Suspended male Princeton student’s Title IX lawsuit against U. can proceed, appeals court rules

A federal appeals court ruled that a Title IX lawsuit brought by a male undergraduate student who was suspended in 2023 after being found responsible for choking two female students can move forward. 

The ruling, decided on July 21, reversed the New Jersey district court’s decision dismissing the lawsuit in its entirety. The ruling allows the male student to continue pursuing his Title IX lawsuit against the University. 

At issue is whether or not sex motivated the University’s decision to suspend the male student.

At the center of the case are claims from two female students, identified in court documents as “Sarah Smith” and “Jane Roe.” They filed separate complaints against the male student, “John Doe,” alleging that he choked them in arguments at or on the way to campus parties during the spring of 2023.

The following fall, Doe, a sophomore at the time, was investigated for the two incidents after Smith and Roe separately submitted reports to the University. According to court documents, the Faculty-Student Committee on Discipline found Doe responsible for assaulting Smith and Roe. Doe was also found in violation of the University’s Alcohol Policy by allegedly hosting a serving alcohol to underage individuals. 

Doe was suspended for two years on grounds that he violated the University’s Personal Safety Policy, which bans “any physical assault committed … on the premises of the University or in the local vicinity, especially when unprovoked and/or when injury results.”

Doe filed a lawsuit against the University for breach of contract, Title IX violations, and negligence in June 2024, which was later dismissed by the New Jersey district court for failing to state a claim.

In a ruling released this July, a three-judge panel of the U.S. Court of Appeals for the Third Circuit reversed the dismissal unanimously and sent the case back to the district court for further evidence-gathering and trial. 

The appeals court found that Doe’s allegations about the University’s handling of the investigation were sufficient to allow his Title IX claim to proceed. Doe alleged that both Smith and Roe’s stories had “evolved” over the course of Princeton’s internal investigation and an “inconsistent manner of seeking out evidence.”

Universities including Princeton have “struggled to find the proper balance” between protecting victims and ensuring that respondents receive fairness, Circuit Judge Cheryl Ann Krause wrote in the ruling. 

University spokesperson Jennifer Morrill emphasized that the appeals court did not rule on the merits of Doe’s allegations. In a statement to The Daily Princetonian, she highlighted that the court was reviewing the District Court’s decision “to dismiss [Plaintiff’s] complaint for failure to state a claim,” rather than determining the factuality of the allegations.

According to the complaint, Princeton gave the students who accused Doe multiple opportunities to address his account of the incidents, interviewing each of them three times during the investigation. Doe, who denied the allegations, was questioned about these claims only once by Princeton during the investigation. 

“John’s supportive witnesses, all of whom were male, likewise went largely unheard,” Krause wrote. 

“The University intends to defend the matter vigorously,” Morrill wrote in a statement to the ‘Prince.’ 

Doe’s attorney, Christopher Muha, wrote to the ‘Prince’ that his legal team “hope[s] to move forward as quickly as possible for our client.” He added, “we are just very pleased with the unanimous decision.” 

The ruling follows a separate 2022 ruling in a case involving “a steady, and steadily volatile, relationship” that led to a male student’s expulsion. The Third Circuit allowed the male student’s Title IX discrimination complaint to proceed, which is still currently being litigated.  

Seven sexual misconduct cases were fully investigated by the Title IX office during the 2024–25 academic year, according to the University’s latest sexual misconduct report. Over the same year, two sex discrimination matters were investigated and adjudicated internally. In both cases, the proceedings did not result in the finding of a violation of Princeton’s discrimination or sexual misconduct policies.

Sena Chang is the associate News editor for the ‘Prince’ leading investigations. She is from Japan and South Korea, and she often covers local politics and student life. She can be reached at sena[at]dailyprincetonian.com.

Please send any corrections to corrections[at]dailyprincetonian.com.