Doe v. Trustees of Indiana University, No. 22-1576 (7th Cir. 2024)
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The case involves a medical student at Indiana University–Purdue University Indianapolis, referred to as John Doe, who was accused of physical abuse by a fellow student, Jane Roe. The University’s Office of Student Conduct found Doe culpable and suspended him for one year. Doe applied to the University’s MBA program and described his suspension as an exoneration. This led to an investigation by the University’s Prior Misconduct Review Committee, which concluded that Doe had withheld pertinent information and gave false or incomplete information to the business school. Dean Hess of the medical school, without inviting further response from Doe, expelled him from the medical school. Doe accused the University of violating both the Due Process Clause of the Constitution’s Fourteenth Amendment and Title IX of the Education Amendments Act of 1972.
The district court granted summary judgment to the defendants. The court found that the record did not support an inference of sex discrimination. The court also found that the University’s delay in launching an investigation into Doe’s complaint that Roe hit him on occasion did not contribute to the ultimate decision, and it was justified by the fact that Doe elected not to pursue this charge against Roe.
The United States Court of Appeals for the Seventh Circuit found that Doe’s constitutional argument was stronger. The court held that Doe had a legitimate claim of entitlement to remain a student unless he transgressed a norm, which is a property interest in constitutional lingo and requires some kind of hearing. The court vacated the judgment and remanded the case to the district court. If Doe elects to continue with the suit, his true name must be disclosed to the public, and the district court must decide what remedy is appropriate for Dean Hess’s failure to allow Doe an opportunity to present his position before expelling him. If Doe elects not to reveal his name, the complaint must be dismissed.
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