Title IX process have access to the Title IX case records for students who go through an actual hearing process,” making it difficult to see how the offices would know. The reason for this, she said, is that “for all policy violations we have to follow FERPA, so we need to consider the confidentiality rights of the students who go through the Title IX or student conduct process.”

FERPA dictates that educational records, which include grades and disciplinary information, among other things, cannot be shared without a student’s consent.

RAs have a GPA minimum they must meet to continue being RAs. To ensure that all RAs meet this requirement, Hartwig said that “we ask the registrar’s office. We give them a list of students, and we ask ‘do these students meet this requirement.’” 

The Registrar’s Office was unable to confirm this. “We haven’t really gotten that request that we can recall,” said Records and Registration Assistant Charlie Saini, a Registrar’s Office employee. But, he said, “if it fell under legitimate educational interest, that is something we could verify….without giving them specifics.”

He clarified that they “ would have to determine if that interest was legitimate/valid and if the requested information falls within that policy” before giving any office information about students’ records.

A common theme among members of the administration was that FERPA protects students’ disciplinary records, making it difficult to check Title IX violations when hiring them as peer leaders. When asked whether it would be possible for an office to view information in a student’s record, Saini said, “students could…sign a waiver saying they allow their records to be viewed by this person.”

Interim Title IX Coordinator Kari Hohn discussed the possibility of barring people from being peer leaders based on Title IX violations: “If someone does go through the [Title IX] process and is found responsible, they’re given sanctions…That varies, some cases would end in suspension or expulsions. Some cases, even when someone is found responsible and their behavior wasn’t egregious enough on the scale of misconduct to be suspended or expelled, they might have sanctions that relate to their life on campus.” 

Those sanctions are determined on a case by case basis. Depending on the circumstances, they can include that the student is “not allowed to live on campus or they’re not allowed to participate in co-curricular activities or they’re not allowed to participate in student leadership opportunities or employment opportunities,” Hohn said.

Hohn was uncertain how often Carleton applies this sanction because she started working at Carleton in July, but said, “in my experience as a coordinator at other institutions, I’ve certainly seen… as a sanction that the respondent is not allowed to hold leadership positions at the institution.”

According to Hohn, sanctions are determined by the Community Board on Sexual Misconduct, a board formed of a combination of faculty and staff members and students.

Amelia Asfaw ’25, one of the members of the committee, told the Carletonian that the list of sanctions they follow does not mention the peer leader program. It has options relating to residential or disciplinary probation, but she believed neither of those affects the peer leader program. “I’ve gone to all of these [committee] meetings since freshman year and no one has brought that up, as far as I know,” said Asfaw. “I’ve never thought about [whether Title IX violations should affect peer leader hiring] actually, it would probably be a good thing though.”

A peer leader reported a student for violating Title IX. The person went through a formal Title IX hearing, in which the student was found to have assaulted them. Some time later, the person who was found responsible was hired as a peer leader. 

The reporter was upset to learn that the student was able to become a peer leader. It also led them to question the value of reporting Title IX violations. “They went through the entire process and had meetings with SMPR, and what does it do? There were no consequences.

“It’s a mockery to [the peer leader program],” they said. “Peer leaders, by the very nature of how they’re set up, deal with some of the most vulnerable people on campus. If you want to have people be leaders among their peers, you’re letting the worst among us do that?”

The Carletonian is aware of at least one peer leader that has committed Title IX violations. There is no way to estimate how many others there are.

Between interviewing members of the college administration and publication, the Carletonian received an update from Sillanpa. “This topic was brought up this week at the Peer Leader Committee and we plan to have a thorough discussion and review of what we do, or need to do, for student conduct checks for Peer Leaders,” she said.

Dean of Students Carolyn Livingston was unavailable for comment.