Rebecca Broadbent, Jared Rasband, and Hazel Sainsbury v. Richard “Biff” Williams, Jordan Sharp, Del Beatty, Michael Lacourse, Henrie Walton, Tiffany Wilson, Utah Tech University, Geoff Landward, Utah Board of Higher Education, Utah System of Higher Education, The Office of the Commissioner of Higher Education, Alison Adams, Eric Pedersen, Matt Black, Jyl Hall, Jared Madsen, Stacy Schmidt, Brooke Ulrich, Travis Rosenberg, Kyle Wells, and Courtney White, and John and Jane Does I-X

CourtDistrict Court, D. Utah
DecidedApril 30, 2026
Docket4:24-cv-00091
StatusUnknown

This text of Rebecca Broadbent, Jared Rasband, and Hazel Sainsbury v. Richard “Biff” Williams, Jordan Sharp, Del Beatty, Michael Lacourse, Henrie Walton, Tiffany Wilson, Utah Tech University, Geoff Landward, Utah Board of Higher Education, Utah System of Higher Education, The Office of the Commissioner of Higher Education, Alison Adams, Eric Pedersen, Matt Black, Jyl Hall, Jared Madsen, Stacy Schmidt, Brooke Ulrich, Travis Rosenberg, Kyle Wells, and Courtney White, and John and Jane Does I-X (Rebecca Broadbent, Jared Rasband, and Hazel Sainsbury v. Richard “Biff” Williams, Jordan Sharp, Del Beatty, Michael Lacourse, Henrie Walton, Tiffany Wilson, Utah Tech University, Geoff Landward, Utah Board of Higher Education, Utah System of Higher Education, The Office of the Commissioner of Higher Education, Alison Adams, Eric Pedersen, Matt Black, Jyl Hall, Jared Madsen, Stacy Schmidt, Brooke Ulrich, Travis Rosenberg, Kyle Wells, and Courtney White, and John and Jane Does I-X) is published on Counsel Stack Legal Research, covering District Court, D. Utah primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rebecca Broadbent, Jared Rasband, and Hazel Sainsbury v. Richard “Biff” Williams, Jordan Sharp, Del Beatty, Michael Lacourse, Henrie Walton, Tiffany Wilson, Utah Tech University, Geoff Landward, Utah Board of Higher Education, Utah System of Higher Education, The Office of the Commissioner of Higher Education, Alison Adams, Eric Pedersen, Matt Black, Jyl Hall, Jared Madsen, Stacy Schmidt, Brooke Ulrich, Travis Rosenberg, Kyle Wells, and Courtney White, and John and Jane Does I-X, (D. Utah 2026).

Opinion

THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH

REBECCA BROADBENT, JARED RASBAND, AND HAZEL SAINSBURY, MEMORANDUM DECISION AND Plaintiffs, ORDER GRANTING PLAINTIFFS’ [178] MOTION FOR LEAVE TO FILE v. SECOND AMENDED COMPLAINT

RICHARD “BIFF” WILLIAMS, JORDAN SHARP, DEL BEATTY, MICHAEL Case No. 4:24-cv-00091 LACOURSE, HENRIE WALTON, TIFFANY WILSON, UTAH TECH District Judge David Nuffer UNIVERSITY, GEOFF LANDWARD, UTAH BOARD OF HIGHER EDUCATION, UTAH SYSTEM OF HIGHER EDUCATION, THE OFFICE OF THE COMMISSIONER OF HIGHER EDUCATION, ALISON ADAMS, ERIC PEDERSEN, MATT BLACK, JYL HALL, JARED MADSEN, STACY SCHMIDT, BROOKE ULRICH, TRAVIS ROSENBERG, KYLE WELLS, and COURTNEY WHITE, and JOHN AND JANE DOES I-X,

Defendants.

Plaintiffs, Rebecca Broadbent (“Broadbent”), Jared Rasband (“Rasband”), and Hazel Sainsbury (“Sainsbury,” and collectively “Plaintiffs”), move for leave to file their Second Amended Complaint.1 Plaintiffs’ Motion seek to add “Shane B. Smeed (“President Smeed”) as a party defendant” and “a new claim for free speech retaliation related to their termination,” and “voluntary dismissal of certain claims and the addition of certain claims and parties based on

1 Motion for Leave to File Second Amended Complaint (“Motion”), 2, docket no. 178, filed June 6, 2025. first-time arguments raised in the Motions to Dismiss, none of which will be prejudicial to Defendants”2 The following defendants oppose the motion to amend: (1) Defendants Utah Board of Higher Education (“UBHE”) with Geoffrey Landward (“Landward”);3 (2) Richard Williams (“Williams”) with Michael Lacourse (“Lacourse”) and Eric Pedersen (“Pedersen”);4 (3) Utah Tech University (“Utah Tech”), Jared Madsen (“Madsen”), Jyl Hall (“Hall”), Stacy Schmidt (“Schmidt”), Brooke Ulrich (“Ulrich”), Courtney White (“White”), Travis Rosenberg (“Rosenberg”), and President Smeed (collectively these eight defendants are referred to as the “Utah Tech Defendants”).5

These memoranda in opposition argue that the amendments are (1) unduly delayed; (2) with dilatory motive; and (3) futile.6 Defendants Alison Adams (“Adams”), Jordan Sharp (“Sharp”), Del Beatty (“Beatty”), Henri Walton (“Walton”), Tiffany Wilson (“Wilson”), and Kyle Wells (“Wells”) did not file an opposition to the Motion, and the time for doing so has expired.7 Following a review of the Motion, Oppositions, and Reply, and for the reasons stated herein, the Motion is GRANTED, and the Motions to Dismiss are terminated as MOOT.

