Lema v. The Board of Trustees of the California State University System

CourtDistrict Court, S.D. California
DecidedMarch 28, 2024
Docket3:21-cv-02131
StatusUnknown

This text of Lema v. The Board of Trustees of the California State University System (Lema v. The Board of Trustees of the California State University System) 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
Lema v. The Board of Trustees of the California State University System, (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 JOHN LEMA, Case No.: 3:21-cv-02131-JAH-KSC 12 Plaintiff, ORDER GRANTING 13 v. DEFENDANTS’ SPECIAL MOTION TO STRIKE THE 14 THE BOARD OF TRUSTEES OF THE AMENDED COMPLAINT CALIFORNIA STATE UNIVERSITY 15 SYSTEM, through its subdivision San 16 Diego State University, ANDREA PARASHOS (in her individual capacity), 17 ECF No. 18 LEE MINTZ (in her individual capacity), 18 and DOES 1-20 (in their individual Capacities), 19 Defendants. 20 21 I. INTRODUCTION 22 Pending before the Court is Defendants Andrea Parashos and Lee Mintz’s 23 (collectively, “Defendants”) Special Motion to Strike. (“Mot.,” ECF No. 18). Plaintiff 24 John Lema (“Lema” or “Plaintiff”) filed a Response in Opposition to the Motion, (“Opp’n,” 25 ECF No. 22), and Defendants filed a Reply, (“Reply,” ECF No. 23). The motion is decided 26 on the submissions without oral argument pursuant to Civil Local Rule 7.1.d.1. Having 27 considered the pleadings and the applicable law, and for the reasons set forth below, 28 Defendants’ Special Motion to Strike is GRANTED. 1 II. BACKGROUND 2 Plaintiff John Lema brings this action against Andrea Parashos (“Parashos”), San 3 Diego State University’s Title IX Investigator, and Lee Mintz (“Mintz”), Director for the 4 Center of Student Rights and Responsibilities and Deputy Title IX Coordinator for San 5 Diego State University, alleging Due Process violations under the Fifth2 and Fourteenth3 6 Amendments pursuant to 42 U.S.C. § 19834, and California state claims for negligence (as 7 to Parashos and Mintz), negligent infliction of emotional distress (as to Parashos and 8 Mintz), negligent misrepresentation (as to Parashos and Mintz), and fraudulent 9 misrepresentation (as to Parashos only). (“FAC,” ECF No. 15). In his amended complaint, 10 Plaintiff asserts he suffered humiliation, mental anguish, and emotional distress when 11 Defendants investigated him in connection with hazing allegations on San Diego State 12 University’s (“SDSU”) campus, resulting in a delay to Lema’s graduation date. (Id. at ¶¶ 13 25, 36, 47, 49). 14 While at SDSU, Plaintiff was a member of the Phi Gamma Delta Fraternity. (Id. at 15 ¶ 17). However, Plaintiff contends his attendance and participation at fraternity sponsored 16 17 18 1 Page numbers referenced herein refer to the page numbers generated by the CM/ECF 19 system. 2 The Fifth Amendment states that the federal government may not deprive a person of 20 “life, liberty, or property, without due process of law; nor shall private property be taken 21 for public use, without just compensation.” U.S. Const. amend. V; Castillo v. McFadden, 399 F.3d 993, 1002 n.5 (9th Cir. 2005) (“The Fifth Amendment prohibits the federal 22 government from depriving persons of due process, while the Fourteenth Amendment 23 explicitly prohibits deprivations with due process by the several States[.]”). 3 The Fourteenth Amendment states in pertinent part, “nor shall any State deprive any 24 person of life, liberty, or property, without due process of law.” U.S. Const. amend. XIV, 25 § 1. State action is required to trigger the protections afforded citizens by the Fourteenth Amendment. Brentwood Acad. v. Tenn. Secondary Sch. Athletic Ass’n., 531 U.S. 288, 295 26 (2001). 27 4 Section 1983 is not itself a source of substantive rights, but merely provides a method for vindicating federal rights conferred elsewhere. Graham v. Connor, 490 U.S. 386, 393- 28 1 activities was infrequent. (Id.) Lema planned to graduate from SDSU in August 2020. 2 (Id. at ¶ 18). In July 2020, Plaintiff was notified by Defendants that the University had 3 opened a student misconduct investigation against him to investigate reports of hazing by 4 members of the Phi Gamma Delta fraternity. (Id. at ¶¶ 20-21). Allegations against Lema 5 included: 6 provid[ing] alcohol to minors, physically assault[ing] members of the campus community, interfere[ing] with the orderly progress of a 7 student disciplinary proceeding, attempt[ing] to influence impartiality 8 of any participant in a student discipline matter, and encourag[ing], permit[ing], or assist[ing] another to do any act that could subject them 9 to discipline. 10 11 (Id. at ¶ 21 (formatting altered)). Defendants also alleged Plaintiff violated subsections of 12 Title V, section 41301 of the California Code of Regulations.5 (Id. at ¶ 22). 13

