Elizabeth Doe Lawsuit vs. Baylor University



Good evening, Atlantic Coast Conference (ACC) fans.

As you know, we’ve written about Baylor (and their unconscionable environment for sexual assault victims) on many occasions here at the site.

Recently, a lawsuit was filed by Baylor sexual assault victim, Elizabeth Doe (her name is protected for privacy purposes) – and the lawsuit alleges the following (I went through all 26 pages in this brief):

  • Baylor coaches’ recruiting efforts used sex to sell the program. (Doe vs. Baylor, P. 4, 1/27/17)
  • Baylor football coaches implemented a “Show’em a good time” policy using the Baylor Bruin hostess program (many of these women had sex with a recruit to gain his football commitment – Baylor generally looked the other way on this sort of activity), paying for and escorting underage recurits to bars and strip clubs, and paying for off-campus football parties (which resulted in gang rape of women by the athletes). (Doe vs. Baylor, P. 4-5, 1/27/17)
  • Kendall Briles, while recruiting a Dallas area athlete stated, “Do you like white women?  Because we have a lot of them at Baylor and they LOVE football players.” (Doe vs. Baylor, P. 4, 1/27/17)
  • Almost all of the football players involved in the rapes were recruited and brought to Waco to play football. (Doe vs. Baylor, P. 6, 1/27/17)
  • Under Briles, the culture of Baylor football and rape became synonymous. (Doe vs. Baylor, P. 7, 1/27/17)
  • From 2011 to 2014, there were 52 acts of rape, including five gang rapes (with at least two of those committed by 10 or more different Baylor football players), by not less than 31 different football players under Briles.  And only two players were dismissed by Baylor. (Doe vs. Baylor, P. 7, 1/27/17)
  • A former Title IX investigator through that culture of sexual violence terrible – she was informed by the Baylor Police Department that she was not safe to do her job – and that she should look over her shoulder when walking to her car. (Doe vs. Baylor, P. 8, 1/27/17)
  • Baylor had a policy of little or no discipline for football players, had a policy of interference with female students’ access to help, had a separate system of discipline for the football team (for sexual and dating violence), had a policy of not reporting allegations of sexual violence and dating violence, had a policy of diverting [sexual violence and dating violence] cases from student conduct or criminal processes, had a policy of not educating students/staff [on sexual violence and dating violence], had a policy of accepting football players with histories of violence towards women, had a policy of “Show’em a good time” in recruiting, and the use of a sexually hostile football hostess program. (Doe vs. Baylor, P. 9-13, 1/27/17)

In April 2013, Elizabeth Doe was violently gang raped two football players (this is rather graphic here – entire quote below is from Doe vs. Baylor, P. 16-18, 1/27/17):

81. Mr. Oakman was hosting a football party that evening with a number of his teammates in attendance, including freshman football players Tre’Von Armstead and Shamycheal Chatman

82. While at Mr. Oakman’s party, Ms. Doe became very intoxicated

83 Ms. Doe later learned that Mr. Chatman and Mr. Armstead accompanied Ms. Doe from the party and back to her apartment.

84. Later that evening, Ms. Doe’s roommate came home with her boyfriend, and noticed that the front door to the apartment was ajar. Concerned that someone was in the house unlawfully, the roommate’s boyrfriend walked through the residence checking for any trouble.

85. As he was checking the upstairs bedroom, the door to the room shared by Ms. Doe and the man’s girlfriend was closed. The roommate’s boyfriend could hear what sounded like wrestling and a fist hitting someone. The next thing that he heard was a loud bang and a slapping noise accompanied by hearing a woman’s voice loudly saying “no.” The roommate’s boyfriend then shouted from the other side of the door to determine if everything was okay. One of the men inside of the bedroom yelled out that she “was fine” but the roommate’s boyfriend insisted further on seeing her come out of the room. Armstead and Chatman would soon emerge from the room with 6’7”, 311 pound Armstead attempting to stare down the roommate’s boyfriend. The young man looked into the dark room and saw Ms. Doe partially unclothed on the floor of the bedroom and said “she is not fine.”

