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Doe v. Gonzaga University

Washington Supreme Court
24 P.3d 390 (Wash. 2001)


John Doe (plaintiff) was a student in the teaching program at Gonzaga University (Gonzaga) (defendant). During his time as a student, Doe had sexual relations with Jane Doe, another student. The following year, Roberta League, Gonzaga’s teacher certification specialist, overheard student Julia Lynch talking about how John Doe had sexually assaulted Jane Doe, and how she was unhappy Gonzaga had not done anything to investigate the incident. League told another school official, Dr. Susan Kyle, about the incident and the two decided to conduct an investigation. League and Kyle interviewed Lynch who said Jane Doe told her she had been sexually assaulted by John Doe three times. Gonzaga further investigated the crime with multiple witnesses. However, John Doe was not informed of the investigation against him. Gonzaga interviewed Jane Doe about the incident, but she was equivocal in her testimony. After the school concluded its investigation, the Dean of the School of Education concluded John Doe was not fit to be licensed as a teacher due to problems with his moral character application from the incident. The Dean only told John of this a month later, and told him he had no right to appeal the situation. John Doe brought suit against Gonzaga for defamation. At trial, a videotaped deposition of Jane Doe corroborated his story, and Jane Doe stated there were false statements in many of the key declarations in the school’s investigation. The jury awarded John Doe $500,000 for defamation, and other damages for other counts, including invasion of privacy. Gonzaga appealed. The appellate court reversed on the ground that Gonzaga could not be held liable for communications made among its own employees. John Doe appealed.

Rule of Law


Holding and Reasoning (Ireland, J.)

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