John Doe v. Columbia University, 2016 U.S. App. LEXIS 13773

Background

John Doe, a Columbia student, was accused by Jane Doe of non-consensual sexual intercourse; Columbia’s Title IX investigator prepared a report and a disciplinary panel found Doe responsible and suspended him until Fall 2015.
Doe alleges the investigator (Sessions-Stackhouse), the hearing panel, and the Dean acted with pro-female, anti-male bias, failed to follow procedures, declined to interview witnesses Doe identified, and relied on an investigator’s report that omitted favorable evidence.
The complaint asserts the University was under contemporaneous pressure from students and the press to appear tougher on sexual-assault complaints, creating an institutional motivation to favor complainants.
Columbia moved to dismiss under Rule 12(b)(6); the district court granted dismissal of federal claims and declined supplemental jurisdiction over state-law claims.
The Second Circuit reviewed whether the McDonnell Douglas/Littlejohn minimal-pleading inference of discriminatory intent applies to Title IX claims and whether Doe’s complaint plausibly alleged sex-based discrimination and institutional liability.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the McDonnell Douglas/Littlejohn minimal pleading framework apply to Title IX claims alleging sex discrimination in university discipline?	Littlejohn framework applies; Title IX claims should benefit from the same temporary presumption reducing pleading burden.	Title IX differs and does not require the Title VII-style burden-shifting at the pleading stage.	Held: Yes. The court applies the McDonnell Douglas/Littlejohn minimal plausible-inference pleading standard to Title IX disciplinary discrimination claims.
Did Doe plead sufficient facts to raise a minimal plausible inference of sex bias to survive 12(b)(6)?	Alleged investigator and panel ignored witnesses, deviated from procedures, reached conclusions unsupported by evidence, and acted against a backdrop of public pressure to protect female complainants.	Columbia: University’s conduct reflected lawful aims (taking allegations seriously, avoiding publicity/Title IX liability), not discrimination.	Held: Complaint sufficiently alleged specific facts giving rise to a minimal plausible inference of sex discrimination; dismissal vacated.
Can bias by an investigator who did not sit on the adjudicatory panel be imputed to the University?	Investigator had institutional influence; her report substantially informed the panel’s decision, so her bias is relevant to institutional liability.	Investigator did not make the ultimate decision; procedural errors by a non-decisionmaker cannot establish Title IX liability.	Held: Bias by an influential investigator can support institutional liability if the biased actor played a meaningful role in causing the adverse action.
Were state-law claims properly dismissed without prejudice pending resolution of federal claims?	Doe asserted diversity jurisdiction as well; state claims should be addressed on remand.	District court declined supplemental jurisdiction and dismissed state claims without prejudice.	Held: Dismissal of state-law claims vacated; district court must address them on remand.

Key Cases Cited

Littlejohn v. City of New York, 795 F.3d 297 (2d Cir. 2015) (articulating minimal plausible-inference pleading standard in Title VII discrimination suits)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (framework for burden-shifting in discrimination cases)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (pleading must allege facts supporting plausible inference of unlawful conduct)
Yusuf v. Vassar College, 35 F.3d 709 (2d Cir. 1994) (applying Title VII principles to Title IX disciplinary-discrimination claims)
Staub v. Proctor Hosp., 562 U.S. 411 (U.S. 2011) (employer liability where biased subordinate’s actions proximately cause adverse employment action)
Holcomb v. Iona College, 521 F.3d 130 (2d Cir. 2008) (biased institutional actors with meaningful role can support employer liability)