id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
inlawrev-28855	Lambert Hillman, Regina	Boosted by Bostock: LGBTQ Title IX Protections	2025	94	.pdf	application/pdf	50375	2676	56	A decade before the Bostock decision, the U.S. Department of Education (DOE) interpreted Title IX’s protective reach to include sex discrimination protections based on gender identity.17 However, changing presidential administrations led to withdrawn guidance and confusing and conflicting agency interpretations of Title IX’s application to LGBTQ students.18 During Obama’s presidency, the DOE engaged in several important efforts to extend Title IX’s sex discrimination protections to LGBTQ students, including releasing federal agency guidance to federal fund recipients subject to Title IX.19 However, Trump’s subsequent presidency and the shift in political party in control of the White House negatively impacted the progress of LGBTQ rights, including Trump’s withdrawal of Obama-era DOE Title IX guidance and the denial of Title IX sex discrimination protections to LGBTQ students.20 The release of the Bostock decision during the last months of Trump’s presidency did not immediately impact his DOE’s interpretation of Title IX; instead, his administration worked to limit Bostock’s broad holding.21 In contrast, seven months after the Bostock decision, Biden was sworn in as ————————————————————————————— 14. [Vol. 58:503 516 During Obama’s presidency, the DOE made clear that Title IX’s sex discrimination protections extended to LGBTQ students, and it remained constant until Obama left office in January 2017.71 All told, Obama’s administration made substantial efforts to recognize the needs of LGBTQ students and provide Title IX sex discrimination protections to ALL students.	cache/inlawrev-28855.pdf	txt/inlawrev-28855.txt