FALSELY ACCUSED: Title IX investigation clears Michigan State basketball players of rape. “The attorney for one of the accused players says the fact that the investigation found his client not culpable demonstrates how unbelievable Kowalski’s story was: ‘The burden of proof is so low in these kind of cases for a complainant to prevail,’ he said. ‘They just have to believe one side a little more than the other side. They couldn’t even meet that low threshold.'”