John Doe v. Univ. of Kentucky
860 F.3d 365
| 6th Cir. | 2017Background
- John Doe sued the University of Kentucky and Denise Simpson seeking injunctive and monetary relief during ongoing university disciplinary proceedings.
- Disciplinary proceedings arose from a complaint accusing Doe of nonconsensual sexual activity with a female student identified as Student A, leading to multiple hearings.
- The Hearing Panel found a violation and imposed a one-year suspension; the University Appeals Board reversed due to due-process concerns about Simpson’s withholding of evidence and witness questions.
- A second hearing occurred; the UAB again found violations, and Doe appealed with the UAB returning the matter for another hearing due to due-process errors including improper partitioning and denial of a supplemental proceeding.
- A third hearing was anticipated; Doe filed suit in district court seeking to enjoin the university proceedings and asserting federal due process, equal protection, and Title IX claims; the district court abstained and dismissed damages against Simpson.
- The Sixth Circuit affirmed abstention, reversed the dismissal of claims against Simpson, and remanded to stay the case pending the university proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Younger abstention applies | Doe argues ongoing state disciplinary proceedings should allow federal relief. | Univers ity contends abstention is proper under Younger due to ongoing state proceedings and state interests. | Abstention applies; Younger doctrine abstains federal involvement. |
| Whether Middlesex factors support abstention | Doe contends state process inadequately protected due to prior due-process flaws. | University argues proceedings are ongoing adjudicative activities with substantial state interest and adequate opportunity to raise claims. | Middlesex factors satisfied; abstention proper. |
| Whether the district court should have stayed or dismissed claims against Simpson after abstention | Doe seeks to proceed against Simpson in federal court despite abstention. | Simpson argues dismissal is appropriate following abstention. | Damages claims should be stayed, not dismissed; affirmed in part and remanded. |
Key Cases Cited
- Nimer v. Litchfield Twp. Bd. of Trustees, 707 F.3d 699 (6th Cir. 2013) (framework for reviewing Younger abstention)
- New Orleans Pub. Serv., Inc. v. Council of City of New Orleans, 491 U.S. 350 (1989) (NOPSI categories for Younger abstention)
- Middlesex County Ethics Committee v. Garden State Bar Ass'n, 457 U.S. 423 (1982) (three-factor test for abstention after exceptional finding)
- Sprint Commc'ns, Inc. v. Jacobs, 134 S. Ct. 584 (2013) (clarified Middlesex factors application post-NOPSI)
- Doe v. Cummins, 662 F. App’x 437 (6th Cir. 2016) (school disciplinary proceedings can be adjudicative and trigger Younger)
- Fieger v. Thomas, 74 F.3d 740 (6th Cir. 1996) ( Younger exceptions and harassment considerations)
- Carroll v. City of Mount Clemens, 139 F.3d 1072 (6th Cir. 1998) (proper course is to stay damages claims after abstention)
- Quackenbush v. Allstate Insurance Co., 517 U.S. 706 (1996) (separation of abstention decision from merits; stay vs. dismiss)
- Meyers v. Franklin County Court of Common Pleas, 23 F. App’x 201 (6th Cir. 2001) (stay rather than dismiss injunctive claim after abstention)