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Keywords

lawsuitplaintiffdefendantdamagesattorneyhearingmotionharassmentcorporationmotion to dismisspiracy
plaintiffattorneyhearingpiracy

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Ericson v. Syracuse University, 35 F.Supp.2d 326, 133 Ed. Law Rep. 70

Facts

Former members of the Syracuse University women's tennis team filed a lawsuit against the university and its officials, alleging that their former coach, Jesse Dwire, sexually harassed them over a three-year period. They claimed that the university officials had actual notice of Dwire's misconduct, which spanned over 20 years, and conspired to conduct a sham investigation to conceal the extent of the harassment. The plaintiffs sought relief under Title IX, the Violence Against Women Act, and various New York State laws. The court addressed multiple motions to dismiss various counts of the complaint.

Issue

Whether the plaintiffs sufficiently stated a claim against the university under Title IX and whether the intracorporate conspiracy doctrine barred claims against the university's attorney and a student member of the hearing panel.

Whether the complaint states a claim against the university under Title IX and whether the intracorporate conspiracy doctrine bars the claim against the university's attorney and a student member of the hearing panel.

Rule

Under Title IX, a student may not bring a private damages claim against an institution unless an official with authority to institute corrective measures has actual notice of and is deliberately indifferent to the employee's misconduct. The intracorporate conspiracy doctrine prevents claims against agents of a corporation for conspiracy when they act within the scope of their employment.

Analysis

The court found that the plaintiffs' allegations met the standard for stating a claim under Title IX, as they indicated that university officials had actual notice of the harassment and failed to act. However, the court ruled that the intracorporate conspiracy doctrine applied, as the attorney and student acted in their official capacities, thus barring the conspiracy claim. The court also analyzed the claims under New York law regarding intentional infliction of emotional distress, determining that the university vice president's actions could potentially meet the high standard required for such claims.

Conclusion

The court granted in part and denied in part the defendants' motion to dismiss, allowing the Title IX claim to proceed while dismissing the conspiracy claim and certain other claims.

The complaint was sufficient to state claim against university under Title IX.

Who won?

The plaintiffs prevailed in part as the court allowed their Title IX claim to proceed, indicating that their allegations were sufficient to state a claim against the university. The court recognized the seriousness of the allegations regarding the university's failure to act on known harassment, which is a critical aspect of Title IX claims. However, the court also dismissed several claims, indicating a mixed outcome for the plaintiffs.

The plaintiffs prevailed in part as the court allowed their Title IX claim to proceed, indicating that their allegations were sufficient to state a claim against the university.

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