Project 2025 Targets Civil Rights in Schools: Title IX, Discipline, and Special Education Rollbacks
Project 2025 calls for redefining 'sex' as biological in Title IX, ending disparate impact enforcement under Title VI, and rescinding the Equity in IDEA regulation. The Trump administration has implemented the Title IX changes via executive order and rulemaking, but has not yet rescinded the Equity in IDEA rule — a critical distinction the piece now carries.
Project 2025's education chapter is not a quiet governance reform. It is a blueprint to dismantle the federal civil rights infrastructure that protects students in public schools. The most immediate harm is the redefinition of 'sex' in Title IX as exclusively biological sex, which strips protections for LGBTQ+ students and survivors of sexual assault. The Trump administration has already signed executive orders on January 20, 2025, directing the Department of Education to rescind the Biden Title IX rule and drop ongoing investigations into gender-identity discrimination. This reverts schools to the 2020 Trump rule that narrowed what qualifies as misconduct and required live cross-examinations — barriers that discourage reporting.
Project 2025 also targets two decades of civil rights enforcement under Title VI and the Individuals with Disabilities Education Act (IDEA). It calls for ending Title VI investigations based on disparate impact — the legal standard that allows the Office for Civil Rights to hold schools accountable when race-neutral policies produce racially inequitable discipline outcomes. The Trump administration has moved to align with this by rescinding the 2014 Obama-era discipline guidance, though as of available reports, the Department has not signaled intent to rescind the Equity in IDEA regulation (which requires states to consider race in special education identification and discipline). This is a critical distinction: the Executive Order on DEI rescinds some prior guidance but does not specifically target IDEA. Students with disabilities, particularly Black students, remain at risk of being pushed out of special education services if the regulation is rescinded. The fight is ongoing to protect these provisions.
The humanitarian alternative
Congress should immediately pass the Equality Act to codify protections for LGBTQ+ students in federal law. The Department of Education should issue a new regulation explicitly incorporating disparate impact into Title VI enforcement, making it unreachable by future administrations. The Equity in IDEA regulation should be strengthened, not rescinded, with additional funding for early intervening services rather than raiding special education budgets.
Original source — excerpted
project2025 Project 2025 ch. 12: Department of Energy (pp 367-369)"— 334 — Mandate for Leadership: The Conservative Promise l The next Administration should abandon this change redefining “sex” to mean “sexual orientation and gender identity” in Title IX immediately across all departments. l On its first day in office, the next Administration should signal its intent to enter the rulemaking process to restore the Trump Administration’ s Title IX regulation, with the additional insistence that “sex” is properly understood as a fixed biological fact. Official notice-and-comment should be posted immediately. l At the same time, the political appointees in the Office for Civil Rights should begin a full review of all Title IX investigations that were conducted on the understanding that “sex” referred to gender identity and/or sexual orientation. l All ongoing investigations should be dropped, and all school districts affected should be given notice that they are free to drop any policy changes pursued under pressure from the Biden Administration. l The OCR Assistant Secretary should prepare a report of OCR’ s actions for the new Secretary of Education, who should—by speech or letter— publicize the nature of the overreach engaged in …"