Summary
The United States Court of Appeals for the Seventh Circuit affirmed summary judgment for Loyola University Chicago on Matthew Metzler’s Title IX sex-discrimination and breach-of-contract claims arising from his expulsion for sexual misconduct. The court held that evidence of generalized public pressure, credibility determinations, and alleged procedural errors did not permit a reasonable fact-finder to infer sex discrimination. It also held that the alleged procedural errors did not eliminate the rational basis for Loyola’s expulsion under Illinois contract law.
Topics
Practice areas
Questions Presented
- Whether the record contained sufficient evidence from which a reasonable fact-finder could conclude that Loyola discriminated against Metzler on the basis of sex in violation of Title IX.
- Whether Loyola breached its contractual community standards by expelling Metzler through a procedurally flawed disciplinary proceeding or without a rational basis.
Holdings
- Metzler did not present sufficient evidence from which a reasonable fact-finder could conclude that Loyola discriminated against him on the basis of sex. Generalized public pressure, a credibility determination allegedly influenced by sexual inexperience, and procedural errors not connected by evidence to sex bias were insufficient.
- Loyola did not breach the contract. Under Illinois law, a university’s disciplinary decision breaches its contractual obligations only when it lacks any rational basis because the university acted arbitrarily or in bad faith rather than exercising academic judgment. A substantiated sexual-misconduct accusation provided a rational basis for expulsion, and the alleged procedural errors did not negate that basis.
Key quotations
“Title IX specifically prohibits sex discrimination, not botched disciplinary proceedings.” (8)
“Federal courts do not micro-manage disciplinary hearings for universities.” (16)
“Considering the circumstances together, no reasonable fact-finder could conclude Loyola discriminated against Metzler on the basis of sex.” (17)
Factual background
Loyola expelled Metzler after a disciplinary hearing board found him responsible for nonconsensual sexual contact and penetration based principally on its assessment that the complainant was more credible. Metzler contended that Loyola’s disciplinary process contained procedural errors, including failure to consider a report concerning the complainant’s early statement that she had not been forced or coerced and failure to interview two witnesses identified by Metzler. He argued that public pressure, credibility reasoning, and those procedural irregularities showed sex discrimination and that the expulsion breached Loyola’s contractual community standards.
Procedural history
Metzler sued Loyola in the Northern District of Illinois after his expulsion for sexual misconduct, asserting Title IX and contract claims. The district court granted Loyola summary judgment. The Seventh Circuit previously remanded for determination of whether Metzler could proceed anonymously and whether his claims were moot. On remand, the district court required Metzler to proceed under his legal name, found the claims justiciable, entered an amended judgment for Loyola, and Metzler appealed.