United States v Morrison 529 U S 598 120 S Ct 1740 U S 2000 May 15 2000 SUMMARY Petitioner Christy Brzonkala enrolled at Virginia Polytechnic Institute Virginia Tech in the fall of 1994 In September of that year Brzonkala met respondents Antonio Morrison and James Crawford who were both students at Virginia Tech and members of its varsity football team Brzonkala alleges that within 30 minutes of meeting Morrison and Crawford they assaulted and repeatedly raped her Morrison threatened Brzonkala that she better not have any diseases In the months following the assault Morrison was also overheard speaking about vulgar offensive topics such as getting women drunk and taking advantage of them Brzonkala alleges that this attack caused her to become severely emotionally disturbed and depressed She sought assistance from a university psychiatrist who prescribed antidepressant medication Shortly after the rape Brzonkala stopped attending classes and withdrew from the university ISSUE In early 1995 Brzonkala filed a complaint against respondents under Virginia Tech s Sexual Assault Policy During the school conducted hearing on her complaint Morrison admitted having sexual contact with her despite the fact that she had twice told him no After the hearing Virginia Tech s Judicial Committee found insufficient evidence to punish Crawford but found Morrison guilty of sexual assault and sentenced him to immediate suspension for two semesters Virginia Tech s dean of students upheld the judicial committee s sentence However in July 1995 Virginia Tech informed Brzonkala that Morrison intended to initiate a court challenge to his conviction under the Sexual Assault Policy University officials told her that a second hearing would be necessary to remedy the school s error in prosecuting her complaint under that policy which had not been widely circulated to students The university therefore conducted a second hearing under its Abusive Conduct Policy which was in force prior to the dissemination of the Sexual Assault Policy Following this second hearing the Judicial Committee again found Morrison guilty and sentenced him to an identical 2 semester suspension This time however the description of Morrison s offense was without explanation changed from sexual assault to using abusive language Morrison appealed his second conviction through the university s administrative system On August 21 1995 Virginia Tech s senior vice president and provost set aside Morrison s punishment She concluded that it was excessive when compared with other cases where there has been a finding of violation of the Abusive Conduct Policy Virginia Tech did not inform Brzonkala of this decision After learning from a newspaper that Morrison would be returning to Virginia Tech for the fall 1995 semester she dropped out of the university In December 1995 Brzonkala sued Morrison Crawford and Virginia Tech in the United States District Court for the Western District of Virginia Her complaint alleged that Morrison s and Crawford s attack violated The Fourteenth Amendment and that Virginia Tech s handling of her complaint violated Title IX of the Education Amendments Morrison and Crawford moved to dismiss this complaint on the grounds that it failed to state a claim The District Court dismissed Brzonkala s Title IX claims against Virginia Tech for failure to state a claim upon which relief can be granted It then held that Brzonkala s complaint stated a claim against Morrison and Crawford under The Fourteenth Amendment but dismissed the complaint because it concluded that Congress lacked authority to enact the section under either the Commerce Clause or 5 of the Fourteenth Amendment RULES OF LAW Violence Against Women Act VAWA Virginia Tech s Sexual Assault Policy Virginia Tech s Abusive Conduct Policy Fourteenth Amendment the part to protect the civil rights of victims of gender motivated violence Education Amendment Title IX APPLICATION Morrison was found guilt of the Violence Against Women Act VT s Sexual Assault Policy and VT s Abusive Conduct Policy Morrison and Crawford were not found guilt under section 5 of the Fourteenth Amendment and Virginia Tech was not penalized under the Education Amendment due to insufficient claims CONCLUSION Morrison was punished by suspension of 2 semesters Crawford was not charged Virginia Tech was not charged Brzonkala spent a lot of money
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