Fisk v. Board of Trustees of the California State University

CourtDistrict Court, S.D. California
DecidedNovember 1, 2022
Docket3:22-cv-00173
StatusUnknown

This text of Fisk v. Board of Trustees of the California State University (Fisk v. Board of Trustees of the California State University) 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
Fisk v. Board of Trustees of the California State University, (S.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 MADISON FISK, RAQUEL CASTRO, Case No.: 22-CV-173 TWR (MSB) GRETA VISS, CLARE BOTTERILL, 12 MAYA BROSCH, HELEN BAUER, ORDER (1) GRANTING IN PART 13 CARINA CLARK, NATALIE AND DENYING IN PART FIGUEROA, ERICA GROTEGEER, DEFENDANTS’ MOTION TO 14 KAITLIN HERI, OLIVIA PETRINE, DISMISS, AND (2) GRANTING IN 15 AISHA WATT, KAMRYN PART AND DENYING IN PART WHITWORTH, SARA ABSTEN, DEFENDANTS’ REQUEST FOR 16 ELEANOR DAVIES, ALEXA DIETZ, JUDICIAL NOTICE 17 and LARISA SULCS, individually and on behalf of all those similarly situated, (ECF Nos. 30, 32) 18 Plaintiffs, 19 v. 20 BOARD OF TRUSTEES OF THE 21 CALIFORNIA STATE UNIVERSITY 22 and SAN DIEGO STATE UNIVERSITY, 23 Defendants. 24 25 Presently before the Court are Defendants the Board of Trustees of the California 26 State University and San Diego State University’s (collectively, “SDSU”) Motion to 27 Dismiss Plaintiffs’ First Amended Complaint (“Mot.,” ECF No. 30) and Request for 28 Judicial Notice of Documents in Support of Defendants’ Motion to Dismiss Plaintiffs’ First 1 Amended Complaint (“RJN,” ECF No. 32). Plaintiffs filed an Opposition to Defendants’ 2 Motion to Dismiss (“Opp’n,” ECF No. 33), to which Defendants filed a Reply (“Reply,” 3 ECF No. 34). The Court held a hearing on the Motion on July 14, 2022. (See ECF No. 4 35.) Having carefully considered the parties’ arguments, the First Amended Complaint 5 (“FAC,” ECF No. 24), those documents properly subject to judicial notice or incorporated 6 by reference, and the relevant law, the Court GRANTS IN PART AND DENIES IN 7 PART Defendants’ Motion to Dismiss and GRANTS IN PART AND DENIES IN PART 8 Defendants’ Request for Judicial Notice. 9 BACKGROUND 10 I. Factual Background1 11 Plaintiffs, “past and current female varsity student-athletes at SDSU,” initiated this 12 suit against Defendants on February 7, 2022. (See ECF No. 1; FAC ¶ 15.) Defendants 13 receive federal funds, and thus must comply with Title IX. (See FAC ¶¶ 130, 132, 135); 14 see also 20 U.S. Code §§ 1681, 1687. The guiding regulation in this case is that “[n]o 15 person shall, on the basis of sex, be excluded from participation in, be denied the benefits 16 of, be treated differently from another person or otherwise be discriminated against in any 17 interscholastic, intercollegiate, club or intramural athletics offered by a recipient, and no 18 recipient shall provide any such athletics separately on such basis.” 34 C.F.R. § 106.41(a). 19 The Office for Civil Rights (“OCR”) has adopted additional regulations to ensure schools, 20 like SDSU, “provide equal athletic opportunity for members of both sexes.” See 34 C.F.R. 21 § 106.41(c). 22 Plaintiffs allege that none of them “received all of the athletic financial aid for which 23 they were eligible at SDSU” and that SDSU is depriving current student-athlete Plaintiffs 24 of “treatment and benefits equal to those provided to male student-athletes at SDSU.” 25 26 27 1 For purposes of Defendants’ Motion, the facts alleged in Plaintiffs’ First Amended Complaint are accepted as true. See Vasquez v. Los Angeles Cty., 487 F.3d 1246, 1249 (9th Cir. 2007) (holding that, in 28 1 (FAC ¶¶ 19, 23.) If SDSU had complied with Title IX, Plaintiffs contend each of them 2 would have “had an opportunity to receive her fair share of equal financial aid” and “would 3 have received more athletic financial aid than she did.” (Id. ¶¶ 20–21.) Plaintiffs further 4 allege that SDSU “directly retaliated” against some Plaintiffs after they filed this lawsuit, 5 which had a “chilling effect on the willingness of other female varsity student-athletes to 6 challenge, expose, and remedy SDSU’s sex discrimination.” (Id. ¶ 24.) There are 7 seventeen named Plaintiffs in this case: 8 Total Aid Received Plaintiff2 Sport/Year3 9 (Specific Year) 10 1 Madison Fisk Rowing/Sr. $28,200 11 2 Raquel Castro Rowing/Jr. $2,400 12 3 Greta Viss Rowing/Grad. ‘21 $24,000 (Fr. & Soph.) 13 4 Clare Botterill Rowing/Jr. $38,000 (Soph.) 14 5 Maya Brosch T&F/Grad. ’21 $19,640 15 6 Olivia Petrine Rowing/Soph. $800 16 7 Helen Bauer Rowing/Sr. $30,000 17 8 Carina Clark*^ T&F/Sr. $800 (Sr.) 18 9 Natalie Figueroa Rowing/Jr. $0 19 10 Erica Grotegeer*^ T&F/Sr. $37,879 20 11 Kaitlin Heri*^ T&F/Sr. $64,600 21 12 Aisha Watt*^ T&F/Jr. $4,600 22 13 Kamryn Whitworth Rowing/Grad. ‘21 $13,200 23 24 25 2 An asterisk (*) indicates current varsity student-athlete as of February 7, 2022, (FAC ¶¶ 68, 81, 26 88, 95, 108), while a carat (^) indicates presence at the Zoom meeting at which SDSU allegedly retaliated. (Id. ¶¶ 73, 86, 93, 100.) 27 3 SDSU eliminated its women’s varsity rowing team in Spring 2021. (FAC ¶ 27.) The year in 28 1 14 Sara Absten* T&F/Sr. “Partial” / “Fluctuated” 2 Rowing/Soph. (Transferred 15 Eleanor Davies $22,500 3 Jan ‘22) 4 16 Alexa Dietz Rowing/Sr. $18,400 5 17 Larisa Sulcs Rowing/Jr. $22,800 6

