"A complainant does not need a personal connection to a school. Indeed, petitioners don’t even have to live in the same state, and legal standing is not a factor. They do not even need to identify themselves. They are not required to try to resolve their problems at the local level before notifying the feds – though many do. Consequently, the office’s operations sometimes function as a nationwide anonymous sounding board rather than a source of last resort, a place where anyone can make a federal case out of any slight, real or perceived.

Although OCR probes include many serious allegations, the system’s structure means the number of cases can be inflated through duplication, serial filers and ambitious bureaucrats.

"The numbers aren’t really what they first appear,” said Teresa R. Manning, policy director at the National Association of Scholars, a conservative counterweight in higher education to the liberal American Association of University Professors. "A lot of this was by design. If they didn’t have complaints, they wouldn’t have jobs, so a lot of federal bureaucrats and campus officers want any grievance to become a federal case.”

"Skepticism is legitimate, because by declaring something is ‘systemic,’ then rather than resolve that one issue they can turn it into a federal case,”

"Also, totals were swollen by one unnamed individual. For example, in 2022 when OCR received 9,948 complaints of Title IX violations, nearly three out of four – 7,339 – came from this person. That same individual slipped a bit the following year, accounting for only 69% of the 5,590 complaints. RCI asked several people familiar with Office of Civil Rights work who this person might be, but none said they know.

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