SEATTLE, Wash. – The Washington State Court of Appeals ruled last week that Washington State University (WSU) was responsible for the November 2019 hazing death of 19-year-old Sam Martinez during a fraternity event.
Last week’s decision is the first time a university has been held accountable for a hazing-related fatality in the state, reports King5. The court ruled that WSU owed a “duty of care” to Martinez, who died of acute alcohol poisoning while pledging at Alpha Tau Omega – a WSU-recognized fraternity.
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“Because WSU has a special relationship with its recognized fraternal organizations, we conclude that it owed a duty to use reasonable care to control the fraternity and protect Sam from the foreseeable harms of fraternal hazing and alcohol misuse,” said the appeals court in its ruling.
A lawsuit was filed by Martinez’s parents in 2020, but the case was dismissed in 2022 by a King County Superior Court judge, reports The Seattle Times. The superior court judge ruled WSU didn’t owe Martinez a duty of care.
The appeals court overturned the 2022 ruling. It didn’t, however, rule specifically if WSU is liable for Martinez’s death. The case will now go back to the superior court.
WSU Fraternity Pledge Died During Big Brother Party
According to a police and university investigation, as Alpha Tau Omega pledges, Martinez and another student were given a half gallon of rum to drink during the fraternity’s annual Big Brother Party.
The court found that WSU was aware of Alpha Tau Omega’s long, troubled history with hazing. In the five years leading up to Martinez’s death, dozens of complaints about the fraternity were reported to the school.
After his death, WSU shut the fraternity chapter down. In 2026 they will be allowed to petition to be reinstated.
Victim’s Parents Successfully Lobby for Anti-Hazing Legislation
Martinez’ death prompted his parents – Jolayne Houtz and Hector Martinez – to lobby for state and federal anti-hazing laws.
Their efforts led to former Governor Jay Inslee signing a law in 2022 that updated the state’s definition of hazing. Schools in Washington are now required to publicly report all investigations.
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On the federal level, President Joe Biden officially signed into law the Stop Campus Hazing Act in December. The new law, which went into effect January 1, requires college campuses to:
- Include hazing statistics in campus annual security reports,
- Implement hazing policies, including those specific to hazing prevention, and
- Compile a campus hazing transparency report.
To help college campus administrators learn how to comply with the new law, Campus Safety is hosting “Clery Compliance: Preparing and Planning for the Stop Campus Hazing Act” on February 6. For more information and to register for the free webinar, click here. After February 6, 2025, the presentation will be available on demand.
The new law and how to comply with it will also be covered in this summer’s Campus Safety Conference being held in Austin, Texas, July 21-23. For more information about the CSC 2025, visit CampusSafetyConference.com.