A significant legal development is unfolding in Massachusetts that could reshape how harassment claims are handled across the Commonwealth. The state’s highest court, the Supreme Judicial Court (SJC), has agreed to take up a case that goes to the heart of individual liability for sexual harassment claims. While the case arises in an educational context, the implications could impact employers across the state.
Key Takeaways
- A major legal question is pending: The Massachusetts Supreme Judicial Court will decide whether individuals (like teachers or supervisors) can be personally sued for sexual harassment in educational settings.
- Lower courts said “no” to individual liability: So far, courts have ruled that only the institution, not the individual, can be held responsible under G.L. c. 214, § 1C.
- Different rules for work vs. education: Massachusetts law allows individual liability in workplace harassment cases, but not clearly in education cases, creating an inconsistent legal framework.
- Strict interpretation is driving decisions: Courts are increasingly sticking closely to the exact wording of statutes and won’t assume individual liability unless the law clearly says so.
- The SJC decision could reshape liability: The ruling may expand liability to individuals, or confirm that only institutions can be sued, impacting how claims are brought and resolved.
- Real impact on claim leverage: If individuals can’t be sued, claimants may have less negotiating power, and more alleged bad actors may avoid personal accountability.
- Employers should pay attention now: Regardless of the outcome, this is a critical moment to review harassment policies, training, and internal response procedures to reduce risk.
The Case: Sabatini v. Knouse
The case in question, Sabatini v. Knouse, centers around allegations made by Kristin Knouse against David Sabatini, her former thesis advisor at MIT and subsequent supervisor, that he pressured her into a sexual relationship during and after her graduate studies. An internal investigation later found that Sabatini created a sexualized and inappropriate work environment. Sabatini resigned his post but denied wrongdoing. He claimed the relationship was consensual and sued Knouse for defamation, while Knouse brought claims against him for sexual harassment.
Sabatini argued that, because the conduct occurred in an educational setting, he cannot personally be held liable and that claims must be filed against the institution.
Current Law Treats Educational Institutions Differently
Following recent federal precedent, both the trial court and the Appeals Court agreed and declined to extend liability to Sabatini as an individual actor in an educational institution under G.L. c. 214, § 1C. Instead, the courts held that only educational institutions can be held liable under this statute.
Chapter 214, § 1C declares that people have “the right to be free from sexual harassment,” and references the definitions of sexual harassment from two other statutes: G.L. c. 151B (the employment discrimination law) and G.L. c. 151C (the educational institutions law).
- G.L. c. 151B (employment law)
- Broadly allows for individual liability, including for aiding and abetting prohibited conduct
- G.L. c. 151C (education law)
- Focuses specifically on institutions as the responsible parties
- Makes no reference to individual actors
Chapter 214 references both of these definitions but does not clearly incorporate 151B’s broader liability framework. In a strict textual reading of the statute, the lower courts in Sabatini v Knouse took the narrower approach under 151C, limiting liability to institutions.
Why the SJC Is Taking a Closer Look
The key question at issue before the SJC is:
Did the Legislature intend to create different rules for harassment liability depending on the context (employment vs. education), or should the law be interpreted more broadly to include individual actors in all settings?
This is not just a technical statutory interpretation issue. It goes directly to how harassment claims are enforced and against whom.
The Pattern Extends Beyond Education: Laughlin v. Binstar
A Massachusetts Superior Court reached a similar conclusion in a completely different statutory context: the Massachusetts Paid Family and Medical Leave Act (PFML). In Laughlin v. Binstar, the court also declined to read individual liability into the PFML statute, finding that where the text doesn’t mention it, courts won’t imply it. No aiding and abetting, no personal exposure for managers or employees who may have wrongfully interfered with an employee’s PFML rights.
This signals a broader trend toward strict textualism in Massachusetts courts in which statutes are read strictly as written, rather than expanding their reach to serve broader remedial goals.
What It Means for Employers
Removing the prospect of individual liability for employees/managers and educators from such claims will undoubtedly impact the leverage that claimants can bring to resolve such claims as well as immunizing a large group of potential bad actors.
For employers, the practical takeaway right now is this: the legal landscape around who bears liability for harassment and leave interference is unsettled. The SJC’s decision in Sabatini could clarify the rules or prompt the Legislature to revisit the statutory framework altogether. Either way, this is a moment to ensure your harassment prevention policies, manager training, and response protocols are airtight.
Reach out to the employment law team at Parker Scheer or for a review of your current sexual harassment policies and procedures, sexual harassment prevention training, or for more detail on how this ruling could affect your business.
