OLYMPIA, Wash – The Washington Supreme Court sided with a Court of Appeals court ruling, saying Washington State University can be held liable for a student who died in a fraternity hazing incident.
The Court’s decision in the Sam Martinez case upholds the appeals court decision that ruled the family can sue the university for their son’s death.
Martinez was a freshman at WSU in 2019. He died from acute alcohol poisoning during a hazing incident at the Alpha Tau Omega fraternity.
15 people faced criminal charges related to his death.
The incident death led to a wider conversation about hazing and the passage of Sam’s Law, which put in place mandatory reporting and policy requirements at Washington’s private and public colleges.
Martinez’s family sued WSU, saying the university breached its duty to protect students.
The lawsuit was initially dismissed, but in 2025, the Court of Appeals disagreed and ordered the case to proceed.
WSU appealed that decision to the Washington Supreme Court.
In its decision, the Court points out that WSU has a special relationship with fraternities and sororities. By recognizing the organizations and even promoting them, the university takes on a duty to protect students.
The Court points out that “WSU was aware for years before Sam’s death that fraternities put their members and potential members at risk by allowing them to drink alcohol and by engaging in hazing.”
The Court’s opinion points out that first-year students were especially susceptible to hazing and that WSU had a duty specifically to protect students like Sam.
“It should surprise no one that a house run by young men and full of other young men, many away from home for the first time in their lives, is fertile ground for abusing alcohol and engaging in dangerous initiation rituals,:the opinion reads. “It was certainly no surprise to WSU.”
While the Court’s opinion says WSU can be held liable, it does not specifically say whether it believes WSU actually breached its duty.
You can read the full opinion here.
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