California Court Finds College Not Liable for Third Party Harassment Not Related to College’s Programs or Activities

In Karasek v. Regents of the University of California, No. 3:15-cv-03717-WHO (N. D. Cal. April 12, 2018), the court granted summary judgment to the University of California (UC) on the plaintiff’s Title IX claims.

The plaintiff, Aryle Butler, was an undergraduate student at UC Berkeley from 2012 to 2015. During the summer of 2012, she was employed as a research assistant to a UC Berkeley graduate student in a remote part of Alaska. Butler did not earn academic credit for her work and was not paid through UC, but was paid directly by the graduate student using grant funds. While working that summer, Butler lived at the Wrangell Mountains Center, an entity unaffiliated with UC. The Center also housed programming for the Alaska Wildlands Studies Program, which was also unaffiliated with UC. Butler claimed she was sexually assaulted by a part-time instructor with the Alaska Wildlands Studies Program at the Center. She filed suit against UC alleging gender discrimination in violation of Title IX.

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