Student Files Sexual Assault Complaint Against UC Regents


Gwendolyn Wu
Campus Beat Reporter

A University of California, Santa Barbara student filed a complaint for damages against the University of California Board of Regents on Tue., Jan. 26, stating that the University had mismanaged campus grounds that led to her case of rape and sexual assault.

The student, who is using the pseudonym Jane Doe, started school at UCSB in 2012. The incident, believed to be premeditated, took place on Feb. 23, 2014, where she says that three male attackers dragged her away when she was walking home in Isla Vista, to a secluded area on university grounds by the tennis courts. The area was filled with overgrown foliage and, according to the plaintiff, was home to criminal activity prior to the incident. She alleges that the university was aware of such criminal history, and did nothing to cut back on the trees that obscured the area from view.

On that night, the plaintiff was repeatedly assaulted for hours before finally escaping to her apartment around 4 AM. Immediately after, she was transported to Santa Barbara Cottage Hospital, where an incomplete rape kit was allegedly performed. Doe sustained a number of severe injuries, and may have been exposed to HIV or other sexually transmitted infections as a result.

None of the plaintiff’s assailants have been found. The university has since cleared out the area in question.

Doe listed the charges of personal injury (assault, battery, rape and kidnapping), intentional infliction of emotional distress, negligent infliction of emotional distress and premises liability in the complaint. Santa Barbara-based attorneys Joshua Lynn and Tyrone Maho are representing the plaintiff, and the case is scheduled for a conference in Santa Barbara County Superior Court on May 27.

The complaint reads: “In order to induce students and their parents to enroll at the university and pay tuition, and to induce them to continue their enrollment, attendance at, and payment of tuition to UCSB, certain statements were made and statistics were skewed or omitted to communicate that UCSB was safe and that students only experienced a minimal number of sexual assaults in order to create a misleading portrayal of campus safety.”

Failure to report cases of sexual assault and thoroughly investigate them would violate the federal Clery Act, a requirement for universities to report accurate and thorough crime statistics, and Title IX, the federal statute that protects students from discrimination on the basis of sex and allows students the right to call for schools to investigate sexual assault cases.

It also states that UCPD understaffing and insufficiently trained faculty and staff played a contributing role in her assault. Doe’s complaint, which also discusses what some perceive as lax punishment standards by university administration, echoes calls by other survivors of sexual assault for better university response.

The university and Board of Regents, while aware, have yet to respond. Previously, former UCSB student Hayley Moore filed a civil lawsuit against the Board of Regents on Wed., Dec. 16 for Title IX violations. Moore’s case claims that the university discouraged her from requesting a formal investigation.

Update Wed., Feb 10 at 9:01 PM: San Ramon resident and former UCSB student, 21-year-old Daniel Jiang Chen, was arrested on Wed., Feb. 10 in connection with the Feb. 23, 2014 sexual assault. Chen has been jailed on “suspicion of rape, false imprisonment, and battery with serious bodily injury,” according to the press release.


  1. I wonder how they dragged her all the way from IV to the field. Did they use a car? Did they muffle her? Did she not scream? Was there nobody, anywhere? These are questions I’m curious to know.

  2. As the father of a daughter, a UCSB alum and a Santa Barbara resident, I can say that based on the facts presented I’d never convict UCSB in a case like this. What happened to the young lady was as bad as anything I can remember in my 40 plus years of experience in and around Isla Vista/UCSB. That said, it’s not the university’s fault. It’s the criminal’s fault. Thousands of other young women get through UCSB without this happening. She and the attorneys are looking for some deep pockets taxpayer money is all.

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