Doe v. Syracuse University, 5:19-cv-01467

"John Doe," a Syracuse University student and DKE fraternity president, was accused by a female student (Jane Roe) of sexual assault after a party; Doe and Roe both had memory lapses about the night.
Syracuse/Onondaga County criminal investigators (Syracuse Police and ADA) did not file charges after SANE/toxicology results showed no incapacitating drugs, no physical evidence of assault, and Roe could not recall events.
Roe filed a University Title IX complaint; investigator Bernerd Jacobson credited Roe’s later "flashes" of memory and certain photo evidence despite inconsistencies and did not consult police, the DA, or the SANE nurse, according to Doe’s complaint.
A three-member University Conduct Board (UCB) accepted the investigator’s report, found Doe responsible (preponderance standard), and expelled him; the Appeals Board denied Doe’s appeal.
Doe sued under Title IX (erroneous outcome/gender bias), breach of contract (Student Handbook procedures), and promissory estoppel; defendants moved to dismiss.
The court denied dismissal of the Title IX erroneous-outcome claim, granted leave to replead the limited contract claim about the Handbook’s 60-day notice, and dismissed promissory estoppel with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Title IX — erroneous outcome (gender bias)	Investigator and panels were biased toward believing female complainants, ignored exculpatory evidence (police/DA/SANE), and acted under "trauma-informed"/public pressure to side with accusers	Pleading fails to link procedural errors to intentional sex-based discrimination; national enforcement climate has shifted away from prior pressure	Denied dismissal: allegations create articulable doubt about outcome and, coupled with alleged institutional pressure, plead a minimal plausible inference of sex discrimination under Columbia framework
Breach of contract (Student Handbook procedures, timeliness, fairness)	Syracuse breached express/implied Handbook promises to provide fair, impartial process and complete investigation/hearing within 60 days	Handbook guarantees are general non-actionable policy statements; university provided notice/excuse for delay	Mostly dismissed: general fairness claims not actionable under NY law; limited leave to replead only as to whether Syracuse actually failed to notify Doe of a delay beyond 60 days
Promissory estoppel	Student relied on Syracuse's explicit assurances (process, protections) to his detriment	An enforceable contractual relationship exists (or promises are too vague) so estoppel does not apply; promises lack the required specificity	Dismissed with prejudice: promissory estoppel unavailable given contract context and vagueness of alleged promises

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard: plausibility and exclusion of mere conclusory allegations)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (established plausibility pleading framework)
Holmes v. Grubman, 568 F.3d 329 (2d Cir. 2009) (accept factual allegations as true on Rule 12(b)(6))
Doe v. Columbia Univ., 831 F.3d 46 (2d Cir. 2016) (Title IX erroneous-outcome framework; minimal inference of sex discrimination may survive dismissal)
Yusuf v. Vassar Coll., 35 F.3d 709 (2d Cir. 1994) (distinguishes erroneous outcome and selective enforcement Title IX claims)
Rolph v. Hobart & William Smith Colleges, 271 F. Supp. 3d 386 (W.D.N.Y. 2017) (applies Columbia factors to campus disciplinary bias claims)
Papelino v. Albany Coll. of Pharm. of Union Univ., 633 F.3d 81 (2d Cir. 2011) (student–university relationship is contractual)
Gally v. Columbia Univ., 22 F. Supp. 2d 199 (S.D.N.Y. 1998) (general institutional policy promises are insufficient to state breach-of-contract claims)