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Scratching the Surface: Manning Alleged Sexual Assault Incident One of Many

Peyton Manning

By Macy Manolis*

April 11, 2016

Peyton Manning’s alleged sexual abuse of Ms. Jamie Naughright is raising questions about the newly retired quarterback’s character, as well as that of his alma mater, the University of Tennessee (“University”).[1]  Although the incident occurred nearly two decades ago, its facts are being looked at anew after multiple women brought suit against the University this February, claiming to have been sexually assaulted by male athletes.[2]  In their complaint, these women allege “numerous Title IX violations by the school, an adjudication process heinously biased against victims, and a pattern of sexual assault by male athletes.”[3]

Allegations Against Manning

Naughright, a former athletic trainer at the University, claims to have been sexually assaulted by Manning in 1996 while working at the University.[4]  Specifically, she claimed Manning “pulled his pants down and exposed himself” while she tended to his injured foot “after asking [her] several personal questions.”[5]  Naughright reported the incident to the University, but Manning faced no repercussions.[6]  Quite the opposite, Naughright reported that the University dismissed his actions as juvenile stunts.[7]

Apparently, Manning’s conduct was not the only of its kind.[8]  Naughright brought suit against the University for employment discrimination shortly after the Manning incident, citing dozens of other occurrences of sexual abuse and discrimination.[9]  The case eventually settled and Naughright’s employment with the University ended.[10]  As part of the settlement, the parties agreed to keep much of the information surrounding the suit confidential.[11]  Manning never faced criminal repercussions for his conduct.[12]

Instead of letting the allegations fade away indefinitely, Manning co-wrote a book in 2001, which included his version of the Naughright allegations.[13]  In the book, he seems to acknowledge that something inappropriate happened between the two, but that it was not nearly as serious as Naughright claimed.[14]  He also describes Naughright in a rather critical manner.[15]  As a result, Naughright brought a defamation suit against Manning and one of his co-authors.[16]  The case eventually settled and the matter was forgotten again until recently.[17]

Lawsuit Filed Against University of Tennessee

Naughright’s claims did not attract much public attention at the time, but in light of recent similar happenings at the University, her allegations cannot be dismissed so easily.[18]  Six unnamed plaintiffs recently sued the University arguing that it maintains “a toxic culture . . . that enables sexual assault and allows perpetrators to go unpunished.”[19]  The women are seeking damages for their individual troubles as well as injunctive relief to protect women facing the same hardships in the future.[20]

The complaint establishes the University’s unresponsiveness to take protective and preventative measures by detailing the facts surrounding each instance of sexual assault for all six plaintiffs.[21]  For example, one of the plaintiff’s claims she was raped by a football player in a school dormitory after she attended a fraternity party.[22]  The complaint also includes the employment discrimination claim filed by Naughright, which indicates sexual abuse has been a campus issue for quite some time.[23]  The complaint also references a memorandum written by a University higher-up expressing discontent in the way the University was handling student “misconduct and sexual assaults,” particularly the considerable role of the athletic department in investigating reported sexual assaults.[24]  The plaintiffs utilize the information in this memo to support their contention that the University created a “‘hostile sexual environment [and] rape culture.’”[25]

The complaint criticizes the University’s utilization of the “Tennessee Uniform Administrative Procedures Act,” which “provides students accused of sexual assault the right to attorneys and to confront their accusers through cross-examination and an evidentiary hearing in front of an administrative law judge.”[26]  These hearings favor alleged perpetrators at the expense of victims, who are exposed to extreme humiliation.[27]  Even more surprising, the judges presiding over these hearings are personally selected by the University’s chancellor and thought to be “favorable to athletes.”[28]  The plaintiffs also aver that the investigation process sometimes dragged on so long that athletes escaped answering to the claims against them altogether.[29]

It remains to be seen what will come of this lawsuit, but headway is being made considering multiple athletes accused in the complaint will be tried for rape this summer.[30]  As for Manning, the allegations will likely slip into the shadows again in light of his newly announced retirement.[31]


*Staff Writer, Jeffrey S. Moorad Sports Law Journal; J.D. Candidate, May 2017, Villanova University Charles Widger School of Law

[1] See Shaun King, KING: Peyton Manning’s Squeaky-Clean Image was Built on Lies, As Detailed in Explosive Court Documents Showing Ugly Smear Campaign Against His Alleged Sex Assault Victim, N.Y. Daily News (Feb. 13, 2016), (reporting on Peyton Manning alleged sexual assault scandal).

