YOUNGSTOWN (OH)
Chandra Law [Berkeley, CA]
November 10, 2025
By Chandra Law
New victim and family join suit; allegations of obstruction of justice and a continuing cover up by school officials
Victims of misconduct within the Ursuline High School football program have filed a Second Amended and Supplemental Complaint in federal court, broadly expanding the original 200-page lawsuit’s scope (the “Ursuline-hazing Complaint”).
The expanded, 290-page complaint adds a second family, Plaintiffs John and Jill Roe and their son, Son Roe (pseudonyms), and incorporates vital new evidence and allegations that detail at least a four-year pattern of systemic abuse, hazing, and official cover-ups by school administrators and coaches.
New allegations and revelations
The amended and supplemental complaint adds these new allegations:
- Multi-year hazing tradition: The Roe family alleges that Son Roe was subject to hazing and threats during the 2024 football-camp trip, a year before the assaults detailed in the “Doe” family’s initial filing. The complaint now includes evidence that the hazing and sexual-abuse tradition dates back to 2022, including descriptions of new video evidence and first-hand accounts from other football players. According to the complaint, after a victim from the 2022 trip was attacked, his parents immediately notified Athletic Director John DeSantis, who told Coach Daniel Reardon. Yet, neither Ursuline official took any action to address and stop the hazing. As a result, the hazing escalated over the years. (DeSantis is now added as a defendant.)
- New video evidence: The complaint alleges details from several new videos obtained since the original complaint’s filing. The new videos provide explicit and graphic details of the football team’s hazing activities. Because the videos contain minors and child pornography, plaintiff’s counsel are prohibited from releasing them to the public. The updated complaint describes the videos obtained as follows:
- 2022 camp video 1: While the victim was on his knees, players ordered him to repeat ”Please don’t beat my ass” and “I’ll do whatever you need.” When the victim refused, players stomped, kicked, and punched the victim repeatedly. One player said, “Finger him! Finger him, please!” Players wrapped a sheet/towel over the victim’s head and throat and proceeded to choke and swing him around. Another player then puts his buttocks on the victim’s head/face.
- 2023 camp video 1: Two players wrestled on a hotel bed.
- 2023 camp video 2: One player held a victim-player face down on the bus floor while the player humped and ground his penis into the victim’s buttocks.
- 2023 camp video 3: The victim was on the floor with no pants or underwear. The victim was covering his genitals with his hands while another player said, “So much for that f*cking orgy that you wanted, b*tch!”
- 2023 camp video 4: Players and victim appear to be in a tug-of-war over clothing. The video has a meme caption saying, “get you drawls [sic] back [victim].”
- 2023 camp video 5: Player held up a pair of ripped underwear saying, “I’m the ma f**king WWE champ n***a. What you talking about. Got this shit on me. F**k you talking about.”
- 2023 camp video 6: Player held up a pair of ripped pants and underwear, and said, “Man. I got this n***a’s drawers and his phone.”
- 2023 camp video 7: Player picked up the victim by the throat and slammed him onto the hotel bed, then ripped off the victim’s pants and underwear exposing the victim’s naked body; the victim tried covering his genitals with his hands. Other players stood around watching, laughing, and cheering. The player recording the attack walked over and stood over the naked victim while recording.
- 2023 camp video 8: One player was held face down on a hotel bed while a second player humped and ground his penis into the first player’s buttocks. A third player humped and ground the second player. Then a fourth player joined in and humped and ground the third player, and then a fifth player joined in and humped and ground the fourth player. All players were clothed.
- 2023 camp video 9: Three shirtless players stood in the hotel hallway wearing only shorts. One player grabbed the second player and ripped off his shorts and underwear, exposing the second player’s genitals and buttocks, while the third player laughed.
- 2025 camp video 1: Multiple players held down the victim and ripped off his pants and underwear exposing the victim’s genitals.
- 2025 camp video 2: Two players held the victim down on the bed. One player then lifted the victim’s legs over his head, but didn’t hump the victim. But when the first player jumped off the bed, the second player grabbed and held the victim’s leg over his head in a similar manner and humped and ground his penis into the victim’s buttocks. The players were clothed.
- 2025 camp videos (multiple): These videos show the attack and hazing of Plaintiff Son Doe, in which multiple players held Son Doe down and ripped off his pants and underwear, exposing his genitals and buttocks. One player slapped Son Doe’s bare buttocks; another player threw Son Doe to the ground after the attack, and another player slapped Son Doe’s head/face.
- Obstruction of justice: The complaint alleges Principal Matthew Sammartino instructed players involved in the hazing to “delete” any evidence from their phones and ordered them, “Don’t say anything to anyone about this,” thus inducing evidence destruction and obstructing a likely criminal investigation.
