Doe v. Regents of University of California

John Doe (plaintiff) and Jane Roe were undergraduate students at the University of California, Santa Barbara (university) (defendant). After John and Jane attended a party, they engaged in sexual relations. The next day, Jane filed a police report claiming that the relations were not consensual. A criminal investigation ensued, but no charges were filed. The university conducted its own investigation. After university investigators interviewed John and Jane, they submitted a report to the university’s office of judicial affairs. The report concluded that John either knew or should have known that Jane was incapacitated during the encounter. The office of judicial affairs adopted the report’s recommendation to suspend John for three years for committing sexual assault. A university review committee upheld the decision. John sued the university, seeking a writ of mandamus ordering the university to set aside its disciplinary decision. Among other things, John argued that the decision was invalid because of procedural-due-process violations, such as the university’s failure to give John an opportunity to question Jane. The trial court agreed that John was not afforded proper procedural due process and granted the requested writ. Jane learned of the writ when the university notified her it was reopening the case against John. She filed a motion to vacate the writ, arguing, among other things, that the writ was void because the trial court’s failure to join her as a party as required by California’s compulsory-joinder statute deprived the court of jurisdiction. The court denied Jane’s motion, and Jane appealed.