An international student is suing Penn State for allegedly depriving him of a fair student conduct hearing, according to a lawsuit filed on Monday.

The student, identified as John Doe in the complaint, stated he had a contentious relationship with Penn State Law Professor Jud Mathews, and that the university unfairly sided with Mathews during a student conduct hearing held to evaluate the incidents that occurred between Doe and Mathews.

Additionally, Doe claims his right to privacy was violated as the university allegedly accessed information from a confidential phone conversation he had with Penn State Counseling and Psychological Services.

The complaint, which was filed in U.S. Middle District Court, names Penn State, the Board of Trustees and Karen Feldbaum — the interim senior director for the Office of Student Conduct — as defendants. It demands a jury trial.

Doe's complaint stemmed from his working relationship with Mathews. Doe, who was a second-year law student during the 2018-2019 academic year, first came to the United States in 2017 to attend law school.

Mathews, an affiliate professor of law in the School of International Affairs, was Doe's civic procedure professor during Doe's first year, the 2017-2018 academic year. The complaint states Doe did research for Mathews during this time and viewed Mathews as a "father figure."

In April 2018, Doe offered to create a website for Mathews under Mathews' name, which Mathews agreed to if Doe could "get a good deal" on the domain, according to the suit.

After Doe purchased the domain, Mathews was allegedly unhappy with the purchase and offered to buy the domain from Doe. Doe said he would give the domain to Mathews as a gift, as purchasing the domain with the sole intent to resell would illegally break his contract with the domain's provider, according to the suit.

The suit says Mathews agreed to receive the domain as a gift.

Several weeks later, Doe began working for Mathews as a research assistant in the summer of 2018. During his research, Doe alleges he began to face numerous ethical concerns.

According to the complaint, when Doe could not find authors to match Mathews' assertion, Mathews told Doe to make up citations because the material was in a different language and claimed "no one [would] check" to verify the citation.

Additionally, the suit alleges that on July 2, 2018, Mathews told Doe to fraudulently copy opinion texts directly from a commercial database, remove proprietary materials and falsify information if cases were from a public source to "save time." When Doe questioned the ethics behind this, Mathews allegedly yelled at Doe and threw a pen at him, according to the suit.

After this incident, Doe called CAPS, in which he was reportedly advised to stop working for Mathews and told his conversation with CAPS was confidential.

On July 6, 2018, the suit claims Doe reached out to Mathews to talk about the incident. Six days later, Doe and Mathews discussed the incident during a video conference that was recorded by Mathews, in which Doe reported that Mathews indicated he could speak negatively of Doe to future employers.

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At the end of summer 2018, Mathews again asked to purchase the domain from Doe, and Doe refused. Doe offered to relinquish the domain but Mathews "strongly opposed," according to the complaint.

The two officially terminated their relationship on Aug. 7, 2018.

Three days later, Mathews filed a 10-page "Behavioral Threat Management Team Referral Form" about Doe in which he said Doe made him feel "uncomfortable." Mathews referenced CAPS 10 times in the form, according to the complaint.

On Aug. 15, Penn State Law Deans Keith Elkin and Victor Romero initiated a meeting with Doe in which they discussed the "pen incident," video conference, domain and Mathews' alleged threat to "tarnish Doe's reputation." During this meeting, Doe was told he would not be permitted to take Mathews' administrative law class, despite the fact that no other professor teaches the class, according to the suit.

Doe also relinquished the domain following his meeting with Elkin and Romero.

On Aug. 17, 2018, Doe then met with Feldbaum — who, according to the complaint, has publicly expressed bias against international students.

During the meeting, Doe was given a notification of administrative directive, according to the complaint. Feldbaum allegedly did not tell Doe why the directive was issued or what allegations Mathews made against Doe.

While Doe and Feldbaum had scheduled another meeting for Feb. 20, 2019 to discuss Doe's "side of the story," the university was closed that day due to heavy snow. Doe showed up for the 10 a.m. meeting, but Feldbaum did not, according to the complaint.

That morning, Mathews told Feldbaum he received anonymous text messages he believed to be sent by Doe. Twelve minutes before the scheduled meeting, Feldbaum emailed Doe about the text messages, and told him she would "move forward with the conduct process" if Doe did not wish to acknowledge the messages.

"If you wish to get help with these issues and see if there is a way for you to continue in school, you need to acknowledge what you are doing and agree to get the assistance we require," Feldbaum wrote to Doe, according to the suit.

When Doe emailed Feldbaum back asking for "confirmation" that he violated the directive, Feldbaum issued the university charge and sanction for failure to comply, according to the suit. She added the text messages received by Mathews were "timely" because Doe was scheduled to meet with Feldbaum the same day Mathews received the messages.

Doe maintained he did not send the text messages, and the suit claims the area codes of the messages sent to Mathews are identical or nearly identical to Matthews' area code. The content of the messages is unclear.

Doe was charged with a code violation for failure to comply with a directive, according to the suit. Additionally, a counseling assessment sanction was filed in which CAPS would meet with Doe for a consolation session to "discuss options for ongoing treatment as needed," according to the suit. These sanctions would appear on Doe's transcript until Dec. 20, 2019.

Doe contested the charges, and a hearing was scheduled for March 12.

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On Feb. 26, Mathews wrote an eight-page "statement to the hearing officer" about Doe. In the statement, Mathews said it was hard to imagine the text messages to be sent by anyone other than Doe. According to the suit, Mathews claimed the messages' writing style was similar to Doe's and the texts had a "sexual or amorous tone."

Mathews also reportedly referred to himself as a "low-drama person” in the statement.

Doe was given access to the statement and the previously filed Behavioral Threat Management Team Referral Form on March 4, according to the suit.

During the March 12 hearing, both Doe and Mathews were questioned about the domain and text messages. Four hours after the hearing, Doe was found responsible of violating the administrative directive, according to the suit.

The results of the hearing claimed Doe fraudulently used other phone numbers to text Mathews. When Doe asked for evidence to support this claim, the suit alleges Feldbaum obtained Doe's private CAPS records "as a retaliatory act" and told Doe CAPS was willing to meet with him "on a regular basis."

Since the hearing, the suit claims Mathews has published a book that uses Doe's research without crediting him.

According to the suit, immediately after the hearing, Feldbaum discussed the book with Doe and allegedly "pressured" him to be acknowledged in it. The complaint says Doe refused, and told Feldbaum that because the research was now almost a year old, it would need to be updated.

The suit claims the research has not been updated. Mathews published the book, titled "Proportionality Balancing and Constitutional Governance: A Comparative Global Approach" in May. The suit states that Doe is mentioned nowhere in the book.

In addition, the suit alleges that Mathews has sent negative references about Doe to future employers, including the professor who employed Doe in August 2018 following Doe and Mathews' fallout. Mathews has also allegedly discussed Doe in his classes to other law students.

Mathews, who was previously an associate professor, was promoted to Professor of Law in July 2019.

The suit states that the university violated Doe's 14th Amendment rights, retaliated against his First Amendment exercise, committed a breach of contract, committed negligence and invaded Doe's privacy.

Doe seeks monetary damages and injunctions requiring Penn State to reinstate him in good standing, vacate the finding that he was responsible for a Code of Conduct violation, and expunge his disciplinary file.

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