On May 19, 2026, the Massachusetts Supreme Judicial Court unanimously held in Sabatini v. Knouse, SJC-13781, that individuals in academic settings can be held personally liable for sexual harassment under M.G. L. c. 214, § 1C. Until this decision, professors and advisors accused of sexual harassment could argue that the statute permitted suits only against institutions, not individuals. The SJC has now rejected that argument. For schools, universities, and employers, this decision has immediate implications and should prompt a review of policies, training, and risk management strategies.
Link to What Happened? What Happened?
David Sabatini was a prominent professor at MIT and lab director at the Whitehead Institute for Biomedical Research. Kristin Knouse was his student and later a research fellow under his supervision at Whitehead. According to Knouse, Sabatini used his position of power to coerce her into a relationship while she was under his mentorship, leaving her feeling trapped and afraid to speak up.
The matter came to light in 2020 when Whitehead’s director, Ruth Lehmann, commissioned a diversity survey that revealed reports of a “sexualized culture and retaliatory environment” at the lab. An independent investigation concluded that Sabatini had violated Whitehead’s sexual harassment policy. He resigned from Whitehead; MIT placed him on leave.
Sabatini then sued Knouse for defamation, along with the Whitehead Institute and Lehmann. Knouse countersued for sexual harassment. Sabatini moved to dismiss her claim, arguing that under Massachusetts law, you can only sue an institution for sexual harassment—not an individual person. Both the trial court and the Appeals Court agreed with him. The Supreme Judicial Court unanimously reversed.
Link to Why Did the Court Rule This Way? Why Did the Court Rule This Way?
The court offered several reasons for its decision:
- The law says what it means. The statute gives people “a right to be free from sexual harassment.” As Justice Wendlandt wrote for the unanimous court: “Nothing in the statute’s plain meaning shields individuals who perpetrate sexual harassment.”
- Legislative intent supports individual liability. The Legislature expressly borrowed certain provisions from other statutes—including the definition of sexual harassment and available damages—but pointedly left out any limitation on who can be sued. That omission was intentional. Because civil rights statutes like this one are “remedial,” courts interpret them broadly to fulfill their purpose. The statute was specifically designed to extend protection to people who might otherwise fall through the cracks, such as students who cannot use the administrative complaint process available to employees.
- A similar law already applies to individuals. The sexual harassment statute uses nearly identical language to the Massachusetts privacy statute, which says people have “a right against unreasonable, substantial or serious interference with [their] privacy.” Courts have long allowed privacy claims against both individuals and institutions. The SJC saw “no reason to adopt a narrower construction” for sexual harassment.
The case was sent back to the lower court for further proceedings on Sabatini’s remaining defenses.
Link to Why This Matters Why This Matters
For educational institutions, including K-12 schools and institutions of higher education,, the impact is direct and immediate. Individual faculty members or other individuals at such institutions can now be personally sued for sexual harassment under Massachusetts law. The institutional shield that lower courts had created is gone. As Knouse’s lead appellate attorney, Ellen Zucker, stated: “Individual advisors, teachers and mentors cannot hide behind their institutions and will not be spared responsibility for the damage they cause to those who come to them to learn and to train.” This is particularly significant for K-12 schools, colleges, and universities where faculty and staff have substantial influence over students, fellows, and early-career professionals—the very power imbalance at the heart of the Sabatini case.
For employers more broadly, the court’s reasoning is worth watching, but the procedural landscape differs. In the employment context, M.G. L. c. 151B provides a comprehensive administrative scheme, and employees generally must pursue remedies through the Massachusetts Commission Against Discrimination (MCAD) before filing suit. The court’s opinion does not disturb this framework. That said, because the statute’s plain language does not distinguish between academic and employment settings, the decision may invite future litigation testing whether individual managers, supervisors, and mentors can be held personally liable in the workplace.
Link to What Should Schools and Employers Do Now? What Should Schools and Employers Do Now?
- Ensure your anti-harassment policies are current and comprehensive. Policies should clearly prohibit sexual harassment, outline a robust process for reporting and investigating complaints, and explain the potential consequences for violations.
- Train supervisors, faculty, and mentors on personal liability. Training should go beyond explaining what constitutes sexual harassment. Make clear that individual perpetrators face direct legal exposure, including actual and punitive damages and attorney’s fees. This is a fundamentally different message than “the institution could get sued.”
- Evaluate supervisory and mentoring relationships for power imbalances. The facts of Sabatini underscore how vulnerable individuals can be when their careers depend on a single supervisor’s endorsement. Assess whether adequate structural safeguards (multiple mentors, reporting channels that bypass the direct supervisor, regular check-ins) are in place to prevent exploitation.
- Revisit indemnification and insurance. If your institution has historically agreed to cover individual faculty or staff for harassment claims, consider whether that arrangement remains appropriate. Review your liability insurance to confirm individual claims are covered.
- Strengthen your reporting mechanisms. The “culture of fear and retaliation” described in Sabatini illustrates the danger of reporting structures that depend on the alleged harasser. Ensure students, fellows, and employees have confidential, accessible reporting channels that do not require disclosure to the person with supervisory authority over them.
- For higher education institutions, address the faculty-student dynamic directly. Colleges and universities should issue specific guidance regarding professional boundaries, noting that any romantic or sexual relationships with students, fellows, or individuals under supervision or mentorship are prohibited or, at minimum, subject to mandatory disclosure and reassignment where appropriate. Violations may expose the individual to personal liability under Sabatini.
- For K–12 schools, the message is even more direct. Romantic or sexual relationships between teachers or staff and K-12 students generally constitute criminal conduct and must be treated as such in school policies. Note that the Massachusetts Senate recently voted unanimously for a budget amendment to close a longstanding gap in state law that does not currently criminalize consensual sexual relationships between educators and students over the age of 16; the amendment now heads to a conference committee with the House. K-12 schools should ensure their codes of conduct unequivocally prohibit these relationships, and train staff on the criminal and civil consequences.
- Document and investigate promptly. The independent investigation at Whitehead that uncovered Sabatini’s conduct provided the factual record supporting Knouse’s claims. Prompt, thorough, and impartial investigations remain your best tool for identifying misconduct and limiting exposure.
The court’s conclusion was clear: “in the academic context, the sexual harassment statute permits claims against individual perpetrators.” The case was sent back to the lower court for further proceedings on Sabatini’s remaining defenses, including whether Whitehead qualifies as an “educational institution” and whether Knouse was a “student” during her fellowship. But the core legal question is now settled: in academic settings, individuals can be personally sued for sexual harassment under M.G. L. c. 214, § 1C.
We will continue monitoring developments in this area. If you have questions about how this decision affects your policies, training, or potential exposure, please contact a member of Shipman & Goodwin’s School Law or Employment Law practice groups.