14 15 5 According to the Complaint, the relevant regulations Defendants assert Plaintiff violated are: 16 b.7.A – Conduct that threatens or endangers the health or safety of any 17 person within or related to the University community, including physical abuse, threats, intimidation, or harassment; 18

19 b.8 – Hazing, or conspiracy to haze;

20 b.10 – Use, possession, manufacture, or distribution of alcoholic 21 beverages . . . or public intoxication while on campus or at a university- related activity; 22

23 b.16 – Violation of any published University policy, rule, regulation, or presidential order; 24

25 b.19.B – Violations of the Student Conduct Procedures, including Disruption or interference with the orderly progress of a student 26 discipline proceeding; 27 b.20 – Encouraging, permitting, or assisting another to do any act that 28 1 On July 10, 2020, Defendants notified Plaintiff that he would not graduate in August 2 2020 as planned. (Id. at ¶ 25). Around this time, Lema retained counsel to assist him with 3 the pending disciplinary proceedings. (Id. at ¶ 26). On August 20, 2020, Parashos called 4 Plaintiff to further discuss the disciplinary investigation that was being conducted. (Id. at 5 ¶ 27). During this phone call, Parashos informed Lema that the investigation was 6 predicated on his association with the Phi Gamma Delta Fraternity. (Id.) 7 On November 23, 2020, Plaintiff received an email asking him to sign a settlement 8 agreement (“Agreement”) acknowledging responsibility for the alleged disciplinary 9 charges. (Id. at ¶ 28). The Agreement solicited admissions from Lema for: 10 (A) compel[ing] physically demanding activities; . . . (B) compel[ing] 11 forced alcohol consumption; (C) compel[ing] individuals to drink foreign or unusual substances; (D) compel[ing] acts of servitude; (E) 12 blindfolding; (F) paddling; (G) bullying; (H) intimidation; (I) physical 13 and emotional degradation and humiliation of other students; (J) compel[ing] pledges to contribute money to pay for alcohol that would 14 be consumed during events. 15 16 (Id. at ¶ 29 (formatting altered)). Additionally, the Agreement concluded Plaintiff violated 17 the aforementioned subsections from the California Code of Regulations, supra fn. 5. (Id. 18 at ¶ 30).6 The Agreement sought to compel Lema into accepting punishment, in the form 19 of counseling and suspension, for his purported involvement in the fraternity hazing. (Id. 20 at ¶ 32). 21 On December 19, 2020, Defendant Parashos sent Lema a prepared report containing 22 specific accounts of Phi Gamma Delta hazing. (Id. at ¶ 35). Plaintiff’s name is not 23 explicitly mentioned in this report. (Id.) After pressure from Lema’s retained counsel, the 24 25 26 27 28 1 disciplinary proceedings against Plaintiff were abandoned. (Id. at ¶ 36). Lema graduated 2 from SDSU in May of 2021. (Id.) 3 III. DISCUSSION 4 A. Legal Standard 5 Defendants filed a special motion to strike Plaintiff's state law claims, pursuant to 6 California Code of Civil Procedure section 425.16, California's anti-SLAPP (“Strategic 7 Lawsuit Against Public Participation”) statute.

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Lema v. The Board of Trustees of the California State University System, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lema-v-the-board-of-trustees-of-the-california-state-university-system-casd-2024.