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Khan v. Yale University

Conn.June 27, 2023No. SC20705Cited 11 times
Plaintiff WinYale University
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Case Details

Judge(s)
Robinson; McDonald; D’Auria; Mullins; Ecker; Alexander; Keller
Status — whether other courts must follow this ruling
Published
Procedural Posture — the stage the case had reached
appeal

Related Laws

No specific laws identified for this ruling.

Outcome

The Connecticut Supreme Court reversed the District Court's dismissal and held that Yale University's disciplinary proceeding was not quasi-judicial, thereby denying the defendant witness absolute immunity for statements made during the sexual misconduct hearing. The case was remanded for further proceedings.

Excerpt

The plaintiff, who was an undergraduate student at Yale College, sought to recover damages in the United States District Court for the District of Connecticut in connection with statements the defendant D, a classmate of the plaintiff, made during a disciplinary hearing conducted by the named defendant university's committee on sexual misconduct (commit- tee). In 2015, D accused the plaintiff of sexually assaulting her in her dormitory, and the university suspended the plaintiff. The committee, however, stayed the disciplinary proceedings against the plaintiff pend- ing the outcome of a criminal case that the state had filed against him. The plaintiff subsequently was acquitted on multiple counts of sexual assault, and, in 2018, he resumed full-time student status at Yale. Shortly thereafter, however, as a result of the reporting in a student newspaper of additional allegations of sexual assault involving the plaintiff, the plaintiff agreed to undergo a mental health consultation, but he refused a request that he meet with university administrators. Subsequently, the university again suspended the plaintiff on the ground that it was necessary for the safety and well-being of the plaintiff and the university community. Thereafter, the committee convened a hearing in connection with D's 2015 sexual assault complaint. At the hearing, D, who had since graduated, provided a statement via teleconference, but she did not testify under oath or provide any sworn statement. The plaintiff and his counsel were not permitted in the hearing room when the hearing panel questioned D and, instead, listened to an audio feed from an anteroom. The plaintiff's counsel was not permitted to speak, question D or any other witness, or raise objections, and the hearing panel denied the plaintiff's request for a recording or transcript of the hearing. Addition- ally, the committee's procedures allowed the parties to submit questions that they wanted the hearing panel to ask and to request tha

What This Ruling Means

**Khan v. Yale University: Student Wins Right to Sue Over Disciplinary Hearing Statements** This case involved a Yale undergraduate student who was accused of sexual assault by a classmate in 2015. The university suspended the student after a disciplinary hearing. The suspended student then sued both his accuser and Yale University, claiming the accuser made false statements during the hearing that damaged his reputation and interfered with his future opportunities. The key legal question was whether the accuser had absolute immunity from being sued for statements made during the university's disciplinary process. Lower courts initially dismissed the case, but the Connecticut Supreme Court reversed this decision in 2023. The court ruled that Yale's disciplinary proceedings are not "quasi-judicial" (meaning they don't function like real courts), so the accuser doesn't have absolute protection from defamation lawsuits. This matters for workers because it clarifies that workplace disciplinary proceedings and internal investigations may not provide complete legal immunity for participants who make statements. If someone makes false statements about you during a workplace investigation or disciplinary hearing, you may have legal options to pursue defamation claims, depending on your state's laws and the specific circumstances.

This summary was generated to explain the ruling in plain English and is not legal advice.

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