John Doe v. Pa. State Univ.

336 F. Supp. 3d 441
CourtDistrict Court, M.D. Pennsylvania
DecidedAugust 21, 2018
DocketNo. 4:18-CV-00164
StatusPublished
Cited by5 cases

This text of 336 F. Supp. 3d 441 (John Doe v. Pa. State Univ.) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Doe v. Pa. State Univ., 336 F. Supp. 3d 441 (M.D. Pa. 2018).

Opinion

Matthew W. Brann, United States District Judge

Defendants moved to dismiss John Doe's Complaint. For the reasons that follow, that motion will be granted in part and denied in part.

I. BACKGROUND1

In August 2014, John Doe and Jane Roe2 were both undergraduate students at The Pennsylvania State University's ("PSU's") University Park Campus.3 In *443the early morning hours of August 10, 2014, a sexual encounter occurred between the two of them while they were alone in Mr. Doe's dorm room.4 Mr. Doe maintains that the encounter was consensual.5 Ms. Roe, however, maintains that it was not,6 and consequently filed sexual assault complaints with PSU's Office of Student Conduct as well as University Police.7

A. The Investigative Model

PSU conducted an inquiry into Ms. Doe's complaint using a procedure it dubbed the "Investigative Model."8

Pursuant to this model, sexual assault complaints are assigned to an "Investigator," who interviews the complainant and respondent separately (as well as any other "possible witnesses") in order "to collect information regarding the allegation."9 This information is gathered into an "Investigative Packet," which the parties may review and respond to.10 These responses may prompt the Investigator to "address and correct ... factual inaccuracies, misunderstandings, etc." in the Investigative Packet, and may also prompt him or her to "conduct additional investigation as appropriate."11

If the Investigator decides to revise the packet as a result of such additional investigation, the parties are to be given another chance to "review and respond to" it.12 When this iterative process is complete, the Investigator will "finalize[ ]" the packet and decide whether or not "the acquired information reasonably supports a Code of Conduct violation."13 If it does, "charges will be assigned"; if it does not, "the case will be closed."14

If charges are assigned, both parties are given another opportunity to respond, which responses are forwarded along with the Investigative Packet to the school's "Title IX Decision Panel."15 This panel, made up PSU faculty and staff members,16 uses the preponderance of the evidence standard to decide whether the respondent was "responsible" for the charged conduct.17 The panel also decides on the "appropriate sanction[ ]," if applicable.18 These decisions are based entirely on the paper record before the panel; no in-person testimony is permitted by either the complainant or the respondent.19

B. PSU's Investigation of the August 10, 2018 Encounter

After Ms. Roe filed her complaint, Defendant Danny Shaha, in his capacity as Senior Director of PSU's Office of Student *444Conduct, initiated disciplinary proceedings against Mr. Doe.20 Defendant Spencer Peters (a former University Police investigator who was involved in the initial criminal investigation of Ms. Roe's complaint21 ) was assigned as the case's Investigator, and he was-according to a letter sent to Mr. Doe from the Office of Student Affairs-to be "considered a neutral fact finder."22

Pursuant to the Investigative Model's procedures, Mr. Peters conducted a series of separate, alternating meetings with Ms. Roe and Mr. Doe, during which the parties spoke about the sexual encounter and commented on the other's previous statements.23 At two of these meetings, Mr. Peters directed "a few follow[-]up questions" to Ms. Roe "at the request of" Mr. Doe.24 Mr. Peters also met with several witnesses-including Ms. Roe's roommate and a nurse who examined Ms. Roe after the incident-who spoke to Mr. Peters about their observations of, and interactions with, Ms. Roe and Mr. Doe before and after the sexual encounter.25 Based on his investigation, Mr. Peters "determined [that] there was enough information to reasonably support" charging Mr. Doe with nonconsensual sexual activity.26 As a result, the written materials were sent to the Office of Student Conduct.27 Karen Feldbaum, in her capacity as associate director of that office, forwarded the materials to a Title IX Decision Panel.28

When the panel met to discuss Mr. Doe's case on December 17, 2015, its members received copies of several additional documents from Ms. Feldbaum, presumably to guide the panel while it was making its decision.29 One of these documents was titled "A Decision-Making Model for Sexual Misconduct Cases," which defined "sexual misconduct" and noted that "the focus of concern" for such cases "is whether consent was expressed in a context in which it can be considered valid."30 Another document defined the preponderance of the evidence standard, noting that "[i]f the panel believes that the information provided indicates that it is more likely than not that a violation occurred, then [it] should find the student responsible for the violation," even if the panel is "not ... completely convinced," or "ha[s] consideration reservation."31 And a third document indicated that "the percentage of false reports [of sexual assault] is 2%."32

Pursuant to the procedures detailed above, neither Ms. Roe nor Mr. Doe were permitted to appear before the panel, which issued its decision finding Mr. Doe "responsible" for the charged conduct less than a week later.33 As a result of that finding, Mr. Doe was suspended from PSU for two semesters and lost his on-campus *445housing privileges.34

Mr. Doe instituted this suit against PSU, Mr. Peters, Mr. Shaha, and Ms. Feldbaum on January 23, 2018.35 His single-claim complaint argues that various aspects of the Investigative Model-as designed and as implemented in his case, individually and in the aggregate-violated his rights under the Due Process Clause.36 He seeks (1) declarations that PSU's Investigative Model was unconstitutional, both facially and as applied to his case; (2) injunctions requiring PSU to reverse the panel's decision, expunge his disciplinary records, and reinstate him as a student in good standing; and (3) monetary damages.37

Defendants moved to dismiss Mr. Doe's complaint on March 26, 2018.38 Their supporting brief argues: (1) that this Court does not have subject-matter jurisdiction over Mr. Doe's claims for injunctive relief; (2) that Mr.

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Cite This Page — Counsel Stack

Bluebook (online)
336 F. Supp. 3d 441, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-doe-v-pa-state-univ-pamd-2018.