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Williams v. Coppin State University
1:23-cv-02590
D. Maryland
Aug 22, 2024
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Background

  • Plaintiff Ibn Williams was a student-athlete on the Coppin State University basketball team, recruited by head coach Juan Dixon.
  • Williams alleges he was catfished, blackmailed, and sexually harassed by assistant coach Lucian Brownlee (previously a fellow player), with threats to expose compromising material unless he complied with sexual demands.
  • Williams claims university officials, including Dixon and athletic director Derek Carter, knew Brownlee was a predator and failed to act, then retaliated against Williams after he reported the incidents.
  • After reporting, Williams experienced further distress during the university's investigation, including invasive questioning and loss of housing/tuition aid, allegedly for retaliatory reasons.
  • The defendants moved to dismiss the amended complaint, asserting sovereign immunity and failure to state cognizable claims on various counts.
  • The court considered whether the claims could proceed against individual and institutional defendants under Maryland law (including the Maryland Tort Claims Act) and federal law (notably Title IX).

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Sovereign Immunity for Torts State actors (incl. Carter, Dixon) not immune for gross negligence/malice State and officials immune under MTCA unless gross negligence is specifically pled Carter/Dixon not immune for gross negligence, but Coppin State/USM/State are immune
Negligent Hiring/Retention Defendants had notice of Brownlee’s dangers yet hired/retained him negligently Carter, Dixon immune for negligence; no specific knowledge alleged Motion granted as to Carter/Dixon, denied as to Coppin State/USM/State re: Brownlee only
Breach of Contract Written scholarship contract with university signed by AD Carter No written contract alleged, or time-barred Suit may proceed; sufficient facts alleged in complaint
Title IX Sexual Harassment/Retaliation University failed to act despite notice, then retaliated by withholding aid Insufficient allegations to impute liability; no individual capacity liability Claims may proceed against institutional defendants; dismissed against Carter/Dixon
IIED Defendants’ conduct was intentional, extreme, and caused genuine distress Allegations conclusory or only against Brownlee IIED claim survives only as to Brownlee; insufficient facts as to Carter/Dixon

Key Cases Cited

  • Barbre v. Pope, 402 Md. 157 (Md. 2007) (distinguishing when state personnel may lose immunity for malice/gross negligence)
  • Jennings v. Univ. of N.C., 482 F.3d 686 (4th Cir. 2007) (deliberate indifference standard for imputing Title IX liability to institution)
  • Fitzgerald v. Barnstable Sch. Comm., 555 U.S. 246 (2009) (no individual liability under Title IX)
  • Stern v. Bd. of Regents, Univ. Sys. of Md., 380 Md. 691 (Md. 2004) (sovereign immunity and the requirement for written contracts for waiver)
Read the full case

Case Details

Case Name: Williams v. Coppin State University
Court Name: District Court, D. Maryland
Date Published: Aug 22, 2024
Citation: 1:23-cv-02590
Docket Number: 1:23-cv-02590
Court Abbreviation: D. Maryland