A former student of the Yale School of Drama has filed suit against the University, alleging she was expelled for complaining of repeated sexual harassment by faculty and students, including an alleged incident in which Dean James Bundy kissed her against her wishes.

The plaintiff, Sally Greenhouse, who was 49 years old while a drama student and had already worked in professional theater, alleges that after reporting three instances of sexual harassment she was “berated” and warned that she would be dismissed from the drama school, which she ultimately was on May 15, 2003. Greenhouse filed her complaint with the United States District Court Sept. 12.

University spokeswoman Gila Reinstein said the University does not believe Greenhouse’s case is particularly strong.

“Yale believes this case has no merit and as it is in litigation we are not able to make further comment,” she said.

Bundy declined to comment Thursday. Repeated calls to Yale’s counsel, Patrick M. Noonan of Delanay, Zemetis, Donahue & Noonan, were unreturned, and representatives of Yale’s Office of General Counsel were unable to be reached.

Discrimination on the basis of sex — including sexual harassment — is illegal under Title IX of the Education Amendments of 1972, which applies to any institution that receives federal funding. Yale’s official guidelines on sexual harassment state that such harassment can consist of either an instance of “quid pro quo” harassment in which someone’s job or evaluation is linked to that individual’s willingness to grant or deny sexual favors, or an instance in which a “hostile environment” is created that interferes with the victim’s work or study. Retaliating against someone who reports sexual harassment is itself another violation of Title IX, according to a ruling of the U.S. Supreme Court earlier this year, said John Williams, Greenhouse’s attorney.

Williams, who said he won the largest jury award in Connecticut history for a case he brought under Title IX while representing a student at East Haven High School, called the case against the drama school “unusually strong,” saying he believes he can prove that the school was “deliberately indifferent” to harassment of which it was aware.

“Literally days after she complained, she was placed on warning,” Williams said. “She went through the administrative process and filed her administrative complaint, which was investigated by a faculty committee which filed a report confirming that the events in question had indeed occurred and saying, in effect, ‘So what?'”

In the Sept. 12 filing with the court, Greenhouse claimed that she had reported a number of instances of what she perceived as sexual harassment to the drama school administration. In addition to allegedly being kissed by Bundy, she said she reported concerns about a fellow male graduate student whom a faculty member had told her was “psychotic” and “potentially dangerous.” In response, the filing says, the interim chair of the Directing Department said she was “pissed off” that Greenhouse had reported her complaint.

Greenhouse’s other complaint centers around a Sept. 21, 2002 rehearsal led by visiting instructor Frank Deal in which Deal “announced that he had changed the title [of the play being rehearsed] to ‘Metamorphoses Revisited Or Rock Out With Your Cock Out’ and instructed the male actors to simulate masturbation while standing next to the plaintiff.” Deal allegedly then told his male students to simulate orgasm, at which point, Greenhouse states in the filing, she fled the stage. Six days after reporting the incident to the chair of the Acting Department, Greenhouse alleges that she was warned that she would be dismissed from the drama school for having reported about the male graduate student and for having complained about Deal’s rehearsal.

Deal has since moved and messages left at his current places of employment were not returned.

Catherine Sheehy DRA ’92, the chair of the Dramaturgy and Dramatic Criticism Department, said she had heard of a few situations, usually involving student work, in which a participant in a play might become uncomfortable with the content of the play. However, she said those problems usually are resolved within the school, either by the student government or in established discussion sessions run by each department that discuss the content and artistic merit of the works being studied.

“It happens around the portrayal of women, it happens with sexuality on stage — those things happen from time to time, and usually there are school-wide responses, ‘Let’s get together and talk about this,'” she said. “It’s not often that it happens, actors who are asked to play parts and are like, ‘I don’t want to go there.'”

Each school at Yale has its own specific procedures for handling complaints of sexual harassment, said Valerie Hayes, the University’s Title IX coordinator, but the procedures are all based on the University’s standard set of guidelines. The Title IX coordinator for the drama school, Victoria Nolan, a deputy dean of the drama school and chair of the Department of Theater Management, said there are a variety of ways for students within the drama school to file a complaint of harassment, but that most complaints are investigated by her and then resolved amicably.

“If they want to bring a complaint in a formal way with the school, they can ask for the Yale School of Drama’s Dean’s procedure,” Nolan said.

A committee would then be formed of at least two faculty members and one student to investigate the complaint, she said. If that fails, students have access to University-wide procedures, which can also be invoked if a student prefers not to bring the complaint through the drama school.

“If they feel at all fearful, I take it to the next level — I would immediately call in for help from [Hayes],” Nolan said. “If a student feels at all threatened at the drama school, it goes outside; there are lots of avenues.”

Although she was the Title IX coordinator at the time Greenhouse was a Yale student, Nolan said she did not help adjudicate Greenhouse’s complaint, but that she believed Greenhouse’s complaint had been brought through appropriate Yale grievance procedures. She said it would be inappropriate and illegal for students to be punished for bringing a complaint against a member of the faculty.

Sheehy said all faculty members at the School of Drama try to approach issues of sexual harassment in a way that creates a “comfort zone” for those bringing complaints.

“We all attend sexual harassment training, and the school takes that very seriously,” Sheehy said. “I don’t know if it’s because we’re all artists, but the culture at the drama school is to speak as opposed to keep it to yourself. In the last 10 or 15 years, there has been an absolute encouragement to speak about things and not to clamp things down.”

Williams said Greenhouse is seeking compensation for emotional distress and punitive damages both for the sexual harassment of his client and for the alleged retaliation against her. Yale’s official guidelines on sexual harassment state that retaliation for filing a complaint is prohibited and that anyone who retaliates is subject to termination of employment or expulsion.

Greenhouse’s attorney said he had hoped not to bring the case to a public trial by jury and had therefore waited until the three year statue of limitations on the case had nearly expired. As the case has now arrived at litigation, he said he did not expect that Yale would now agree to an out-of-court settlement.

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