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CASE ARCHIVE · Virginia TechVirginia Tech · Brzonkala / Morrison · 1994–2000
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VIRGINIA TECH

Brzonkala and the federal civil remedy

A 1994 allegation led to university proceedings and a Supreme Court decision on the federal civil remedy for gender-motivated violence.

Institutional accountability

Read the university’s account alongside dated external developments. Leadership roles, allegations and findings are distinguished.

Added Updated
Burruss Hall at Virginia Tech, photographed from the Drillfield on April 9, 2005. Contextual campus view; not an incident photograph.
Burruss Hall at Virginia Tech, photographed from the Drillfield on April 9, 2005. Contextual campus view; not an incident photograph.
Buridan · Public domain (released by copyright holder, worldwide) ↗ · Original & credit ↗ · Resized to WebP.
STATUS AT 1 OCT 2026
Allegations · University proceedings · Constitutional ruling

What is documented?

The Supreme Court’s opinion recounts the university proceedings. It invalidated the federal civil remedy in 42 U.S.C. §13981 on constitutional grounds.

Limits of this record

The 2000 constitutional decision was not a criminal verdict about the alleged assault. University disciplinary findings and court rulings are separately identified.

The dated record

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Virginia Tech
Institutional process

University disciplinary proceedings

The opinion recounts two hearings and a suspension of Morrison, later set aside by the university provost on 21 August 1995.

Brzonkala: Fourth Circuit panel opinion ↗

Source date: 23 Dec 1997

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Virginia Tech
Court ruling

Supreme Court invalidates the federal civil remedy

The majority held Congress lacked authority to enact this remedy. The decision did not determine criminal guilt or innocence.

United States v. Morrison, 529 U.S. 598 ↗

Source date: 15 May 2000

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Leadership & court roles

Roles are recorded at the relevant time. Holding an office, deciding a legal question or being named in a report does not establish individual wrongdoing.
University leadership

Paul Torgersen

President, 1994–2000

Term recorded by Virginia Tech archives. Holding office does not establish personal involvement in a disciplinary decision.

Source for this role ↗

Source date: Publication date not confirmed · Checked 1 Oct 2026

District court decision

Chief Judge Kiser

7 May and 26 July 1996

The district opinions record dismissal of Title IX claims and the federal civil-remedy claim on separate legal grounds. These were not criminal acquittals.

Source for this role ↗

Source date: 26 Jul 1996 · Checked 1 Oct 2026

Court decision

William H. Rehnquist

Supreme Court majority opinion · 15 May 2000

Authored the majority opinion invalidating the federal civil remedy. The ruling concerned congressional authority.

Source for this role ↗

Source date: 15 May 2000 · Checked 1 Oct 2026

Sourcebook

5 linked records
Court opinion

United States v. Morrison, 529 U.S. 598 ↗

Source date: 15 May 2000 · Checked 1 Oct 2026

Opinion includes the procedural history of the 1994 allegation and university proceedings. Legal language may be distressing.

University leadership record

Virginia Tech archives: Paul Torgersen ↗

Source date: Publication date not confirmed · Checked 1 Oct 2026

Publication date not displayed; checked 1 October 2026.

Court opinion

Brzonkala: district court Title IX opinion, 935 F. Supp. 772 ↗

Source date: 7 May 1996 · Checked 1 Oct 2026

District court ruling; later appellate history is separately linked.

Court opinion

Brzonkala: district court civil-remedy opinion, 935 F. Supp. 779 ↗

Source date: 26 Jul 1996 · Checked 1 Oct 2026

Opinion accepts allegations for purposes of the dismissal analysis, not as a criminal verdict.

Court opinion

Brzonkala: Fourth Circuit panel opinion ↗

Source date: 23 Dec 1997 · Checked 1 Oct 2026

Panel opinion; subsequently vacated for en banc review. Read alongside the Supreme Court history.