Doe v. Icahn School of Medicine at Mount Sinai

Background

John Doe, a medical student at the Icahn School of Medicine at Mount Sinai, challenged sanctions imposed after the school found him responsible for sexual misconduct directed at fellow student Jane Roe. The sanctions included a 20-month suspension, an alcohol-use evaluation, notations on his transcript and Medical Student Performance Evaluation, a no-contact order with Roe, and a requirement that he leave student housing.

Doe alleged that Mount Sinai’s handling of Roe’s complaint discriminated against him because of his gender, violating Title IX and the New York City Human Rights Law. He also brought a breach-of-contract claim. Mount Sinai’s hearing panel considered evidence and witness testimony, found Doe responsible, and issued its decision on November 14, 2023. An appeals panel and a dean’s designee upheld that decision.

Motion for Emergency Relief

Doe moved for a temporary restraining order and preliminary injunction. He asked the court to stop Mount Sinai from enforcing his suspension, allow him to attend classes, confer his degree after he completed the requirements, and prevent the school from adding information about the Title IX matter to his medical school performance evaluation.

A preliminary injunction is an extraordinary remedy. To obtain one, a party generally must show irreparable harm—harm that cannot be repaired through money damages—and either a likelihood of success on the merits or sufficiently serious legal questions combined with a strongly favorable balance of hardships. Because Doe sought to restore the status that existed before his suspension, the court treated his request as a prohibitory injunction rather than a mandatory injunction.

Court’s Analysis

The court concluded that Doe was unlikely to succeed on his Title IX claim under an erroneous-outcome theory. Such a claim required him to show an identifiable reason to doubt the disciplinary result and that gender bias helped cause the result.

The court declined to second-guess Mount Sinai’s credibility determinations. It found that the hearing panel had discussed the inconsistencies Doe identified in Roe’s account and explained how it evaluated them. The panel also told Doe that he was presumed not responsible and did not bear the burden of proof. The court therefore found no identifiable reason to doubt the outcome based on the arguments presented at this stage.

The court also found no evidence of gender bias. It rejected Doe’s reliance on examples in a general employee-training module, the Title IX coordinator’s social-media posts and role in processing Roe’s complaint, policy language concerning trauma, the way witnesses were questioned, and public pressure associated with an earlier lawsuit. The court found that these points did not show anti-male bias by the hearing or appeals panels.

Because Doe had not shown an unfair or discriminatory outcome, the court concluded that he was also unlikely to succeed on his New York City Human Rights Law and breach-of-contract claims. The court therefore did not analyze the balance of hardships.

The court separately found that Doe had not shown irreparable harm. It reasoned that the delay in his medical training and becoming a doctor could be remedied with money damages. It also found that Doe would not lose progress toward graduation: he could present his required research and complete his coursework after returning, and he could reapply during the 2025 residency match cycle.

Disposition

The court denied Doe’s motion for a temporary restraining order and preliminary injunction and directed the clerk to terminate the motion. This order addressed Doe’s request for temporary emergency relief; the opinion does not state that the court entered final judgment on his underlying Title IX, New York City Human Rights Law, or breach-of-contract claims.