John Doe 2 v. North Carolina State University

John Doe 2 v. North Carolina State University

In this appeal, the Fourth Circuit held that a school’s Title IX obligation to investigate sexual harassment could be triggered by a report of “sexual grooming.”

The case arises from 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 suit, 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. In January 2025, the Court reversed, holding that the report of “sexual grooming” could have provided the school actual notice. The case will now proceed at the district court.