The Duality of Title VI in Trump’s Funding War Against Northwestern
By: Reed Zimmerman
Edited by: Jerry Benedict, Michael Stewart
On April 8, 2025, the Trump administration froze $790 million in federal funding—the majority of which is research grants—for Northwestern University due to alleged violations of civil rights law surrounding antisemitism. [1]
Specifically, the Trump administration claims Northwestern is in violation of Title VI of the Civil Rights Act of 1964, which states: “No person in the United States shall, on the grounds of race, color, or national origin, be excluded from participation in, denied the benefits, or be subjected to discrimination under any program… receiving Federal financial assistance.” [2] For Jewish students and faculty, protections from antisemitism through Title VI come through discrimination on the basis of historical ideologies defining Jews as a race, more so than a religious group, and national origin based on shared ancestry. [3] In turn, the federal government can rescind its funding for a “program” that is antisemitic and thus in violation of the Civil Rights Act. [4]
In the eyes of the current administration, Northwestern violated Title VI by failing to address antisemitism that arose in the wake of resumed conflict between Israel and Palestine. [5] A large majority of such failure is tied to the pro-Palestine encampment that occurred on Deering Meadow in the spring of 2024. During the duration of the encampment, some of its participants directly harassed Jewish students and promoted antisemitic narratives. While Northwestern did end the encampment peacefully through a settlement deal–referred to as the Deering Meadow Agreement, minimal disciplinary action against encampment participants promoting antisemitism was undertaken by the University. [6]
The primary leader of the Title VI investigations of Northwestern is the Department of Education’s Office on Civil Rights (OCR). In February 2025, acting on a Trump executive order regarding antisemitism at institutions of higher education, the OCR formally launched investigations into five schools regarding their management of antisemitic harassment, one of which was Northwestern. [7]
The following month, the OCR underscored the possibility of repercussions for continued violations of Title VI–namely through loss of funding. In a letter to 60 schools undergoing Title VI investigations for antisemitism, the OCR warned schools that their federal funding was at risk. [8] In the letter, Secretary of Education Linda McMahon wrote that taxpayer-supported federal funding to these universities “is a privilege and it is contingent on…adherence to federal antidiscrimination law.” [9]
Working alongside the OCR in the Northwestern Title VI investigations is the Department of Justice. A few weeks after the OCR’s announcement, the Department of Justice’s Federal Task Force to Combat Antisemitism announced Northwestern would be one of ten institutions it would visit based on allegations that NU “may have failed to protect Jewish students and faculty members from unlawful discrimination.” [10] In these investigations, the task force highlighted that “remedial actions” for universities may be deployed if their management of antisemitism was deemed to be in violation of federal civil rights laws. [11]
The findings of Title VI violations by these agency investigations form the evidential basis for Northwestern’s federal government funding freeze. However, the provisions of Title VI also call into question the legality of the Trump administration freezing of Northwestern’s funding.
Within §2000d–1 of Title VI, there exist clear stipulations that federal departments and agencies must adhere to and fulfill in the process of “suspending, terminating, or refusing to grant or continue Federal financial assistance” based on the program’s violations of the statute. [12]
One requirement that must be fulfilled before any funding changes are effected is that “the responsible Department official has advised the applicant or recipient of his failure to comply and has determined that compliance cannot be secured by voluntary means.” [13] Additionally, the program in question must be given a hearing to determine if their alleged Title VI violations hold sufficient legal standing. [14]
But for Northwestern, this did not occur. In a statement given in the immediate wake of the funding freeze, Northwestern asserted the school was given no such notice and that Northwestern had been “fully cooperating” in the ongoing Title VI investigations. [15] If this was the case, the federal government would clearly not have been in compliance with Title VI.
Similarly, regarding Northwestern’s compliance being unsecured through “voluntary means,” there also appears to be disregard for this stipulation by the federal government. In the summer of 2024, Northwestern announced a multitude of changes to school policy, enacting mandatory antisemitism training for students, expanding the campus police force, and creating new policies surrounding on-campus demonstration. [16] All of these efforts to address and mitigate antisemitism arguably show Northwestern’s efforts to fully comply with Title VI voluntarily. Lastly, Northwestern was given no opportunity to defend itself or its funding in court, as seen in the lack of any court hearing on the matter.
The damning implications of the governmental disregard for Northwestern’s policy changes are established in the next section: §2000d–2. Here, Title VI enshrines that alleged acts of noncompliance and disregard for the stipulations in §2000d–1 by federal agencies and departments can be taken to court by impacted programs. [17] Consequently, if the government is deemed in violation of §2000d–1 following judicial review, the ruling may order the program’s funding to be restored or continued, as well as potentially voiding the funding cut. While a remand is a possible ruling, that secondary investigation may also ascertain the program to be in accordance with Title VI.