86. The young man indicated to Armstead and Chatman that he was calling 911, which he did as soon as they left.

87. Prior to the police arriving, another BAYLOR Bruin showed up at Ms. Doe’s apartment with at least one other individual. The Bruin was somehow already aware that a rape had been reported and was trying to get Ms. Doe to cover for the assailants. The Bruin told Ms. Doe that she needed to tell the police that she had “consensual sex with one white male” in an apparent effort to protect the BAYLOR athletes.

88. The Title IX investigation would later show that Chatman had called the Bruin and given her this assignment.

89. The Bruin remained on scene when the Waco Police Department arrived, interfering with Ms. Doe’s recitation of events. Nonetheless, the roommate’s boyfriend and Ms. Doe’s roommate clearly reported the events as rape by Chatman and Armstead.

90. While on scene, Waco Police noted that Ms. Doe was highly intoxicated, had a bruise on her cheek and a bite mark on her neck.

91. The Waco Police Department did little with the case, indicating that it was likely too difficult to prove and gave Ms. Doe the alternate option of placing the investigation in “suspended” status. Not wanting the Waco Police to close the case, she chose suspended status.

92. Waco Police never even attempted to interview Armstead or Chatman.

93. Prior to suspending their investigation, Waco Police notified BAYLOR Police of what had been reported about their two football players.

94. In response to learning that two of their football players had been reported for rape, BAYLOR took no action.

95. In a 60 Minutes Sports interview that aired on October 31, 2016, BAYLOR Chief Financial Officer, Reagan Ramsower who oversees the BAYLOR Police Department admitted, “There was a police report; I suppose it stayed with the police department. It never came out of the police department. That was a significant failure to respond by our police department, there’s no doubt about it.”

96. After Ms. Doe became the second woman to implicate Chatman in a rape, Chatman left BAYLOR.

But Baylor didn’t stop there – it continued to subject Doe to harassment (entire quote below is from Doe vs. Baylor, P. 18-20, 1/27/17):

101. The result of BAYLOR’s continued sexually hostile and discriminatory policies combined with Ms. Doe being required to attend school with one of her rapists, created a highly hostile educational environment for Ms. Doe on a daily basis.

102. BAYLOR was clearly on notice of the report that one of their female students, Ms. Doe, was raped by two BAYLOR football players.

103. As a result, BAYLOR had control over both of the offenders as well as the context of the ongoing harassment and had the ability to address its effects and prevent its recurrence.

104. As a result of BAYLOR’s policies to avoid discipline for football players, Ms. Doe was forced to continue to attend school in the presence of Armstead.

105. Ms. Doe walked onto campus in daily fear of running into her rapist and in fact did just that on repeat occasions. Such run-ins would trigger panic attacks where Ms. Doe would hyperventilate, suffer from nausea, have light headedness and experience other emotional trauma.

106. Following these panic attacks, Doe would then struggle to attend classes and concentrate. With her learning environment shattered, her grades suffered and she began to limit her involvement in any nonessential activity at BAYLOR by staying away from campus except when needed for classes. Ms. Doe also resigned from the BAYLOR Bruin program.

107. As a result of the rape and when Ms. Doe would get overwhelmed with anxiety, Ms. Doe would stay the night at her then-boyfriend’s residence. At some point, Ms. Doe learned that Armstead lived in that very same building. Ms. Doe could not escape him both on and off campus.

108. For the remainder of her time at BAYLOR, Ms. Doe struggled under the pressure of the hostile environment and her academics, her educational opportunities, and her emotional well-being suffered.

109. Meanwhile, Armstead and his football career remained unhindered and he would become one of the star athletes for Briles’ program earning all Big-12 honors in 2014.


115. As a result of BAYLOR’s actions and inactions as alleged herein, Plaintiff has suffered, and continues to suffer, physical injury, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, humiliation, and loss of enjoyment of life; and expenses for future medical and psychological care.

You can never know how a rape victim feels, but you have to read the brief yourself to know that Baylor did nothing to protect any of its sexual assault victims.

Doe is suing Baylor for 1.) Discrimination under Title IX: Sexually Hostile Culture, 2.) Gender Discrimination Under Title IX:  Deliberate Indifference to Plaintiff’s Rape, 3.) Negligence – a Sexually Hostile Culture, 4.) Negligence – Failure to Supervise (Employees Within the Football Program), 5.) Failure to Response to First Rape of Samycheal Chatman, and 6.) Gross Negligence.

I hope she wins her lawsuit – but more importantly, I want Doe to get her life back.

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