7 II. Plaintiffs’ Allegations 8 A. Disproportional Financial Aid 9 “To the extent that a recipient [of federal funds] awards athletic scholarships or 10 grants-in-aid, it must provide reasonable opportunities for such awards for members of 11 each sex in proportion to the number of students of each sex participating in interscholastic 12 or intercollegiate athletics.” 45 C.F.R. § 86.37. Plaintiffs allege that SDSU violated this 13 regulation by failing to provide athletic financial aid to female student-athletes in 14 proportion to their participation rates, thereby intentionally discriminating against female 15 student-athletes. (FAC ¶ 171.) 16 By October 15 of each year, SDSU compiles and discloses data for the prior year’s 17 athletic expenditures and participation to the federal government pursuant to the Equity in 18 Athletics Disclosure Act (“EADA”). (Id. ¶¶ 176, 185 n.5) SDSU can provide athletic 19 financial aid at any point during an academic year and thus is able to correct any 20 “discriminatory allocation” at any point. (Id. ¶¶ 183–84.) Plaintiffs allege that SDSU’s 21 data indicates that for over ten years, “female varsity student-athletes at SDSU have been 22 deprived of athletic financial aid in proportion to their participation in SDSU athletics.” 23 (Id. ¶ 175.) On August 19, 2021, the parties entered into a tolling agreement that preserves 24 all Title IX athletic financial aid claims for at least two years prior. (Id. ¶ 181 n. 4.) 25 B. Unequal Treatment and Benefits 26 “A recipient [of federal funds that] operates or sponsors interscholastic, 27 intercollegiate, club or intramural athletics shall provide equal athletic opportunity for 28 members of both sexes.” 34 C.F.R. § 106.41. Plaintiffs allege that, in violation of this 1 regulation, SDSU does not “provide athletic treatment and benefits to its female varsity 2 student-athletes equal to those it provides to its male varsity student-athletes and, 3 accordingly, intentionally discriminates” against its female student-athletes. (FAC ¶ 192.) 4 Plaintiffs assert that SDSU provides more equipment to the men’s teams and that 5 that equipment is of “superior quality” to that that SDSU provides to its women’s teams. 6 (Id. ¶¶ 194, 196.) SDSU additionally gives men’s teams priority to schedule their practice 7 times and tutoring sessions and provides unequal travel benefits and per diem allowances. 8 (Id. ¶¶ 199, 202, 208.) Further, SDSU spends far more money to pay men’s head and 9 assistant coaches, to provide men’s teams with more publicity, and to recruit student- 10 athletes for men’s teams than it does for women’s teams. (Id.

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Fisk v. Board of Trustees of the California State University, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fisk-v-board-of-trustees-of-the-california-state-university-casd-2022.