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Case Result · Hazing

Samuel H. Martinez Fraternity Hazing Death

2026 WA Supreme Court — WSU owed Sam a duty of care

Washington State University · Pullman, WA

Last updated October 7, 2026

Martinez, Estate of Samuel H. vs. Washington State University, Alpha Tau Omega Fraternity and Individual Defendants

Case Details

Who: Samuel H. Martinez was a freshman student whose death occurred in connection with alcohol-related fraternity conduct at Washington State University.

What Happened: Washington State University freshman, Samuel Martinez, 19, died from alcohol poisoning in November 2019 while attending an event at the Alpha Tau Omega. Martinez and another pledge were allegedly ordered to finish a half-gallon of rum between them, and his blood-alcohol content was measured at 0.372% after his death, nearly five times the legal limit. Pullman Police originally ruled out hazing, but later rescinded that statement following witness interviews. The coroner later ruled Martinez died accidentally from acute alcohol intoxication and said 911 was not called until four hours after he died.

Results

Washington State University was initially dismissed from the matter, but in January 2025, “in a landmark decision, the Washington State Court of Appeals ruled that Washington State University (WSU) bears responsibility for the 2019 alcohol-related death of a freshman student, marking the first time a university has been held accountable for a hazing-related fatality in the state.”

The Court of Appeals found WSU was aware of ATO’s problematic past but didn’t implement effective measures. University and law enforcement documents reveal that despite numerous reports about ATO’s conduct filed with campus authorities in the five years before Sam died, disciplinary actions were minimal.

In July 2026, the Washington Supreme Court affirmed. In Martinez & Houtz v. Washington State University (No. 104108-0), the court held that WSU’s long-standing relationship with the fraternity, and its ability to control it, meant WSU “owed a legal duty to Sam Martinez to act with reasonable care to protect him from the foreseeable harm of Gamma Chi’s hazing rituals.” The case now returns to the trial court. Read the Supreme Court opinion.

Impact

The ruling marked the first time a university in Washington State has been held accountable for a hazing-related fatality, significantly expanding institutional responsibility for student safety and alcohol-related fraternity misconduct.

In the Media

Sam's death, the fight for accountability, and the law it inspired, as covered by national and local media.

60 Minutes

Washington · 60 Minutes

Anti-hazing “Sam’s Law” enacted in Washington

Anderson Cooper reports for 60 Minutes on the hazing death of Sam Martinez and the Washington law his family fought to pass in his name.

Washington · KOMO News

“The hazing death of Sam Martinez, a mother’s call to action”

Sam’s mother, Jolayne Houtz, joins KOMO News anchor Kelly Koopmans on Connect with Kelly Koopmans to talk about navigating the loss of her son and the work she has taken up since — pressing for transparency about hazing on college campuses nationwide.

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