Schiebel v. Schoharie Cent. Sch. Dist.
N/A - Case recently decided, reporter info not yet available (2024)
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Rule of Law:
An individual accused of sexual misconduct states a plausible Title IX sex discrimination claim against a federally funded educational institution by alleging either: (1) the institution was deliberately indifferent to the truth or falsity of the accusation, evidenced by a procedurally deficient sham investigation and an inexplicable outcome; or (2) the institution took official action to affirmatively discriminate, evidenced by procedural irregularities coupled with facts suggesting the bias was sex-based, such as stereotypical comments from a decision-maker.
Facts:
- Keith Schiebel, an agriculture educator, brought his 'Mobile Maple Experience' educational trailer to the Schoharie Central School District (SCSD) campus.
- Nearly a month later, Superintendent David Blanchard informed Schiebel that a student's mother reported he made her daughter 'uncomfortable,' but specified that the mother did not want any further action taken.
- Over the next few weeks, Schiebel repeatedly requested details about the incident, but SCSD officials ignored his requests.
- SCSD eventually held a single meeting lasting less than 25 minutes, where Title IX Coordinator Kristin DuGuay stated she was scared of Schiebel and 'was aware of the exits'.
- DuGuay then informed Schiebel he was accused of reaching around a female student with two hands and touching her breast and buttocks.
- Schiebel, unable to recall the specific student or incident, speculated that in the crowded trailer he 'may have reached around a student at one point... to get something.'
- Immediately after Schiebel made this statement, DuGuay abruptly ended the meeting without further questions.
- Two weeks later, DuGuay issued a finding that Schiebel committed sexual harassment, basing her conclusion on his failure to deny that he 'may have reached around the Student.' As a result of this finding, Schiebel's contracts with the New York State Maple Producers Association were terminated.
Procedural Posture:
- Keith Schiebel filed a lawsuit in the United States District Court for the Northern District of New York against Schoharie Central School District, Kristin DuGuay, and David Blanchard.
- Schiebel's complaint alleged a Title IX sex discrimination claim against the school district and various state law claims against all defendants.
- The defendants filed a motion to dismiss for failure to state a claim.
- The district court (trial court) granted the motion to dismiss the Title IX claim, concluding Schiebel had failed to plausibly allege that sex-based bias was a motivating factor in the erroneous finding.
- Having dismissed the federal claim, the district court declined to exercise supplemental jurisdiction over the state law claims and dismissed them without prejudice.
- Schiebel (Plaintiff-Appellant) appealed the district court's judgment to the United States Court of Appeals for the Second Circuit.
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Issue:
Does an accused individual plausibly allege a Title IX sex discrimination claim by asserting that an educational institution's investigation was procedurally deficient, its decision inexplicable, and its Title IX coordinator exhibited sex-based bias against him?
Opinions:
Majority - Menashi
Yes. An accused individual plausibly alleges a Title IX sex discrimination claim by demonstrating that the institution's disciplinary process was either deliberately indifferent to the truth or affirmatively discriminatory on the basis of sex. The court found Schiebel stated a plausible claim under two distinct theories. First, under a 'deliberate indifference' theory, the complaint alleged the investigation was a sham process because SCSD was deliberately indifferent to the truth or falsity of the accusation. This was supported by numerous procedural deficiencies, including lack of notice, no opportunity to present evidence, a biased investigator who also acted as decision-maker, and a failure to presume innocence, all contrary to Title IX regulations. The outcome was 'inexplicable' as it relied on twisting Schiebel's speculative statement into a confession and misapplied the district's own definition of sexual harassment. Second, under an 'official action' theory, the complaint plausibly alleged affirmative discrimination. The procedural irregularities suggested bias, and DuGuay's statement that she was aware of the exits because she was scared of Schiebel allowed a plausible inference that this bias was sex-based, reflecting an 'invidious sex stereotype' that men are inherently dangerous. This combination of procedural flaws and direct evidence of a decision-maker's sex-based bias is sufficient to state a claim.
Analysis:
This decision solidifies two viable legal theories for respondents (accused parties) in Title IX cases within the Second Circuit, enhancing their ability to challenge disciplinary proceedings they allege are biased. By recognizing that deliberate indifference to the truth of a sex-based accusation constitutes a Title IX violation, the court extends a theory traditionally used by complainants to respondents. Furthermore, the ruling establishes that direct comments from a decision-maker reflecting sex stereotypes, when combined with a flawed investigation, are sufficient to plausibly allege affirmative sex discrimination, lowering the pleading burden for accused individuals who believe they were victims of anti-male bias.
