IN THE UNITED STATES DISTRICT COURTEASTERN DISTRICT OF MICHIGANJOSEPH M. CORLETT
, an individualPlaintiff, Case No. 2:13-cv-11145v. Honorable Patrick J. Duggan
OAKLAND UNIVERSITY BOARD
Magistrate Judge Paul J. Komives
, in its official capacity;
, individually and in hisOfficial capacity as the President of OaklandUniversity; and
MARY BETH SNYDER
,Individually and in her official capacity asVice President for Student Affairs and EnrollmentManagement of Oakland UniversityDefendants. _____________________________________________________________________________/
MOTION TO DISMISS PLAINTIFF’S COMPLAINTPURSUANT TO FED. R. CIV. P. 12(b)(6)
Defendants Oakland University Board of Trustees, Gary Russi and Mary Beth Snyder move to dismiss Plaintiff’s complaint pursuant to Fed. R. Civ. P. 12(b)(6) for the followingreasons:1.
Plaintiff Joseph Corlett (“Corlett”) claims that Defendants violated his rights tofreedom of expression and due process by taking certain measures after he submitted a project inan English course in which he described the instructor as “stacked,” depicted her as the object of his sexual urges, compared her with an oversexed caricature from a television sitcom, anddismissed any concerns about his wife discovering what he had written.
2:13-cv-11145-PJD-PJK Doc # 12 Filed 04/30/13 Pg 1 of 25 Pg ID 87