INDIANAPOLIS — Three members of the Butler University women’s soccer team have filed a lawsuit alleging that a former assistant athletic trainer sexually assaulted and groomed multiple players while he trained the team.
According to court documents, filed in the United States District Court for the Southern District of Indiana Indianapolis Division on Wednesday, three players, listed as respective Jane Does in three separate complaints, alleged the following charges against Michael Howell, a former assistant athletic trainer, Ralph Reiff, the senior associate athletic director for student-athlete health, performance and well-being at Butler University, and the university itself:
- Negligence against Butler University and Reiff;
- Gross negligence against Butler University and Reiff;
- Battery against Butler University and Howell;
- Assault against Butler University and Howell;
- Intentional infliction of emotional distress against Butler University and Howell.
The lawsuit claims that Howell “groomed, illicitly photographed and sexually assaulted” members of the team as a trainer starting in 2019, and other claims of misconduct. The lawsuit cited “multiple-hour full body massages” in private locations where he touched the athletes’ genitals and breasts. Howell worked with the university as the sole athletic trainer for the women’s soccer and men’s tennis teams from 2012 to October 2021.
As Howell’s supervisor, the lawsuit claimed that Reiff did not do enough to stop what Howell was doing and did not protect the women in these circumstances.
“Howell’s misuse of his position of power and authority over Butler athletes and deviation from standard practices were numerous and obvious,” the complaints said. “Defendant Reiff did not do anything reasonably required to investigate the circumstances, train the coaches, keep Howell or the athletes under watch, promulgate or request the implementation of safety policies, or otherwise protect multiple women as they were repeatedly abused by Howell in various locations on and off campus over extended periods of time.”
Jane Doe 1
The documents said that Howell targeted Jane Doe 1 in early 2021 and used his “authority and power as an athletic trainer to isolate, groom, manipulate, control, sexually assault and otherwise abuse” the player.
The documents outline many instances of alleged misconduct, which included lengthy private massages from Howell to Jane Doe 1. Regardless of where her pain was, the documents allege that Howell would go under the base of her sports bra, pull at her spandex and go past the waistband line of her underwear, becoming progressively invasive as time went on.
“Ms. Doe came to fear Howell, experienced great apprehension regarding his treatments and massages, tried to prevent him from touching intimate areas of her body and eventually began trying to avoid him altogether,” the documents said.
The documents cited one specific “three-hour long treatment” on Sept. 18, 2021 where Howell touched the player’s breasts and rubbed his genitals on her hand. After this treatment, the documents said that Jane Doe 1 confronted Howell and then tried to avoid his treatments.
The documents also said that Howell told Jane Doe 1 that he knew her social security number and that he knew “everything” about her. The documents also provided details on how Howell took pictures of and video recorded Jane Doe 1 without her permission.
“Howell told Ms. Doe and others, ‘If I go down, I’m taking you with me,” the documents read.
After players reported the misconduct to a coach, the documents said that Jane Doe 1 “could not stop crying because she was so relieved.” The report of the misconduct led to a Title IX investigation against Howell.
The documents said that athletes did not report Howell earlier “because of the high regard in which he was held by Butler, how Butler’s coaches spoke of him and because of his intimidating and threatening manner towards players.”
Jane Doe 2
According to court documents, Jane Doe 2 began attending Butler in Fall 2019. She alleged that Howell targeted her during her freshman year, continuing through her junior year until she was one of the players who reported Howell for sexual misconduct in October 2021.
The documents said that Howell treated the player “almost every day of her freshman year.” During the treatments, Howell allegedly asked her to take her shirt off, moved her bra straps to expose her breasts and touched her in other places.
During multiple hour-long massages over time, the documents said that Howell continued these actions in private rooms, therefore isolating her from other players. The player said that during these massages, she felt uncomfortable and powerless.
The documents specified an incident during her junior year. Jane Doe 2 said that she went to Howell for a neck treatment. During the treatment, however, Howell “quickly moved to her hips and groin…” and “rubbed her groin so forcefully that her groin was bruised and hurt the next day.”
Howell told the players, including Jane Doe 2, that he had files against members of the women’s soccer team and would use them if they ever said anything bad about him. This included alleged photos of student-athletes breaking team rules and information about parties. This caused Jane Doe 2 to be “frightened of Howell” and feel powerless against him.
Through the Title IX investigation, officials determined that Howell had sexually harassed Jane Doe 2 and had an “inappropriately close relationship” with the player, in which she was manipulated.
Jane Doe 3
In her court documents, Jane Doe 3 said that Howell sexually assaulted her on Sept. 11, 2021 after she came in for a treatment for lower back pain.
The documents said that Howell insisted on a full-body massage for her treatment and lifted her waistband and rubbed beneath it without her consent.
“He then started to massage Ms. Doe’s glutes, quads and eventually worked his way up to her groin,” the documents read. “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. Does felt powerless as she was being used for his sexual gratification.”
Jane Doe 3, who was one of the players who reported Howell, said in the documents that she was told Howell had things against her, like other players on the team. She specified that it included a picture of her roommate with an alcoholic drink. Jane Doe 3 said that she was “afraid of and intimidated by Howell.”
According to the documents, Reiff and other university employees reportedly admitted during the Title IX investigation that Butler University “had no written policies or procedures regarding proper athletic trainer conduct, setting boundaries with athletes or working with athletes of the opposite sex.”
The investigation also uncovered that Howell sexually assaulted and harassed multiple members of the team, “evidencing a widespread pattern of inappropriate conduct.” The officials who conducted the investigation recommended that Howell be fired.
Howell was employed by the university until Oct. 6, 2021. Officials with Butler University said that Howell was suspended and removed from campus on Oct. 6, 2021 and was fired after an investigation on June 2, 2022.
According to the respective complaints, the plaintiffs are three of six women who “formally reported Michael Howell’s sex abuse to Butler University.” They stressed that they comprise “just a few of the many victims of Howell’s abuse.”
“This action is brought by (the respective plaintiffs) to recover (their) injuries and damages, compel Butler to institute safety protocols to protect (their) current teammates and future athletes,” the documents said, “compel Butler to contact former student-athletes to assess whether they were also abused by Howell and need resources and assistance, prevent Howell from maintaining licensure that would give him the ability to abuse others, and to hold Defendants responsible for their acts and omissions that enabled a dangerous predator to gain unfettered access to and abuse (them) and many other young female athletes.”
The only other documents filed in the respective lawsuits are joint motions for each of the plaintiffs to proceed in the lawsuit under a pseudonym.
In a statement provided to FOX59/CBS4 from Butler University, officials said:
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.Butler University Officials