Niblock v. University of Kentucky

CourtDistrict Court, E.D. Kentucky
DecidedNovember 30, 2020
Docket5:19-cv-00394
StatusUnknown

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

Bluebook
Niblock v. University of Kentucky, (E.D. Ky. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION AT LEXINGTON

ELIZABETH NIBLOCK, individually and CIVIL ACTION NO. 5:19-394-KKC on behalf of those similarly situated, Plaintiffs, V. OPINION AND ORDER

UNIVERSITY OF KENTUCKY, BOARD OF TRUSTEES, MITCH BARNHART, in his official capacity, and ELI CAPILOUTO, in his official capacity Defendants. *** *** *** This matter is before the Court on the defendants’ motion to dismiss (DE 11). For the following reasons, the motion will be granted in part and denied in part. I. Background Unless noted otherwise, the facts set forth in this opinion are taken from the factual allegations of the plaintiffs’ complaint. As it must on a motion to dismiss, the Court has assumed that all the allegations are true. Scheid v. Fanny Farms Candy Shops, Inc., 859 F.2d 434, 436 (6th Cir. 1988). Plaintiff Elizabeth Niblock is a senior at the University of Kentucky, which is an NCAA Division I school. Niblock transferred to UK in 2017 from another Division I institution, which recruited her to play on the women’s lacrosse team. She played on the lacrosse team at the prior institution, but she transferred to UK because it was closer to home and she wanted the bigger school atmosphere. Niblock also played competitive field hockey in high school. She would join a varsity lacrosse or field hockey team at UK if one were offered, but UK does not offer a women’s varsity team in either sport. She asserts that UK discriminates against female students on the basis of sex by providing them fewer and poorer opportunities in sports than male students. (DE 8, Complaint at 1.) She asserts four claims against the defendants. Three of those claims are based on Title IX of the

Education Amendments of 1972, 20 U.S.C. § 1681, et seq. (DE 8, Complaint, ¶ 6 & Counts I-III.) With certain inapplicable exceptions, that statute prohibits any education program or activity that receives federal financial assistance from, on the basis of sex, excluding any person from participation in the program or activity, denying any person the benefits of the program or activity, or subjecting any person to discrimination under the program or activity. 20 U.S.C. § 1681(a). Niblock asserts that UK needs to add approximately 183 female varsity sports positions to comply with Title IX. There is no dispute that UK receives federal financial assistance and, thus, must comply with Title IX. Niblock asserts that UK is violating Title IX by the following conduct:

1) failing to provide female and male students equal athletic participation opportunities (DE 8, Complaint, Count I);

2) failing to provide female and male students an equal allocation of athletic financial assistance (DE 8, Complaint, Count II); and

3) failing to provide female and male students with “equal athletic benefits.” (DE 8, Complaint, Count III.)

Niblock’s fourth claim is that, by failing to provide enough opportunities for women to play on varsity sports teams, the defendants have violated the Equal Protection Clause of the 14th Amendment to the U.S. Constitution, as enforced through 42 U.S.C. § 1983. (DE 8, Complaint, Count IV.) For this claim, Niblock alleges that UK fails to provide female students with “equal athletic participation opportunities” and with “equal financial assistance.” (DE 8, Complaint, ¶ 125.) As for the remedy that Niblock seeks, she requests: 1) an injunction that would compel the defendants to “provide equal athletic participation and scholarship opportunities for female students by establishing varsity opportunities for women at UK sufficient to eliminate the gender disparities in athletic opportunities and that reflect [the] interest and ability of female student athletes in field hockey, lacrosse, and/or other sports.” (DE 8, Complaint, ¶ 131; Prayer for Relief);

2) recovery of the attorneys’ fees and expenses incurred in prosecuting this action under 42 U.S.C. § 1988 (DE 8, Complaint, ¶ 135, Prayer for Relief);

3) a declaration that defendants have violated and continue to violate Title IX and the Equal Protection Clause. (DE 8, Complaint, Prayer for Relief); and

4) compensatory damages. (DE 8, Complaint, Prayer for Relief.) In her complaint, Niblock named four defendants: UK; the UK Board of Trustees; Mitch Barnhart, UK athletic director; and Eli Capilouto, UK president. Niblock later voluntarily dismissed the Board of Trustees. (DE 20, Order.) In response to the motion to dismiss, Niblock clarifies that she asserts claims against Barnhart and Capilouto in their official capacities only, not in their individual capacities. (DE 16, Response at 29.)1

1 Because Niblock asserts no claims against any defendant in his individual capacity, the parties’ arguments about whether any defendant is entitled to qualified immunity on Niblock’s Equal Protection claim under 42 U.S.C. § 1983 are irrelevant. “[Q]ualified immunity [is] a defense available only to individual government officials sued in their personal capacity.” United Pet Supply, Inc. v. Chattanooga, 768 F.3d 464, 484 (6th Cir. 2014). It is for this defense that the issue of whether an asserted constitutional right is “clearly established” is significant. This is because the qualified immunity doctrine “protects government officials ‘from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.’” Goodwin v. City of Painesville, 781 F.3dun 314, 320–21 (6th Cir. 2015) (quoting Pearson v. Callahan, 555 U.S. 223, 231 (2009)). The three remaining defendants – UK and Barnhart and Capilouto in their official capacities – move to dismiss each claim against them. II. Analysis A. Title IX Claims In her complaint, Niblock asserts the Title IX claims against only UK and the now-dismissed

Board of Trustees. (DE 8, Complaint, Counts I, II, III.) Sovereign immunity is abrogated for Title IX claims against the university. Franks v. Kentucky Sch. for the Deaf, 142 F.3d 360, 363 (6th Cir. 1998). In Franks, the Sixth Circuit explicitly stated, “Therefore, since Congress made its intention to abrogate the states’ Title IX immunity unmistakably clear, and it had the authority to do so pursuant to Section 5 of the Fourteenth Amendment, we hold that Congress successfully abrogated the states’ Eleventh Amendment immunity from Title IX lawsuits.” Id. UK argues in a footnote in its reply brief that Supreme Court decisions have “cast doubt on the continued validity” of Franks. (DE 22, Reply at 9 n.10 ). To the extent that this can be deemed to constitute an argument that the Court should ignore Franks, it is insufficient. “Until a court of appeals revokes a binding precedent,

a district court within the circuit is hard put to ignore that precedent unless it has unmistakably been cast into disrepute by supervening authority.” Eulitt v. Me. Dep't of Educ., 386 F.3d 344, 349 (1st Cir. 2004). Niblock can assert claims under Title IX for damages and injunctive relief against the university.

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Niblock v. University of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/niblock-v-university-of-kentucky-kyed-2020.