Background - John Doe (male student) and Jane Doe (female student) engaged in alcohol consumption and sexual contact on Sept. 13–14, 2014; John alleges he was too intoxicated to remember events; Jane submitted a statement describing a mix of consensual and nonconsensual acts. - Miami University initiated disciplinary proceedings after a report; John received notice, a summary hearing, and then an Administrative Hearing Panel found him responsible for nonconsensual oral sex and suspended him for multiple terms (later reduced on appeal). - John sued Miami University and several individual university officials under Title IX and 42 U.S.C. § 1983 (procedural and substantive due process; equal protection), dismissing state claims against Jane by settlement. - The district court granted defendants’ Rule 12(b)(6) motion and dismissed John’s claims; John appealed multiple issues to the Sixth Circuit. - Sixth Circuit affirmed dismissal of Title IX hostile-environment and deliberate-indifference claims and § 1983 substantive-due-process claim; reversed dismissal of Title IX erroneous-outcome claim and § 1983 procedural-due-process and equal-protection claims as to the investigator/administrator (Vaughn); remanded. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---|---| | Title IX hostile-environment | University process was permeated by gender bias that altered educational environment | No facts show severe or pervasive discrimination altering access to education | Dismissed — allegations insufficient | | Title IX deliberate indifference | University was deliberately indifferent to sexual misconduct against John | Plaintiff failed to allege sexual-harassment severe/pervasive enough to trigger Davis standard | Dismissed — single incident insufficient | | Title IX erroneous outcome | Panel decision was flawed and attributable to gender bias (statistical patterns, external pressure, inconsistencies in evidence) | Outcome explanation adequate and no plausible causal link to gender bias | Reversed — pleadings plausibly cast doubt on accuracy and allege circumstantial evidence of gender bias; remanded | | §1983 Equal Protection (Vaughn) | Vaughn pursued disciplinary action against John but not Jane despite information that both may have violated policy — intentional gender-based treatment | Decisions were discretionary and not motivated by gender; presumption of neutrality | Reversed as to Vaughn — plaintiff plausibly alleged disparate treatment and discriminatory intent; claims against other individual defendants affirmed dismissed | | §1983 Procedural Due Process (Vaughn) | Vaughn served as investigator/prosecutor and panel member, dominated hearing, made statements suggesting pre-determination; plaintiff was denied evidence | Defendants argue presumption of impartiality and adequate notice/process; internal policy deviations not constitutional violations | Reversed as to Vaughn — plausible claim that Vaughn was not impartial and withheld evidence; other defendants affirmed dismissed | | §1983 Substantive Due Process | University conduct was conscience-shocking or deprived property interest in education/transcript | Sanctioning rationally related to legitimate interest; no conscience-shocking conduct; no fundamental right to continued education | Affirmed dismissal — no substantive due-process violation | ### Key Cases Cited Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard requires plausibility) Bell Atlantic v. Twombly, 550 U.S. 544 (2007) (plausibility pleading framework) Goss v. Lopez, 419 U.S. 565 (1975) (due process requirements for student suspensions) Davis v. Monroe County Bd. of Educ., 526 U.S. 629 (1999) (Title IX deliberate-indifference standard requires harassment severe, pervasive, and objectively offensive) Yusuf v. Vassar Coll., 35 F.3d 709 (2d Cir. 1994) (theories for Title IX challenges to disciplinary proceedings, including erroneous outcome) Heyne v. Metropolitan Nashville Public Schools, 655 F.3d 556 (6th Cir. 2011) (impartiality requirement for school disciplinary decision-makers) Flaim v. Medical College of Ohio, 418 F.3d 629 (6th Cir. 2005) (procedural due process in higher-education discipline; appeal-related discussion) University of Cincinnati v. _, 872 F.3d 393 (6th Cir. 2017) (minimum process: notice, explanation of evidence, opportunity to present defense; relevance to sexual-assault adjudications) Bell v. Ohio State University, 351 F.3d 240 (6th Cir. 2003) (relation between equal-protection and substantive-due-process claims in academic-discipline context) Pahssen v. Merrill Community School District, 668 F.3d 356 (6th Cir. 2012) (single or limited incidents may be insufficient to meet severe/pervasive standard)