Muhammad v. The Trustees of Columbia University & Alex Jurado

Background

Shahida Nisa Muhammad, who was representing herself, sued the Trustees of Columbia University and Alex Jurado. The second amended complaint asserted four counts: a sex-discrimination claim under Title IX of the Education Amendments of 1972; a race, color, or national-origin discrimination claim under Title VI of the Civil Rights Act of 1964; discrimination and retaliation claims under Title III of the Americans with Disabilities Act; and a claim under 42 U.S.C. § 1983, a statute allowing claims for violations of federal rights by people acting under state authority.

Muhammad alleged that Columbia students and staff harassed her between September and November 2024. Among other things, she alleged that students tracked her movements through Bluetooth devices, another person photographed her, and a student sent threatening messages. She also alleged that Columbia failed to investigate some complaints, that Jurado required her to meet with a male harasser in a way that conflicted with her Islamic modesty requirements, and that she was coerced into a psychiatric evaluation and denied access to her dorm. The complaint sought $100 million in compensatory damages and orders requiring anti-discrimination training and changes to religious-accommodation policies.

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6). On such a motion, the court accepts the complaint’s factual allegations as true and asks whether they state a legally plausible claim, rather than deciding what evidence would ultimately prove.

Title IX claim

The court dismissed the Title IX claim against Jurado because Title IX does not allow suits against individual school officials. The court also dismissed the claim against Columbia because the complaint did not include specific facts supporting a plausible inference that the challenged conduct occurred because of Muhammad’s sex or that Columbia treated a similarly situated male student differently.

To the extent the claim concerned harassment by other students, the complaint also did not plausibly allege that Columbia had actual knowledge of severe, pervasive, and objectively offensive sex-based harassment and responded with deliberate indifference that denied Muhammad equal access to educational opportunities. The court did not reach whether the allegation about meeting with a male harasser showed religious discrimination because Title IX prohibits discrimination based on sex, not religion. The motion to dismiss Count I was granted.

Title VI claim

The court dismissed the Title VI claim because the complaint did not plausibly allege that Columbia’s conduct was motivated by Muhammad’s race, color, or national origin. The court found that the alleged threatening messages, Columbia’s handling of an investigation, an investigator’s reaction to Muhammad’s comment about white women, and the alleged audit statistic did not establish discriminatory intent or show that race, color, or national origin was a substantial or motivating factor.

The complaint also did not provide enough facts about the timing or outcome of the investigation, comparisons with investigations involving students of another race, color, or national origin, Columbia’s knowledge of severe race-based harassment, or how any response affected Muhammad’s education. The court dismissed the Title VI claim against Jurado because Title VI provides for liability against entities receiving federal financial assistance, not individual employees. The motion to dismiss Count II was granted.

Americans with Disabilities Act claims

The court construed the complaint as asserting disability discrimination and retaliation claims under Title III of the Americans with Disabilities Act against Columbia only, because the allegations did not connect Jurado to those claims.

For the discrimination claim, the complaint did not plausibly allege that Muhammad had a disability covered by the Act. It did not describe an impairment that substantially limited a major life activity, a record of such an impairment, or facts showing that Columbia regarded her as having such an impairment. The complaint’s only possible reference to a disability was a disputed diagnosis of paranoia, which Muhammad contested.

For the retaliation claim, the complaint did not plausibly allege that Muhammad engaged in activity protected by the Americans with Disabilities Act, such as opposing disability discrimination or requesting an accommodation based on disability. The allegation that she was coerced into a psychiatric evaluation after reporting harassment did not show that her complaints concerned disability discrimination. The motion to dismiss Count III was granted.

Section 1983 claim

The court dismissed the Section 1983 claim against Columbia only. A private party can be treated as acting under state authority in limited circumstances, such as when compelled or controlled by the state, performing a public function, or jointly participating with state officials.

Muhammad alleged that the New York Police Department collaborated with Columbia to conceal the identities of harassers and that she was confined for psychiatric treatment without a hearing. The court found that the complaint contained no specific facts showing that Columbia was compelled by the state, performed a public function, or knowingly participated in joint activity with the police. The statement that the police and Columbia collaborated was conclusory and did not allege an agreement, coordinated action, or an act advancing a shared unconstitutional objective. Because of this conclusion, the court did not decide whether the alleged confinement otherwise violated due process. The motion to dismiss Count IV was granted.

Disposition

The court granted the defendants’ motion to dismiss without prejudice. Muhammad may file an amended complaint by October 29, 2025. If she does not file an amended complaint by that date, the current complaint will be dismissed with prejudice. The Clerk was directed to close all pending motions.