Encourage the Department of Justice and other agencies to robustly enforce disparate impact via regulations and funding conditions.
Push DOJ and peer agencies to use their existing enforcement tools to address disparate impacts in federally funded programs even when private suits are limited. Focus on reversing or neutralizing the Dec. 10, 2025 DOJ rule and on issuing clear guidance that applies disparate impact analysis in investigations and funding oversight. Use targeted lobbying to align agency leaders, enforcement staff, and partners on a practical enforcement playbook.
Why this works
- This leverages existing authority – agencies can still act on disparate impact (Sandoval only stopped private suits, not agency enforcement).
- A strong signal from agency heads (like an EPA administrator aggressively pursuing Title VI environmental justice complaints) could deter recipients from discriminatory practices.
The Leadership Conference on Civil and Human Rights
AdvocacyCoalition driving civil rights progress
Mechanism
About LobbyingHow The Leadership Conference on Civil and Human Rights uses funding
- Map the key agencies and the specific guidance and funding levers available under existing authority.
- Meet with leadership and staff to press for consistent enforcement guidance and complaint handling.
- Provide model language and examples so disparate impact analysis is applied predictably.
- Track rulemaking and enforcement windows; respond quickly with comments, briefings, and coalition support.
- Publish an enforcement tracker so progress and gaps are visible.
Milestones
Checkpoints and the expected timing for each step
- 1
Enforcement map + asks set
0–30 daysPriority agencies, levers, and requested actions are documented with owners and a timeline.
- 2
Guidance push launched
1–3 monthsMeetings, draft language, and written follow-ups are in motion with target agencies.
- 3
Rule or guidance action occurs
2–6 monthsA memo, guidance, or rule posture shifts toward robust disparate impact enforcement.
- 4
Enforcement tracker sustained
OngoingStakeholders receive updates tied to enforcement milestones and decisions.

