Abstract: Title VI of the 1964 Civil Rights Act prohibits discrimination on the basis of race, color, or national origin by any recipient of federal funds. Discrimination occurs when members of a protected class have their access to the institution’s programs restricted when other members of the community have unrestricted access. One form of discrimination occurs when a hostile environment for a protected group has the effect of denying them equal access to the college’s programs. How is a hostile environment created? Sometimes in part or almost exclusively by words uttered by people present on the campus, including other students, faculty members, members of the staff, and casual invitees. Title VI is violated when race- or national-origin-disparaging words pervade the campus. Imposing liability on the basis of statements brings free expression considerations into the picture. This Essay, written by someone versed in free speech law but not in the details of Title VI law, examines the interaction between free speech principles and institutional liability under Title VI for hostile environment discrimination created mainly by words. Section II examines what kinds of utterances can be taken into account when we try to figure out whether a hostile environment exists, and how that class of utterances can be taken into account. After distinguishing between targeted utterances aimed at an identifiable individual and general statements that disparage a racial or nation-origin group, the Section deals with targeted utterances. Section III turns to general statements, typically of a rather clearly political sort. After describing the quite limited circumstances under which individuals can be held liable for general statements, the Section argues that such statements can be part of the “dossier” about hostile environment discrimination, exposing the institution, though not the individuals who make the statements, to liability. Section IV examines some available institutional responses to the possibility that words contribute to the creation of a hostile environment. It proposes that Title VI liability should be similar to that emerging for liability for disseminating objectionable content on social media platforms. Under such a system colleges and universities would have a duty to create a unit charged with receiving complaints about race- and national-origin-disparaging statement. That unit’s reports should be regularly reviewed for accuracy by higher-level institutional actors. If the reports disclose problems arising from words, the institution should have and enforce rules against targeted statements but not similar rules against general statements. Instead, the institution should develop counterprogramming and take other ameliorative actions with the aim of assuring members of protected groups that they are indeed as welcome on the campus as everyone else. The Section then applies its analysis to agreements between the University of Michigan, Muhlenberg College, and the U.S. Department of Education resolving an investigation into the University’s compliance with Title VI. A brief conclusion emphasizes that nothing in this Essay is novel in discussions of Title VI and free speech. Its contribution, if any, is to focus more closely on distinctions and legal categories than one finds in more casual treatments.