APPLETON, Wis. (WBAY) - A woman has filed a federal lawsuit against Lawrence University alleging the school failed to respond to reported sexual assaults on campus, making the plaintiff "more vulnerable to sexual assault."
The woman, who filed the suit as "Jane Doe", claims a fellow student sexually harassed or assaulted at least three other students prior to her assault.
We are not naming the man in the suit as he has not been criminally charged with sexual assault.
Jane Doe claims the student assaulted her on Oct. 28, 2017 on the private college campus in Appleton, and a second time on early November, 2017.
The lawsuit alleges Lawrence violated Title IX and Wisconsin negligence claims.
The suit says Doe was working at a campus athletic facility when she "became acquainted" with the man she says assaulted her. They would chat on social media and "socialize periodically."
She says she was unaware that this man had a record of reported assaults and harassment that was known by Lawrence.
Doe says at least three different female students had accused him of sexually assaulting or harassing them.
The student had been banned from attending "most fraternities because of his sexually aggressive behavior at those parties," reads the lawsuit.
On Oct. 28, Doe went to a frat party. The male student was also there. They did not leave together, but both ended up at a Lawrence dorm. The woman says he asked her to come to his dorm room to watch videos, but she told him that she was "too drunk and did not want anything to happen if she went to his dorm."
The lawsuit claims the man assured her nothing would happen.
At 3 a.m., the plaintiff went to the man's dorm. She said she was intoxicated to the point where she was barely conscisious.
The suit claims the man sexually assaulted her while she was too intoxicated to give consent.
The suit also claims the man lured Jane Doe into a study room in November, accused her of leading him on, and groped her. She says he tried to block her exit from the room unless she sat on his lap and gave him a kiss. She says she was afraid and complied in effort to get out of the room.
Jane Doe says her friends convinced her to make a complaint through Lawrence University's SHARE program, which is used to report sex assault on campus.
She didn't hear anything from the campus. She was informed that "there was nothing anyone could do about the situation until there were multiple reports about the same perpetrator," reads the lawsuit.
Jane Doe says she made a complaint to the Appleton Police Department on Jan. 5, 2018.
On Jan. 8, the parents of Jane Doe met with Lawrence Dean Curt Lauderdale and Title IX coordinator Kimberly Jones. The lawsuit states that Jones and Lauderdale told them they had received at least three reports from other women who had been harassed or assaulted by the accused.
Jones said she had been trying to get prior victims to file formal complaints. Jones told the Does that without formal complaints, the school could take no action.
Jones said the school took no action on Jane Doe's SHARE complaint because they "never received it."
On Jan. 13, Jane Doe gave a statement to Lawrence describing the assaults. Jones told Jane Doe she was the man's fourth assault victim, and that other victims had made similar claims against the man.
Jones put into place a "no contact order" limiting the male student's activities on campus and ordering Doe to "remove herself" when he was present.
Doe says the campus offered to waive an on-campus living requirement to allow Doe to live at home. Doe says living off campus would violate her right to an equal educational experience under Title IX.
Title IX ensures "no person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subject to to discrimination under any education program or activity receiving Federal financial assistance."
They offered Doe a "safe room" in a dorm. That room was right across from a friend of the accused student. She says he visited the room of his friend.
"On such occasions, Doe was trapped in her room and could not attend class, go to the library or eat in the cafeteria," reads the lawsuit.
Doe ended up spending time at home during the four-month investigation into the assault claims. She says it was impossible to avoid the accused. She missed classes and was forced to quit her job on campus, according to the lawsuit.
On March 16, Lawrence completed its investigation into Jane Doe's complaint. During the investigation period, another victim reported being sexually assaulted by the accused.
On April 4, the investigation was released. It found that the student had assaulted at least three female students and had harassed another female student.
About two weeks later, Lawrence expelled the male student.
The lawsuit states that Jane Doe's assault "adversely affected her educational opportunities."
The lawsuit requests a jury of six people hear the case.
Lawrence University tells Action 2 News it followed its policies when it comes to sexual assault, but cannot comment further on this case.
"We're taking care of students, ensuring that they have a safe environment and that students understand that they have recourse and that there are clear steps that they can take," said Ken Anselment, Lawrence University Vice President for Enrollment & Communication.