Jane Doe v. University of Chicago

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Submitted March 5, 2025*
Decided March 6, 2025
Before
MICHAEL B. BRENNAN, Circuit Judge
CANDACE JACKSON-AKIWUMI, Circuit Judge
JOSHUA P. KOLAR, Circuit Judge
No. 23-3070
JANE DOE,
Plaintiff-Appellant,
v.
UNIVERSITY OF CHICAGO, et al.,
Defendants-Appellees.
Appeal from the United States District
Court for the Northern District of
Illinois, Eastern Division.
No. 22-cv-01032
John F. Kness,
Judge.
* We have agreed to decide the case without oral argument because the briefs and record
adequately present the facts and legal arguments, and oral argument would not significantly aid the
court. FED . R. A PP . P. 34(a)(2)(C).
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with F ED. R. APP . P. 32.1

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No. 23-3070 Page 2
O R D E R
Jane Doe1, a former student at the University of Chicago School of Law, appeals
the dismissal of her wide-ranging suit against the University and various employees as
barred by the statute of limitations. The district court ruled that the limitations period
had expired before Doe filed suit, and that no theory of tolling could save her claims.
We affirm.
Doe enrolled as a student at the University of Chicago School of Law in 2006, but
her time at the law school was not as successful as she had hoped. Throughout her time
in law school, she failed numerous courses. Although she graduated law school in
June 2010, Doe asserts that her law school transcript is “fraudulent” because it did not
include any reference to her failed courses, and her law degree is invalid because she
received credit for courses that she failed. She took the New York bar exam but ended
her pursuit of becoming an attorney because of her alleged invalid law degree.
In December 2021, she sued the University along with several faculty members
and deans of the law school. She alleged one federal claim under the Racketeer
Influenced and Corrupt Organizations Act, 18 U.S.C. § 1962, and five state-law claims
including violation of Illinois’s Consumer Fraud and Deceptive Business Practices Act,
breach of fiduciary duty, breach of contract, fraudulent concealment, and unjust
enrichment.
Doe initially sued in the Southern District of New York, but the court transferred
the case to the Northern District of Illinois because Doe did not allege that any of the
defendants reside in New York and her claims arose primarily from her experiences
while at law school in Chicago. After the transfer, the defendants moved to dismiss the
complaint under Federal Rule of Civil Procedure 12(b)(6), arguing, among other things,
that the suit was untimely.
The district court agreed with the defendants that the statute of limitations
barred Doe’s claims. Noting that the longest possible limitations period was 5 years,
see 735 ILCS 5/13-205, the court ruled that the statute of limitations had lapsed because
the clock began to run when Doe received her law degree—June 8, 2010—and she did
not file her suit until December 2021. The court rejected Doe’s theories for tolling the
time to sue. And based on all the connections that this case had to the Northern District
1 Because plaintiff’s allegations reflect numerous details relating to her physical and mental
health, the district court permitted her to proceed under the pseudonym “Jane Doe.” We will do the
same.

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No. 23-3070 Page 3
of Illinois, the court denied Doe’s motion to transfer the case to the Southern District of
New York.
On appeal, Doe first challenges the dismissal of her complaint based on the
statute of limitations. But dismissal was correct here. Doe does not dispute that the
longest possible limitations period for her claims was subject to the Illinois 5-year
statute of limitations. 735 ILCS 5/13-205. Under Illinois law, Doe’s claims accrued as
soon as she should have discovered her injury. Khan v. Deutsche Bank AG, 978 N.E.2d
1020, 1028–29 (Ill. 2012). As the district court correctly noted, Doe should have known of
her invalid law degree by June 2010. That is when, according to the complaint, she
received a law degree despite failing multiple courses. When she sued—more than
11 years later—the limitations period had expired.
Doe insists that her claims were tolled because her professors, acting in a
fiduciary capacity, fraudulently concealed the fact that the University awarded her an
invalid law degree. See 735 ILCS 5/13-215 (statute of limitations on claims that are
fraudulently concealed does not expire until five years after the claim is discovered).
Even if we assumed that a fiduciary relationship existed, Doe’s tolling argument fails
because she does not allege any causal connection between her professors’ silence and
her failure to timely discover her claims. See Guarantee Tr. Life Ins. Co. v. Kribbs,
68 N.E.3d 1046, 1057 (Ill. App. Ct. 2016) (no fraudulent concealment where plaintiff
failed to attribute its failure to discover its claims to fiduciary’s silence).
Doe also invokes equitable tolling, pointing to mental-health issues that she says
have rendered her legally disabled. See 5 ILCS 5/13-211. Illinois law defines a “legal
disability” as one that prevents an individual from being able to manage her person or
estate. 5 ILCS 70/1.06; see Parks v. Kownacki, 737 N.E.2d 287, 295 (Ill. 2000). Doe contends
that her impaired cognition and declining mental health prevented her from filing suit,
but she did not allege that she had any difficulty managing her person or her estate.
Finally, Doe challenges the district court’s denial of her request to transfer venue
to the Southern District of New York. See 28 U.S.C. § 1404(b). But the district court
appropriately exercised its discretion to deny the motion, given that Doe’s claims
primarily arose from events that occurred in the Northern District of Illinois—a court
that was available, adequate, and more convenient for witnesses. Id. § 1404(a); see Rsch.
Automation, Inc. v. Schrader-Bridgeport Int’l, Inc., 626 F.3d 973, 979 (7th Cir. 2010).
We have considered Doe’s remaining arguments; none merits further discussion.
AFFIRMED

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