PART 2: A System Under Scrutiny - Questions About IPC’s Role in Title IX Failures Across Districts

This is Part 2 of an ongoing series examining the structure and operations of the Inland Personnel Council (IPC). Part 1 explains the structure and controversies surrounding IPC.

A System Built to Respond—But Failing at Intake

At the heart of every Title IX case is a simple legal requirement: when a school receives notice of sexual harassment or abuse, it must respond promptly, investigate thoroughly, and do so without bias.

That obligation is not optional. It is the foundation of both student protection and legal accountability.

But recent records—and formal enforcement actions by the California Attorney General—show what happens when that system breaks down. And increasingly, those breakdowns are occurring at the earliest stage: when reports are first received.

These failures raise broader questions about the role of the Inland Personnel Council (IPC), a little-understood two-county structure spanning more than 60 school districts and agencies across Riverside and San Bernardino counties. Publicly described as a collaborative Joint Powers arrangement, IPC coordinates training, investigations, and personnel practices—often through the same law firm that provides legal defense to those same districts.

Despite its broad reach, IPC operates with limited public visibility. There are no publicly available bylaws, no regular public meetings, and little clarity about how decisions are made across the agencies it serves. Yet its influence is significant: it shapes how investigations are conducted, how complaints are handled, and ultimately how districts respond to allegations of misconduct.

Those questions are not theoretical—they are already reflected in how some districts are handling reports of sexual misconduct, including whether those reports are investigated at all.

In at least one district, those concerns are reflected in a decision not to investigate reported misconduct.

When Reports Are Rejected at the Door: Etiwanda School District

In an April 2026 letter, the Etiwanda School District declined to investigate reported sexual harassment—based not on the allegations themselves, but on who submitted the report.

Alicia Lyon, the Etiwanda School District Title IX Coordinator, acknowledged receiving reports of “sexual harassment” and “sex-based misconduct,” but stated the District would not proceed unless the complaint came directly from the alleged victim or a parent.

That position is not just inconsistent with best practices. It directly contradicts both federal law and the State of California’s most recent guidance.

Just days after that response, California Attorney General Rob Bonta issued a statewide legal alert reminding school districts of their obligations:

“If anyone reports that a child is sexually harassed, assaulted, or abused… the school district has a legal responsibility to” act. And even more directly: A district “must take immediate action if it receives a report… no matter what. It cannot ignore a report because you failed to ‘fill out the right form’ or ‘report to the right person.’”

Bonta’s accompanying “Know Your Rights” guidance makes the point unmistakable: students, parents, and community members have the right to report misconduct to any school employee, and once a report is made, the district must act—no matter who made the report.

Yet Etiwanda’s response imposes the exact limitation the law forbids.

Policy Says One Thing. Practice Does Another.

The District’s own Title IX notice states: “Any individual may report sex discrimination, including sexual harassment…” Its Administrative Regulation likewise requires reports to be forwarded to the Title IX Coordinator and allows the Coordinator to initiate a formal complaint—even if the alleged victim does not.

But the District’s actual response applies a different rule—one that shuts the process down at intake based solely on who submitted the report which is a fundamental misapplication of Title IX.

The law distinguishes between reporting and a formal complaint. While a “complainant” is defined as the alleged victim for procedural purposes, that definition does not limit who can report misconduct—or when a district must act. By treating the identity of the reporter as a barrier to action, the District is doing precisely what the law prohibits.

Mandated Reporters—and Vulnerable Students—Left Without Protection

The consequences of that misinterpretation of Title IX by Etiwanda are serious. It ignores the very purpose of California’s mandated reporting laws—to protect those who cannot report or are too afraid to report.

Under California’s Child Abuse and Neglect Reporting Act (CANRA), teachers and school employees are mandated reporters, legally required to report suspected abuse. Those reports are meant to trigger protective action. Under Etiwanda’s approach, those reports may not result in any investigation or protective response for students as required by law.

If a report is dismissed because it was not submitted by a victim or parent, then mandated reporting laws are effectively rendered meaningless.

Recent changes in state law reinforce this obligation. Senate Bill 848 expands mandated reporter training requirements and strengthens school responsibilities related to student safety and reporting procedures.

These updates reflect a clear legislative direction: reports of suspected misconduct must be taken seriously and acted upon. Yet, as the April 2026 letter indicates, reports were acknowledged but not treated as complaints, and “the District deems this matter to be closed.”

Where students are very young, have disabilities, or are otherwise unable to report misconduct themselves, schools have a heightened duty of care. The law depends on adults to act on their behalf. If those reports are rejected at intake, the system fails before it begins.

State Oversight Is Becoming More Common

In its enforcement action against El Monte Union High School District, the Attorney General found systemic breakdowns, including cases where the District: “failed to conduct any investigation” despite receiving detailed allegations.

According to the Attorney General, in some instances, investigations were not used to determine what happened, but rather “for the purpose of assessing the extent of the District’s civil liability in lieu of conducting a legally compliant investigation.”

The result was predictable: missing records, lost evidence, and continued harm.

In Redlands Unified School District, similar failures led to a sweeping court-enforced judgment requiring the District to receive, investigate… and resolve complaints and to track “all oral and written reports… including those submitted anonymously.”

In both cases, the State had to step in to enforce what the law already required: once a district has notice, it must act.

The Redlands–IPC Connection

The Redlands enforcement action highlights what happens when those requirements are not met.

At the time of these failures, Redlands Unified was a member of the Inland Personnel Council (IPC). Its longtime Human Resources director, Sabine Robertson-Phillips, served on the IPC Advisory Board for more than a decade according to the IPC website—even after her departure from the District under a settlement agreement, and despite Joint Powers Agreement language limiting advisory terms to two years.

In addition, the same IPC attorney who signed the 2020 IPC addendum—expanding the role of investigations within a litigation framework—also represented Redlands Unified. These overlapping roles are difficult to ignore.

They place individuals involved in a district found to have systemic Title IX failures within a broader structure that helps shape personnel practices across dozens of agencies. They also reflect a system in which the same legal and advisory framework may influence both how investigations are conducted and how they are later defended.

That dual role raises a fundamental concern.

If investigative practices are developed, guided, or reinforced within a shared structure—particularly one that is closely tied to legal defense—then failures identified in one district may not be isolated. They may instead reflect broader patterns in how complaints are received, evaluated, and documented across the system.

Whistleblowers Raise Concerns About Biased IPC Investigations

These accounts provide real-world examples of the concerns raised earlier—how investigative structures may influence not just how complaints are handled, but whether they are meaningfully investigated at all, and how those investigations—and the records they produce—may later be relied upon in appeals to school boards or scrutinized in litigation.

Two whistleblowers, Antoinette Jensen and Debra Kamm, say their experiences raise questions about how investigations are conducted—and who is overseeing the vendors responsible for conducting them.

While their situations differ, Jensen and Kamm describe a common experience: investigations they believe were not designed to determine what happened, but instead to protect institutions. They further state that concerns raised about those investigations were met with silence and, in some instances, retaliation.

Antoinette Jensen, a former teacher in the Etiwanda School District, says she was terminated after making a mandated report regarding potential sexual harassment involving her preschool students. She believes the IPC structure contributed to a biased investigation in which the focus was not on student protection, but on protecting the institution, including the districts and the two County Superintendents.

Jensen says there was secrecy surrounding the investigation. The investigator’s name and the names of the 11 witnesses reportedly interviewed, were omitted from the report. She refers to this as a “ghost report,” with no trace of the core components of the investigation and no meaningful way to challenge or dispute its findings.

According to Jensen, the same attorneys appeared in multiple, and at times conflicting, roles throughout the process, raising concerns about conflicts of interest. When Kamm later discovered the IPC structure, Jensen said it clarified what she had experienced.

“Once I saw that IPC controls all aspects of training and investigations and also represents the districts and the San Bernardino and Riverside County Superintendents, I saw all of the conflicts of interest,” she said.

Jensen also states that, while the investigator’s name does not appear in the report, she has records indicating that the investigator was Kelly Binks, the husband of Cali Binks, a candidate for San Bernardino County Superintendent of Schools. Public records reveal that Kelly Binks has recently signed a consulting contract with Etiwanda School District to continue conducting investigations.

Jensen says she identified issues that should have triggered Title IX protections, but her complaint was reframed as an administrative dispute involving a co-teacher. Law enforcement declined to intervene, describing the matter as a workplace issue. Even after explicitly referencing sexual harassment and Title IX, she says the district denied the complaint on the basis that only students or parents could file. The letter from Etiwanda's Title IX Coordinator is posted above.

“My students were 3-year-olds, some of them with disabilities and some were nonverbal,” Jensen said. “How are they supposed to report potential sexual harassment? And how can a school district ignore a mandated reporter?”

Debra Kamm describes a similar experience in a separate matter not involving Title IX. After filing a complaint against an administrator in Upland Unified School District, she was notified that an attorney who is listed as an IPC presenter, would conduct the investigation. Kamm submitted a request for recusal to the board, citing concerns about a conflict of interest, and understood that the request was under review. Instead, the investigation proceeded without a response to the recusal request and was completed without her being interviewed, without being contacted for additional information, and without interviews of the two key witnesses.

Kamm says the complaint itself was reframed in ways that did not reflect what she had reported. She later discovered, through a public records request, that at least two different versions of the investigative report existed.

“I have no idea which version of the investigation report the board was given in my appeal,” Kamm said. “One said I filed the complaint against Sherman Garnett, a school board member, when my complaint was against an administrator. How does an investigator get that wrong?”

Kamm cites concerns that the Upland Unified School Board—which includes a Deputy Attorney General—may have reviewed her appeal under the mistaken belief that her complaint was directed at a fellow board member, rather than the administrator she had identified.

This underscores a key consequence of flawed or incomplete investigations: school boards may be making decisions based on an incomplete or unreliable factual record, without meaningful oversight or verification of its accuracy.

The complaint involved an administrator’s role in contacting the Fair Political Practices Commission (FPPC), raising questions about whether she was authorized to act on behalf of the district. The matter was connected to Upland School Board member Sherman Garnett, who has been under FPPC investigation since May 2024.

When Systems Fail at Intake: State Intervention, AB 218, and the Risk of a System Under Strain

In El Monte, a district outside the IPC structure, the failures were so significant that the California Attorney General imposed a sweeping, multi-year corrective framework requiring the District to rebuild how it receives, tracks, investigates, and resolves complaints—beginning at intake. The reforms mandate centralized tracking, documentation of all reports (including oral and anonymous complaints), and ongoing oversight to ensure compliance.

These requirements reflect a critical reality: the failure was not just in outcomes, but in the process itself—specifically, how complaints were received, documented, and acted upon.

Because these reforms are not limited to current complaints. They are designed to ensure that every report is captured and preserved—creating a record that can be relied upon later. Without that record, there is no way to reconstruct what was reported, what was known, or what action was taken.

In today’s legal landscape, that absence carries significant consequences.

In 2020, California enacted AB 218, expanding the statute of limitations for childhood sexual abuse claims and reviving previously time-barred cases. Districts now face claims involving conduct that may date back decades—often with little or no contemporaneous documentation.

At the same time AB 218 was enacted, IPC’s 2020 addendum expanded the role of investigations. It formally connected investigative work to litigation by allowing investigators to later testify and by integrating investigative findings into legal defense processes. These changes blur the distinction between independent fact-finding and legal strategy, creating a structure in which the investigative process may also serve litigation objectives.

Together, these changes mark a shift: investigations are no longer just compliance tools—they play a central role in future litigation.

That shift makes failures at intake far more consequential.

When a report is dismissed at the outset, no investigation is opened, no evidence is preserved, and no factual record is created. In the post-AB 218 environment, that absence carries significant legal consequences.

Title IX requires investigations to be impartial and independent. But when the same system trains investigators, conducts investigations, and participates in legal defense, the line between neutrality and advocacy becomes difficult to maintain. Even without intentional bias, the structure itself introduces risk—because the investigation may influence not only what is found, but how the case is later defended.

That risk extends beyond the investigation itself.

