Case name: Doe v. Brown University, et al., No. 16‐614 (D. R.I. 09/06/17).Ruling: The U.S. District Court, District of Rhode Island dismissed a suit against Brown University.What it means: The protection of Title IX prohibits student‐on‐student harassment only when both the perpetrator and victim are enrolled in the same school.Summary: Providence College freshman Jane Doe reported to the city police in 2014 that she had been raped in a Brown University residence hall by three Brown University football players.Pursuant to Doe's requests, Brown agreed to conduct an inquiry into her allegations. However, Brown never completed it.Because both institutions were located in the same town, Doe withdrew from Providence because of her claimed fear of encountering the three student‐athletes in the future.She then filed a suit claiming violations of Title IX.Brown filed a motion to dismiss, arguing the act applied only when both students were enrolled in the same school where the alleged assault occurred.The district judge said that the few cases addressing the issue held that the protection of Title IX was generally limited to scenarios where the accuser and the alleged attacker attended the same school.He dismissed the suit, stating that Brown's acts — or failures to act — couldn't have prevented her from getting an education at Providence, because Brown didn't have any control or influence over the classes in which Doe was enrolled. He also explained that no one at Brown had the authority to take corrective action to prevent future encounters that allegedly prevented her from staying enrolled at Providence.
Campus Legal Advisor – Wiley
Published: Jan 1, 2018
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