John Doe 2 v. North Carolina State University

John Doe 2 v. North Carolina State University

This is an appeal concerning sexual abuse at North Carolina State University. In 2016, the University’s senior associate athletic director received a report that an athletic trainer and administrator, Robert Murphy, was engaging in “sexual grooming” of male student-athletes. “Grooming” is behavior designed to prime victims for sexual abuse. The University adjusted Murphy’s responsibilities. It did not, however, take meaningful action to stop him from abusing further student-athletes. One of Murphy’s later victims was “John Doe 2,” a student who was twice sexually abused by the trainer in 2021.

Mr. Doe sued the University under Title IX of the Education Amendments of 1972 for failing to stop Murphy’s pattern of abuse. The district court dismissed the case, reasoning that the University did not have “actual notice” of sexual harassment. Public Justice joined the case to assist with an appeal to the U.S. Court of Appeals for the Fourth Circuit. The appeal is currently pending.