Corlett v. Tong

District Court, S.D. California·Decided April 1, 2025·No. 3:24-cv-00078·Unknown

Opinion

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

1 Because the First Amended Complaint largely tracks Plaintiff’s original Complaint, (compare FAC, with ECF No. 1 (“Compl.”)), and the Court’s Prior Order provided a comprehensive compilation of 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”) 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, 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 Defendants’ prior motion. (See generally Prior Order.) Specifically, the Court dismissed with prejudice Plaintiff’s claims against Defendants in their official capacities, (see id. at 52; see also id. at 35–37, 42), and Plaintiff’s claims for damages against Defendants in their individual capacities, (see id. at 52; see also id. at 37–42), and dismissed without prejudice Plaintiff’s first cause of action to the extent it was predicated on Plaintiff’s alleged use of gender slurs in his Spring 2022 Philosophy 512 course, (see id. at 52–53; see also id. at 42–50); Plaintiff’s second cause of action as abandoned, (see id. at 53; see also id. at 50); Plaintiff’s third cause of action in its entirety, (see id. at 53; see also id. at 50–51); and Plaintiff’s fourth cause of action to the extent it was directed to the CSU Senate Policy, (see id. at 53; see also id. at 51–52). Because the Court had granted Plaintiff leave to amend, (see id. at 53), Plaintiff filed the operative First Amended Complaint against Defendants in their individual capacities only on October 11, 2025, (see generally ECF No. 25), which Defendants answered on October 25, 2025. (See generally ECF No. 27.) In his First Amended Complaint, Plaintiff alleges three causes of action for (1) retaliation in violation of the First and Fourteenth Amendments based on Dean Casper’s reassignment and Provost Tong’s suspension of Plaintiff, (see FAC ¶¶ 150–55); (2) Dr. Tong’s application of SDSU’s non-discrimination policy against Plaintiff in violation of the First and Fourteenth Amendments, (see id. ¶¶ 156–63); and (3) a declaration that Dean Casper and Provost Tong violated Plaintiff’s rights to free speech and academic freedom under the First Amendment, (see id. ¶¶ 164–68). To address the Court’s prior dismissal of Plaintiff’s first cause of action to the extent it was predicated on Plaintiff’s alleged use of gender slurs because Plaintiff had failed to allege that his use of the words “pussy” and “bitch” was germane to the subject matter of Philosophy 512, Plaintiff has alleged the following additional facts: 86. During the Philosophy 512 class (Political Philosophy), Dr. Corlett discussed in detail philosopher John Rawls’ work, “A Theory of Justice,” which was also the primary text for the course. Dr. Corlett specifically addressed Rawls’ discussion of the liberty right to freedom of speech and conscience. In so doing, Dr. Corlett discussed, among other things, SDSU’s administrative harassment of him in connection with his use of protected speech during his courses on Critical Thinking and Composition. Dr. Corlett was illustrating the importance of Rawls’ point in favor of freedom of expression, especially, Dr. Corlett added, in a university classroom concerning pedagogically relevant language. 87. Dr. Corlett always begins the Critical Thinking and Composition course with lectures on logic and language and warns students about the importance of language and to always avoid vagueness and ambiguity. He shows the students slides listing examples of ambiguous words and language including, among others, the word “bitch.” He then encourages students to, if 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 avoid sexism. Dr. Corlett points out that there was a time when the word was 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 illustration in the classes taken by the Complainants. 88. At Dr. Corlett’s invitation, the Critical Thinking and Composition students were encouraged to voluntarily participate in the classroom discussion by offering their suggestions as to the meanings or uses of the word “bitch.” Their suggestions included “pussy bitch,” “rich bitch,” “ugly bitch,” and perhaps 20–30 more. Dr. Corlett’s pedagogy involved him repeating aloud the students’ suggestions so that all students could hear what other students were contributing, writing them on the dry erase board, and noting the word’s various modifiers to indicate just how ambiguous “bitch” is and why one ought to avoid ambiguity in language. The male and female students enjoyed and laughed during the class discussion while learning about ambiguity and why and how to avoid it. 89. In his employment of the illustration from his Critical Thinking and Composition course with hi

Free access — add to your briefcase to read the full text and ask questions with AI

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

Corlett v. Tong (Corlett v. Tong) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Graham v. Connor
490 U.S. 386 (Supreme Court, 1989)
Albright v. Oliver
510 U.S. 266 (Supreme Court, 1994)
Groh v. Ramirez
540 U.S. 551 (Supreme Court, 2004)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
John Desoto v. Yellow Freight Systems, Inc.
957 F.2d 655 (Ninth Circuit, 1992)
Nos. 94-1247, 94-1248
19 F.3d 873 (Third Circuit, 1994)
Marder v. Lopez
450 F.3d 445 (Ninth Circuit, 2006)
Waters v. Churchill
511 U.S. 661 (Supreme Court, 1994)
Crown Point Development, Inc. v. City of Sun Valley
506 F.3d 851 (Ninth Circuit, 2007)
Neilson v. Union Bank of California, N.A.
290 F. Supp. 2d 1101 (C.D. California, 2003)
New York City Employees' Retirement System v. Berry
667 F. Supp. 2d 1121 (N.D. California, 2009)
David Demers v. Erica Austin
746 F.3d 402 (Ninth Circuit, 2014)
Alexandria Gregg v. Hawaii Dept. of Public Safety
870 F.3d 883 (Ninth Circuit, 2017)
Karim Khoja v. Orexigen Therapeutics, Inc.
899 F.3d 988 (Ninth Circuit, 2018)
Hutsell v. Sayre
5 F.3d 996 (Sixth Circuit, 1993)
Armendariz v. Penman
75 F.3d 1311 (Ninth Circuit, 1996)
Hufford v. McEnaney
249 F.3d 1142 (Ninth Circuit, 2001)