[2] See Diana Moskovitz, How Tennessee’s Sexual Harassment Allegations Caught Up With Peyton Manning 20 Years Later, Deadspin (Feb. 16, 2016, 12:16 p.m.), (noting renewed interest in Peyton Manning alleged sexual assault).

[3] See Kevin Draper, Lawsuit: University of Tennessee Had “Deliberate Indifference” Toward Sexual Assaults by Athletes”, Deadspin (Feb. 9, 2016, 11:52 p.m.), (explaining nature of suit against University of Tennessee).  For additional background on Title IX, see Title IX  & Issues, Woman’s Sports Foundation, (last visited Apr. 10, 2016).  In short, Title IX prohibits discrimination on the basis of sex “under any educational program or activity receiving Federal financial assistance.”  Id.

[4] See T.J. Quinn, Documents Reveal Peyton Manning Accuser Called Sexual Assault Crisis to Report 1996 Incident, ESPN (Feb. 23, 2016), (discussing facts relating to Manning’s alleged incident of sexual assault).

[5] See Employment Discrimination Complaint at 5, Naughright v. University of Tennessee (1996) (EEOC 25A963209), available at

[6] See Moskovitz, supra note 2 (discussing lack of action after Naughright’s alleged assault).

[7] See id. (noting University’s dismissal of seriousness of Naughright’s claims).

[8] See generally Employment Discrimination Complaint, supra note 5 (listing twenty-six instances of assault and discrimination in addition to claim against Manning).

[9] See id.see also Moskovitz, supra note 2.

[10] See Quinn, supra note 4 (“Naughright agreed to leave the university as part of a $300,000 settlement”).

[11] See Michael McCann, Breaking Down Sexual Assault Allegations Against Peyton Manning, Sports Illus. (Feb. 13, 2016), (explaining terms of settlement in Naughright case).

[12] See Quinn, supra note 4 (noting Manning was never criminally charged for conduct).

[13] See McCann, supra note 11 (explaining events that triggered defamation suit against Manning).

[14] See id. (discussing Manning’s acknowledgment of an incident with Naughright).

[15] See id.  Manning did not mention Naughright by her name, but it was obvious to whom he was referring in his book.  See id.  He described her as “‘vulgar,’” among other things.  See id.

[16] See id. (noting parties sued in defamation lawsuit).  Naughright filed suit against Manning and one of his co-authors, John Underwood.  See id.

[17] See id. (reporting outcome of defamation lawsuit).


[18] See Anita Wadhwani & Nate Rau, Sweeping Sex Assault Suit Filed Against University of Tennessee, The Tennessean (Feb. 24, 2016, 10:07 a.m.),

/story/news/2016/02/09/sweeping-sexual-assault-suit-filed-against-ut/79966450/ (explaining lawsuit filed against University of Tennessee).

[19] See Draper, supra note 3 (reporting on contents of lawsuit against Tennessee).

[20] See Complaint at 63, Doe v. Univ. of Tenn., No. 3:16-mc-09999 (M.D. Tenn. filed Feb. 9, 2016), available at (stating requested relief).

[21] See Draper, supra note 3 (referring to facts set forth in Complaint).

[22] See Complaint, supra note 20, at 21-22 (explaining Jane Doe I’s allegations).

[23] See Ray Sanchez, Peyton Manning Mentioned in Lawsuit Against University of Tennessee, CNN (Feb. 21, 2016, 4:30 p.m.), (noting reference to Manning in lawsuit filed against University).

[24] See Wadhwani & Rau, supra note 18 (referencing memorandum written by former Vice Chancellor, Tim Rogers, criticizing University’s reaction to sexual assault complaints).

[25] See id. (quoting plaintiffs’ statement in Complaint against University).


[26] See id. (discussing University’s procedures for sexual assault cases).

[27] See id. (identifying disparate treatment between athletes accused of sexual assault as opposed to other types of misconduct).

[28] See Draper, supra note 3 (noting alleged bias of hearing officers chosen to hear sexual assault cases).

[29] See Wadhwani & Rau, supra note 18 (explaining University’s use of stalling tactics throughout investigation process).

[30] See Draper, supra note 3 (“Johnson and Williams will be tried for rape this summer”).  Johnson and Williams are both “former football players” for the University.  See id.

[31] See Jeff Legwold, Emotional Peyton Manning Officially Retires After 18 Seasons, ESPN (Mar. 7, 2016), (reporting on Manning’s retirement from NFL).