Washington State Supreme Court Issues Landmark Ruling: Universities May Be Responsible for Preventing Hazing Deaths

Court rules Washington State University owed a duty to protect student Sam Martinez, who died in 2019 hazing incident

SEATTLE – Schroeter Goldmark & Bender (SGB) today announced a landmark victory before the Washington Supreme Court, which ruled that Washington State University owed a legal duty to protect freshman Sam Martinez from the foreseeable dangers of fraternity hazing. Martinez died in 2019 during a fraternity initiation event while pledging at WSU.

The Supreme Court upholds the Washington Court of Appeals, finding that the university owed Martinez a legal duty to take reasonable steps to protect him from the dangers of fraternity hazing and alcohol abuse because of its longstanding relationship with, and ability to exercise control over, campus fraternities.

The trial court initially dismissed the family’s negligence claims against WSU, finding that the university owed no legal duty to protect Martinez. The appeals court reversed that decision in 2025, and this latest ruling from the Supreme Court allows the case to continue with further trial proceedings.

The ruling is among the first in the nation to recognize that a university's relationship with its fraternities may create a legal duty to protect students from foreseeable harm when the university has knowledge of dangerous conduct and the ability to intervene.

"This decision sends a clear message that universities cannot simply look the other way when they know dangerous hazing is occurring within organizations they recognize, support and oversee," said Becky Roe, attorney at Schroeter Goldmark & Bender. "When institutions have the ability to prevent foreseeable harm, they also have a responsibility to step in."

Sam Martinez, a 19-year-old freshman from Bellevue, died from acute alcohol intoxication during a fraternity initiation event in November 2019. His family filed a lawsuit alleging WSU knew of ongoing hazing and dangerous alcohol practices within its fraternity system but failed to take steps to protect students.

The Supreme Court did not determine whether WSU was negligent. Instead, it ruled that the university can be held legally responsible if a jury ultimately finds it failed to uphold that duty. The case will return to the trial court for additional proceedings.