Doe v. Sarah Lawrence College

Background

Jane Doe, identified in the opinion by the pseudonym Jane Doe, was a student at Sarah Lawrence College. She alleged that another student sexually assaulted her after a party. She reported the assault to the college’s Title IX office on October 9, 2017, but alleged that the meeting was rushed, disorganized, and poorly documented; that college staff did not fully explain her rights or options; and that the college did not adequately explain the consequences of her request for confidentiality or her decision not to seek a no-contact order.

Doe alleged that the college informed the other student of the allegations, after which he contacted her and allegedly spread statements that she had made false accusations. She further alleged that college officials treated her as failing academically, placed pressure on her to leave campus, and required her to take medical leave. She alleged that she later attempted suicide and was hospitalized. The college eventually investigated her complaint, but hearing panels found the other student not responsible after two hearings.

Doe asserted three claims under Title IX of the Education Amendments of 1972: deliberate indifference to sexual harassment, hostile educational environment, and retaliation. She also asserted state-law claims for breach of contract, negligence, negligent infliction of emotional distress, and respondeat superior.

Motion-to-Dismiss Standard

The defendants moved to dismiss the complaint under Federal Rule of Civil Procedure 12(b)(6), which asks whether the complaint states enough facts to support a legally recognized claim. At this stage, the court accepts well-pleaded factual allegations as true, draws reasonable inferences for the plaintiff, and does not decide whether the allegations will ultimately be proven.

The defendants submitted several exhibits, including a student handbook, an investigative report, hearing-panel decision letters, and emails. The court held that these materials were not incorporated into the complaint or integral to it for purposes of the motion. It therefore considered the complaint’s allegations but not the defendants’ exhibits, and it declined to convert the motion into a motion for summary judgment.

Title IX Claims

The court held that Doe plausibly alleged deliberate indifference by Sarah Lawrence College. A school may be liable under Title IX when it receives federal funding, has actual knowledge of severe sexual harassment, and responds in a clearly unreasonable way that causes or increases the student’s vulnerability to harassment. The court relied on allegations that the college failed to explain Doe’s rights and options, failed to explain the possible consequences of confidentiality, disclosed the allegations to the other student despite her stated fear of retaliation, and did not clearly inform her about any formal-complaint requirement. The court concluded that these allegations plausibly supported a finding that the college acted unreasonably.

The court also held that Doe plausibly alleged a hostile educational environment. It considered the alleged calls and messages from the other student, campus rumors that Doe had made false allegations, statements by college officials characterizing her as lazy or merely a resident, and the pressure she experienced to leave campus. Viewed together, the court found that the allegations plausibly supported an inference that the conditions of her education were altered and that the conduct was motivated by sex. Doe’s allegations concerning the college’s handling of complaints by female students also supported, at this stage, a minimal inference of sex-based discrimination.

The court further held that Doe plausibly alleged Title IX retaliation. She engaged in protected activity by reporting the alleged sexual assault, the defendants knew about that report, and she alleged adverse school-related actions—including being placed on medical leave and pressured to leave campus—within approximately four weeks. The court found that the timing and surrounding allegations plausibly supported an inference of retaliatory motive.

State-Law Claims

The court held that Doe plausibly stated a breach-of-contract claim. It reasoned that a student’s enrollment may create an implied contract based on the college’s policies and that Doe identified alleged failures to follow the college’s policy, including failures to investigate her complaint properly, explain protections against retaliation, and offer accommodations or interim measures.

The court also held that Doe plausibly stated a negligence claim. Although colleges generally do not have a duty to protect students from sexual assaults by other students, the court found a plausible inference that the college assumed a special duty after Doe reported the assault and was led to believe that the college would investigate and take prompt action. The alleged mishandling of the investigation and alleged knowledge of employees’ conduct were sufficient at the pleading stage.

For similar reasons, the court held that Doe plausibly stated a negligent-infliction-of-emotional-distress claim. The complaint alleged an independent duty, a breach of that duty, and severe emotional distress, including depression, fear, and a suicide attempt.

The court distinguished the respondeat superior doctrine from an independent cause of action under New York common law. It stated that respondeat superior may remain relevant as a theory of liability attached to an underlying claim, but it dismissed the seventh claim for relief because respondeat superior is not itself an independent claim.

Disposition

The court denied the defendants’ motion to dismiss as to the first six claims for relief and granted the motion as to the seventh claim for relief. The opinion did not resolve whether Doe would ultimately prove the surviving claims. The court directed the defendants to file an answer within 30 days and scheduled an initial pretrial conference.