In an opinion by Justice Wendlandt, the court held that G. L. c. 214, § 1C, which guarantees a person’s right to be free from sexual harassment in academic and employment contexts, does not shield individual abusers from liability.
The decision reverses the Superior Court’s allowance of a motion to dismiss Kristin A. Knouse’s counterclaim against David M. Sabatini, her former instructor, thesis committee advisor, and fellowship director.
Knouse alleged that Sabatini, a laboratory director at the Whitehead Institute and tenured professor at the Massachusetts Institute of Technology, engaged in a sexual relationship with her that ended in 2019, after which he continued to make sexualized comments.
The counterclaim alleged that Sabatini expressed concern that Knouse took herself too seriously and asked whether she ever had “fun,” “fuck[ed] around,” or had sex during a 2016 discussion about a fellowship endorsement.
Knouse, then a graduate student at Harvard and MIT, joined Whitehead as a fellow in 2018. She alleged she feared professional repercussions if she terminated the relationship, leading to “debilitating feelings of entrapment and hopelessness.”
The Appeals Court had affirmed the dismissal, reasoning that because the substantive law for academic sexual harassment is set forth in G. L. c. 151C, § 2 (g), and that statute applies only to educational institutions, the sexual harassment statute must also apply only to institutions.
The Supreme Judicial Court rejected that interpretation, noting that the sexual harassment statute incorporates the definition of sexual harassment from G. L. c. 151C but does not reference the “unfair educational practices” provision that limits liability under c. 151C to institutions.
“We do not read into the statute a provision which the Legislature did not see fit to put there, whether the omission came from inadvertence or of set purpose,” the court wrote, citing City Elec. Supply Co. v. Arch Ins. Co.
The court emphasized that the statute’s plain language grants the Superior Court jurisdiction to enforce the right to be free from harassment and award damages, creating a cause of action against any person who violates that right.
The court also drew a parallel to G. L. c. 214, § 1B, the right to privacy statute, which allows claims against both individuals and institutions.
Sabatini had argued that the sexual harassment statute was intended to fill gaps in the comprehensive remedial schemes of G. L. cc. 151B and 151C, not to create new liability for individuals.
The court acknowledged that the statute’s anti-duplication clause requires victims in the workplace to first file with the Massachusetts Commission Against Discrimination, but noted that no comparable administrative remedy exists for nonvocational students under c. 151C.
Consequently, the court declined to construe the statute narrowly to provide relief only against educational institutions, citing its broad remedial purpose.
Sabatini resigned from Whitehead after an independent investigation found he had “engaged in and otherwise tolerated sexist and sexualized work discussions with his lab” and violated policies, including its sexual harassment policy, by engaging in sexual relations with a fellow.
MIT placed him on leave pending its own investigation.
Knouse’s counterclaim also included claims for defamation and tortious interference, which Sabatini initiated in the Superior Court in 2021 while the MIT investigation was ongoing.
The case is remanded for further proceedings consistent with the court’s opinion.