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Sterrett v. Cowan

Citations: 85 F. Supp. 3d 916; 2015 U.S. Dist. LEXIS 13056; 2015 WL 470601Docket: Case No. 14-cv-11619

Court: District Court, E.D. Michigan; February 3, 2015; Federal District Court

Narrative Opinion Summary

The case involves a plaintiff, a university student, who filed a lawsuit against the university and its officials alleging violations of his rights under 42 U.S.C. § 1983, specifically the Fourteenth Amendment Due Process and First Amendment Free Speech. The plaintiff contends that he was not properly notified of sexual misconduct allegations and was denied due process in the university's disciplinary proceedings. The university conducted an investigation which concluded with the plaintiff's suspension, a decision he challenged through various procedural steps, including appeals and submissions of affidavits. The court partially granted and denied the defendants' motion to dismiss, retaining the due process claim against one official while dismissing others. The court also dismissed the First Amendment claim, finding that restrictions on discussing the investigation were typical and permissible in educational settings. The court denied the plaintiff's motion to amend the complaint to include Title IX and Elliott Larsen claims due to insufficient evidence of gender bias. Additionally, motions to compel deposition and amend the complaint were denied. Qualified immunity was granted to most university officials, shielding them from liability. A scheduling conference was set to address further proceedings.

Legal Issues Addressed

Amendment of Complaints under Rule 15

Application: Sterrett's request to amend his complaint to include Title IX and Elliott Larsen claims was denied due to the lack of factual support for gender discrimination, rendering the amendment futile.

Reasoning: Sterrett’s allegations under Title IX and Elliott Larsen are insufficient as they fail to identify any female counterpart, aside from the Complainant, who received more favorable treatment.

Due Process in University Disciplinary Proceedings

Application: Sterrett contends he was not properly notified of the allegations against him and lacked due process, particularly concerning the August 6, 2012 interview and the issuance of a Final Report without a meaningful hearing.

Reasoning: Sterrett claims he did not receive any notice before the August 6 interview, which may support a due process violation given the length of his suspension.

First Amendment Rights in Educational Context

Application: The court evaluated Sterrett's claim that Defendants' prohibition on discussing the investigation with other witnesses infringed on his speech rights, finding that such instructions are typical in criminal cases and valid in educational settings to maintain discipline.

Reasoning: The Court notes that First Amendment rights must be evaluated within the context of the educational environment.

Qualified Immunity for University Officials

Application: The court determined that several university officials were entitled to qualified immunity as Sterrett's allegations did not sufficiently demonstrate a violation of clearly established rights.

Reasoning: Matney is accused of approving sanctions without proper analysis and disregarding due process violations, but the allegations do not establish a claim against him for violating Sterrett's Due Process rights regarding notice or a meaningful hearing.