👨‍🎓 Former UMass Lowell Dean Ordered to Pay Over $500,000 for Sexual Harassment, Appeals Court Affirms

In 2017 Shontae Praileau became an academic advisor at the University of Massachusetts in Lowell.  Her direct supervisor was the associate dean of undergraduate studies, Oliver Ibe.

Praileau claims that Ibe made unwanted comments and advances towards her that amounted to sexual harassment.  In particular, she alleges that Ibe took her out to lunch on her first day at the university.  During lunch Ibe supposedly asked Praileau about her sexual orientation and dating preferences.  She claims that Ibe referred to her first day on the job as their “anniversary” and frequently called Praileau his “girlfriend.”  Praileau also asserts that Ibe engaged in unwanted hugging, touching, and kissing (on the forehead), while they worked together.  Moreover, Ibe allegedly reminded Praileau that she was on employment probation and that he could “erase” her (i.e., fire her) at any time.

Praileau reported Ibe’s behavior to the University’s office of equal opportunity and outreach (EOO).  That office investigated the matter and sent a notice to Ibe advising him that his conduct violated school guidelines.  Additionally, EOO relocated Praileau to another building at the university to distance her from Ibe.

In June 2019, Praileau filed a lawsuit against Ibe in Bristol County Superior Court.  Her complaint alleged that Ibe’s conduct created a hostile work environment and constituted sexual harassment.  The matter was settled at a bench trial three years later (June 2022).  Ibe represented himself at trial and lost big.  The superior court judge ruled in favor of Praileau and awarded her $250,000 in compensatory damages, $100,000 in punitive damages, and a staggering $114,000 in attorney’s fees.  When prejudgment interest was added, the total amount came to $554,092.

Ibe appealed the judgment arguing, in part, that prejudicial hearsay was admitted at trial and that improper questions were asked by Praileau’s lawyer during cross-examination. 

First, Ibe contends that the trial judge erred when she allowed Praileau’s attorney to submit EOO’s letters into evidence.  These were the letters informing Ibe that his behavior violated the university’s rules of conduct.  Ibe argued that these letters contained inadmissible hearsay evidence because no one from EOO testified at trial. 

Next, Ibe claims that the trial judge erred by allow Praileau’s lawyer to question Ibe on cross examination about his alleged sexual misconduct while employed at George Tech.  The questions were, according to Ibe, irrelevant and “devastatingly prejudicial.”

The Appeals Court rejected Ibe’s arguments because he failed to object to either point at trial.

[N]one of the issues Ibe raises on appeal were preserved by a proper objection at trial.  (Ibe either did not object or did so on grounds different from those he presses on appeal.)  Accordingly, the issues are waived, and we need not address them.  (Citations and quotations omitted.)

The fact that Ibe represented himself made no difference to the appeals justices:

Nor are we persuaded that we should excuse the absence of proper objections on the ground that Ibe representated himself at trial.  It is well settled that pro se litigants are held to the same standards as practicing attorneys.

The justices also concluded that the $114,000 legal bill submitted by Praileau’s attorney was reasonable.  That lawyer charged, according to the justices, $500 per hour.

The full text of the opinion is attached below.