Doe v. Gonzaga University

John Doe (plaintiff), a Gonzaga University (defendant) teaching-program student, was accused by a fellow student of sexually assaulting another student, Jane Doe. Two Gonzaga officials investigated by interviewing witnesses and discussing the allegations with other students and faculty, but never told John about the investigation or gave him a chance to respond. Based on the investigation, the Dean concluded John lacked the moral character to be licensed as a teacher, and John was never allowed to appeal. At trial, Jane's own deposition undercut key statements from the investigation, and a jury awarded John $500,000 for defamation. The appellate court reversed, reasoning Gonzaga could not be liable for statements made only among its own employees.