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