S. v. Missouri State High School Activities Association

CourtDistrict Court, E.D. Missouri
DecidedMarch 28, 2025
Docket4:25-cv-00395
StatusUnknown

This text of S. v. Missouri State High School Activities Association (S. v. Missouri State High School Activities Association) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
S. v. Missouri State High School Activities Association, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION K.S., by and through next friends, ) CHRIS SELLERS and WENDY DILLINGER, ) ) T.D., by and through next friends, ) GLENN and AMY DOUGLAS, ) ) Plaintiffs, ) v. ) No. 4:25-cv-00395-SEP ) MISSOURI STATE HIGH SCHOOL ) ACTIVITIES ASSOCIATION, ) ) Defendant. ) MEMORANDUM AND ORDER Before the Court is the March 27, 2025, Motion for Temporary Restraining Order and Preliminary Injunction filed by Plaintiffs K.S. and T.D, Doc. [2]. Plaintiffs are female high school soccer players enrolled in Whitfield School, an independent school in St. Louis, Missouri. In conjunction with the Motion for Temporary Restraining Order, Plaintiffs’ parents, who seek to proceed as next friends, filed a civil complaint, Doc. [1].1 Having reviewed the filings, the Court will require Plaintiffs’ parents to pay the $405 filing fee and submit individual motions for leave to proceed as next friends pursuant to Federal Rule of Civil Procedure 17(c)(2). Additionally, prior to a hearing on the Motion for Temporary Restraining Order and Preliminary Injunction, Plaintiffs K.S. and T.D. must be represented by counsel. If Plaintiffs are unable to find counsel, they must timely seek leave for appointment of counsel by this Court. COMPLAINT AND MOTION FOR TEMPORARY RESTRAINING ORDER AND PRELIMINARY INUNCTION Plaintiffs K.S. and T.D., female high school soccer players enrolled at Whitfield High School in St. Louis, Missouri, filed this action pursuant to 42 U.S.C. § 1983 and Title IX of the 1The Court has placed the Complaint under seal due to the inclusion of personal identifiers in violation of Local Rule 2.17 (A)(2) (“In compliance with the policies of the Judicial Conference of the United States and the E-Government Act of 2002, promoting electronic access to case files while also protecting personal privacy and other legitimate interests, parties shall refrain from including, or shall partially redact where inclusion is necessary. . ..[the names of minor children].”). Education Amendments Act of 1972.2 Plaintiffs allege gender discrimination, violation of their due process rights and an equal protection violation under the Fourteenth Amendment. Plaintiffs assert that they are seeking to remedy an unlawful pattern or practice of gender- based discrimination in Missouri high school athletics, maintained by the Missouri High School Activities Association (MSHSAA). Specifically, Plaintiffs allege that MSHSAA schedules girls’ high school soccer games during the Spring semester, placing girls’ high school soccer in conflict with college recruiting events and club soccer competitions, while MSHSAA schedules boys’ high school soccer in the Fall semester, which does not conflict with “non-school opportunities.” Doc. [1] at 1. Plaintiffs also contend that MSHSAA enforces one of its by-laws, By-Law 3.13.2, against female soccer players to restrict them from participating in club soccer during the Spring semester, while granting male soccer players a “dual participation” window in the Fall semester.3 Plaintiffs allege that, despite seeking guidance and waivers as to By-Law 3.13.2 from MSHSAA for the past several years, they have not been granted a dual participation window, while boys have been given a 22-day window to participate in club soccer activities at the same time as they are participating on their high school soccer teams. According to Plaintiffs, in 2025 MSHSAA issued a limited waiver of 15 days for girls’ dual participation only after their season had already begun and only for “competition” days, and they failed to define the term “competition” or offer written guidance. Doc. [1] at 1, 4. K.S. and T.D. allege that, because By-Law 3.13.2 was not applied fairly and predictably in the 2024-25 school year to both males and females, they were suspended from a high school game after self-reporting their participation in club soccer scrimmages in March of 2025. Doc. [1] at 1. Plaintiffs seek an order from this Court declaring that MSHSAA’s current enforcement of By-Law 3.13.2 against female high school soccer players during the Spring semester constitutes unlawful discrimination. Doc. [1] at 8. They also seek an injunction requiring MSHSAA to “adopt and implement a constitutionally and statutorily compliant dual participation policy,

2 Under Title IX, “[n]o person in the United States shall, on the basis of sex, be excluded from participation in, be denied the benefits of, or be subjected to discrimination under any education program or activity receiving Federal assistance[.]” 20 U.S.C. § 1681(a) (emphasis added). 3 MSHSAA By-Law 3.13.2 prohibits students from practicing or competing in the same sport for a non- school team or in organized non-school competition during their school’s sport season, unless specific exceptions apply. including equal access for male and female athletes, and to take immediate steps to prevent future discriminatory enforcement of eligibility rules.” Doc. [1] at 9. In addition, Plaintiffs seek a Temporary Restraining Order and Preliminary Injunction with several purposes: (1) to enjoin MSHSAA from enforcing By-Law 3.13.2 in a manner that prohibits Plaintiffs from participating in both high school and club soccer sports during the Spring of 2025; (2) to enjoin MSHSAA from applying different dual participation windows for male and female soccer athletes; (3) to require MSHSAA to reinstate Plaintiffs’ full eligibility to compete in the 2025 girls’ high school soccer season without penalty; and (4) to require MSHSAA to take timely and affirmative steps to revise its by-laws and scheduling practices to bring them into compliance with Title IX and the Constitution. Doc. [1] at 8. THE COURT FILING FEE AND PLAINTIFF K.S.’S MOTION TO PROCEED IN FORMA PAUPERIS Self-represented Plaintiffs K.S. and T.D., through their parents as putative next friends, filed this civil action on March 27, 2025, but neither Plaintiff paid the Court filing fee of $405, nor filed a Motion to Proceed Without Prepayment of Fees or Costs. After being contacted by an Assistant Clerk of Court, Plaintiff K.S. filed a Motion to Proceed in Forma Pauperis in this matter, but, as a minor, she is not permitted to file motions in this Court on her own behalf. The Motion for Leave to Proceed in Forma Pauperis would have to be filed by her next friend, or parent. The Court therefore denies K.S.’s Motion to Proceed in Forma Pauperis, without prejudice. Plaintiffs’ parents must submit Motions to Proceed in Forma Pauperis (individually) if they seek waiver of the filing fee in this matter, or else the full $405 filing fee must be paid. PLAINTIFFS’ PARENTS’ REQUESTS TO PROCEED AS NEXT FRIENDS Plaintiffs’ K.S. and T.D.’s parents informally seek to proceed in this action as next friends of their daughters. Plaintiffs’ parents must formally move for leave from the Court to proceed as next friends, pursuant to Federal Rule of Civil Procedure 17(c)(2), which allows that “[a] minor or an incompetent person who does not have a duly appointed representative may sue by a next friend or by a guardian ad litem.” In their motions for leave to proceed as next friends, they should indicate their relationships to the Plaintiffs, why they are seeking to pursue this matter on behalf of the Plaintiffs, and how they anticipate protecting the Plaintiffs’ rights. The law does not allow a parent appointed as next friend to act as a pro se representative of the minor party (their child). See Crozier for A.C. v.

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Bluebook (online)
S. v. Missouri State High School Activities Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/s-v-missouri-state-high-school-activities-association-moed-2025.