Majumdar v. Fair
| Decision Date | 19 October 2021 |
| Docket Number | Case No. 21 C 928 |
| Citation | 567 F.Supp.3d 901 |
| Parties | Rochona MAJUMDAR, Plaintiff, v. C. Christine FAIR, Defendant. |
| Court | U.S. District Court — Northern District of Illinois |
Cynthia H. Hyndman, Robert Lawrence Margolis, Robinson Curley P.C., Chicago, IL, for Plaintiff.
Wayne B. Giampietro, Poltrock & Giampietro, William J. McKenna, Jr., Jena Louise Levin, Foley & Lardner LLP, Chicago, IL, for Defendant.
In this diversity case, plaintiff Rochona Majumdar brings suit against defendant, C. Christine Fair, asserting claims of defamation and false-light invasion of privacy. Defendant moves to dismiss for lack of personal jurisdiction. For the following reasons, the Court denies the motion.
The following is a summary of the allegations of the complaint, which the Court must assume true at this early stage. Plaintiff Rochona Majumdar is an associate professor in the Departments of South Asian Languages and Civilizations ("SALC") and Cinema and Media Studies ("CMS") at the University of Chicago ("the University"). She has lived in Illinois for over twenty years. Her husband is also a professor in the University's SALC department.
Defendant C. Christine Fair holds three degrees from the University, including a Ph.D. in SALC. Defendant is now a Professor in the Walsh School of Foreign Service at Georgetown University. She lives in Virginia.
While defendant was studying at the University in the nineteen-nineties, plaintiff's husband made an offensive comment to defendant, which defendant interpreted as an improper sexual advance. Since then, defendant has made a number of public statements criticizing plaintiff's husband for the comment. Beginning in 2017, defendant began to make public statements critical of plaintiff.
In December 2017, defendant wrote a letter to the Title IX Coordinator at the University, alleging that plaintiff had only come to be hired because her husband "exploited his position" at the University, and her "tenure was a foregone conclusion" for the same reason. (Compl. ¶ 9, ECF No. 1.) Defendant claimed that plaintiff had boasted that she "danced around" tenure, although she had an "unorthodox career trajectory." (Id. ¶ 14.) Defendant also alleged in the letter that plaintiff had made "disparaging remarks" about her own students, including "homophobic" and "caste-based" remarks. .)
In or around March 2020, Zain Jamshaid, a former Ph.D. student in the University's CMS department, began making allegations within the University community that plaintiff had sexually harassed and assaulted him in 2015 and 2016. Sometime in the spring of 2020, Jamshaid filed a formal Title IX complaint against plaintiff.
During the same time frame, defendant began to post disparaging statements about plaintiff and her husband on the internet. On March 14, 2020, defendant posted to her blog a piece entitled, "The University of Chicago is a Predator Protection Racket." The blog post primarily consists of the 2017 letter defendant had written to the University's Title IX coordinator. Defendant also reposted the blog post on Twitter. In the tweet containing the link to the blog post, defendant wrote that plaintiff "sexually assaulted" Jamshaid, "mocked him for being gay, Muslim, low-caste, ... plagiarized him, ... mocked his national origins and held his visa status over him."
On the same day, March 14, 2020, defendant posted another piece to her blog, this one titled "A Sadistic Couple that Preys Together Stays Together?" In this post, defendant alleged that plaintiff "forced [Jamshaid] to let her fondle him": she had allegedly "demand[ed] that [Jamshaid] TA a course with her" and "instructed him to sit next to her while she put her hands on the insides of his thighs." This blog post incorporated a new email that, earlier that same day, defendant had sent to the University's Title IX coordinator. In the March 14, 2020 email to the University's Title IX coordinator, as reposted on defendant's blog, defendant alleged that plaintiff had obtained her position at the University only because her husband "tanked a Hindi job search after short-listed candidates were flown out to give job talks and, after doing so, argued that she should have the job." (Id. ¶ 18.) Further, defendant alleged, plaintiff was plainly less qualified than other candidates "by any empirical standard," but it was a "foregone conclusion" that she would obtain tenure, nevertheless, because of her husband. (Id. ) Defendant concluded by stating that she hoped plaintiff and her husband were "held to account for tormenting myriad students ... who have been blackmailed into tolerating their sadism for the sake of their careers." (Id. )
On April 2, 2020, defendant posted on Twitter that plaintiff had filed a complaint against Jamshaid, in which she had alleged that "the content of HIS [Title IX] complaint constituted sexual harassment OF HER." According to plaintiff, this statement was false. Defendant referred to plaintiff as a "harridan" and to plaintiff and her husband as "sadistic." (Id. )
On May 13, 2020, defendant reposted her "A Sadistic Couple That Preys Together Stays Together?" blog post to her Twitter account. In the same Twitter post, defendant stated, "There is ONE serious upside to universities like @UChicago being virtual: it deprives predatory ‘professors’ like these wretches from abusing students." (Id. ¶ 20.)
