Fan v. State of Nevada Ex Rel. Board of Regents of the Nevada System of Higher Education, On Behalf of the University of Nevada, Reno

District Court, D. Nevada·Decided June 24, 2025·No. 3:24-cv-00427·Unknown

Opinion

3 UNITED STATES DISTRICT COURT

4 DISTRICT OF NEVADA

5 * * *

6 FEI FEI FAN, Case No. 3:24-cv-00427-MMD-CLB

7 Plaintiff, ORDER v. 8 STATE OF NEVADA EX REL. BOARD 9 OF REGENTS OF THE NEVADA SYSTEM OF HIGHER EDUCATION, ON 10 BEHALF OF THE UNIVERSITY OF NEVADA, RENO, 11 Defendant. 12 13 I. SUMMARY 14 This dispute stems from Plaintiff Fei Fei Fan’s employment at the University of 15 Nevada, Reno (“UNR” or Defendant1) as an Assistant Professor. (ECF No. 1 at 3.) This 16 order addresses the following, pending motions: (1) Defendant’s motion for summary 17 judgment (ECF No. 15 (“Motion”));2 (2) Defendant’s motion to seal documents filed in 18 support of its Motion (ECF No. 16); and (3) Plaintiff’s motion to change venue, or in the 19 alternative, for judicial reassignment (ECF No. 49).3 Because Fan responds to the Motion 20

21 1The Complaint names State of Nevada ex. rel. Board of Regents of the Nevada System of Higher Education, on behalf of the University of Nevada, Reno. 22 2Defendant filed the Motion shortly after filing its Answer. (ECF No. 11.) Plaintiff 23 filed a response to the Motion after her counsel withdrew. (ECF No. 46.) Defendant filed a reply. (ECF No. 50.) Defendant objects to the length of Plaintiff’s response as exceeding 24 the page limit for a response to a dispositive motion. (ECF No. 50 at 5.) Local Rule 7-3(a) provides that motions for summary judgment and responses are limited to 30 pages. 25 Plaintiff filed a 22-page opposition but attached an appendix that is 21 pages in length to raise various objections and arguments in response to exhibits attached to Defendant’s 26 Motion. (ECF Nos. 46, 46-1.) The objections raised in the appendix contain arguments, so the Court considers the appendix part of the response for purposes of LR 7-3(a)’s limit 27 on the length of briefs. So considered, Plaintiff’s response exceeds the applicable page limit. While the Court has reviewed Plaintiff’s response and considered all the arguments 28 raised in it, Plaintiff is admonished to comply with the Court’s Local Rules going forward. 2 relevant standards for transfer or recusal, and as further explained below, the Court will 3 deny the Motion, deny the motion to change venue, and grant Plaintiff leave to file an 4 amended complaint within 45 days. The Court will also grant Defendant’s motion to seal 5 because Defendant presented compelling reasons supporting sealing. 6 II. RELEVANT BACKGROUND 7 Defendant hired Plaintiff, a Chinese national woman, as a tenure-track Assistant 8 Professor on July 1, 2015, and terminated her employment on January 19, 2024. (ECF 9 No. 1 at 3.) Plaintiff alleges she “filed a harassment complaint against Defendant in 2021.” 10 (Id. at 2.) Defendant asserts that, “[i]n January, 2021, Fan filed a complaint against 11 Professor X with EOTIX4, alleging sexual assault, harassment and misconduct.” (ECF 12 No. 15 at 4.) Plaintiff was awarded tenure in March 2021. (Id.) Plaintiff alleges she 13 “received retaliation, discrimination and was eventually terminated as a result of making 14 the harassment complaint.” (ECF No. 1 at 2.) After her employment termination on 15 January 19, 2024, Plaintiff filed a charge of discrimination with the Nevada Equal Rights 16 Commission (“NERC”) and then this lawsuit after she received a NERC right to sue notice. 17 (Id.) 18 More specifically, on September 23, 2024, Plaintiff, through counsel, filed the 19 Complaint, alleging three causes of action: discrimination based on race and gender 20 under Title VII of the Civil Rights Act of 1964 and state law; retaliation under Title VII; and 21 violation of NRS § 613.330 for alleged discrimination based on her sexual orientation. 22 (ECF No. 1 at 4-6.) Defendant filed an Answer on January 9, 2025 (ECF No. 11), followed 23 by the Motion on January 23, 2025 (ECF No. 15). The Court granted the parties’ 24 stipulation to extend the response deadline to March 14, 2025 (ECF No. 21), and 25 subsequently granted Plaintiff’s motion to extend the deadline to April 15, 2025 (ECF No. 26 27

