Doe v. Columbia College Chicago, No. 18-1869 (7th Cir. 2019)Annotate this Case
Columbia students Jane and John had a sexual encounter. Weeks later Jane alleged she had not consented to the encounter. Columbia investigated. John did not provide any exculpatory evidence. Columbia’s Title IX coordinator reviewed the investigative report and notified John that there was sufficient evidence for a hearing panel. John responded that the allegations were false and that he had been physically assaulted and verbally harassed by Jane and her friends. Campus safety identified the student who struck John and addressed the issue. Columbia addressed each of his concerns, reminded John that he could submit evidence, including evidence of bias by a Columbia employee, and identified an academic advisor who could approve any accommodations John might need. John responded with screenshots of text messages, his earlier letter, and a toxicology report. The hearing panel found by a preponderance of the evidence that John violated Columbia’s student sexual misconduct policy and suspended him for the academic year. Columbia's appeals officer upheld the findings and discipline. John filed suit, alleging violations of Title IX, 20 U.S.C. 1681, breach of contract, promissory estoppel, negligent and intentional infliction of emotional distress, and negligence. The district court dismissed. The Seventh Circuit affirmed. John failed to allege particularized facts that could lead to a reasonable inference that Columbia denied him an educational benefit because of his sex. Columbia responded quickly and diligently to his complaints and gave him multiple opportunities to present evidence.