Campus Due Process Litigation Tracker

Doe v. St. Joseph’s University, No. 2:18-cv-02044 (E.D. Pa. Apr. 23, 2019)

School type: Private
State: Pennsylvania
Federal Circuit: Third
Decision primarily favorable to: University
Stage of litigation: Motion for summary judgment
Keywords: Erroneous outcome, Title IX, Training materials

The court granted summary judgment for the university on Plaintiff’s Title IX claim, and declined to consider Plaintiff’s state-law claims.

With regard to Plaintiff’s Title IX erroneous outcome claim, the court assumed arguendo that articulable doubt existed, but held that there was no evidence of a causal connection to gender bias. The arguments of Plaintiff’s that the court rejected include:

  • The fact that SJU did not implement DOE’s 2017 recommendations to provide additional procedural safeguards for accused students;
  • SJU’s acceptance of a $300K federal grant to address sexual misconduct;
  • SJU’s use of victim-centered, trauma-informed training materials;
  • Statements by employees that the majority of sexual assaults are committed by men (the court held that since Plaintiff offered no factual information challenging the veracity of these statements, they could not be evidence of gender bias).

Having dismissed the federal claims, the court declined to exercise jurisdiction over the state-law claims and dismissed them without prejudice.