On May 25, 2020, defendant posted on Twitter that "Roachana [sic] Majumdar is a rabid vulture combing over vulnerable students whom she can exploit and abuse." In other Twitter posts on or around that day, defendant referred to plaintiff and her husband as "predatory," and stated,
In a series of tweets posted on June 2 and June 3, 2020, defendant called plaintiff a "sexual predator with permanent job security" and suggested that she obtained her position at the University because she "bang[ed] a prominent faculty member." Defendant continued, "The entire notion of the ‘trailing spouse’ incentivizes this predatory behavior and provides a different kind of response to sexual harassment other than insisting upon accountability." (Id. )
On August 16, 2020, defendant posted on Twitter that the University provided plaintiff with a "perquisite of preying upon students" that was unavailable while classes were being conducted remotely due to the COVID-19 pandemic.
On December 28, 2020, defendant posted on Facebook that plaintiff was an "abusive harridan" and a "churail," a derogatory term in Hindi and Urdu. In this Facebook post, plaintiff invited "SALC people" with whom she had studied at the University to come forward with stories of harassment by plaintiff to help Jamshaid with his claim. Defendant "tagged" a number of people, including, plaintiff alleges, at least one person in Illinois. (Id. )
On December 31, 2020, defendant posted on Twitter that Jamshaid is "one of Roch[o]na Majumdar's victims." In a Facebook post that same day, defendant stated that she is aware of "at least four victims" of harassment by plaintiff, including Jamshaid, whom she identified by name.
On January 2, 2021, defendant reposted on Twitter a GoFundMe page Jamshaid had created in connection with claims against the University, and she asked for donations, stating that "Rochona Majumdar targeted him because of his numerous vulnerabilities: gay, Ahmadi, from Pakistan, with a visa status contingent upon his student status." Defendant posted Jamshaid's GoFundMe page again on January 3, 2021, stating that plaintiff had harassed and assaulted him. On the same day, she posted the GoFundMe page on Facebook, stating that plaintiff had assaulted and harassed Jamshaid and that plaintiff had participated in a "long reign of predation."
On January 20, 2021, defendant referred in a Facebook post to plaintiff as a "predator" and stated that she and her husband "need to be brought to account." In another Facebook post the same day, defendant stated that plaintiff "hir[ed] a SALC grad student who needed the money to revise her dissertation, which became the basis of her ‘book.’ " Defendant also reiterated her allegation that plaintiff's husband "tanked a job search" so that plaintiff could get the position, and that plaintiff attained tenure despite her allegedly "pathetic publication record." (Id. )
On February 2, 2021, after plaintiff's counsel sent her a cease-and-desist letter, defendant posted on Twitter, On February 13, 2021, in a Twitter post about plaintiff's husband, defendant wrote, "He and his wife are a predatory couple who have [im]miserated many students."
Plaintiff claims that defendant's campaign of accusations has damaged her reputation "in academic circles and the UChicago community." (Id. ¶ 39.) For example, plaintiff was scheduled to participate on February 4, 2021, in a virtual panel discussion of the scholarly work of two colleagues. The two colleagues canceled the event, citing the social media controversy surrounding plaintiff. Additionally, on February 9, 2021, a group of students at the University sent a letter to their professors refusing to...
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