The U.S. Court of Appeals for the Seventh Circuit affirmed a district court's summary judgment in favor of Loyola University Chicago, upholding the university's 2017 expulsion of student Matthew Metzler for sexual misconduct in a decision issued Jan. 13, 2026.
The three-judge panel, consisting of Circuit Judges Frank Easterbrook, Ilana Rovner, and Amy St. Eve, unanimously rejected Metzler's claims that his expulsion violated Title IX's prohibition on sex discrimination and breached his contract with the university. Judge St. Eve wrote the opinion for the court.
Metzler was expelled in January 2017 after Loyola found him culpable for sexual misconduct involving a fellow undergraduate student identified in court documents as Jane Roe. The case stems from incidents that occurred in mid-January 2016 following three encounters between Metzler and Roe after they met on a campus shuttle bus and arranged a first date.
According to court records, both students acknowledged they engaged in sexual activity during their brief relationship. However, Roe alleged that Metzler pressured her into sexual acts without obtaining her consent and despite her protestations. The allegations came to light when Roe described the events to her athletic coach days after the incidents occurred.
On Jan. 26, 2016, Roe met with Loyola's Deputy Title IX Coordinator Rabia Khan Harvey to discuss the incidents. During that meeting, Roe indicated she did not want to pursue a formal complaint. Khan Harvey's summary of their conversation noted that although Roe "doesn't believe she was forced or coerced, she performed oral sex on the accused student and now feels that he is trying to manipulate the situation by accusing her that she'll report that he raped her."
The situation escalated later in the spring semester when Roe encountered Metzler at an athletic facility, though the court opinion does not detail what transpired during that encounter or how it led to the formal proceedings that resulted in Metzler's expulsion.
Following his expulsion, Metzler filed a federal lawsuit against Loyola in 2018, arguing that the university's disciplinary action constituted sex discrimination under Title IX. Title IX, enacted in 1972, prohibits sex-based discrimination in education programs and activities at federally funded institutions. Metzler also alleged that Loyola breached its contractual obligations to him as a student.
The case was heard in the U.S. District Court for the Northern District of Illinois, Eastern Division, before Judge Steven C. Seeger. The district court granted summary judgment to Loyola, concluding there was insufficient evidence to support a finding of sex discrimination for either Metzler's Title IX claim or his contract-based allegations.
Summary judgment is a legal procedure that allows courts to resolve cases without a full trial when there are no genuine disputes about material facts and one party is entitled to judgment as a matter of law. In granting summary judgment for Loyola, the district court determined that even viewing the evidence in the light most favorable to Metzler, he could not establish his discrimination claims.
Metzler appealed the district court's decision to the Seventh Circuit, which has jurisdiction over federal appeals from Illinois, Indiana, and Wisconsin. The case was argued before the three-judge panel on Sept. 22, 2025.
In affirming the lower court's decision, the Seventh Circuit found that the evidence was insufficient to establish that Loyola discriminated against Metzler based on his sex. The appeals court's analysis focused on whether the university's disciplinary process and ultimate decision to expel Metzler were motivated by gender bias rather than the merits of the sexual misconduct allegations.
The decision reflects ongoing challenges in Title IX litigation, where students expelled for sexual misconduct increasingly claim their universities applied discriminatory standards based on gender. These cases often involve complex factual disputes about consent, university procedures, and whether disciplinary outcomes reflect bias rather than evidence-based determinations.
Title IX has evolved significantly since its enactment, particularly in how it addresses sexual harassment and assault on college campuses. Federal guidance has shifted over different presidential administrations, affecting how universities investigate and adjudicate sexual misconduct claims while balancing the rights of both accusers and accused students.
The Seventh Circuit's decision in *Metzler v. Loyola University Chicago* adds to a growing body of appellate case law examining the boundaries of Title IX liability when students challenge university disciplinary decisions. Courts have generally required plaintiffs to demonstrate that gender bias, rather than the substantive evidence of misconduct, drove university actions.
This case was designated No. 24-2956 on the Seventh Circuit's docket and No. 18-cv-7335 in the district court. The decision reinforces universities' authority to investigate and sanction sexual misconduct when supported by adequate evidence and proper procedures, even when the disciplinary outcomes are challenged in federal court under anti-discrimination laws.