- Ursuline administrators allegedly knew of the football team’s years long “tradition” of hazing: In June 2025, when Principal Sammartino, Assistant Principal Margaret Damore, and Athletic Director John DeSantis met with players to discuss the hazing allegations, several players confessed their involvement in the hazing and one player even told the administrators that the football team’s “tradition” of hazing “has been going on for years.” The administrators also possessed several of the videos from the 2025 trip. Yet Ursuline officials have continued to issue false and misleading public statements about the hazing. The Ursuline officials also failed to inform law enforcement that the players confessed and the hazing had been occurring for years.
- New evidence contradicts Ursuline officials’ claim that they investigated the matter: In June 2025, Ursuline possessed several of the videos from the 2025, had the confessions of several players, and were informed the hazing had been occurring for years. Despite possessing all of this evidence, the Ursuline administrators issued no punishments or discipline, instead “the players were still permitted to return to the field to win football games.” Despite knowing what they knew, the administrators waited until this suit was filed to suspend the coaches.
- Coaches allegedly knew about and tolerated abuse: The updated complaint alleges that Head Coach Daniel Reardon, Assistant Coach Timothy McGlynn, and Assistant Coach Christian Syrianoudis heard players openly discuss their hazing plans, including “taking butts” and initiating fights, in McGlynn’s case dismissing the assaults as “just boys being boys.” The hazing discussions occurred during the 2022, 2023, 2024, and 2025 football-camp trips, yet the coaches failed to address or stop the abuse.
- History of abuse: The complaint quotes public records alleging that McGlynn in his prior job at Champion High School resigned under investigation after serial victim and witness allegations that he physically assaulted and abused players, and cites a consent agreement he entered with the Ohio Department of Education. Ursuline hired him anyway.
- Illegal recruiting: The complaint details text messages suggesting Assistant Coach Timothy McGlynn actively violated OHSAA rules by promising a mother “a vacation” and directing the mother to “lie” about a rival school’s scholarships to lure a player to Ursuline—demonstrating the administration’s willingness to break rules to win.
- Cooperating parties: The new filing includes information from cooperating individuals, including football-player defendants and other victims and witnesses, who have verified the multi-year culture of violence and the institutional rot described in the lawsuit.
- Misleading lies: Ursuline is alleged to have issued a series of false statements to parents, alumni, and the public falsely claiming it had investigated, was investigating, and had disciplined those involved, when it had done no such thing. But Ursuline never admitted in any public statement that school officials and coaches knew the hazing had occurred over a period of four years.
- Disinformation escalating into threats of violence: After the original complaint’s filing, Ursuline held a parent meeting to discuss the football team’s future. Rather than accepting responsibility, Coach Reardon falsely accused a rival high school and one of plaintiff’s counsel for the lawsuit’s filing—even falsely alleging that the video evidence was altered or manufactured. Reardon’s false statements have now been echoed by fervent Ursuline supporters on social media, which have escalated into threats of violence—including a threat to “Kill” and “shoot up the school” apparently directed toward the rival school. Even after learning of the threat, Ursuline officials failed to notify law enforcement, its own parents, and the rival school.
- Criminal violations and failure to report: Until June 2025, none of the administrators and coaches fulfilled the mandatory reporting obligations to children services and law enforcement imposed on them by criminal law. The complaint alleges various violations of criminal statutes during 2024 and 2025 camp trips in Indiana, Wisconsin, Alabama, Florida, and Tennessee.
This lawsuit is one of two related federal cases filed thus far against Ursuline and its officials, all alleging a systemic failure to protect students: the original “Ursuline-hazing Complaint” and the “Ursuline-dragging Complaint” (alleging physical assault against a female student and a cover-up). Plaintiffs’ counsel anticipate filing more suits from more victims in the coming weeks..
The plaintiffs allege that Ursuline’s administration and the Catholic Diocese of Youngstown were deliberately indifferent to student safety, prioritizing the “glory of the football team alone” at any cost.
Subodh Chandra, plaintiffs’ lead counsel, issued the following statement:
The Second Amended and Supplemental Complaint provides evidence that the misconduct at Ursuline was not only systemic but that the school’s top administrators and coaches shielded it. When presented with videos of assault and child pornography, the principal’s alleged response was to tell students to destroy evidence and keep quiet. That would represent an institutional choice to obstruct justice and protect the football program over children.
Our clients are determined to hold everyone accountable for perpetuating this toxic culture.
And they ask, ‘Why isn’t the Bishop doing anything about this? Why is he letting Ursuline administrators run the show when the evidence submitted suggests they knew about and indulged the hazing culture for years, and covered it up when caught?’
Chandra added, “We urge other witnesses and victims to contact us through our secure contact form. You are not alone.”
The legal team for the plaintiffs includes lead counsel Subodh Chandra and Alexandra Day Lavelle of The Chandra Law Firm LLC. The matters are co-counseled by local Youngstown counsel.
The case is captioned, Doe, et al. v. Ursuline High School, et al., N.D. Ohio Case No. 4:25-cv-01822-BYP and is before U.S. District Judge Benita Y. Pearson.