Plaintiff appealed a partial final judgment by a United States District Court judge dismissing his claims alleging "defamation and tortious interference with contract" brought against Yale University and certain named parties [University]. University had accused Plaintiff, of sexual assaulting another student, "Jane Doe" [Doe], while both were students at Yale.
Plaintiff argued that the district court erred in finding:
1. University had absolute quasi-judicial immunity for statements made at a University disciplinary hearing that resulted in Plaintiff’s expulsion from Yale; and
2. Plaintiff’s tortious interference claims were untimely.
In its preliminary review, the Second Circuit said it was unable to determine whether the Connecticut Supreme Court [Connecticut] would recognize the Yale disciplinary hearing at issue as a quasi-judicial proceeding, supporting University's claim of absolute immunity in the action brought by Plaintiff. Accordingly, it certified questions pertinent to that issue to Connecticut.
Connecticut responded, indicating that absolute immunity could not be claimed by University in Plaintiff's action because the Yale disciplinary hearing at issue was not a quasi-judicial proceeding. Connecticut explained the Yale disciplinary hearing lacked certain procedural safeguards such as an oath requirement, the ability to call witnesses, an opportunity to cross-examine witnesses, meaningful assistance of counsel, and an adequate record for appeal, all typically associated with judicial proceedings.
Further, while Connecticut recognized the possibility for participants in such a hearing to be shielded by qualified immunity, Connecticut concluded the "University is not presently entitled to dismissal on that ground because [Plaintiff’s] complaint sufficiently pleads the malice necessary to defeat such immunity."
Accordingly, the Second Circuit:
1. Affirmed, in part, so much of
the district court's judgment that dismissed as untimely Plaintiff’s tortious interference
claim based on Doe’s 2015 statements; and
2. Vacated, in part, so much of the district court's judgment that dismissed Plaintiff's action under color of absolute immunity with respect to Plaintiff’s defamation and tortious interference claims based on Doe’s 2018 statements.
The Second Circuit then remanded the matter to the district court "for further proceedings consistent with this opinion."
Click HERE to access the Second Circuit's decision posted on the Internet.