EVANSTON, IL — Northwestern University’s cheerleading program functioned as an illegal sex trafficking operation that subjected cheerleaders to pervasive sexual assault and harassment, according to a lawsuit filed by one of its members.
The suit alleges that positions on the cheerleading team were conditioned on being groped by wealthy older donors and intoxicated fans in order to encourage contributions to the university. In order to avoid the financial penalties associated with losing a spot on the team, cheerleaders were forced to endure groping and harassment, according to the suit.
“Northwestern has long placed its financial priorities ahead of supporting survivors and has only acted in response to negative publicity, when it had absolutely no choice but to act,” the suit alleges. “As a general rule, Northwestern has implemented a policy of shaming and silencing survivors. Plaintiff experienced this firsthand in her efforts to expose the Athletic Department’s strategy of intentionally exploiting its cheerleaders, and subjecting them to sexual assault and harassment, for financial gain.”
Hayden Richardson, Northwestern senior from Nebraska, joined the university’s cheerleading team in her sophomore year after transferring from the University of Nebraska-Lincoln, according to a complaint filed Friday on her behalf in federal court in Chicago.
Richardson, 22, received a $5,500 scholarship after joining the team for the 2018-19 season, according to the suit. She and other members of the “Spirit Squad” were required to sign contracts agreeing to attend any events coaches required in addition to games.
If a cheerleader quit or was terminated, she would be responsible for reimbursing the university for all expenses associated with those events. In this way, according to the suit, Richardson was “essentially trapped in her degrading, dehumanizing and exploitative role as a sex object for fans and alumni donors.”
Being a Northwestern cheerleader required attending pre-game tailgating events where she was required to endure inappropriate sexual behavior from fans. The university’s cheer program is not NCAA-sanctioned or considered a competitive sport.
“At every home game, the cheerleaders were instructed to saunter around the tailgating lots as if they were Victoria’s Secret models on a runway, unsupervised, in their skimpy cheerleading uniforms,” the suit said. “They were expressly told to split up and flirtatiously mingle with extremely intoxicated fans alone and were not provided any security.”
The role also included mandatory attendance of alumni events, where cheerleaders were instructed to prance around alone for men old enough to be their fathers or grandfathers, the suit alleged. Men on the Spirit Squad were not required to do so.
“These men would then take advantage of the situation to sexually assault the team, slyly touching them inappropriately on their lower backs and behinds while taking photos,” it said. “The University used these events to portray [Richardson] as a sex object rather than the athlete and scholar that she is.”
Richardson received a Truman Scholarship last year and is a Miss Nebraska candidate who has worked with Nebraska Attorney General’s Office to raise awareness about gender equality and sex education. She intends to attend law school and become a federal prosecutor, according to the suit and an archived version of her website.
During Richardson’s first football season on the squad, she reported her safety concerns a coach, and described being assaulted during tailgating, but the coach did nothing, according to the suit.
Then in January 2019, Richardson described the harassment and assault to a team doctor, which led to a meeting a few days later with Northwestern’s associate athletic director for marketing.
According to the suit, the university official did not believe Richardson and demanded that she provide other testimony and supporting evidence before taking her concerns seriously — in violation of the university’s Title IX policy.
Later that month, Richardson provided evidence backing up her allegations about the coach and the “culture of sexual exploitation that permeated” the cheerleading program, the suit alleged. She said the the deputy director of athletics for external affairs prevented her from having a meeting with former Athletic Director Jim Phillips, who recently announced his departure to become head of the Big Ten Conference.
According to the suit, Richardson and another cheerleader met with athletic department officials on Jan. 24, 2019. At that meeting, the school staffers allegedly accused her of falsifying the evidence and failing to corroborate her allegations.
Richardson said her requests for a formal investigation into what she describes as systematic sexual exploitation, harassment and assault of the cheerleading team were refused by the university’s Title IX office. Instead, the coach was offered some form of unspecified training and remained in charge of the cheerleading team.
That fall, Richardson decided to remain on the cheerleading team for the 2019-20 season. She would receive a scholarship of about $4,000 in 2020, according to the suit.
Cheerleaders were no longer forced to attend tailgating, but they were still required to attend alumni events and appear at the Wilson Club during games. According to the suit, Richardson continued “to be paraded around in her skimpy uniform to please alumni and garner donations,” and wealthy Northwestern alumni continued to grope and harass her.
Richardson raised the issue again after the season, and the Title IX office opened an official investigation in June 2020, according to the suit. Richard offered a list of witnesses who could testify about the hostile environment the coach created, but she never heard any follow-up.
On Oct. 7, 2020, Richardson followed up with the Title IX office but was told she was considered a “witness” rather than a “complainant,” even though she was the one that brought the matter to the office, the suit alleged. That meant Richardson was unable to get any information about the case, which was considered “closed” as of a few days later.
In an interview with The Daily Northwestern published Oct. 7, 2020, Richardson said the coach was furloughed. According to the complaint, the coach was terminated Oct. 31.
In addition to Northwestern, the 58-page complaint names as defendants the university’s former cheerleading coach, who has not responded to a request for comment; its associate athletic director for marketing; its deputy director of athletics and its deputy Title IX coordinator.
It accuses the university of violations of Title IX by deliberate indifference and its employees’ creation of a hostile environment.
The complaint also accuses the university and the staffers of violating three parts of the Victims of Trafficking and Violence Protection Act — “trafficking with respect to peonage, slavery, involuntary servitude, or forced labor,” “sex trafficking of children or by force, fraud, or coercion.” and “forced labor.”
Other counts concern Richardson’s reliance on the school’s promises to provide an environment free from harassment, the allegation that the university violated its own binding code of conduct and that its employees intentionally inflicted emotion distress on Richardson.
In response to questions about the former coach’s departure and whether anyone at the university had been disciplined for their conduct relating to violations of Title IX policy, a university spokesperson said privacy rules prevented him from commenting on personnel.
No comment was immediately available from a university representative with regard to accusations that the university violated federal sex trafficking prohibitions.
According to the suit, university officials worked together to cover up investigations into the former coach’s actions “in order to avoid public criticism and to continue receiving large financial grants from donors.”
Northwestern “enticed” cheerleaders to join the squad, while knowing “that members would be forced to engage in commercial sex acts,” while school officials “collectively received a financial benefit as a result of the sexual exploitation it subjected Northwestern cheerleaders to in the form of large alumni donations which funded Northwestern athletics and subsequently Defendants’ salaries.”
Richardson’s suit said she was prescribed medications to combat the effects of the trauma she endured, which have hindered her academic progress and preparation for law school. It said the lack of preparation resulted in rejections from Yale, Georgetown and Arizona State university law schools. The suit asks for more than $75,000 in damages.
“Northwestern’s commitment to supporting victims was a façade to conceal a much uglier reality,” the complaint said. “Northwestern was willing to silence, and sacrifice the well-being of, its female athletes in order to keep its donors happy.”
Read full complaint below: