On February 5, 2025, President Trump signed Executive Order 14201, titled “Keeping Men out of Women’s Sports.” The order directs federal agencies to enforce Title IX in a manner that excludes transgender female athletes from participating in women’s sports, basing eligibility strictly on biological sex.
Since 2005, the Maine Human Rights Act has prohibited discrimination based on gender identity, including in educational settings. In 2024, the Maine Principals’ Association (MPA) updated its policies to explicitly allow transgender students to compete on sports teams matching their gender identity.
On February 21, 2025, the U.S. Department of Education’s (DOE’s) Office for Civil Rights (OCR) launched a Title IX investigation into the Maine Department of Education and Maine School Administrative District #51 (MSAD #51). MSAD #51 oversees Greely High School, where a transgender student competes on a girls’ sports team. DOE’s OCR stated that it initiated the investigation “amid allegations that [the Maine Department of Education and MSAD #51] continues to allow male athletes [transgender girls] to compete in girls’ interscholastic athletics and that it has denied female athletes female-only intimate facilities, thereby violating federal antidiscrimination law.”
That same day, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) initiated a Title IX compliance review of the Maine Department of Education and the University of Maine System. HHS stated that the review was “based on information that Maine intends to defy” Executive Order 14201 by permitting transgender female athletes to compete in women’s sports.
On February 22, the U.S. Department of Agriculture (USDA) initiated a Title IX compliance review of the University of Maine System (UMS) due to concerns that the State of Maine was not complying with Executive Order 14201.
On February 25, 2025, the U.S. Department of Justice (DOJ) issued a formal letter warning to Maine Governor Janet Mills. Attorney General Pam Bondi asserted that federal law overrides state law and that “requiring girls to compete against boys in sports and athletic events violates Title IX.” The letter warned that the DOJ is prepared to take “all appropriate enforcement actions” to ensure compliance, including litigation or terminating federal funds.
On March 5, 2025, HHS expanded its investigation, adding the Maine Principals’ Association (MPA) and Greely High School to the compliance review.
On March 11, 2025, USDA suspended funding to UMS, affecting various agricultural and research programs. UMS assured USDA that its athletic programs comply with state and federal laws, as well as the National Collegiate Athletic Association’s (NCAA) updated policy, which restricts athletes assigned male at birth from competing in women’s sports. USDA restored the funding on March 13, 2025.
On March 17, 2025, HHS issued a formal determination letter, concluding that the Maine Department of Education, the MPA, and Greely High School had violated Title IX by permitting transgender female athletes to compete in girls’ sports. HHS gave the entities 10 days to voluntarily comply. HHS warned that if they failed to do so, it would refer the case to the DOJ for legal action.
Notes: This matter represents one of the first major enforcement actions under Executive Order 14201 and demonstrates a coordinated effort by HHS, DOE, the DOJ, and USDA to enforce the Trump administration’s interpretation of Title IX. Under this interpretation, eligibility for women’s sports must be based strictly on biological sex.