The Connecticut Supreme Court recently concluded a university disciplinary proceeding arising from a sexual assault allegation was not quasi-judicial and therefore did not afford the complainant with absolute immunity for the statements she made during the proceeding.
According to the court’s opinion, “Jane Doe” accused the plaintiff of sexual misconduct in disciplinary proceedings conducted by the Ivy League university they both attended. The plaintiff was expelled from the University. He filed suit in federal court against the university, several university employees, and Doe. His claims against Doe included defamation and tortious interference with business relationships.
The District Court concluded the disciplinary proceeding was quasi-judicial and Doe had absolute immunity for the statements she made during the proceeding under Connecticut law. It concluded extending immunity to the university’s disciplinary proceedings was warranted under Connecticut’s six-factor test to identify quasi-judicial proceedings and as a matter of public policy.