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Brown students file a federal class-action lawsuit claiming the school doesn’t protect women from sexual abuse

End Sexual Violence at Brown, a new student-led organization, held a protest on campus in April.Lola Hakim/Handout

PROVIDENCE — Four women have filed a federal class-action complaint against Brown University, alleging it has systematically and repeatedly failed to protect women from harm, including rape, and that sexual assault at Brown is an “epidemic.”

Each of the women is a current or recent student at the university.

The suit was filed Aug. 6 in federal court in Providence. The prospective class would include all women — an estimated 4,000, according to recent surveys conducted by the university — who attended Brown starting in 2018, were survivors of sexual violence, and were allegedly further traumatized by the “complete neglect and dysfunction” of the university’s sexual misconduct response team.


The suit alleges that Brown “failed and continues to fail” to protect women and creates a campus culture that “ignores and even tacitly allows trauma to be inflicted on women.” The four women, all self-identified as sexual misconduct victims at the university, allege that Brown has violated its own pledge to investigate all forms of sexual misconduct under Title IX.

The filed complaint said that the school “actively prevented the reporting” of incidents of sexual violence and created an “inexcusable breach of trust with its students.”

Cass Cliatt, a university spokeswoman, rejected the women’s characterization of Brown’s efforts related to sexual harassment and assault.

“Brown has taken a strategic and sustained approach to confronting sexual harassment and gender-based violence on campus dating back to transformative recommendations from the University’s Sexual Assault Task Force in 2015,” she said in an e-mailed statement to The Boston Globe. “Every element of Brown’s approach to preventing and responding to issues of incidents of sexual misconduct is based on the reality that this is a serious issue, not only at colleges and universities across the U.S., but also beyond college campuses.”


Cliatt said that “every element” of Brown’s approach to prevent and respond to issues of incidents of sexual misconduct is based on the “reality that this is a serious issue.”

“Brown has made it an institutional priority to create an environment in which no incident of sexual violence is tolerated, and the experiences and perspective of students and others impacted by sexual violence have been instrumental in informing the actions we’ve taken,” said Cliatt.

The four women who filed the suit are Chloe Burns, a 2019 graduate; Taja Hirata-Epstein, a 2020 graduate; Katiana Soenen, a rising sophomore; and Carter Woodruff, who is on medical leave from Brown. They are seeking a permanent injunction to ensure “strict compliance with Title IX provisions.”

In a statement sent to the Globe, the four women claimed that survivors at Brown are “silenced, harmed, dismissed and discouraged from seeking justice by the university.”

“Brown’s recent history has been punctuated by numerous student uprisings led by survivors and their allies; however, the university has never responded to these pleas for justice with anything but begrudging, minor changes to policy and procedure,” said the women in a statement. “Despite claiming otherwise, the university has failed to ameliorate the rampant public health crisis of sexual violence on our campus. Though we four plaintiffs speak out against Brown’s abuse today, we hope our lawsuit will bring justice to the countless survivors who have suffered at the hands of the university.”

In early April, more than 200 students decked out in shades of pink marched to university president Christina Paxson’s home on College Hill and demanded the administration take a tougher stand against sexual violence on campus. The rally was one of several held on campuses across the country under the direction of University Survivors Movement, a student-led coalition looking to end sexual violence on campuses.


Organizers of Ending Sexual Violence at Brown had sent an open letter to the administration, demanding that it “put an end to its long history of neglect, apathy, and institutional exacerbation of the chronic public health and safety crisis that is sexual violence at Brown.”

But the first protest against sexual violence at Brown began in 1985 when survivors wrote the names of their perpetrators on the library bathroom walls.

In 2019, Brown released survey data on campus-based sexual assault and misconduct that said students had reported “increased trust” in the university and knowledge of resources. Of the 3,100 Brown students surveyed, one-quarter of undergraduate women reported receiving nonconsensual sexual contact while at Brown. But more than 48 percent of all students reported experiencing at least one type of offensive or inappropriate behavior of a sexual nature.

The four women are being represented by firms Grant & Eisenhofer and Saltz Mongeluzzi & Bendesky.

Cocounsel Kim Evans of Grant & Eisenhofer, who heads the firm’s civil rights group, told the Globe that Brown has ignored the voices of these four women, and others who have demanded reform.


“We hold Ivy Leagues to a different standard. We expect institutions like that to go above and beyond. Here, it was shocking to us that Brown isn’t even doing the bare minimum here,” said Evans, who has worked similar cases such as Sterling et al v. Evanstown Township High School District 202 et al, which was an action related to claims in connection with the sexual assault and inappropriate grooming of the plaintiff and other female students by the school’s safety officers.

“It’s what sets this case apart,” Evans said. “Brown should know better and they should be doing more. There’s a repeat pattern of failures.”

Trial attorney Elizabeth Bailey of Saltz Mongeluzzi & Bendesky said that based on the firm’s presuit investigation, she believes many more sexual violence survivors will come forward.

Alexa Gagosz can be reached at alexa.gagosz@globe.com. Follow her on Twitter @alexagagosz and on Instagram @AlexaGagosz.