Corlett v. Tong

CourtDistrict Court, S.D. California
DecidedApril 1, 2025
Docket3:24-cv-00078
StatusUnknown

This text of Corlett v. Tong (Corlett v. Tong) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Corlett v. Tong, (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 J. ANGELO CORLETT, Ph.D., an Case No.: 24-CV-78 TWR (MPP) individual, 12 ORDER GRANTING IN PART AND Plaintiff, 13 DENYING IN PART DEFENDANTS’ v. SECOND MOTION FOR 14 JUDGMENT ON THE PLEADINGS WILLIAM TONG, in his individual and 15 official capacities; MONICA J. CASPER, (ECF No. 29) 16 in her individual and official capacities; and DOES 1 through 50, inclusive, 17 Defendants. 18 19 20 Presently before the Court is Defendants William Tong and Monica J. Casper’s 21 Motion for Partial Judgment on the Pleadings as to Plaintiff’s First Amended Complaint 22 (“Mot.,” ECF No. 29), as well as Plaintiff J. Angelo Corlett, Ph.D.’s Opposition to 23 (“Opp’n,” ECF No. 38) and Defendants’ Reply in Support of (“Reply,” ECF No. 41) the 24 Motion. The Court held a hearing on March 6, 2025. (See ECF No. 44.) Having carefully 25 considered the Pleadings (ECF No. 25 (“FAC”), ECF No. 27 (“Ans.”)), those documents 26 properly subject to judicial notice or incorporated by reference, the Parties’ arguments, and 27 the relevant law, the Court GRANTS IN PART AND DENIES IN PART Defendants’ 28 Motion, as follows. 1 BACKGROUND 2 As thoroughly detailed in the Court’s September 20, 2024 Order Granting in Part 3 and Denying in Part Defendants’ Motion for Judgment on the Pleadings, (see ECF No. 24 4 (“Prior Order”) at 7–31),1 in March 2022, SDSU Dean Casper reassigned Plaintiff from his 5 Philosophy 200 and Philosophy 328 courses following student complaints of his use of the 6 “n-word” in Philosophy 200, and, following an investigation by the California DOJ, 7 Provost Tong suspended Plaintiff from his position as Professor in the Department of 8 Philosophy for one semester without pay for harassment based on gender based on his use 9 of the words “bitch” and “pussy” in his Philosophy 512 course that same semester. Plaintiff 10 instituted this action on January 11, 2024, filing his Complaint against Defendants in their 11 individual and official capacities and alleging four causes of action for (1) retaliation in 12 violation of Plaintiff’s First and Fourteenth Amendment rights against both Drs. Tong and 13 Casper, (2) retaliation based on viewpoint in violation of Plaintiff’s First and Fourteenth 14 Amendment rights against both Drs. Tong and Casper, (3) violation of Plaintiff’s 15 substantive due process rights under the Fourteenth Amendment against Dr. Tong only, 16 and (4) a declaration that both Drs. Tong and Casper violated the California State 17 University’s (“CSU”) “Freedom of Expression” and “Academic Freedom” Senate Policies. 18 (See generally ECF No. 1.) 19 After answering on February 27, 2024, (see ECF No. 8), Defendants moved for 20 judgment on the pleadings. (See generally ECF No. 15.) Following oral argument, (see 21 ECF No. 23; see also ECF No. 26 (“Tr.”)), the Court granted in part and denied in part 22

