Butler soccer players sue school, former athletic trainer for sexual assault

IL file photo

Editor’s note: This article contains explicit sexual language.

Three Butler University soccer players have filed suit against the school and its agents, alleging sexual abuse at the hands of a former athletic trainer.

The three cases — Jane Doe 1 v. Butler University; Michael Howell, individually and as an agent of Butler University; and Ralph Reiff, Individually and as an agent of Butler University, 1:23-cv-01302, Jane Doe 2 v. Butler University; Michael Howell, individually and as an agent of Butler University; and Ralph Reiff, individually and as an agent of Butler University, 1:23-cv-01303, and Jane Doe 3 v. Butler University; Michael Howell, individually and as an agent of Butler University; and Ralph Reiff, individually and as an agent of Butler University, 1:23-cv-01306 — were filed Wednesday in the U.S. District Court for the Southern District of Indiana.

All three complaints allege sexual assault by Michael Howell, an athletic trainer for the university from 2012 until his termination in 2022, and negligence by Ralph Reiff, Butler’s senior associate athletic director and Howell’s supervisor.

“The assaults and sexual misconduct — which included Howell rubbing his erect penis against female players and dripping his sweat on the athletes as he groped their outer vaginal areas, breasts, and nipples — trace back many years and were perpetrated in Butler’s training room, offices, buses, and in Howell’s private hotel rooms as he traveled with the team for away games; locations and times when Howell was presumably under the supervision of Defendant Ralph Reiff … and, more generally, the co-head coaches for the Butler women’s soccer team, Tari St. John and Robert Alman,” the complaints allege.

Jane Doe 1’s complaint alleges she was first targeted by Howell in early 2021, when she was a freshman.

According to her lawsuit, Doe 1 was recruited to the university to play soccer and, during a recruitment visit, she heard other players refer to the “breeze.” She later learned that phrase referred to Howell lifting the players’ bras, spandex and underwear, causing air to rush over them.

Because Doe 1 had a lack of experience with athletic trainers and because the practice was common among the players, she thought it was normal, she claims.

The complaint further alleges that in one instance in 2021, Howell told Doe 1 to report for treatment outside of regularly scheduled hours. He kept her for three hours in a windowless office with the lights off and, according to the complaint, sexually assaulted her during the incident. She had pain urinating after and thought he gave her a urinary tract infection.

“Multiple versions of this and other gross misconduct were perpetrated upon Ms. Doe numerous times before and after this incident, causing her substantial emotional, physical, and other injuries and damages,” the complaint continues. “Unfortunately, Howell perpetrated similar misconduct on other athletes.”

Doe 1 and five other women reported Howell’s misconduct to the university, including their belief that he was photographing and videotaping athletes. The university retained independent legal counsel to investigate the allegations under the Title IX statute.

According to the complaint, Butler alerted Howell to the investigation before contacting law enforcement or seizing his work-issued phone, allowing him to remove any photos or videos taken of athletes.

Following an investigation and hearings, the Title IX panel “confirmed the gravamen of the allegations, concluded that Butler did not have a formal policies and procedures manual for its athletic trainers, lacked necessary safety protocols, and emphasized Howell’s stark deviations from standard practices,” the complaint says.

The investigation revealed that the athletic training staff knew Howell was inappropriately handling and sharing body composition scan results and had indicators that he was infatuated with Doe 1. The panel also found Doe 1 was slowly and steadily isolated, stalked and manipulated in an “unconscionably abusive environment.”

For his part, the complaint alleges Reiff was aware that Howell created a “bubble” around the women’s soccer team while one of the head coaches, St. John, was aware that the culture could have prevented players from coming forward and reporting Howell.

Lastly, the panel found that Howell had sexually assaulted, sexually harassed and stalked Doe 1 and other women on the soccer team.

According to the complaint, Howell told Doe 1 and others, “If I go down, I’m taking you with me.”

In her complaint, Jane Doe 2 alleges Howell began assaulting her during her freshman year in 2019.

One incident in her complaint allegedly occurred in 2021, when Doe 2 went in for treatment on her neck. Howell began rubbing different parts of her body and rubbed her groin so forcefully that she was bruised and in pain.

The complaint also claims Howell told Doe 2 that he knew where she lived and referenced a pink pillow that she had sitting in her dorm room window. The complaint goes on to claim that Howell referred to Doe 2 as one of the “beasts” he created.

Like the other two plaintiffs, Jane Doe 3’s complaint references a treatment session in 2021, hers for lower back pain.

“Howell insisted on a massage and quickly after he began, he lifted her waistband and rubbed beneath it. He then started to massage Ms. Doe’s glutes, quads and eventually worked his way up to her groin. Howell continued until his hands were massaging her inner groin. He then lifted Ms. Doe’s shorts, spandex, and underwear as he was massaging her, exposing her vagina. Ms. Doe felt powerless as she was being used for his sexual gratification,” the complaint states.

Like the Doe 1 complaint, the other two complaints reference the plaintiffs and five other women reporting the alleged misconduct and going before the Title IX panel, which determined that Howell had committed sexual misconduct against the plaintiffs and other members of the soccer team.

The complaints also allege that the head coaches of the women’s soccer team knew Howell stopped providing written reports detailing the players’ injuries and his treatment in 2021, despite it being his responsibility to do so.

The lawsuits are brought for the players to recover their injuries and damages and to compel the university to institute safety protocols that would protect current and future athletes. The complaint also urges the university to contact former student-athletes to assess if they were also abused by Howell and prevent Howell from maintaining licensure that would give him access to abuse others.

Attorneys with Cohen & Malad LLP in Indianapolis and The Fierberg National Law Group PLLC in Traverse, City, Michigan, are representing the plaintiffs in each suit.

“Our clients and other student-athletes on the Butler women’s soccer team reported the abuse perpetrated against them by a predator employed by their university, and they subsequently proved their allegations in an extensive investigation and Title IX hearings. Afterward, they tried for months to obtain justice from Butler without being forced to file suit, but Butler’s responses, such as they were, were inadequate and compelled them to file lawsuits,” Andrea Simmons of Cohen & Malad said.

“By these lawsuits, these brave athletes seek to obtain full justice for the harms they suffered, notify other athletes who may have been sexually assaulted while playing sports for the University that they are not alone, and ensure that the predator once employed by Butler — who assaulted vulnerable female student-athletes multiple times, in multiple locations on and off campus — cannot hurt another athlete,” Simmons continued.

The complaints are seeking compensation for the plaintiffs’ injuries, as well as damages for past, present and future physical and psychological pain, suffering and impairment, medical bills, counseling, and other costs and expenses for past and future medical and psychological care.

“We look forward to representing these women as they seek justice for the sexual assaults they endured during their dedicated service to Butler University and its athletic program,” Simmons said.

Butler University issued a statement saying, “The health, safety, and well-being of our campus community is always our top priority. In late September 2021, student-athletes on the women’s soccer team reported misconduct by Michael Howell, an assistant athletic trainer. Upon being informed of the allegations, the University promptly notified law enforcement, removed Howell from campus and suspended him from his job duties, pending further investigation. After a thorough investigation and hearing, the trainer was found responsible for violating University policies, and he was then terminated in summer 2022. Butler looks forward to the opportunity to show the high integrity and responsiveness of the coaches and senior personnel. Because the complaints do not name the plaintiffs and they have not waived federal student privacy protections, Butler is limited from further comment outside of the legal process.”

Reiff did not respond to a request for comment.

Online court records do not yet list an attorney for any of the defendants.