A former female student of Rhodes College, only identified as Jane Doe, has filed a lawsuit against Rhodes College, Sigma Alpha Epsilon (SAE), Tennessee Zeta Chapter and three additional parties.

In February, Doe reported to Memphis police that she had been raped at the SAE house. Police executed a search warrant and notified the college. Rhodes launched its own Title IX investigation and expelled two SAE members in connection to the alleged assault.

The two expelled students filed their own lawsuits against Rhodes, saying they were denied a fair hearing. The parties settled the matter out of court and dismissed the case with prejudice.

According to Jane Doe’s complaint, SAE National has a dark history of alcohol and drug abuse and sexual assault that “seemingly permeates throughout the entire organization.” The complaint notes that the fraternity has been named the “Deadliest Fraternity in America,” and on college campuses SAE is often said to stand for “Sexual Assault Expected.”

Despite this, the complaint alleges, SAE National and SAE Zeta Chapter ignore their responsibility to mitigate the risks of alcohol and drug abuse and sexual assault.

Doe also claims that Rhodes is well aware of the incidence of alcohol and drug abuse and sexual assault at its fraternities and many of the reasonable precautions it can enact to prevent these problems. Despite this, “Rhodes largely does nothing to mitigate these hazards,” according to the complaint.

Defendant Smith invited Doe to attend a formal at the SAE house on Feb. 14. Smith was a member of SAE and was a senior at Rhodes College set to graduate in May 2019. Doe claims that the party was specifically planned so that “copious amounts of alcohol and illegal drugs would be made available to members and guests.” Smith, according to the complaint, encouraged Doe to drink during the party and made her multiple Vodka drinks, and encouraged her to consume illegal drugs. Smith then took Doe up to an unfinished attic area where others were doing drugs and drinking. At some point during the evening while in the attic, Doe became incapacitated, the complaint claims.

Around 10:15PM, Doe alleges that Smith and others sexually assaulted her. Because of her incapacitation, Doe “had no way to resist the sexual assaults from these individuals and certainly could not consent to the sexual assaults.”

Neither the Zeta chapter nor SAE National reported the incident to Rhodes’ Title IX office, which is a requirement according to SAE and Rhodes policies.

Doe claims that all defendants “breached the duty of care by acting with reckless disregard for [Doe’s] rights and well-being, causing her harm through non-consensual sexual assault.” Since the night of the alleged assault, Doe has suffered from post-traumatic stress disorder and continues to have flashbacks of the assault.

Doe’s complaint asserts claims of assault, battery and intentional infliction of emotional distress against Smith and two unnamed defendants. It also asserts a claim of negligent infliction of emotional distress against all defendants.

Doe seeks compensatory and punitive damages in an amount according to proof at trial.

When asked for comment, Rhodes College wrote:

“The college recognizes the courage it takes for victims of sexual assault to come forward. Rhodes is committed to approaching the legal process with as much sensitivity and care as possible while defending itself against the claims asserted against the college in the complaint.”