28 4UNR’s Equal Opportunity and Title IX Office. (ECF No. 15 at 4.) 2 requested that her attorney be terminated, and her attorney filed a motion to withdraw, 3 which was granted. (ECF Nos. 35, 37, 38.) Since then, Plaintiff has represented herself. 4 III. DISCUSSION 5 The Court first addresses the Motion, then the motion to seal, and then the motion 6 to change venue. 7 A. Motion for Summary Judgment 8 Defendant’s primary argument focuses on Plaintiff’s retaliation claim. (ECF No. 15 9 at 14-18.) Defendant further argues that to the extent the Complaint asserts discrimination 10 claims, these claims are legally deficient on several grounds, including for failure to 11 exhaust administrative remedies and failure to state a claim under Fed. R. Civ. P. 12 12(b)(6). (Id. at 18-20.) While Plaintiff’s response mostly alleges procedural defects, 13 Plaintiff does point out that the alleged retaliatory actions were not limited to her 14 termination. (ECF No. 46 at 8.) Because Plaintiff’s response raises allegations that are 15 not in her Complaint—and as further discussed below—the Court will deny the Motion 16 and grant leave for Plaintiff to file an amended complaint. The Court addresses below 17 Defendant’s arguments along with the arguments Plaintiff raises in her response. 18 Defendant relies on the McDonnell Douglas framework to argue that Plaintiff failed 19 to establish her prima facie case and Defendant had a legitimate, non-retaliatory reason 20 for its decision to terminate her employment that was not pretextual. (ECF No. 15 at 14- 21 18.) To prevail on a retaliation claim, a plaintiff must first establish a prima facie case of 22 retaliation by demonstrating: (1) she engaged in a protected activity; (2) she suffered an 23 adverse employment action; and (3) there is a causal link between the protected activity 24 and the adverse employment action. See Dawson v. Entek, 630 F.3d 928, 936 (9th Cir. 25 2011). “Title VII retaliation claims require proof that the desire to retaliate was the but-for 26 cause of the challenged employment action.” Univ. of Tex. Sw. Med. Ctr. v. Nassar, 570 27

28 5Judge Baldwin subsequently granted Plaintiff’s pro se motion to extend the response deadline to May 15, 2025. (ECF No. 45.) 2 production shifts to the employer to present legitimate reasons for the adverse 3 employment action.” Brooks v. City of San Mateo, 229 F.3d 917, 928 (9th Cir. 2000) 4 (citation omitted). “Once the employer carries this burden, plaintiff must demonstrate a 5 genuine issue of material fact as to whether the reason advanced by the employer was a 6 pretext.” Id. (citation omitted). “Only then does the case proceed beyond the summary 7 judgment stage.” Id. 8 Defendant argues that Plaintiff cannot establish a causal link between her 9 complaint about Professor X in 2021 and her employment termination in January 2024 10 because of the three year gap in time. (ECF No. 15 at 14-15.) In response, Plaintiff asserts 11 that retaliation “began with the Title IX investigation itself, which was triggered after 12 Plaintiff’s complaint and conducted in a manner that ignored exculpatory evidence, 13 fabricated interview notes, and denied Plaintiff meaningful access.” (ECF No.

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Fan v. State of Nevada Ex Rel. Board of Regents of the Nevada System of Higher Education, On Behalf of the University of Nevada, Reno, (D. Nev. 2025).

Fan v. State of Nevada Ex Rel. Board of Regents of the Nevada System of Higher Education, On Behalf of the University of Nevada, Reno (Fan v. State of Nevada Ex Rel. Board of Regents of the Nevada System of Higher Education, On Behalf of the University of Nevada, Reno) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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