Vanegas v. Carleton College
- Michael Davis
- 0:19-cv-01878
- U.S. District Court · District of Minnesota
- 6
In Vanegas v. Carleton College, Judge Davis granted in part and denied in part Carleton’s dismissal motion, leaving one narrow negligence claim.
Taariq Vanegas and Carleton College; most claims were dismissed, while one narrow negligence claim was allowed to proceed.
What happened
In Vanegas v. Carleton College, Taariq Vanegas challenged Carleton College’s decision to expel him after a school sexual-misconduct proceeding. He asserted claims involving Title IX, negligence, Title VI, and the Minnesota Human Rights Act.
Carleton asked the court to dismiss every claim. The court dismissed most claims, including some negligence theories, but allowed Vanegas’s claim concerning the timing of the investigation and the failure to include or consider some evidence favorable to him to proceed.
Judge Michael J. Davis held that Minnesota law requires private universities to use reasonable care before making disciplinary decisions. He granted in part and denied in part Carleton’s motion to dismiss, with the specific dismissals and remaining negligence claim stated in the order.
The detailed version
- Vanegas v. Carleton College · No. 0:19-cv-01878
- Michael Davis
- May 1, 2020
Background
During the 2017 spring semester, Taariq Vanegas was a student at Carleton College and was found responsible for violating the school’s sexual-misconduct policy. After an investigation and a hearing before the Community Board of Sexual Misconduct, Carleton permanently expelled him.
Vanegas brought five causes of action: a request for a declaration that Carleton’s disciplinary process violated Title IX and its regulations; a Title IX claim based on an erroneous outcome from a flawed proceeding; negligence; a claim under Title VI; and a claim under the Minnesota Human Rights Act alleging harassment, discrimination, and disparate treatment based on race.
Motion to Dismiss and Report
Carleton moved to dismiss the complaint. Magistrate Judge Leo Brisbois recommended granting the motion in all respects except for one narrow negligence claim. Carleton objected to allowing that negligence claim to proceed, while Vanegas did not file a response or objection.
The negligence claim included allegations that Carleton acted negligently by implementing its sexual-misconduct policy in a biased manner, by using deficient procedures and policy content, and by mishandling the investigation, including its timing and the treatment of evidence favorable to Vanegas.
Court’s Analysis
The court conducted a de novo review of the magistrate judge’s recommendation and Carleton’s objections. It found persuasive the reasoning of a prior Minnesota federal district court decision recognizing that, under Minnesota law, private universities must use reasonable care before making disciplinary decisions. The court noted that the Minnesota Supreme Court had not addressed the precise issues involving a negligence challenge to a private college’s sexual-assault investigation, but it relied on analogous Minnesota cases concerning arbitrary expulsions and the duties of private universities.
The court held that a private university must use reasonable care before making disciplinary decisions. It therefore adopted the Report and Recommendation in its entirety.
Disposition
The court ordered that Carleton’s motion to dismiss was GRANTED in part and DENIED in part:
- Count I was DISMISSED WITH PREJUDICE. - Count II was DISMISSED WITHOUT PREJUDICE. - Count III was DISMISSED WITHOUT PREJUDICE as to the negligence claims based on implementing the sexual-misconduct policy in a biased manner and creating the policy’s content and procedures. The motion was DENIED as to the negligence claim based on the timing of the investigation and Carleton’s failure to include or consider some evidence favorable to Vanegas. - Count IV was DISMISSED WITHOUT PREJUDICE. - Count V was DISMISSED WITHOUT PREJUDICE.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.