In Sabatini v. Knouse, No. SJC-13781 (Mass. May 19, 2026), the Massachusetts Supreme Judicial Court held that, in the academic context, G. L. c. 214, § 1C permits a sexual harassment claim to proceed directly against an alleged individual perpetrator, not only against an educational institution. Massachusetts law, specifically, G. L. c. 214, § 1C, sets forth the right to be free from sexual harassment in Massachusetts and gives the Superior Court jurisdiction to enforce that right and award damages.
In Sabatini, the SJC framed the issue as whether the Massachusetts sexual harassment statute gives a plaintiff/victim in the academic context a cause of action directly against the individual alleged harasser under this Massachusetts-specific law, in addition to claims against the employer institution. The court answered yes, concluding that “in the academic context, the sexual harassment statute permits claims against individual perpetrators of sexual harassment” and that nothing in the statute’s plain meaning shields individual perpetrators from liability.
Why the Decision Matters for Massachusetts Institutions of Higher Education
For Massachusetts colleges and universities, the decision confirms that academic sexual harassment litigation may proceed against both institutions and individual defendants. The SJC also emphasized that the Massachusetts statutory framework operates differently in academic settings than it does in employment cases. In particular, the court explained that nonvocational students generally do not have comparable administrative remedies under G. L. c. 151C and the anti-duplication clause therefore does not bar them from proceeding directly in Superior Court under G. L. c. 214, § 1C.
As a result, institutions should expect academic sexual harassment claims to be filed directly in court, including claims naming individual faculty members, mentors, or other alleged perpetrators in the academic setting.
The Case and the SJC’s Reasoning
In Sabatini, the alleged harasser/defendant was a tenured faculty member and director of a lab at the Whitehead Institute and served as the student/plaintiff’s former instructor, thesis committee advisor, fellowship director, and mentor. The plaintiff alleged that the defendant made sexualized comments toward her while supporting her application for a fellowship in a lab at the Whitehead Institute that was in close proximity to the defendant’s lab, that the two engaged in a sexual relationship during her fellowship, and that the defendant continued to make sexualized comments toward the plaintiff after their relationship ended. Because of the defendant’s position and influence within the Whitehead Institute, the plaintiff experienced concern that ending the relationship could harm her academic and research career because of the alleged harasser’s influence.
The SJC also considered the results of an internal investigation at the Whitehead Institute that found that the defendant had participated in sexist and sexualized work discussions and contributed to a laboratory culture in which such discussions were tolerated or promoted, as well as a culture of fear and retaliation.
Sabatini argued that individual liability under G. L. c. 214, § 1C should be limited by G. L. c. 151C, § 2(g), which identifies sexual harassment as an unfair educational practice by an “educational institution.” The SJC rejected that argument, explaining that G. L. c. 214, § 1C incorporates the definition of “sexual harassment” from G. L. c. 151C, but does not incorporate G. L. c. 151C’s separate unfair educational practices provision.
The court further reasoned that, where the Legislature intended G. L. c. 214, § 1C to incorporate specific provisions from G. L. cc. 151B and 151C, it did so expressly, and the omission of G. L. c. 151C’s institutional-liability provision should not be supplied by the court. The opinion also emphasized the statute’s remedial purpose and declined to construe it narrowly in a manner that would protect alleged individual harassers from suit.
What Massachusetts Institutions of Higher Education Should Do Now
Massachusetts colleges and universities should treat the SJC’s decision in Sabatini as an opportunity to review sexual harassment and consensual relationship policies, as well as related training, to ensure they clearly address misconduct by faculty, instructors, advisors, mentors, program directors, laboratory leaders, and others who exercise academic authority over students or trainees. Universities should emphasize to faculty and staff that, because they may now be personally subject to sexual harassment liability under G. L. c. 214, § 1C, it is essential for them to receive training and communicate with university administrators and general counsel when concerns about sexual harassment or consensual romantic or sexual relationships arise.
Reporting channels likewise warrant close review, including both formal reporting mechanisms and confidential reporting options, particularly for complaints involving senior faculty or other influential academic personnel, where fear of retaliation may deter reporting.
Institutions also should evaluate their litigation readiness for G. L. c. 214, § 1C claims brought by students against faculty or staff, including whether institutional indemnification policies may apply if an individual employee is named as a defendant. If indemnification may be available, institutions should consider in advance how they will address representation, coordination, and risk allocation when both the institution and the individual employee are named in the same action.
How Hunton’s Higher Education Team Can Help
Hunton’s higher education team regularly advises institutions of higher education on compliance with Massachusetts law and federal requirements relating to sexual misconduct and sexual harassment. If you have questions about this decision or its implications for your institution, please reach out to a Hunton attorney.
