Washington Supreme Court rules WSU liable in Sam Martinez fraternity hazing death

The Washington Supreme Court ruled Thursday that Washington State University (WSU) had a legal duty to protect Sam Martinez, a 19-year-old Bellevue freshman who died of alcohol poisoning during a fraternity hazing ritual in 2019.

The 5-4 decision means WSU can be held liable for Martinez’s death and allows his family’s wrongful death lawsuit to go to trial.

“While this decision does not determine the outcome of this case, the university respects the judicial process and will continue to engage responsibly and thoughtfully as the case moves forward,” WSU said in a statement Thursday.

The university said it remains committed to student safety and continually strengthening its policies, education and oversight related to hazing.

“These efforts reflect its ongoing commitment to its students and community, including fostering a campus community that provides students with the education and resources to make responsible choices,” WSU stated.

The university added that its legal counsel will carefully review and analyze the court’s decision before determining next steps.

Ruling upholds appeals court decision

Martinez died while pledging the fraternity Alpha Tau Omega at WSU.

His death led to the passage of Sam’s Law, which requires university employees to report hazing.

The Washington Supreme Court’s ruling upholds a 2025 appeals court decision — the first time a university within Washington has been held accountable for a hazing-related fatality.

That decision overturned a 2022 King County Superior Court ruling in which a judge dismissed the case, finding that WSU did not owe Martinez “a duty of care.”

“Because WSU has a special relationship with its recognized fraternal organizations, we conclude that it owed a duty to use reasonable care to control the fraternity and protect Sam from the foreseeable harms of fraternal hazing and alcohol misuse,” the Washington Court of Appeals, Division 1, wrote in its decision, obtained by The Seattle Times.

‘Nobody called 911’

In 2019, a fraternity member gave Martinez and another “pledge” a half gallon of rum and told them to drink it in less than an hour during the fraternity’s annual Big Brother Party, KIRO 7 confirmed through court documents. Martinez died of alcohol poisoning, police and university investigations confirmed.

“Nobody called 911, and they woke up to a nightmare, and so did we,” Martinez’s mother, Jolayne Houtz, told KIRO 7. “He’s gone, and I can’t stand by and be worried every time a school year begins that another family will have to go through this because it’s wrong.”

15 students charged after fraternity hazing death

Prosecutors charged 15 students with furnishing alcohol to a minor, which, as a gross misdemeanor, was a tougher charge than hazing. Some served jail time between one and 19 days, while others were sentenced to probation.

WSU knew of years of hazing, court found

One of the reasons the appeals court ruled against WSU was that the court found the university knew of and neglected multiple instances of troubling behavior, according to KING 5. In 2013, the WSU conduct board found the fraternity made pledges clean up raw sewage and drink excessive amounts of alcohol. In 2017, the fraternity was documented forcing pledges to drink excessively and endure “aggressive hazing.”

The university also had evidence Alpha Tau Omega humiliated new members by forcing them to stand in toilets.

“They had a terrible history. University leaders knew that all the way to the top, and they did nothing,” Houtz told KING 5. “If I would have known a quarter of what I now know about Alpha Tau Omega, there’s no way Sam would have wanted to join and, furthermore, we wouldn’t have allowed him to join. They knowingly put Sam and other students in harm’s way.”

Contributing: Frank Sumrall, MyNorthwest

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