A federal court dismissed the United States government's lawsuit against Harvard University alleging violations of Title VI related to anti-Semitism. The amended complaint, filed on March 20, 2026, primarily focused on incidents occurring during the 2023-2024 academic year. The court noted that these allegations had been extensively addressed in prior cases such as Kestenbaum v. Harvard.

Only three incidents were alleged to have occurred after the 2023-2024 school year, specifically in March 2025, nearly a full year before the lawsuit was filed. The court found these incidents too isolated and episodic to support a plausible inference of ongoing institutional noncompliance with Title VI at Harvard.

The government argued alternatively that it had stated a viable claim for damages related to the 2023-2024 violations. However, the controlling statute permits action only if the government has notified the appropriate parties of noncompliance and determined that voluntary compliance cannot be secured. The government provided such notice on June 30, 2025, but the amended complaint lacked factual allegations of noncompliance occurring after that date.

The court also emphasized the government's duty under the Administrative Procedure Act to act reasonably and found no rational basis for the government's determination that compliance could not be secured voluntarily. It clarified that the focus is on compliance with Title VI, not adherence to specific government demands.

Responding to the government's claim that this ruling makes it "virtually impossible for the United States to win a Title VI suit because a reasonable defendant would cease its indifference as soon as the United States threatens to withhold funding," the court stated that this misunderstands the purpose of enforcement actions under § 2000d-1.

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