The Massachusetts Supreme Judicial Court (SJC) recently answered an important question about sexual harassment claims that occur in higher education. In Sabatini v. Knouse, the Court held that G. L. c. 214, § 1C permits a plaintiff to bring a sexual harassment claim directly against an alleged individual harasser in the academic setting. The decision confirms that, in appropriate cases, liability under the statute is not limited to the educational institution.
The ruling addresses a relatively narrow question of statutory interpretation, but it has broader implications for students, researchers, postdoctoral fellows, and others whose academic work places them in close professional relationships with faculty members and senior researchers.
The Facts Behind the Decision
The plaintiff alleged that the defendant, a tenured faculty member and laboratory director, served in several positions that afforded him authority over her academic and research career, including as an instructor, thesis committee advisor, fellowship director, and mentor.
According to the complaint, the defendant made sexualized comments while assisting with her fellowship application. The parties later entered into a sexual relationship during the fellowship, and the plaintiff alleged that sexualized comments continued after the relationship ended. She also alleged that the defendant’s position at the Whitehead Institute was cause for legitimate concern that ending the relationship could adversely affect her academic and research opportunities.
The SJC also considered the findings of an internal investigation conducted by the Whitehead Institute. That investigation concluded that the defendant had engaged in sexist and sexualized workplace discussions and contributed to a laboratory culture in which those discussions were tolerated or encouraged, together with a broader culture of fear and retaliation.
The Court considered whether Massachusetts law permits a claim under G. L. c. 214, § 1C to proceed directly against an alleged individual harasser in an academic setting.
The Court’s Analysis
The defendant argued that claims should be limited by G. L. c. 151C, which identifies sexual harassment as an unfair educational practice by an educational institution. The SJC rejected that argument.
The Court explained that G. L. c. 214, § 1C expressly incorporates the definition of sexual harassment contained in G. L. c. 151C, but it does not incorporate the separate provision describing unfair educational practices by institutions. Where the Legislature intended one statute to adopt provisions from another, it did so expressly. The omission of the institutional liability provision was therefore treated as intentional.
The Court also relied on the remedial purpose of the statute, declining to interpret it in a way that would shield alleged individual perpetrators from liability where the Legislature had not provided such protection.
For that reason, the SJC concluded that claims under G. L. c. 214, § 1C may proceed directly against an alleged individual harasser in the academic context.
Why This Decision Is Relevant to Employees and Researchers at Higher Education Institutions
Although Sabatini arose in the context of higher education, many of the relationships described by the Court resemble workplace supervisory relationships.
Graduate students, research assistants, postdoctoral fellows, clinical trainees, and laboratory researchers frequently work under the direction of faculty members who supervise research, evaluate performance, control access to funding opportunities, write recommendations, and influence future career prospects. Those responsibilities often place academic supervisors in positions of substantial authority.
The SJC’s decision recognizes that claims arising from those relationships are not necessarily confined to proceedings against the institution itself. Depending on the circumstances, an alleged individual harasser may also be named as a defendant under Massachusetts law.
The decision also illustrates the role that institutional investigations may play in subsequent litigation. In Sabatini, the Court referred to findings made during the Whitehead Institute’s internal investigation regarding laboratory culture and allegations of retaliation. While every case depends on its own facts, internal complaints, investigation reports, emails, performance reviews, and other contemporaneous records may become relevant where allegations are later litigated.
Practical Implications
For those working or studying in higher education, Sabatini provides new clarity about who may be named in litigation arising from alleged sexual harassment.
The decision will almost certainly influence how colleges, universities, and research institutions approach internal investigations, reporting procedures, faculty training, and policies governing relationships between supervisors and those whose academic or professional progress depends on them.
For employees whose work overlaps with academic research or teaching, the case shows that workplace rights may be considered under more than one statutory framework, particularly where professional relationships involve supervision, mentoring, or evaluation.
The SJC’s decision in Sabatini v. Knouse confirms that G. L. c. 214, § 1C permits sexual harassment claims to proceed directly against alleged individual perpetrators in the academic setting. By focusing on the statutory language and the Legislature’s intent, the Court clarified an issue that had not previously been addressed by Massachusetts’ highest court.
Sexual harassment claims arising in colleges, universities, research institutions, and other academic environments often involve closely related questions of institutional responsibility, supervisory authority, and individual conduct. As Massachusetts courts continue to interpret these statutes, decisions such as Sabatini provide necessary guidance on how those claims may proceed and the legal framework that applies to those working and studying in higher education.
If you have experienced sexual harassment in an educational workplace setting, contact the attorneys at the Maura Greene Law Group for a confidential consultation, or call us at (617) 936-1580.
The Not So Fine Print:
Every case has its unique facts. Before you take any action, you should contact an employment lawyer and get advice on your own situation. We can’t provide legal advice here, and this isn’t intended as legal advice. It is best, if possible, to establish a relationship with an attorney before a workplace issue turns into a crisis.