Doe v. Grinnell College, 4:23-cv-00400

Background

Plaintiff Jane Doe, a former student at Grinnell College, alleges she was sexually assaulted twice by another student, a male athlete and donor's son, during her enrollment.
Doe sought help from various Grinnell staff, filed a formal Title IX complaint, and engaged with multiple college officials about the assaults and the campus climate for sexual assault victims.
Doe claims she was discouraged from filing a formal complaint, experienced significant institutional delay, and suffered repeated distress during the Title IX process, including being forced to answer sexually explicit and irrelevant questions during the investigation.
The Title IX process found the assailant responsible but imposed relatively light sanctions, including only temporary probation and restrictions tied to Doe's attendance at future events.
Doe brings nine counts, centering on Title IX violations (harassment, discrimination, retaliation), constitutional claims, and breach of contract, against Grinnell and several individual agents.
Defendants moved to dismiss most claims; Doe opposed only select arguments (mainly on Title IX), and failed to resist others, including all claims against individual agents.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Title IX Harassment/Hostile Environment Claims	Grinnell deliberately indifferent to ongoing harassment, causing hostile environment and further harm.	No actionable harassment post-assault; claims are time-barred.	Dismissed as time-barred; no actionable harassment within the statute of limitations.
Title IX Discrimination (Sanctions, Bias)	Sanctions were uncharacteristically lenient due to sex-based bias; process plagued by gender-based errors.	No plausible sex-based bias; sanctions consistent with discretion.	Survives motion; sufficient to infer potential sex-based bias in post-limitations decisions.
Title IX Retaliation	Grinnell retaliated for Jane Doe’s protected activity through various adverse actions during/after process.	Acts before Oct. 10, 2021 are time-barred.	Only acts after Oct 10, 2021 may support a claim; earlier acts are dismissed as untimely.
Claims Against Individual Agents	Individuals liable under Title IX, Constitution, contract theory as Grinnell’s agents.	Title IX does not permit claims against individuals; no contract w/ agents; not state actors.	All claims against individual defendants dismissed; only institution may be liable.
Fourteenth Amendment/State Action	Grinnell’s conduct subject to constitutional scrutiny due to public funding/context.	Grinnell is not a state actor; no Fourteenth Amendment claim can lie.	Dismissed; insufficient allegations to treat Grinnell or agents as state actors.
Breach of Contract (Title IX Policy)	Policy forms a contract; breaches occurred in failure to protect/provide process, discriminatory outcomes.	Preemption by Iowa Civil Rights Act for discrimination; no breach otherwise.	Some contract theories dismissed; only non-preempted breach theories survive.
Punitive Damages under Title IX	Seeks punitive damages for Title IX violations.	Punitive damages unavailable under Title IX.	Request for punitive damages under Title IX dismissed.

Key Cases Cited

Ashcroft v. Iqbal, 556 U.S. 662 (Pleading standard for plausibility in federal complaints)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (Pleading standard—"plausibility" requirement)
Davis ex rel. LaShonda D. v. Monroe Cnty. Bd. of Educ., 526 U.S. 629 (Standard for institutional liability under Title IX for student-on-student harassment)
Jackson v. Birmingham Bd. of Educ., 544 U.S. 167 (Title IX implicit right of action for retaliation)
Fitzgerald v. Barnstable Sch. Comm., 555 U.S. 256 (No individual liability under Title IX)
Shelley v. Kraemer, 334 U.S. 1 (State action requirement for Fourteenth Amendment claims)
Nat'l R.R. Passenger Corp. v. Morgan, 536 U.S. 101 (Statute of limitations and continuing violations doctrine for discrimination claims)
Gebser v. Lago Vista Indep. Sch. Dist., 524 U.S. 274 (Liability standard—actual notice and deliberate indifference in Title IX)
Wickersham v. City of Columbia, 481 F.3d 591 ("Pervasive entwinement" standard for private action as state action)