Complaint filed against Ringling College over alleged mishandling of ‘student-on-student reports’ of sexual assault, sexual harassment and other issues, with focus on former associate dean

College’s initial answer in case due in early July

(Editor’s note: This article was revised on the morning of July 1 to correct the fact that it is not a Title IX complaint. It was filed in the 12th Judicial Circuit Court in Sarasota.)

This is a view of part of the Ringling College campus in north Sarasota. Photo by Jose Luis Batista via Google Maps

Eight former students of the Ringling College of Art + Design in Sarasota have filed a complaint against the college, alleging that it failed to protect them “from the mishandling of student-on-student reports of sexual assault, sexual harassment, threats of violence, and stalking.”

“Moreover,” the complaint says, “Ringling has engaged in a pattern and practice of silencing students and covering up reports of student-on-student misconduct and violations of Florida and federal anti-discrimination laws since 2008. Ringling engaged in this conduct to misrepresent its campus as an extraordinarily safe campus in its marketing and promotion of the college,” the complaint continues.

“Ringling knowingly allowed its student population to suffer repeated traumatization and silenced its students and alumni to profit from tuition and the revenue from housing and expenses,” the complaint adds.

Yet, the eight plaintiffs contend that the college’s Title IX Department, its Human Resources Department and the former associate dean of students for resident life, Christopher Shaffer, “worked in tandem with [President] Larry Thompson” and Tammy Walsh, vice president of student life and Shaffer’s immediate supervisor, “to ensure that student and alumni reporters of student-on-student misconduct and student and alumni reports of discrimination were silenced and that applicable reports were not reported to the [U.S.] Department of Education in compliance with Title IX.”

Prior to their enrollment, the complaint further alleges, Ringling employees knew that multiple students had reported “incidents of student-on-student sexual assault, violence, threats of violence [and] stalking” and that Shaffer was abusing his power. “Through undocumented protocol,” the complaint says, the college “engaged in a pattern and practice of systematically dissuading student victims who attempted to report to its administration their experiences of student-on-student sexual assault, stalking, threats of violence, and violence from reporting these occurrences.” Those students were made to feel that they were at fault or that they were imagining “the harmfulness of the conducts,” the complaint contends.

Represented by the Massey Law Group of St. Petersburg, the plaintiffs are seeking more than $30,000 in damages, “exclusive of costs and interest,” and demanding a jury trial.

The lead attorney for the Massey Law Group in the lawsuit against the college is Starlett M. Massey, founder of the firm.

Starlett Massey. Photo from the Massey Law Group website

Names of four of the eight plaintiffs are redacted in the documents. Those listed are Megan Rose Ruiz, a resident of Los Angeles; Lauren Wilson of Ouchita Parrish, La.; Caitlin Henning of Manatee County; and Nickolas Berger of Orange County.

In March 2020, Ruiz filed a complaint against Shaffer in regard to actions he allegedly took while she was a student. That complaint led to his filing a counter-claim and then Ruiz filing a counter-claim, court records show.

In a separate document filed with the 12th Judicial Circuit Court on June 21, Ruiz asked that the court consolidate that litigation with the new complaint.

Additionally, on June 21, Starlett Massey filed a formal summons for Ringling College. That document states, with emphasis, “You have 20 calendar days after this summons is served upon you to file a written response to the attached complaint with the clerk of this court.”

A deputy clerk in the Sarasota County Office of the Clerk of the Circuit Court and County Comptroller signed the document and dated it “6/21/2022.”

Thus, by calculation of The Sarasota News Leader, the college’s formal answer is due on July 11.

Ruiz’s ‘open letter’ elicits a multitude of allegations

The eight plaintiffs’ lawsuit says that Shaffer supervised Ruiz while she worked as a resident’s assistant at Ringling College for a little more than three-and-a-half years. She was enrolled at the school from August 2015 until her graduation in May 2019, the complaint notes.

On June 22, 2020, the complaint continues, Ruiz posted the following on Facebook: “ ‘Hey guys. There is a big conversation happening around dangerous men in art communities. I’m just going to say it. If you’re a woman and you go to Ringling, or plan on going to Ringling, stay the f**k away from Chris Shaffer. Don’t go into a space alone with him.’”

Larry Thompson is the long-time president of Ringling College. Image from his Twitter account

As a result of that post, the complaint says, Ruiz “received numerous messages from students, alumni, former students, parents of students and alumni, faculty, former administrators, and current employees of Ringling who had negative experiences with Shaffer.” Many of those messages, the complaint adds, expressed fears of retaliation from the college and/or Shaffer. Nonetheless, Ruiz encouraged the individuals to make their concerns known directly to Ringling representatives “through its official channels.”

Then, the complaint continues, on June 24, 2020, Ruiz sent an “Open Letter” to Ringling with an attachment containing accounts from individuals who had responded to her Facebook post.” The complaint points out, “Most of those stories involved negative experiences with Shaffer.”

That open letter was included with the complaint.

One female, who was identified only as a member of the Class of 2017, wrote that, during her freshman year, her roommate “vindictively put all of [the writer’s] information on Craigslist under an ad for a prostitute. My name, my picture, my phone number, where I would be on campus and how I would ‘be ready for sex at any given time … just come up to me!’ I had dudes calling me saying they were on campus trying to find me and sending me pictures trying to schedule time with me.”

The writer added that she called the police, but Shaffer “immediately shut that down.” The writer then pointed out, “He knew I was a survivor of sexual assault.” He told her, she added, “ ‘[T]his is what kids these days do!’ And proceeded to berate me about how I wasted his time and the police’s time.” Her roommate faced no punishment, she noted.

