Sarah Lawrence Avoids Liability for Sex Trafficking of Students

Sarah Lawrence College isn’t liable to students who were sexually abused by a father that the school allowed to live on campus, a federal court said.

The students’ claims were untimely, and even if they weren’t, they failed on the merits, Judge Lewis J. Liman said Tuesday for the US District Court for the Southern District of New York. The students failed to sufficiently allege the college was involved in or benefited from the alleged sex trafficking, Liman said.

Sexual abuse at the college garnered widespread media coverage, including a Hulu documentary miniseries called Stolen Youth: Inside the Cult at Sarah Lawrence.

Plaintiffs Daniel Levin and Santos Rosario met Lawrence Ray in 2010, while they and his daughter, Talia, were Sarah Lawrence students. Ray, who had recently gotten out of prison, openly lived with Talia in her dorm, without any interference from the college. The plaintiffs alleged that while living in the dorm, Ray was able to manipulate, groom, and sexually abuse them and other Sarah Lawrence students.

Ray moved during the summer of 2011 to a condominium in Manhattan, owned by defendant Lee Chen and managed by Gumley-Haft LLC, also a defendant. He continued to host Sarah Lawrence students at the condo and trafficked some for sex. Ray and Chen also also allegedly sexually assaulted a student there, Liman said. Other residents of the building complained to Gumley-Haft, but it did nothing, the judge said.

Ray, Santos, and Felicia Rosario moved to North Carolina in the summer of 2013, where he forced them to do manual labor for free, deprived them of sleep and food, and trafficked Felicia, another alleged victim, though she hadn’t attended Sarah Lawrence.

Ray and Chen continued to traffick the plaintiffs and other students in subsequent years, the court said. Ray and the Rosarios moved to multiple locations in multiple states. Ray and Felicia eventually moved to Piscataway, N.J., where they lived with defendant Scott Muller until Ray was arrested in 2020.

Ray was convicted of multiple crimes, including sex trafficking, forced labor, racketeering, tax evasion, and money laundering. He was sentenced to 60 years in prison and ordered to pay his victims $5.6 million in restitution. His case is currently on appeal.

The plaintiffs sued Sarah Lawrence, Gumley-Huft, and others in November 2023, claiming that Sarah Lawrence and Gumley-Haft are liable for Ray’s wrongdoing under the federal Trafficking Victims Protection Act and New York common law.

There is a three-year statute of limitations for the plaintiffs’ state-law claims, Liman said.

Though their claims were filed more than three years after the events that gave rise to them, the plaintiffs said that they were revived by New York’s Adult Survivors Act. Liman disagreed, noting that the ASA only applies to specific predicate sexual acts, such as forcible touching, under state law and that the plaintiffs’ claims didn’t rely on any of those acts.

Liman also said that the plaintiffs’ federal TVPRA claim couldn’t be revived by state law and that there wasn’t any valid reason to equitably toll the limitations period for it.

Even if the plaintiffs’ state claims were valid, they’d still be dismissed, because they fail to assert that the defendants had a duty to protect them, Liman said.

The TVPRA claims would also fail on the merits because the plaintiffs didn’t adequately allege that Sarah Lawrence or Gumley-Haft knowingly benefited from or participated in sex or labor trafficking, the judge said.

Liman granted the plaintiffs leave to file an amended complaint.

Chaffin Luhana LLP and Justice Law Collaborative LLC represent the plaintiffs. Hodgson Russ LLP represents Sarah Lawrence. Resnick & Louis PC and Harris Beach PLLC represent Gumley-Haft.

The case is Levin v. Sarah Lawrence Coll., S.D.N.Y., No. 1:23-cv-10236 (LJL), 9/3/24.