23 1 Because the First Amended Complaint largely tracks Plaintiff’s original Complaint, (compare 24 FAC, with ECF No. 1 (“Compl.”)), and the Court’s Prior Order provided a comprehensive compilation of 25 the relevant facts based on Plaintiff’s then-operative Complaint, as well as those documents that were subject to judicial notice—including, most critically, the underlying San Diego State University (“SDSU”) 26 policies, (see Prior Order at 2–4)—and those properly incorporated by reference—chiefly, the Confidential Report of Investigation prepared by Jodie Cleesattle, Supervising Attorney General, 27 California Department of Justice (“DOJ”), dated December 15, 2022 (the “Investigative Report,” ECF No. 15-4 at 35–93), (see Prior Order at 4–6), this Order provides only the context, procedural history, and 28 1 Defendants’ prior motion. (See generally Prior Order.) Specifically, the Court dismissed 2 with prejudice Plaintiff’s claims against Defendants in their official capacities, (see id. at 3 52; see also id. at 35–37, 42), and Plaintiff’s claims for damages against Defendants in 4 their individual capacities, (see id. at 52; see also id. at 37–42), and dismissed without 5 prejudice Plaintiff’s first cause of action to the extent it was predicated on Plaintiff’s 6 alleged use of gender slurs in his Spring 2022 Philosophy 512 course, (see id. at 52–53; 7 see also id. at 42–50); Plaintiff’s second cause of action as abandoned, (see id. at 53; see 8 also id. at 50); Plaintiff’s third cause of action in its entirety, (see id. at 53; see also id. at 9 50–51); and Plaintiff’s fourth cause of action to the extent it was directed to the CSU Senate 10 Policy, (see id. at 53; see also id. at 51–52). 11 Because the Court had granted Plaintiff leave to amend, (see id. at 53), Plaintiff filed 12 the operative First Amended Complaint against Defendants in their individual capacities 13 only on October 11, 2025, (see generally ECF No. 25), which Defendants answered on 14 October 25, 2025. (See generally ECF No. 27.) In his First Amended Complaint, Plaintiff 15 alleges three causes of action for (1) retaliation in violation of the First and Fourteenth 16 Amendments based on Dean Casper’s reassignment and Provost Tong’s suspension of 17 Plaintiff, (see FAC ¶¶ 150–55); (2) Dr. Tong’s application of SDSU’s non-discrimination 18 policy against Plaintiff in violation of the First and Fourteenth Amendments, (see id. 19 ¶¶ 156–63); and (3) a declaration that Dean Casper and Provost Tong violated Plaintiff’s 20 rights to free speech and academic freedom under the First Amendment, (see id. 21 ¶¶ 164–68). 22 To address the Court’s prior dismissal of Plaintiff’s first cause of action to the extent 23 it was predicated on Plaintiff’s alleged use of gender slurs because Plaintiff had failed to 24 allege that his use of the words “pussy” and “bitch” was germane to the subject matter of 25 Philosophy 512, Plaintiff has alleged the following additional facts: 26 86. During the Philosophy 512 class (Political Philosophy), Dr. Corlett discussed in detail philosopher John Rawls’ work, “A Theory of 27 Justice,” which was also the primary text for the course. Dr. Corlett 28 specifically addressed Rawls’ discussion of the liberty right to freedom of 1 speech and conscience. In so doing, Dr. Corlett discussed, among other things, SDSU’s administrative harassment of him in connection with his use 2 of protected speech during his courses on Critical Thinking and Composition. 3 Dr. Corlett was illustrating the importance of Rawls’ point in favor of freedom of expression, especially, Dr. Corlett added, in a university classroom 4 concerning pedagogically relevant language. 5 87. Dr. Corlett always begins the Critical Thinking and Composition 6 course with lectures on logic and language and warns students about the 7 importance of language and to always avoid vagueness and ambiguity. He shows the students slides listing examples of ambiguous words and language 8 including, among others, the word “bitch.” He then encourages students to, if 9 they wish, provide examples of the different kinds of meanings of “bitch,” expressly reminding them to think of the word in gender inclusive ways to 10 avoid sexism. Dr. Corlett points out that there was a time when the word was 11 often used only in a gendered and sexist way but is now used in myriad ways, hence its ambiguity. He followed this same pedagogy in discussion of the 12 illustration in the classes taken by the Complainants. 13 88. At Dr. Corlett’s invitation, the Critical Thinking and 14 Composition students were encouraged to voluntarily participate in the 15 classroom discussion by offering their suggestions as to the meanings or uses of the word “bitch.” Their suggestions included “pussy bitch,” “rich bitch,” 16 “ugly bitch,” and perhaps 20–30 more. Dr.

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