Based on the federal government’s methods of freezing Northwestern’s federal funding, an argument for §2000d–1 violations by the Trump administration holds merit. In other words, Northwestern could reverse the $790 million funding freeze by suing the Trump administration and thus weaponizing the very same law responsible for the freeze [18].
However, Northwestern, unlike some universities faced with similar funding freezes, has chosen not to take legal action against the Trump administration over its violation of Title VI [19]. Instead, on November 28, 2025, Northwestern announced it had settled with the Trump administration. Stating that the “cost of a legal fight was too high and the risks too grave,” the University opted to pay $75 million to the Trump administration over the course of three years and roll back the Deering Meadow Agreement. In exchange, all Title VI investigations were closed, funding withheld over Title VI violations was restored, and the University retains control over its hiring and curriculum [20].
Although Northwestern may have chosen a settlement deal, there are still many institutions of higher education whose funds are being withheld for Title VI violations at the time of writing this. In turn, the question of legality over Trump’s funding freezes enacted through the Civil Rights Act, and thus the tension between Title VI violations and §2000d’s connotations, remains.
Notes:
Samantha Waldenberg et al., “Trump Administration Freezes $1 Billion in Funding for Cornell University, $790 Million for Northwestern University,” CNN, 9 April 2025, www.cnn.com/2025/04/09/us/cornell-northwestern-federal-funding-freeze.
Selina Wang and Arthur Jones II, “Trump Administration Halts $1 Billion for Cornell, $790 for Northwestern, Officials Say,” ABC News, 9 April 2025, abcnews.go.com/US/trump-administration-halts-1-billion-cornell-790-million/story?id=120653323.
Benjamin Eidelson and Deborah Hellman, "Antisemitism, Anti-Zionism, and Title VI: A Guide for the Perplexed,” Harvard Law Review 139, no.1 (November 2025), harvardlawreview.org/forum/vol-139/antisemitism-anti-zionism-and-title-vi-a-guide-for-the-perplexed/.
Civil Rights Act of 1964, Title VI, 42 U.S.C. §§ 2000d–2000d-7 (1964).
Michael Bender and Sheryl Gay Stolberg, “Trump Administration Freezes $1 Billion for Cornell and $790 Million for Northwestern, Officials Say,” New York Times, 8 April 2025, www.nytimes.com/2025/04/08/us/politics/cornell-northwestern-university-funds- trump.html.
Nell Salzman, “Federal Warning to Northwestern: Protect Jewish Students or Face Funding Cuts,” Chicago Tribune, 11 March 2025, www.chicagotribune.com/2025/03/10/education-department-warns-northwestern-anti-semitism/.
U.S. Department of Education, “U.S. Department of Education Probes Causes of Antisemitism at Five Universities,” 3 February 2025, www.ed.gov/about/news/press-release/us-department-of-education-probes-cases-of-antisemitism-five-universities.
“U.S. Department of Education’s Office for Civil Rights Sends Letters to 60 Universities Under Investigation for Antisemitic Discrimination and Harassment,” U.S. Department of Education, 10 March 2025, www.ed.gov/about/news/press-release/us-department-of-educations-office-civil-rights-sends-letters-60-universities-under-investigation-antisemitic-discrimination-and-harassment
“U.S. Department of Education’s Office for Civil Rights Sends Letters to 60 Universities Under Investigation for Antisemitic Discrimination and Harassment,” U.S. Department of Education.
“Federal Task Force to Combat Antisemitism Announces Visits to 10 College Campuses that Experienced Incidents of Antisemitism,” U.S. Department of Justice Office of Public Affairs, 28 February 2025, www.justice.gov/opa/pr/federal-task-force-combat-antisemitism-announces-visits-10-college-campuses-experienced.
“Federal Task Force to Combat Antisemitism Announces Visits to 10 College Campuses that Experienced Incidents of Antisemitism,” U.S. Department of Justice Office of Public Affairs.
Civil Rights Act of 1964.
Civil Rights Act of 1964.
Civil Rights Act of 1964.
Bender and Gay Stolberg, “Trump Administration Freezes $1 Billion for Cornell and $790 Million for Northwestern.”
Northwestern University, “Progress Report on Northwestern University Efforts to Combat Antisemitism,” 5 August 2025, www.northwestern.edu/leadership-notes/statements/2025/progress-report-on-northwestern-university-efforts-to-combat-antisemitism.html.
Civil Rights Act of 1964.
Civil Rights Act of 1964.
David Weisenfeld, “The Legal Debate Over Trump’s Title VI Campus Crackdown,” Higher Ed Dive, 30 October 2025, www.highereddive.com/news/title-vi-investigations-trump-administration/804155/.
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