Larsen vs Phi Kappa Psi Fraternity Inc

COMES NOW Plaintiff LARS LARSEN for causes of action against Defendants PHI KAPPA PSI FRATERNITY, INC., an Indiana corporation; PHI KAPPA PSI CALIFORNIA LAMBDA CHAPTER, an entity of unknown form; SAN DIEGO STATE UNIVERSITY, a public entity; THE CALIFORNIA STATE UNIVERSITY, a public entity; CALIFORNIA LAMBDA PHI KAPPA PSI HOUSING CORPORATION, a California corporation; SAN DIEGO STATE UNIVERSITY RESEARCH FOUNDATION, a California corporation; FRATERNITY OWNERS ASSOCIATION, a California corporation; THE ENDOWMENT FUND OF THE PHI KAPPA PSI FRATERNITY, an Indiana corporation; CADEN COOPER, an individual; LUCAS COWLING, an individual; and DOES 1 through 50, inclusive, who complains and alleges as follows:

1. Hazing is a dangerous, illegal, and deeply rooted tradition that continues to plague university-affiliated fraternities, including those formally recognized and overseen by the California State University system. Fueled by a toxic culture of secrecy, bravado, and institutional failure, these violent and humiliating practices have endured for decades despite public outrage, legislative bans, and the mounting toll of serious injuries and deaths. They persist not only because fraternities continue to engage in reckless conduct with impunity, but because universities and their affiliated entities respond with deliberate indifference, willful inaction, or outright negligence. The result is a system that enables abuse, conceals risk, and fails the very students it is entrusted to protect.

2. This case arises from the compounded and ongoing failures of both the Phi Kappa Psi Fraternity and San Diego State University. Acting through its administrators and under the authority of the California State University system, San Diego State University knowingly allowed dangerous hazing practices within the Phi Kappa Psi California Lambda Chapter to continue unchecked. Despite prior disciplinary action and repeated warning signs, both the fraternity and the university, along with their affiliated entities, created and sustained an environment in which violent hazing was not only foreseeable, but effectively sanctioned through inaction. These events unfolded under their direct watch, in facilities they controlled, within a system they were responsible for managing.

3. Plaintiff Lars Larsen, a 19-year-old freshman at San Diego State University, suffered

catastrophic third-degree burns over 16% of his body after being intentionally set on fire during a hazing skit performed by members of the Phi Kappa Psi California Lambda Chapter. The incident occurred on February 17, 2024 , during a fraternity event at the Phi Kappa Psi fraternity house, located at 5525 Aztec Walk in San Diego, a facility historically conveyed by SDSU's nonprofit affiliate for the use and benefit of the fraternity and long utilized for recruitment, pledging, and ritual events.

4. This as not an isolated accident. It was the foreseeable and preventable result of a broader pattern of reckless conduct, institutional indifference, and systemic failure. At the time of the incident, the Phi Kappa Psi California Lambda Chapter was already under disciplinary probation imposed by SDSU for hazing, alcohol violations, and endangerment of the student body. Yet both the fraternity and university officials, including administrators responsible for Student Life, Greek Life and affairs, and risk management, failed to enforce sanctions, intervene in known dangerous activities, or warn incoming students and their families of the known risks. As a result, Plaintiff suffered life-altering injuries from the very conduct that Defendants knew was taking place, had the power to stop, and were legally obligated to prevent.

5. Plaintiff LARS LARSEN is and at all times relevant was a resident of the County of San Diego and a student at San Diego State University.

6. Plaintiff is informed and believes, and thereon alleges, that Defendant PHI KAPPA PSI FRATERNITY, INC. (hereinafter, "PHI PSI NATIONAL"), is a fraternal organization that manages, supervises, and exerts control over the operations and conduct of its local chapters, officers, and members, and/or has the right to exercise control over the activities, assets, and members of its local chapters, and acts, operates and transacts business in the State of California, including through its local chapter the California Lambda Chapter at SDSU.

7. Plaintiff is informed and believes, and thereon alleges that Defendant PHI KAPPA PSI CALIFORNIA LAMBDA CHAPTER (hereinafter, "CALIFORNIA LAMBDA CHAPTER"), was a branch of PHI PSI NATIONAL established at San Diego State University. CALIFORNIA LAMBDA CHAPTER is a fraternal organization that acts, operates and transacts business in the