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Reason
Reason
Eugene Volokh

Title IX Sexual Assault Cases and Extraterritoriality

From today's decision by Judge Paul Maloney (W.D. Mich.) in Doe v. Calvin Univ.:

In 2020, Plaintiff Jane Doe attended Calvin University in Grand Rapids, Michigan. Calvin University offered a study abroad program in the Philippines with Silliman University, a private university in Dumaguete, Philippines. Silliman University selected some of its students to serve as "buddies" for the Calvin University students. Near the end of the program, the students attended a dinner on the Silliman campus. After the dinner, the Silliman students invited the Calvin students to a local bar and club. One of the Silliman students laced or spiked Plaintiff's drink and later escorted her back to the hotel where he sexually assaulted Plaintiff.

Plaintiff sued under, among other things, Title IX, and Calvin defended by arguing "that Title IX does not apply outside of the United States." No, said the court: "Plaintiff pleads deliberate indifference in the administration of the program, a claim based on Calvin University's conduct in the United States."

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