Title IX- Due Process Clause

Listen to this article

7^th Circuit Court of Appeals

Case Name: John Doe v. Trustees of Indiana University

Case No.: 22-1576

Officials: Easterbrook, Ripple, and Wood, Circuit Judges.

Focus: Title IX- Due Process Clause

John Doe, a medical student at Indiana University–Purdue University Indianapolis faced allegations of physical abuse from another student, Jane Roe, with whom he allegedly had a romantic relationship. Following an investigation by the University’s Office of Student Conduct, Doe was found responsible and suspended for a year. Subsequently, when applying to the University’s MBA program, Doe portrayed his suspension as exoneration. This prompted an inquiry by the University’s Prior Misconduct Review Committee, which concluded that Doe had withheld crucial information and provided false or incomplete details to the business school. Dean Hess of the medical school, without further engagement with Doe, expelled him from the program. Doe alleged that the University violated both the Due Process Clause of the Constitution’s 14th Amendment and Title IX of the Education Amendments Act of 1972.

Initially, the district court ruled in favor of the defendants, granting summary judgment. The court determined that there was no evidence supporting a claim of sex discrimination. It also concluded that the University’s delay in investigating Doe’s complaint that Roe had occasionally hit him did not impact the final decision, especially since Doe chose not to pursue this allegation against Roe.

The Seventh Circuit found Doe’s constitutional argument more compelling. It held that Doe had a legitimate expectation of continuing his studies unless he violated a norm, constituting a property interest under constitutional terms and necessitating some form of hearing. Consequently, the court overturned the judgment and sent the case back to the district court. Should Doe opt to proceed with the lawsuit, he would have to disclose his true identity, and the district court would need to determine an appropriate remedy for Dean Hess’s failure to afford Doe the opportunity to present his side before expulsion. If Doe decides against revealing his identity, the complaint would be dismissed.

Vacated and remanded.

Decided 04/26/24

Full Text