School boards rely on investigative reports to make decisions in appeals and disciplinary matters. But if those reports are incomplete, filtered, or influenced by legal considerations, then boards are not seeing the full picture. A flawed investigation leads to a flawed report, and a flawed report leads to a flawed decision—one that may carry legal consequences long after the underlying events.

IPC was created as a collaborative structure to support districts. But its evolution—particularly after 2020—raises a critical concern: whether it now operates as a framework in which investigations, legal strategy, and liability management are intertwined in ways that undermine the purpose of the investigative process.

Failures Across the Process—and the Fight for Transparency and Oversight

After discovering IPC in December, Kamm brought her concerns to the San Bernardino County Board of Education (SBCBOE), citing Ted Alejandre’s role as an Executive Officer of IPC and raising questions about the lack of transparency surrounding its operations. She also alerted the District Attorneys in both San Bernardino and Riverside counties, citing concerns about IPC’s failure to hold open meetings.

Despite months of public comments from Kamm, Jensen, and other members of the public—and the filing of multiple Brown Act complaints specific to IPC—Board President Gwen Dowdy-Rodgers and County Superintendent Ted Alejandre have not placed IPC on the agenda. Under Board Policy 113, their authority is limited to determining where items appear on the agenda; it does not authorize the exclusion of topics altogether—particularly Brown Act complaints, which require a response by the full legislative body within 30 days. The continued omission of IPC from board agendas raises concerns about the appearance of a potential conflict of interest, particularly given Alejandre’s role as an Executive Officer of IPC and Dowdy-Rodgers’ role in approving budgets that include IPC-related expenditures.

The Riverside County Office of Education has also denied having key records relating to IPC, including bylaws, copies of district Joint Powers Agreements, and audit information. It has further denied requests for records relating to the IPC Advisory Committee, asserting they are “protected as confidential by and through the Brown Act.”

Individual districts have likewise continued to deny that they are members of IPC, despite public records indicating ongoing participation. For example, Cali Binks, Superintendent of Yucaipa-Calimesa Joint Unified School District, has denied having any Joint Powers Agreement with IPC, yet the IPC website and other records—including financial records from the San Bernardino County Superintendent of Schools—indicate that the district has been a member of IPC for more than a decade. Jensen has also filed Brown Act complaints with the district that, according to her, were never acknowledged. She expressed concern that this may present a potential conflict of interest, given that Cali Binks—who is running for San Bernardino County Superintendent—serves in a leadership role within the district while her husband, Kelly Binks, is paid with public funds as a consultant conducting investigations.

These contradictions and denials raise broader concerns regarding transparency and potential conflicts of interest. They also extend beyond governance and into how investigations are conducted.

The examples reviewed reveal failures at critical stages of the same process—whether in how complaints are received, investigated, or allowed to proceed—and how those failures carry forward, shaping the record, the response, and the outcome of future claims.

• In El Monte, a district outside the IPC structure, the State was forced to rebuild the system after failures to properly receive, document, and investigate complaints.

  
  

• In Redlands—an IPC member district—sweeping compliance measures were imposed to ensure that reports are consistently received, tracked, and investigated. The district remains under state monitoring for several more years.

  
  

• In Etiwanda, also an IPC-participating district, recent records suggest a more immediate breakdown, where reports may be stopped at intake before the investigative process begins at all, based on who files the complaint.

The question now is whether the IPC structure—and how investigations are conducted under the leadership of district administrators and County Superintendents—is contributing to the failures that continue to surface.

When an investigation is not conducted—or when the record is incomplete or unreliable—there is no clear account of what occurred. In the post-AB 218 landscape, flawed or missing investigations may increase—not reduce—litigation exposure, creating grounds for future claims and extending potential liability for districts and board members for years or decades.

Kamm and Jensen say they will continue to push for transparency and accountability to ensure publicly funded investigations throughout the two counties are conducted fairly and independently—particularly in cases involving allegations of sexual assault of students.

Part 1: Invisible Bonds

Part 1 Continued: Behind-the-scenes IPC Dissolution and "Reorganization" Deepen Transparency Concerns