On January 11, 2022, the U.S. Court of Appeals for the Third
Circuit issued a precedential opinion in Hall v. Millersville
University. The Third Circuit reversed the district
court's grant of summary judgment for Millersville University,
and found that federal funding recipients may be held liable under
Title IX even when the harassment is committed by third parties
completely unaffiliated with the recipient. The Court relied on
U.S. Supreme Court decisions holding that funding recipients could
be liable under Title IX where the recipient was aware of
harassment and had authority to address it, but remained
deliberately indifferent.
BACKGROUND
Plaintiffs John and Jeanette Hall sued Millersville University
pursuant to Title IX after their daughter, a student at
Millersville, was murdered in her dorm room by her boyfriend, a
non-student guest. The student had invited the boyfriend into her
dorm room. The University had previously removed the boyfriend from
campus
