Ludlow’s Lawsuit Against Northwestern Dismissed


Peter Ludlow’s legal claims against Northwestern University (previously), which included a Title IX claim, defamation and false light publicity claims, and a civil conspiracy claim, have all been dismissed, according to a ruling from Judge Sara L. Ellis of the US District Court (Northern District of Illinois, Eastern Division). From the ruling:

Northwestern University professor Peter Ludlow, the subject of two sexual harassment investigations involving both a graduate and an undergraduate student, brings this suit against Defendants Northwestern University (“Northwestern”), Morton Schapiro, Alan Cubbage, [grad student], Jennifer Lackey, and Joan Slavin claiming that Northwestern’s investigation of sexual harassment allegations against him in 2014 violated Title IX of the Education Amendments Act of 1972, 20 U.S.C. § 1681 et seq., and that Defendants’ comments associated with the 2012 and 2014 investigations defamed him and placed him in a false light. Defendants move to dismiss all claims [27, 29]. Because Ludlow has not sufficiently pleaded that the alleged discrimination had any connection to his gender, the Title IX claim against Northwestern is dismissed. Ludlow’s defamation and false light publicity claims against Northwestern and Cubbage are dismissed because the alleged statements are substantially true. The defamation and false light claim against Schapiro are dismissed because the statements attributed to him are either not highly offensive or are substantially true and, in any event, are non-actionable opinion. The false light claims against Slavin and [grad student] are dismissed because Ludlow has not sufficiently pleaded the publicity of those statements. The defamation claim against Slavin is dismissed because the statements attributed to her are either true, not highly offensive, can be innocently construed, or are non-verifiable opinion. Any claims related to statements by Lackey made in 2012 are barred by the one-year statute of limitations for defamation and false light claims. And the counts related to her 2014 complaint to the General Counsel are dismissed as too vague and ambiguous to support a claim. The defamation claim against [grad student] is dismissed because the statement was made under a qualified privilege and abuse of that privilege was not sufficiently pleaded. Finally, because all possible independent torts have been dismissed, Ludlow’s civil conspiracy count is also dismissed.

UPDATE: A redacted version of the judge’s opinion is here (the “notification of docket entry” simply stating the result is here).

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