Moore v. Hamline University

Background

Mariama Moore, proceeding without a lawyer, sued Hamline University, Hamline University Residential Life, and several university officials. She alleged that other students harassed, followed, bullied, intimidated, and otherwise mistreated her in and around her dormitory and elsewhere on campus. She also alleged that university personnel did not respond appropriately to her complaints and that she experienced retaliation after making them.

The complaint referenced claims under Title IX, which prohibits sex discrimination in federally funded education programs, and Title VI of the Civil Rights Act of 1964, which prohibits race, color, and national-origin discrimination in federally funded programs. It also referenced Minnesota claims for breach of contract, negligence, invasion of privacy, defamation, private nuisance, and stalking or harassment.

Federal claims

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not state a legally sufficient claim.

For the Title IX student-on-student harassment theory, the court held that Moore did not provide enough factual detail to plausibly show that the other students’ conduct was because of her sex. The court found that the allegations about following, loitering, noise, noodles near her door, comments about her teeth, and similar conduct did not describe sex-based conduct. The court also held that Moore did not adequately plead quid pro quo harassment because she alleged no facts showing that an academic benefit was conditioned on accepting sexual advances.

The court dismissed Moore’s Title IX sex-discrimination claim because the complaint contained only conclusory allegations and did not identify an instance in which a similarly situated male student was treated differently. The court also found that Moore had not adequately pleaded Title IX retaliation because she did not allege facts supporting a reasonable inference that the university took an adverse action against her because she made a protected complaint about sexual harassment. Separately, the court held that Title IX does not authorize claims against individual school officials in their individual capacities.

As to Title VI, the court held that Moore did not plausibly allege either that she was treated differently from similarly situated students outside her protected class or that Hamline failed to respond appropriately to racially motivated misconduct. The court noted that Moore referred to racial slurs but did not plainly allege that a racial slur was directed at her, that she reported racial comments to a Hamline official, or that the other students’ conduct or the university’s response was motivated by race. The court also held that Title VI claims could not proceed against the individual defendants.

The court dismissed all of Moore’s Title IX and Title VI claims with prejudice.

State-law claims

The court had federal-question jurisdiction over the federal claims and supplemental jurisdiction over the related Minnesota claims. After dismissing all federal claims, the court declined to exercise supplemental jurisdiction over the state-law claims. It dismissed those claims without prejudice, citing judicial economy and respect for Minnesota courts’ role in deciding issues of Minnesota law.

Other motions and disposition

Moore filed three motions for summary judgment. The court denied them because the complaint failed to state a claim and because the motions were filed before the defendants had answered or otherwise responded to the complaint, making them premature.

The court denied Moore’s request concerning electronic filing fees because she had not shown that a fee exemption was necessary. The portion of that motion seeking a decision was moot because the court had ruled on the motion to dismiss. The court also denied Moore’s motion concerning alleged judicial misconduct and recusal. The final order granted the defendants’ motion to dismiss; dismissed the federal claims with prejudice; dismissed the state-law claims without prejudice; and denied Moore’s summary-judgment and remaining motions.