Doe v. University of St. Thomas, No. 19-1594 (8th Cir. 2020)
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Plaintiff filed suit asserting Title IX violations and various state law claims against the University after it began disciplinary proceedings that resulted in plaintiff's suspension. The disciplinary proceedings arose from a fellow student's accusation against plaintiff of sexual misconduct.
The Eighth Circuit affirmed the district court's grant of summary judgment in favor of the University. The court held that, while the district court erred by rejecting Rollins v. Cardinal Stritch Univ., 626 N.W.2d 464, 470 (Minn. Ct. App. 2001), and formulating a reasonable care standard that no Minnesota court has adopted, even applying the more permissive reasonable care standard, no reasonable jury would find the investigators' actions showed bias against plaintiff. In this case, no reasonable jury would find bias because the investigators did question the accuser about inconsistencies in her story and found her to be credible. Furthermore, no implication of bias arises by asking the accuser to preserve evidence or by offering her mental health services.
Court Description: [Kobes, Author, with Gruender and Wollman, Circuit Judges] Civil case. On student's claim that the school's disciplinary proceedings on allegations of sexual misconduct were conducted negligently and in violation of the school's state law duty of care, the district court did not err in granting the school's motion for summary judgment; while the district court erred in rejecting an applicable Minnesota Court of Appeals decision on the level of care which must be shown (arbitrariness), even applying the more permissive reasonable care standard the court used in granting the school summary judgment, no reasonable jury would find the investigators' actions showed biased against plaintiff.
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