── Sabatini v. Knouse ──
Court: Massachusetts Supreme Judicial Court
Date: May 19, 2026
Category: General
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SJC-13781
DAVID M. SABATINI vs. KRISTIN A. KNOUSE & others.1
Suffolk. February 2, 2026. - May 19, 2026.
Present: Budd, C.J., Gaziano, Kafker, Wendlandt, Georges,
& Wolohojian, JJ.
Employment, Sexual harassment. Anti-Discrimination Law, Unfair
educational practice. Statute, Construction. Practice,
Civil, Counterclaim and cross-claim, Dismissal.
Civil action commenced in the Superior Court Department on
October 20, 2021.
A motion to dismiss was heard by Hélène Kazanjian, J.
A proceeding for interlocutory review was heard in the
Appeals Court by Sookyoung Shin, J.
After review by the Appeals Court, 105 Mass. App. Ct. 174
(2025), the Supreme Judicial Court granted leave to obtain
further appellate review.
Ellen J. Zucker (Kimberly Crowley also present) for Kristin
A. Knouse.
Edward Foye (Lisa G. Arrowood & Sarah E. A. Sousa also
present) for the plaintiff.
1 Ruth Lehmann and Whitehead Institute for Biomedical
Research.
2
Naomi R. Shatz & Niamh S. Gibbons, for Jane Doe Inc.
& others, amici curiae, submitted a brief.
WENDLANDT, J. This case presents the question whether
G. L. c. 214, § 1C (sexual harassment statute), which protects a
person's right to be free from sexual harassment in, inter alia,
the academic context, provides a sexual harassment victim with a
cause of action directly against the individual perpetrator of
the harassment. Concluding that it does, we reverse the
Superior Court judge's order dismissing Kristin A. Knouse's
counterclaim asserting that she was sexually harassed by David
M. Sabatini, her former instructor, thesis committee advisor,
and fellowship director and mentor. We remand for proceedings
consistent with this opinion.2
Background. 1. Facts. We summarize the following
allegations from the counterclaim, accepting them as true and
drawing all reasonable inferences in Knouse's favor. See
Cubberley v. Commerce Ins. Co., 495 Mass. 289, 290 (2025),
citing Buffalo-Water 1, LLC v. Fidelity Real Estate Co., 481
Mass. 13, 17 (2018) ("We summarize the allegations in the
operative complaint, accepting them as true and drawing every
reasonable inference in favor of the plaintiffs").
2 We acknowledge the amicus brief submitted by Jane Doe
Inc., the Victim Rights Law Center, the Women's Bar Association
of Massachusetts, and the Massachusetts Employment Lawyers
Association.
3
Sabatini was a laboratory director at the Whitehead
Institute for Biomedical Research (Whitehead) and a tenured
professor at the Massachusetts Institute of Technology (MIT) in
2012 when he met Knouse, then a graduate student at Harvard
University and MIT. Sabatini was one of Knouse's instructors at
MIT and served on her dissertation committee.
During a discussion in 2016 concerning whether Sabatini
would endorse Knouse's application for an upcoming fellowship at
Whitehead, Sabatini expressed concern that Knouse took herself
too seriously and asked Knouse whether she ever had "fun,"
"fuck[ed] around," or had sex. Knouse responded that she did
have fun and quickly left the conversation. Subsequently,
Sabatini recommended Knouse for the fellowship and supported her
grant application, both of which she secured.
Knouse joined Whitehead as a fellow in 2018. That year,
Knouse and Sabatini began a sexual relat