February 28, 2025
From: David Spring, Director, Washington Parents Network
To: U.S. Department of Education, Office for Civil Rights
Lyndon Baines Johnson Department of Education Bldg.
400 Maryland Avenue, SW, Washington, DC 20202-1100
RE: Title IX Complaint against Washington Superintendent, Chris Reykdal and Washington Governor, Bob Ferguson
Sent via email
To Whom It May Concern:
This is a Title IX Civil Rights complaint filed under the U.S. Department of Education’s Office for Civil Rights (“OCR”) Complaint Resolution Process against Washington State Superintendent, Chris Reykdal, Office of the Superintendent of Public Instruction, (OSPI), 600 Washington St SE, Olympia, WA 98504 and Washington State Governor, Bob Ferguson, Office of the Governor, PO Box 40002, Olympia, WA 98504-0002.
The Washington Parents Network is an association of over 2,600 parents in Washington state. We are dedicated to protecting the rights of parents and their children. Our complaint includes this 4 page cover letter, a 74 page summary of their volations – divided into 15 sections – and Declarations from 11 of our members outlining how their rights and the rights of their children and students under Title IX were violated by policies advanced directly or indirectly by Chris Reykdal and Bob Ferguson, who we contend have been violating the plain meaning of Title IX for more than 8 years.
To be clear, in this complaint, we have only summarized a few of the worst violations of Title IX that have been inflicted on our children, parents, teachers and school board members during the past 8 years. We contend that all of our members and all of their children – and in fact, all of the children in Washington state - have been harmed by Reykdal and Ferguson’s failure to comply with Title IX. As we explain below, even the recent Title IX complaint, filed on February 17, 2025 against the Tumwater School District, should more properly be directed against Chris Reykdal and Bob Ferguson, since the school district was forced to comply with Washington State Policy 3211 – under the threat by Chris Reykdal that the school district would lose state funding if they failed to comply.
While Reykdal’s threats to withhold funding from school district was contrary to Article IX, Sections 1 and 2 of the Washington State Constitution, his threats were allowed to be made - and subsequent forced violations of Title IX - were allowed to be made by then Attorney General and now Governor Bob Ferguson. Thus, the two of them have acted in concert to commit thousands of ongoing violations of Title IX.