Victims of alleged misconduct within the football program at Ursuline High School in Youngstown, Ohio, have filed a Second Amended and Supplemental Complaint in federal court, broadly expanding the scope of their original 200-page lawsuit.
Per an announcement Monday by The Chandra Law Firm LLC, which is providing lead counsel to the plaintiffs, the expanded, 290-page complaint adds a second family and incorporates vital new evidence and allegations that detail at least a four-year pattern of systemic abuse, hazing and cover-up by school administrators and coaches.
Related: Ohio High School Cancels Football Season Amid Hazing Investigation
According to the firm, the newly added "Roe" family alleges that their son 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," the firm's announcement states. "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.)"
The complaint also alleges details from several new videos obtained since the original complaint’s filing, according to the firm. 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 one video from the 2022 camp, nine videos from the 2023 camp and three videos from the 2025 camp.
The complaint alleges that 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, the firm states.
The complaint further alleges Ursuline administrators knew of the football team’s years-long “tradition” of hazing. In June 2025, when Sammartino, assistant principal Margaret Damore and 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 law firm notes. Ursuline officials also failed to inform law enforcement that the players confessed and the hazing had been occurring for years.
Moreover, new evidence contradicts Ursuline officials’ claim that they investigated the matter. In June 2025, Ursuline possessed several of the videos from the 2025 camp, had the confessions of several players, and were informed the hazing had been occurring for years. Despite possessing all of this evidence, 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, according to the firm. The updated complaint alleges that Reardon and assistant coaches Timothy McGlynn and 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.
The complaint quotes public records alleging that McGlynn in his prior job at Champion High School in Warren, Ohio, 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, the firm claims in its announcement of the expanded complaint.
According to the firm, the complaint details text messages suggesting 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.
The new filing includes information from cooperating individuals, including football-player defendants and other victims and witnesses, who have verified the multiyear culture of violence and the institutional rot described in the lawsuit.
In addition, Ursuline is alleged to have issued a series of false statements to parents, alumni and the public falsely claiming it had investigated and disciplined those involved when it had not, but Ursuline never admitted in any public statement that school officials and coaches knew the hazing had occurred over a period of four years.
"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," The Chandra Law firm notes. "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."
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.
According to The Chandra Law Firm, 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. As plaintiffs’ counsel, the firm 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, according to the firm.
