On May 15, Middlebury’s general counsel, Hannah Ross, signed a Resolution Agreement with the U.S. Department of Education Office for Civil Rights (OCR), agreeing to remove or relabel 10 women’s scholarships, including BOLD, a scholarship for women in STEM, a scholarship for Japanese University Women, a Mental Health Women’s Scholarship, a Women in Research scholarship, and more.
In 2016, Middlebury welcomed the first cohort of BOLD scholars. The BOLD Women’s Leadership network is a national initiative providing scholarships, mentorships, and leadership training to empower women from underrepresented communities in higher education. The BOLD scholarship is funded by the Helen Gurley Brown Foundation and provides up to $25,000 per year for women in their junior and senior years.
The last cohort of Middlebury’s BOLD scholars graduated in February 2026, marking the end of the program at Middlebury. On Feb 15, Middlebury updated the BOLD section of their website, stating that the Foundation is moving their support elsewhere.
“Over the years, the Foundation has intentionally brought new schools into the Network while concluding their partnerships with others, with the goal of expanding the program’s reach to serve those with greatest need. This means that Middlebury will wind down its BOLD Women’s Leadership Network program, supporting its cohorts through 2026 as planned,” read the statement, which was later taken down from Middlebury’s website.
While Middlebury’s public explanation framed the ending of BOLD in Middlebury as the funder’s decision, documents from the U.S. Department of Education’s Office for Civil Rights (OCR) present a more complicated narrative.
The OCR received three separate Title IX complaints alleging that Middlebury’s promotion of BOLD and other women-only scholarships or clubs is discrimination based on sex, which is a violation of Title IX.
“The Title regulations at 34 C.F.R. §106.37(a) prohibit recipients [of Federal financial assistance] from discriminating on the basis of sex in the provision of financial assistance,” a letter from the OCR to the college states.
“In 2026, Middlebury was notified by the Office for Civil Rights about several unrelated complaints about information appearing on various Middlebury websites, including information about other third-party scholarships. We agreed with the Office to remove outdated or third-party information from certain websites, and we clarified our ongoing compliance with the civil rights law known as Title IX for scholarships, student activities, etc.,” Ross wrote in an email to the Campus.
The OCR originally notified Middlebury of a complaint about the BOLD Scholars Program in 2021.
“Middlebury provided information about the scholarship funding from the private foundation, as well as Middlebury’s longstanding commitment to meet 100% of a student’s demonstrated financial need, during 2022, and did not hear further from the Office for Civil Rights,” Hannah Ross, Middlebury general counsel wrote in an email to The Campus.
“Middlebury has reviewed its other programs and student groups and for those with names/titles that may lead a student to understand that membership and participation is limited or restricted based on sex, Middlebury has ensured that their constitutions and webpage descriptions for the programs or groups prominently include language that indicates that participation is open to any student regardless of sex,” reads Middlebury’s resolution agreement with OCR.
Laurie Essig, professor of Gender, Sexuality, and Feminist Studies voiced her disagreement with the OCR requirements. “The administration is using threats without legal basis, usually withdrawing funding, in order to gain control over universities, whether it’s shutting down certain departments, whether it’s attacking particular professors, or in this case, whether it’s erasing certain sorts of scholarships that help historically underrepresented groups, including women,” said Essig in an interview with the Campus.
On May 18, the OCR’s Chief Attorney, Anamaria Loya, signed a closing letter, stating that Middlebury is in compliance on the BOLD issue.
“In 2026, Middlebury was notified by the Office for Civil Rights about several unrelated complaints about information appearing on various Middlebury websites, including information about other third-party scholarships. We agreed with the Office to remove outdated or third-party information from certain websites, and we clarified our ongoing compliance with the civil rights law known as Title IX for scholarships, student activities, etc.,” Loya wrote.
“I think that the assumption is, ‘if we do this, they’ll leave us alone.’ That is what most experts call anticipatory compliance. So when you accede to demands that actually have no legal basis, in the hopes that you will then be left alone,” Professor Essig said.
While the origin of complaints to the OCR is not known to the public, this chain of events seems to fit a wider pattern of institutions scaling back on women-specific scholarships to avoid scrutiny.
“Rensselaer Polytechnic Institute will stop awarding a women’s scholarship this fall. And Duke University recently opened its Alice M. Baldwin Scholars Program — named for the first dean of its Woman's College — to all undergraduates, instead of just women. Major employers, including Palantir Technologies Inc. and Alphabet Inc.’s Google, have also dropped scholarships and initiatives aimed at increasing female representation,” writes Simone Foxman for Bloomberg.
“So how are you gonna create opportunities for people to gain knowledge that they’ve historically been excluded from? I think it’s gonna involve more the needs-based [scholarships] but it’s possible that we’re going to lose that,” Professor Essig concluded.
