A federal appeals court has upheld a lower court’s decision to dismiss a former Loyola University Chicago student’s lawsuit, ruling that there wasn’t enough evidence to suggest his expulsion for sexual misconduct was a result of sex discrimination or a breach of contract.
Matthew Metzler was expelled by Loyola in January 2017 after being found responsible for sexual misconduct. He subsequently sued the university, alleging that his expulsion violated Title IX, a federal law prohibiting sex discrimination in education, and that it also constituted a breach of contract. The district court had previously granted summary judgment in favor of Loyola, finding that Metzler had not presented sufficient evidence to support his claims. Metzler appealed this decision to the U.S. Court of Appeals for the Seventh Circuit.
The Accusations and Investigation
The case stems from a short relationship Metzler had with another undergraduate student, referred to as Jane Roe. According to Roe, Metzler pressured her into several sexual acts without her consent. Roe initially reported her distress to her athletic coach, which led to a meeting with Loyola’s Deputy Title IX Coordinator, Rabia Khan Harvey. In that meeting, Roe stated she didn’t believe she was “forced or coerced” but felt manipulated. However, she did not wish to file a formal complaint at that time.
Later that semester, Roe expressed her ongoing distress to another university official, Jay Malcolm. The following fall, she reported feeling unsafe and met with Tim Love, Khan Harvey’s interim replacement. It was at this point, in late October, that Roe decided to file a formal complaint against Metzler.
Around the same time, another former Loyola student, who had allegedly experienced similar issues with Metzler, also filed a complaint. The university initiated its student misconduct procedures, which were considered a binding contract between Metzler and Loyola. Investigators were assigned to look into both complaints.
The Investigation’s Findings and Metzler’s Defense
During the investigation, Metzler provided names of potential witnesses, including his roommate and a person they visited after the first incident. However, these individuals were not interviewed by the investigators. Roe’s roommate was interviewed, and text messages between Metzler and Roe were also considered.
The investigation report, which Metzler reviewed and confirmed as accurately representing his perspective, included his account of a conversation with Roe preceding the second incident where they “mutually agreed that they had moved fast physically and ‘that no one was coerced.’” However, during the hearing board proceeding, when asked about this conversation, Metzler stated the subject of coercion did not arise, and the quotation marks around “no one was coerced” misrepresented his comment. An investigator later testified that Metzler had repeatedly used that language.
The hearing board found Metzler responsible for non-consensual sexual contact and penetration, expelling him. The board cited Roe’s consistent account and her providing information against her own interest as reasons for crediting her testimony over Metzler’s, noting his inconsistency regarding the coercion discussion. A separate hearing board found Metzler not responsible for any violations related to the second complaint.
Metzler appealed the decision regarding Roe’s complaint, arguing the board failed to consider his witnesses and interview transcript. Loyola reinstated his expulsion after the appeals officer affirmed the board’s decision.
The Court’s Reasoning
The Seventh Circuit Court of Appeals reviewed the district court’s decision to grant summary judgment, examining the evidence in the light most favorable to Metzler.
Title IX Claim
To succeed on a Title IX claim, Metzler had to show that Loyola discriminated against him based on sex. The court noted that while evidence of public pressure on universities regarding sexual misconduct can be relevant, it is not enough on its own. Metzler pointed to a 2011 “Dear Colleague” letter from the Department of Education encouraging a more rigorous approach to sexual misconduct allegations and pressure from student groups. While acknowledging this evidence is relevant, the court found it less compelling than in previous cases where federal investigations added weight to the pressure. Crucially, Metzler failed to provide evidence of discrimination “particular to his case.”
Regarding the board’s credibility assessment, Metzler argued that a board member’s skepticism about Roe eagerly initiating sex, based on her being a first-time sexual experience, was based on gender stereotypes. The court disagreed, finding the inference was based on sexual inexperience, not gender. Metzler’s claim that the credibility determination was simply incorrect was also insufficient; he had to show the decision was based on his sex. The court deferred to the board’s credibility findings, noting they cited sound reasons like Roe’s statements against her interest and Metzler’s inconsistency.
Metzler also raised procedural errors. The court highlighted two potential errors: the failure to consider Khan Harvey’s report of Roe’s initial statement and the investigators’ decision not to interview Metzler’s witnesses. However, Metzler provided no evidence linking these omissions to sex bias, suggesting they could be explained by incompetence or pro-complainant bias. The court emphasized that federal courts do not micromanage university disciplinary hearings and that procedural mistakes alone do not prove sex discrimination.
Considering all the evidence, the court concluded that no reasonable fact-finder could find that Loyola discriminated against Metzler based on his sex.
Breach of Contract Claim
Metzler argued that Loyola breached their contractual agreement (the community standards) by expelling him through a proceeding inconsistent with those standards. He contended that gender was a motivating factor in the expulsion, relying on his Title IX arguments. Since those arguments failed, the court rejected his contract claim on this basis.
Metzler also argued that Loyola expelled him to appease Roe and campus activists, lacking a rational basis. The court found that even if procedural errors occurred, a substantiated accusation of sexual misconduct provided a rational basis for expulsion. Metzler did not present evidence to overcome this conclusion.
Conclusion
The Seventh Circuit affirmed the district court’s judgment, stating it is not the role of federal courts to re-decide what happened in romantic relationships. Metzler, the court concluded, did not present enough evidence to suggest that Loyola’s disciplinary decision was based on his sex.