School board approves policy changes to comply with new anti-grooming laws

With the new school year about to begin, the School District of Rhinelander Board of Education voted Aug. 17 to revise a bylaw and eight district policies governing staff, volunteer and board member communication with students, bringing the district into compliance with new state laws targeting child grooming.

According to the board packet, grooming behavior is defined as a course of conduct, pattern of behavior, or series of acts with the intention to condition, seduce, solicit, lure, or entice a child for the purpose of engaging in sexual intercourse or sexual contact, or for the purpose of producing, distributing, or possessing depictions of the child engaged in sexually explicit conduct. Prohibited grooming behaviors cover both in-person and digital communications, during non-school and school hours, and include sexualized conversations, inappropriate physical contact, and efforts to isolate a child from their family or peers.

Two new state laws

Superintendent Eric Burke told the board the changes stem from two bills signed by Gov. Tony Evers. 2025 Wisconsin Act 88 creates a new criminal charge for grooming a child for sexual activity and expands the state’s existing school-employee sexual misconduct statute.

2025 Wisconsin Act 89 requires public, charter and private schools to adopt formal policies governing appropriate communication between employees or volunteers and students, with those policies due by Sept. 1, and to begin annual staff training on identifying, preventing and reporting grooming and “boundary violations” starting in the 2026-27 school year.

Burke said the district recently received word that the state Department of Public Instruction is finalizing the required training, which staff will have to complete and document, comparable to existing bloodborne pathogen training. He confirmed the new communication rules apply to school board members as well as staff and volunteers.

What’s prohibited

The revised policy language spells out specific behaviors staff, volunteers and administrators must avoid with students, describing them as boundary violations that, even without intent to groom a child, can still trigger discipline. Examples cited in the policy include:

Inappropriate comments about a student’s body or appearance;

Being overly touchy with students;

Invading a student’s privacy (e.g. walking in on the student in the bathroom, locker room, asking about bra sizes or previous sexual experiences);

Taking an undue interest in a student (i.e. having a special friend or a special relationship)

Giving a student a ride in a personal vehicle or taking a student on personal outings without administrative approval

Initiating or extending contact with a student beyond the school day for personal, non-educational purposes

Using email, text messaging or other platforms to discuss personal topics or interests unrelated to schoolwork

Inviting a student to a staff member’s home without another staff member or the student’s parent present

Giving or accepting gifts or money involving a student with no legitimate educational purpose

Being alone with a student behind closed doors without a legitimate educational reason

Keeping or trading secrets with a student

The policy states staff are “discouraged from engaging students in social media and online networking media” except for approved academic, extracurricular or professional purposes, and are barred from posting any photo, video or comment about an individual student on personal social media accounts.

Board raises concerns about ambiguity

Board members Mike Roberts and Patricia Townsend voiced support for the policy package but pressed administration on how clearly some provisions were written.

Roberts asked whether the district planned to supplement the formal policy language with a plain-language guide for staff and volunteers, noting some sections use terms like “discouraged” rather than outright prohibitions, and citing potential gray areas around mentor-mentee programs and communication tools like the SportsYou app (used by coaches and athletes). Roberts argued that overly broad or ambiguous language could put teachers, coaches and administrators in a difficult position — either chilling legitimate, positive relationships between staff and students or creating confusion for administrators investigating complaints.

State lawmakers write “laws and code and policies for the very few, which can limit positive interaction that affects kids every day,” Roberts said, adding that the law “makes a really great headline” but isn’t “black and white” in practice.

Townsend raised similar questions about what forms of communication remain permissible and how many people need to be included on a message thread to stay compliant. She also described the “fine line” staff face in trying to be a positive, trusted role model for students while protecting themselves from misunderstandings or complaints.

Burke said the district and NEOLA, the district’s policy consulting firm, are still working through how some of the newer requirements will be interpreted and applied in practice, but said the Sept. 1 deadline meant the board needed to adopt the revisions now. Burke said that even before the new law, staff have generally been advised to avoid one-on-one communication with students and to loop in another adult when possible, to protect themselves.