The complaint also includes an account of a situation involving one of the unnamed plaintiffs, who is described as a young Black woman who was a student from August 2016 until she graduated in August 2020. That account says that, as a freshman, she lived in a one-student apartment on campus.

During the fall, it continues, she alleges that she was sexually assaulted in that apartment by another student, who is referenced in the complaint as JD1.

The female student told her friends about the sexual assault, the complaint adds. Then, a few days later, it says, “[S]he received an email from a Residential Coordinator, who asked to meet with her to discuss what had happened to her.”

The woman “promptly reported the sexual assault to the Residential Coordinator and a meeting with Shaffer was scheduled.”

When the female student showed up for the meeting, the complaint continues, she was surprised to find that JD1 was present, along with Shaffer and the Residential Coordinator. Exacerbating her trauma, the complaint continues, she noted that the room “was dimly lit.” Then Shaffer asked her to sit right next to JD1, in chairs across form his desk. That “close proximity,” the complaint adds, “caused her to freeze up,” making it impossible for her to provide an effective report of the assault. Yet, after she managed to talk about the incident, the complaint says, “Shaffer was dismissive of her account.”

After Shaffer told her she could leave the room, the complaint continues, Shaffer remained there with JD1 and the Residential Coordinator.

Walsh, Shaffer’s immediate supervisor, later told the student that she would file a report on the sexual assault, that she would meet with JD1 and that a hearing would be conducted, with JD1’s parents present. The complaint adds that Walsh informed the student that the student would not be allowed to participate in the hearing. The student “never received any report of any further action on her complaint” and believes none took place, the complaint says.

On June 26, 2020, the complaint notes, Thompson, the college president, sent an email to the college community that “confirmed that the ‘allegations [against Shaffer] do not reflect actions that conform to [Ringling’s] core values or [its] expectations of what constitutes appropriate professional and acceptable behavior at [Ringling].’”

An investigation into Shaffer and his dismissal

In late June 2020, the lawsuit points out, the college conducted an internal investigation into the allegations against Shaffer. Beforehand, however, college officials did not limit his access to its “files regarding the reporting students and alumni,” the complaint adds. Instead, Walsh included Shaffer in the investigation.

An exhibit attached to the lawsuit contains copies of text messages between Shaffer and Walsh, providing evidence of their collaboration in the investigation, the lawsuit points out.

These are part of the exchanges between Tammy Walsh and Christopher Shaffer, included as Exhibit D with the lawsuit. Image courtesy Sarasota County Clerk of the Circuit Court Karen Rushing

Then, on June 29, 2020, Shaffer informed Walsh that he intended to file suit against Ruiz. A day later, the eight plaintiffs’ suit says, he met with other Ringling staff members, including the vice president of human resources — Christine Carnegie — and advised them that he intended to file not only a civil lawsuit against Ruiz but also a criminal complaint.

Carnegie told Shaffer that he “was free to pursue civil action” against Ruiz, the former students’ lawsuit says, but that he would have to take that action “at his own expense and [it] may be construed as interfering with the ongoing investigation.”

This is among the rotating banners on the Ringling College homepage. Image from Ringling College

On July 31, 2020, the former students’ complaint continues, Darren Mathews, director of human resources at Ringling, advised Shaffer that the investigation into Ruiz had been completed, “and despite Ringling’s receipt of additional complaints regarding Shaffer, no new investigation would take place.”

During that same meeting, the former students’ lawsuit alleges, Mathews told Shaffer that Shaffer would not be terminated. Further, the complaint contends that Shaffer told Mathews that he would not file his lawsuit against Ruiz if the college would reimburse him for the retainer he had paid an attorney. The college did not respond to that offer, the former students’ complaint adds.

Thus, on Aug. 3, 2020, Shaffer filed his lawsuit, alleging that Ruiz had defamed him.

On Aug. 25, 2020, Ringling advised Shaffer that, while it was retaining him as an employee, he was being reassigned to other duties and being given a new title, with a closer focus “ ‘on student housing and administration,’” the former students’ complaint says.

Moreover, the former students’ complaint adds, Ringling advised Shaffer that “any adverse action” he took against someone who had complained about him “ ‘could constitute unlawful retaliation.’”

Two days later, the complaint continues, Ringling transmitted to Shaffer a letter that was identified as “a separation, waiver, and general release agreement,” which also is attached to the lawsuit as an exhibit. “That letter outlined the terms of a proposed separation and release,” the complaint points out. It gave Shaffer the opportunity to withdraw his lawsuit against Ruiz and to dismiss any other legal action he had taken against other Ringling alumni or current students. The complaint says that he did not sign that document.

On Sept. 10, 2020, Ringling sent Shaffer a letter that terminated his employment, and President Thompson informed “the Ringling College Community” that Shaffer had been fired, the complaint adds.

These are portions of the Sept. 10 letter that Larry Thompson wrote to the ‘Ringling Community.’ Image from Ringling College

However, the complaint points out, the college “took no further action” in regard to persuading Shaffer to dismiss or resolve his lawsuit against Ruiz.

As all of this was happening, the complaint contends, “Ringling held itself out to be and specifically advertised itself as being a uniquely safe campus environment, with zero incidences of sexual assault, violence, and stalking occurring on [its] campus for multiple consecutive years.” Ringling representatives emphasized those points during interview of potential students and during orientation events for new students, the complaint says.