Students May Sue Professors Individually For Sexual Harassment Under Massachusetts Law

Key Takeaways:

• The Massachusetts Supreme Judicial Court held in Sabatini v. Knouse that a student sexually harassed in an academic setting may sue the individual perpetrator directly under G. L. c. 214, § 1C, not just the educational institution.
• The decision expands the universe of potential defendants in academic harassment cases to include faculty, advisors, mentors, and fellowship directors, who now face personal exposure to actual and punitive damages, attorney’s fees, and costs.
• Colleges, universities, and research institutes should review their anti-harassment policies, training, indemnification arrangements, and insurance coverage to account for the risk of individual liability alongside institutional claims.

On May 19, 2026, the Massachusetts Supreme Judicial Court ruled in Sabatini v. Knouse that a student who is sexually harassed in an academic setting may sue the individual responsible, not just the school or institution. The decision expands the universe of potential defendants in academic harassment cases and is significant for colleges, universities, research institutes, and the faculty and administrators who work within them.

In Sabatini, the plaintiff was a tenured MIT professor and director of a laboratory at the Whitehead Institute for Biomedical Research. He served as one of the defendant student’s instructors at MIT and as a member of her dissertation committee, and later, after she joined Whitehead as a fellow, was her fellowship director and mentor. The defendant student alleged that, in 2016, during a discussion about whether the plaintiff would endorse the student’s fellowship application, he made sexually explicit inquiries about her personal life; that they had a sexual relationship from 2018 to 2019; and that his sexualized comments continued after the relationship ended while he remained a mentor and reviewer of her work. An independent investigation commissioned by Whitehead concluded that the plaintiff had engaged in and tolerated sexist and sexualized work discussions in his laboratory, fostered a “culture of fear and retaliation,” and violated Whitehead’s sexual harassment policy. He resigned from Whitehead, and MIT placed him on leave.

While MIT’s investigation was ongoing, the professor sued the student, Whitehead, and Whitehead’s director for defamation and related claims. The student counterclaimed for sexual harassment under G. L. c. 214, § 1C. The Superior Court dismissed the counterclaim, holding that G. L. c. 214, § 1C does not allow claims against individuals. The Appeals Court affirmed, but the SJC granted further review limited to that question.

The SJC reversed the Appeals Court’s decision. It held that nothing in G. L. c. 214, § 1C shields individual harassers from suit, and that immunizing them would be inconsistent with the statute’s broad remedial purpose. The statute gives every person the right “to be free from sexual harassment” and authorizes the Superior Court to enforce that right, without limiting who may be sued. The court noted that the statute closely tracks the Massachusetts right-to-privacy statute, under which both individuals and institutions have long faced suit.

The court rejected the argument that the sexual harassment statute should be limited to suits against educational institutions. While the statute borrows the definition of “sexual harassment” from the Commonwealth’s anti-discrimination laws (G. L. cc. 151B and 151C), it does not adopt the provision in c. 151C that makes only educational institutions liable for “unfair educational practices.” The court reasoned that the Legislature’s decision to expressly incorporate some provisions but not that one strongly suggests it intended to leave the others out. The court distinguished its prior decision in Lowery v. Klemm, 446 Mass. 572 (2006), in which it held that the sexual harassment statute applies only in the employment and academic contexts, explaining that Lowery used the borrowed definitions only to limit where the statute applies, not who can be sued under it.

The court also concluded that allowing direct claims against individuals fits the broader statutory scheme. Because nonvocational students have no administrative remedy under c. 151C, they need not file first with the Massachusetts Commission Against Discrimination before suing. On remand, the trial court will consider the plaintiff’s remaining grounds for dismissal, including whether Whitehead qualifies as an “educational institution” under G. L. c. 151C, whether the defendant qualified as a “student” during her Whitehead fellowship, and whether her claim was timely.

The Sabatini decision meaningfully expands who can be named as a defendant in academic sexual harassment cases in Massachusetts. Many practitioners and lower courts had previously treated the relevant anti-discrimination provision as authorizing claims only against educational institutions. After Sabatini, faculty, advisors, mentors, fellowship directors, and other individuals can be sued directly and face exposure to actual and punitive damages, attorney’s fees, and costs.

Plaintiffs in the academic context generally may proceed directly in court, without first going through an administrative agency, and within the relatively generous limitations period borrowed from G. L. c. 151B. Claims against individuals will frequently be paired with claims against the institution itself, complicating defense strategy, settlement, and indemnification decisions.

In light of the decision, educational institutions and their faculty and administrators should consider taking the following steps:

1. Review anti-harassment policies and training to make sure they address conduct by individual faculty, supervisors, mentors, and program directors, and make clear that those individuals, not just the institution, can face personal legal exposure.
2. Reassess indemnification, insurance, and defense arrangements, including whether indemnification provisions in faculty appointment letters, employment agreements, and bylaws, as well as existing educators’ liability and EPLI coverage, adequately cover claims against individuals, punitive damages, and fee awards.
3. Strengthen reporting, investigation, and documentation protocols so that internal complaint and recordkeeping procedures support prompt, thorough, and well-documented responses. Investigative findings may later be used in private litigation against individuals.
4. Pay close attention to mentorship and power dynamics. The court’s recitation of the facts highlights the risks in relationships involving career-defining power imbalances between faculty and students, postdoctoral fellows, and trainees. Reinforce expectations around personal relationships between mentors and mentees, and provide clear, retaliation-free channels for trainees to raise concerns.

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