Olaoluwa Faparusi v. Case Western Reserve Univ.
711 F. App'x 269
| 6th Cir. | 2017Background
- In March 2016, CWRU suspended sophomore Olaoluwa Faparusi after an incident in which female students accused him of taking photos under women’s restroom stall walls; CWRU investigated, held a hearing, found him responsible for sexual exploitation and disorderly conduct, and suspended him.
- Faparusi alleges he was misidentified, received less than 24 hours' access to evidence before his hearing, was not notified of the disorderly conduct charge in advance, and that the investigation/hearing process deviated from the university handbook.
- He sued pro se, asserting Fourteenth Amendment due process violations (federal) and a state-law breach of contract claim based on the handbook; named CWRU, the hearing administrator, and an investigator as defendants.
- The district court (after a magistrate judge R&R) denied injunctive relief and granted defendants’ motion to dismiss all claims; Faparusi appealed.
- The Sixth Circuit reviewed de novo, construed facts in plaintiff’s favor, and affirmed dismissal of all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the district court fail to perform de novo review of the magistrate judge’s R&R? | District court did not correct factual errors in the R&R and therefore failed to review de novo. | District court properly reviewed the objections and there was no material error in the R&R to correct. | No reversible error; district court performed required review and any alleged R&R inaccuracies were harmless. |
| Should the claims be characterized as Title IX claims or standalone Fourteenth Amendment due process claims? | Faparusi insists his claims are straight Due Process claims, not Title IX. | Defendants and lower tribunals treated the pleadings as effectively raising Title IX-related allegations. | Court agreed the pleadings could be viewed as Title IX-related but assumed Due Process framing; dismissal was affirmed regardless of characterization. |
| Was CWRU a state actor such that Fourteenth Amendment due process applies? | Faparusi contends CWRU acted under color of law (enforcing Title IX) and thus is subject to constitutional due process requirements. | CWRU is a private actor; enforcing federal law or receiving federal funds does not alone convert it into a state actor. | CWRU was not a state actor; plaintiff failed to allege facts meeting public-function, state-compulsion, or nexus tests; due process claims dismissed. |
| Did CWRU breach its handbook (contract) by procedural deviations (e.g., two hearings, inadequate notice)? | Faparusi argues handbook guarantees were violated (notice provisions, single-hearing language, deviation from procedures). | CWRU says meetings with complainants were investigative, not hearings; overall process (notice, evidence, hearing, appeal) met handbook expectations. | Breach of contract claim dismissed: handbook procedures were not clearly breached and proceedings fell within reasonable expectations. |
Key Cases Cited
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard applies)
- Ashcroft v. Iqbal, 556 U.S. 662 (complaints must plead facts supporting legal conclusions)
- Keys v. Humana, Inc., 684 F.3d 605 (6th Cir. 2012) (standard of review for motions to dismiss)
- Lansing v. City of Memphis, 202 F.3d 821 (6th Cir. 2000) (tests for when private conduct is state action)
- Fellheimer v. Middlebury Coll., 869 F. Supp. 238 (D. Vt. 1994) (private-school handbook deviations analyzed under contract principles)
- Pierre v. Univ. of Dayton, 143 F. Supp. 3d 703 (S.D. Ohio 2015) (reasonableness standard for handbook-based contract claims)