2 Id. at 2. 3 Defendants’ UBHE and Geoffrey Landward’s Opposition to Plaintiff’s Motion to file Second Amended Complaint (“UBHE and Landward Opposition”), docket no. 184, filed June 20, 2025. 4 Defendants Richard “Biff” Williams, Michael Lacourse, and Eric Pedersen’s Memorandum in Opposition to Plaintiff[s’] Motion for Leave to File Second Amended Complaint (“Williams, Lacourse, Pedersen Opposition”), docket no. 185, filed June 20, 2025. 5 University Defendants’ Opposition to Plaintiffs’ Motion to Amend their First Amended Complaint (“Utah Tech Defendants’ Opposition”), docket no. 194, filed July 7, 2025. 6 See generally UBHE and Landward Opposition; Williams, Lacourse, Pedersen Opposition; and Utah Tech Defendants’ Opposition. 7 DUCivR 7-1(a)(4)(D)(ii) (“A response to a motion must be filed within 14 days after service of the motion.”). Table of Contents 1 PROCEDURAL BACKGROUND ..................................................................................... 3 1.1 Amended Allegations Against Defendant UBHE ................................................... 7 1.2 Amended Allegations Against Defendant Commissioner Landward ..................... 7 1.3 Amended Allegations Against Defendants Williams, Lacourse, and Pedersen ..... 7 1.4 Amended Allegations Against Utah Tech Defendants ........................................... 8 1.5 Scheduling Orders ................................................................................................... 9 2 STANDARD OF REVIEW ................................................................................................ 9 3 DISCUSSION ................................................................................................................... 10 3.1 Undue Delay and Dilatory Motive ........................................................................ 11 3.2 Inadequately Pled and Futility .............................................................................. 14 3.3 Voluntary Dismissal and Rule 41 ......................................................................... 15 ORDER ......................................................................................................................................... 16

1 PROCEDURAL BACKGROUND 1. On November 6, 2024, Ms. Broadbent and Ms. Sainsbury received Right to Sue letters from the Equal Employment Opportunity Commission (“EEOC”).8 2. The following day, on November 7, 2024, Plaintiffs filed their Complaint (the “Complaint”) against Defendants Williams, Sharp, Beatty, Lacourse, Walton, Wilson, Utah Tech, Landward, UBHE, Utah System of Higher Education (“USHE”), the officer of the Commissioner of Higher Education (“OCHE”), Adams, Pedersen, Black, Hall, Madsen, Schmidt, Ulrich, Rosenberg, and White.9 3. At the time the Complaint was filed all Plaintiffs were employed by Utah Tech.10 4. Between December 30, 2024, and January 10, 2025, named defendants were served with or waived service of the Complaint.11

8 Motion, 2, docket no. 178. 9 See generally Complaint, docket no. 2, filed November 7, 2025. 10 Motion at 3, ¶ 3. 11 Docket nos. 26–28, 86–92. 5. On February 24, 2025, the parties filed a “Stipulation Regarding Scheduling and Protective Order” (“Stipulated Scheduling Order”), which recognized that Plaintiffs would file an amended complaint.12 6. That same date, Plaintiffs filed their First Amended Complaint “to add Defendant

Kyle Wells as a party, information pertaining Plaintiffs’ Right to Sue letters from the DOJ, and other allegations.”13 7. On February 26, 2025, UBHE announced that Mr. Smeed (hereinafter referred to as “President Steed”) had been selected as the 19th president of Utah Tech.14 8. On March 13, 2025, Mr. Lacourse and Mr. Pedersen filed motions for more definite statements which were granted.15 9. On April 9, 2025, the parties filed a stipulated motion to dismiss, which dismissed certain claims without prejudice.16 10. On April 25 and May 9, 2025, all defendants filed motions to dismiss, which have yet to be decided.17

12 Docket no. 117, 1, filed February 4, 2025. 13 Motion at 5, ¶ 12; see also Amended Complaint, docket no. 118, filed February 24, 2025; 14 Motion at 5, ¶ 13. 15 Defendant Michael Lacourse’s, Motion for a More Definite Statement Under Rule 12(e) of the Federal Rules of Civil Procedure and Memorandum of Points and Authorities, docket no. 125, filed March 13, 2025; see also Defendant, Eric Pedersen’s, Motion for a More Definitive Statement Under Fed. R. Civ. P. 12(e) and Memorandum of Points and Authorities, docket no. 26, filed March 13, 2025; Docket Text Order no. 129. 16 Notice of Stipulations to Dismiss Certain Claims Without Prejudice, docket no. 130, filed April 9, 2025. 17 See Motion to Dismiss Claims Against Utah Board of Higher Education, Utah System of Higher Education, the Office of the Commissioner of Higher Education, Geoffrey Landward, and Alison Adams, docket no. 154, filed April 25, 2025; Motion to Dismiss Claims Against Jordon Sharp, Del Beatty, Henrie Walton, Tiffany Wilson, and Kyle Wells, docket no.

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Rebecca Broadbent, Jared Rasband, and Hazel Sainsbury v. Richard “Biff” Williams, Jordan Sharp, Del Beatty, Michael Lacourse, Henrie Walton, Tiffany Wilson, Utah Tech University, Geoff Landward, Utah Board of Higher Education, Utah System of Higher Education, The Office of the Commissioner of Higher Education, Alison Adams, Eric Pedersen, Matt Black, Jyl Hall, Jared Madsen, Stacy Schmidt, Brooke Ulrich, Travis Rosenberg, Kyle Wells, and Courtney White, and John and Jane Does I-X, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rebecca-broadbent-jared-rasband-and-hazel-sainsbury-v-richard-biff-utd-2026.