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Doe v. Pennsylvania State University

Citation: 276 F. Supp. 3d 300Docket: No. 17-CV-01315

Court: District Court, M.D. Pennsylvania; August 18, 2017; Federal District Court

Narrative Opinion Summary

This case involves Plaintiff John Doe, who filed a motion for a preliminary injunction against The Pennsylvania State University and other associated parties following disciplinary actions taken against him based on allegations of sexual misconduct by Jane Roe. Doe was suspended after a Title IX investigation and hearing process, which he contended violated his due process rights under the Fourteenth Amendment. The procedural history includes Doe's repeated objections to the handling of the investigation, particularly regarding limitations on cross-examination and redactions in his response. The Court evaluated Doe's claims of procedural improprieties, emphasizing the necessity of cross-examination in credibility-based determinations as established in case law such as *Furey v. Temple Univ.* The injunction was granted due to Doe's demonstrated likelihood of success on his due process claims, immediate irreparable harm from the suspension, and a favorable balance of harms. The Court underscored the importance of adherence to procedural norms, particularly in educational disciplinary contexts, and recognized the potential impact of Doe's suspension on his educational and professional future. Consequently, the Court ordered Penn State to allow Doe's registration for the Fall 2017 semester, ensuring separation from Roe.

Legal Issues Addressed

Balance of Harms in Injunctive Relief

Application: The Court determined that the balance of harms favored Doe due to the potential irreparable damage to his education and career, outweighing the university's concerns about setting a precedent.

Reasoning: In weighing the balance of harms for injunctive relief, the court recognized that while Penn State expressed concern about establishing a precedent for students seeking relief whenever dissatisfied with disciplinary outcomes, Doe's potential irreparable harm to his career, stemming from a constitutional violation, outweighed the university's concerns.

Due Process under the Fourteenth Amendment

Application: The court found that John Doe presented a likelihood of success on his due process claim due to significant procedural deviations, including the improper handling of cross-examination rights and redactions in the investigative process.

Reasoning: Plaintiff has shown a likelihood of success on his Due Process claim under the Fourteenth Amendment, which prohibits states from depriving individuals of life, liberty, or property without due process.

Irreparable Harm and Education

Application: The Court recognized the immediate and irreparable harm to Doe’s educational and career prospects due to the suspension, citing the impact on medical school admissions and the need for injunctive relief.

Reasoning: Doe has demonstrated immediate irreparable harm due to his suspension from the upcoming Fall 2017 semester and the recommendation for suspension from the Penn State-Thomas Jefferson joint program.

Preliminary Injunction Criteria

Application: John Doe successfully argued for a preliminary injunction by demonstrating a likelihood of success on the merits, irreparable harm, a balance of harms in his favor, and public interest in granting the injunction.

Reasoning: The Court has defined the criteria for granting a preliminary injunction, requiring the moving party to demonstrate a reasonable probability of success on the merits, irreparable harm if the injunction is denied, a balance of harms favoring the injunction, and that the public interest supports granting it.

Title IX and Procedural Fairness

Application: Doe contended that Penn State's Title IX procedures violated his due process rights by dismissing his questions regarding the medical exam and limiting his ability to respond to allegations.

Reasoning: Penn State’s procedure for handling sexual violence cases allows for cross-examination via submitted questions, which are screened for relevance by a hearing panel. Doe contends that the panel deviated from this process by dismissing nearly all of his twenty-two submitted questions.