BRONTE 001 - For CA Higher Education: Office for the Prevention of Harassment & Discrimination (OPHD) Intake and Procedural Circuit Design — Modeling University Civil Rights Intake as an AND-Logic System Under Conditions of Structural Conflict-of-Int

This paper develops a systems-theoretic model of university civil rights/intake processes (e.g., Title IX, Equal Opportunity, Discrimination/Harassment units) using the language of digital logic and signal processing. It treats a complainant’s initial report as an analog input that is quantized through a sequence of conjunctive (AND-gated) decision thresholds to produce a discrete binary output: ACCEPTED (1) vs. NOT ACCEPTED (0) for investigation. Within this framework, the paper examines a structurally critical failure mode: cases in which the complaint alleges retaliation or other misconduct by the compliance infrastructure itself (e.g., Title IX/OPHD leadership, risk management, IRB/ORSP administrators, deans, department chairs). These cases introduce an apparent self-referential recursion: the institution must evaluate the behavior of the very units responsible for evaluation. We show that a well-designed compliance architecture cannot permit genuine recursion or metastability at this node. Instead, conflict of interest must be implemented as a hard interrupt and decision fork: either (a) local compliance actors recuse and control is transferred to a higher-order or external authority, preserving the integrity of the AND-gate system; or (b) recusal fails, and the system enters an invalid, unauthorized state in which any ACCEPTED/NOT-ACCEPTED output is procedurally defective, with independent exposure for retaliation and due-process violations. The paper concludes with design recommendations to encode this conflict-of-interest fork explicitly into policy, workflow, and case-management systems. Keywords: Compliance system design, Compliance engineering, Civil rights intake, Retaliation, Conflict-of-interest, Structural bias, Decision-making architecture, Procedural fairness, Recusal and escalation, Governance failure modes